On Monday, June 16, 2014, Gazprom and Naftogaz each announced that they were commencing arbitration proceedings under the SCC Rules (seated in Stockholm, Sweden).

The arbitration arises under Contract No. KP dated January 19, 2009 (the “Contract”), a 10 year, long-term gas sales agreement between Gazprom and Naftogaz for volumes ranging from 40 to 52 billion cubic meters of gas per year. On the basis of the statements released by the parties, it appears that Gazprom will be alleging a debt claim. Naftogaz appears likely to invoke the price review provisions and seek a decrease in price. The value in dispute is in excess of US$4.5 billion.

To resolve the dispute, the tribunal will likely need to consider the price review provisions in the Contract. Pricing terms and price review provisions are confidential and rarely disclosed. However, Ukrainskaya Pravda — a Ukrainian news outlet — purported to publish the terms of the Contract when it was agreed. Assuming that the Contract published by Ukrainskaya Pravda contains the price review provisions that are relevant to the current arbitration between Naftogaz and Gazprom, the tribunal will be required to interpret some unusual terms.

For instance, the Contract published by Ukrainskaya Pravda does not appear to provide a set period of time during which the parties may initiate price reviews. The parties appear to be allowed to initiate a price review at any time during the Contract’s term. There do not appear to be any limits on the number of times that the parties can commence price reviews. While providing flexibility, this type of price review clause also creates the possibility that the parties are frequently reviewing the price; which would be very disruptive. For example, if either party is unhappy with the result of the arbitration, then it can immediately seek to commence a new price review. The tribunal will be aware of this possibility and it may color the decision it reaches.

The price review provisions in the Contract published by Ukrainskaya Pravda require the tribunal to determine whether there has been a material change in the market for fuel and energy products. But the Contract does not appear to define “market” explicitly. The tribunal will need to determine what market data they should evaluate in order to determine whether there has been a material change. The definition of “market” may be contentious. While Gazprom supplies almost the entirety of the country’s imported gas, Ukraine has begun to diversify its energy supply. Some European energy companies have recently begun providing “reverse flow” gas to Ukraine through Poland and Hungary. Data from markets outside Ukraine may be relevant. The tribunal will need to determine whether it is allowed to consider this data from markets outside Ukraine under the terms of the price review provision.

The terms of the Contract published by Ukrainskaya Pravda also require the tribunal to determine whether or not the price produced by the price formula reflects the “market price”. The Contract does not specify any approach for determining the market price. Moreover, while the price formula is indexed to gasoil and mazut (a low quality fuel oil), and each is weighted equally, there is no explicit wording about why these variables were chosen and whether or not their weighting relates to any specific market segmentation.

In short, the price review provisions of the Contract published by Ukrainskaya Pravda provide the tribunal with little guidance and a tremendous degree of discretion. This makes the proceedings more complex and is likely to increase the uncertainty about the result. Parties entering into long-term gas supply contracts should give careful attention to the lessons that can be learned from this example.

There are an array of options available when negotiating price review provisions and the drafting choices made by the parties can have an impact on the magnitude and complexity of future pricing disputes. Proper consideration of price review provisions is key and can help limit the uncertainty in price review arbitrations. For more information on drafting options and other pricing and dispute resolution considerations in modern long-term gas supply agreements, see our initial post providing a primer on modern long-term gas supply contracts.

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Photo of Jeremy Wilson Jeremy Wilson

Jeremy Wilson is co-chair of the firm’s International Arbitration and Disputes Practice Group. He advises and represents parties in investor-state matters, price review disputes, and commercial arbitrations, including in both ad hoc proceedings under the UNCITRAL Rules, and institutional arbitrations under the rules of…

Jeremy Wilson is co-chair of the firm’s International Arbitration and Disputes Practice Group. He advises and represents parties in investor-state matters, price review disputes, and commercial arbitrations, including in both ad hoc proceedings under the UNCITRAL Rules, and institutional arbitrations under the rules of the ICC, SIAC, HKIAC, the SCC, the DIAC, and the LCIA, in venues around the world. Jeremy has particular experience and a proven track record advising clients in the energy, life sciences, media, and consumer brands sectors.

Chambers UK ranks Jeremy as a leading lawyer for International Arbitration, noting client comments that Jeremy “is an excellent advocate”, “legally knowledgeable, commercially astute, pragmatic and personable to boot”. Clients also comment on his “impressive analytical and tactical skills” as well as his “quick and thorough understanding of complex legal issues”, while market sources have noted that he is “excellent on the law.” Chambers also notes his industry expertise, stating that the “very accomplished and knowledgeable” Jeremy Wilson is particularly commended for handling arbitrations in the oil and gas industries. Legal 500 UK notes “Jeremy Wilson is brilliant. As an advocate he is superb – careful, lucid and sensible submissions, clearly backed by an immense amount of preparation. A well-deserved reputation of excellence.”

Who’s Who Legal (WWL) recognizes Jeremy as a Global Leader in Arbitration in 2023-2024 and Jeremy is showcased in Legal 500’s Arbitration Powerlist: UK (2023).

Photo of William Lowery William Lowery

William Lowery is of counsel in the firm’s international arbitration and litigation practices. His recent work includes securing an award in excess of $5 billion as compensation for expropriated oil and gas assets, representing clients in international arbitration proceedings arising from EPC contracts…

William Lowery is of counsel in the firm’s international arbitration and litigation practices. His recent work includes securing an award in excess of $5 billion as compensation for expropriated oil and gas assets, representing clients in international arbitration proceedings arising from EPC contracts, and advising clients in gas price review negotiations and arbitrations.

William has represented clients in ad hoc proceedings and arbitrations governed by a variety of arbitration rules, including those of the International Chamber of Commerce (ICC), the International Centre for Dispute Resolution (ICDR), the London Court of International Arbitration (LCIA), the London Maritime Arbitrators Association (LMAA), and the United Nations Commission on International Trade Law (UNCITRAL). He also has represented clients in court litigation related to the recognition and enforcement of arbitration awards and foreign court judgments, as well as discovery under 28 U.S.C § 1782.

William has specialized experience in the energy and natural resources sectors, including disputes arising under: production sharing contracts, joint-operating agreements, and other license related agreements; oil and gas services contracts (both onshore and offshore); gas storage contracts; pipeline transportation agreements; long-term supply agreements for a variety of energy-related commodities (including oil, gas, LNG, LPG, coal, U3O8, and LEU); and various electricity-market related contracts and regulatory issues. William has also regularly represented and advised clients in prices reviews under gas supply agreements and LNG sale and purchase agreements.