1. "Mediation + Arbitration" Clause

Any dispute arising from or in connection with this Contract shall be submitted to the Shenzhen Court of International Arbitration (SCIA) Mediation Centre for mediation. If the mediation is successful, the parties agree to submit the settlement agreement to the SCIA to request that an arbitral award be rendered in accordance with the SCIA Arbitration Rules and based on the terms of the settlement agreement. If any party is unwilling to mediate or the mediation fails, the dispute shall be submitted to the SCIA for arbitration.

2. "Mediation + Arbitration" Clause (Arbitral Awards Based on Settlement Agreement)

Both parties agree that either party has the right to submit this settlement agreement to the Shenzhen Court of International Arbitration (SCIA) to request that an arbitral award be rendered in accordance with the SCIA Arbitration Rules and based on the terms of the settlement agreement. The arbitration award is final and binding on both parties.