Confidentiality 21. In order to assist in the resolution of a Disagreement, a mediation will not be open to the public. 22. The Parties, and all persons, will keep confidential: a) all oral and written information disclosed in the mediation; and b) the fact that this information has been disclosed. 23. The Parties will not rely on or introduce as evidence in any proceeding, whether or not that proceeding relates to the subject matter of the mediation, any oral or written information disclosed in or arising from the mediation, including: a) any documents of other Parties produced in the course of the mediation that are not otherwise produced or producible in that proceeding; b) any views expressed, or suggestions, or proposals made in respect of a possible settlement of the Disagreement; c) any admissions made by any Party in the course of the mediation, unless otherwise stipulated by the admitting Party; d) any recommendations for settlement made by the mediator; and e) the fact that any Party has indicated a willingness to make or accept a proposal or recommendation for settlement. 24. Sections 22 and 23 do not apply: a) in any proceeding for the enforcement or setting aside of an agreement resolving the Disagreement that was the subject of a mediation; b) if the adjudicator in any proceeding determines that the interests of public or the administration of justice outweigh the need for confidentiality; or c) if the oral or written information referred to in those Sections is in the public forum. 25. A mediator, or anyone retained or employed by the mediator, is not compellable in any proceeding to give evidence about any oral and written information acquired or opinion formed by that person as a result of the mediation, and all Parties will oppose any effort to have that person or that information subpoenaed. 26. A mediator, or anyone retained or employed by the mediator, is disqualified as a consultant or expert in any proceeding relating to the Disagreement, including any proceeding that involves persons not a Party to the mediation. Referral of Issues to Other Processes 27. During a mediation the Parties may agree to refer particular issues in the Disagreement to independent fact-finders, expert panels or other processes for opinions or findings that may assist them in the resolution of the Disagreement, and in that event, the Parties must specify: a) the terms of Reference for the process; 175

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