_____________________________________ [DRAFT ]SETTLEMENT AGREEMENT—pre-action settlement [WITHOUT PREJUDICE AND SUBJECT TO CONTRACT [SUBJECT TO SIGNATURE BY PARTIES AND/OR SUBJECT TO COURT APPROVAL]][CONFIDENTIAL] _____________________________________ This Agreement is made the day of 20[insert year] Parties: 1 [insert name of party], a company registered in England and Wales (registered number [insert company number]), whose registered office is at [insert address] (‘Party A’)[ and] [;] 2 [insert name of party], a company registered in England and Wales (registered number [insert company number]), whose registered office is at [insert address] (‘Party B’). together the ‘Parties’ Whereas 1 [Set out the background to the dispute; for example, if the dispute arises in connection with a contract, set out the purpose and date of that contract, and a summary of the parties’ obligations therein eg, ‘Pursuant to [insert type of agreement, eg, a distribution agreement] dated [insert date of agreement] between [insert party names], [Party A] agreed to [insert obligation, eg, to provide services....] to [Party B] on the terms set out therein. Further in consideration of the provision by [Party A] of those services, [Party A] is entitled to receive, and [Party B] agreed to pay, a fee on the terms set out in that agreement”.]