Arbitration analysis: In a decision of 28 October 2025, the Paris Court of Appeal dismissed the set-aside proceedings brought by the Gabonese Republic, the Gabonese company Clean Africa (Clean Africa), and two Gabonese municipalities (the Municipalities) against an ICC arbitral award in favour of the Gabonese company Averda Environmental Services Gabon SA (Averda Gabon) (the Award). The court recalled that an award may only be set aside pursuant to Article 1520(5) of the French Code of Civil Procedure (FCCP) (the ground of a violation of international public policy) if its recognition or enforcement would result in a material breach of fundamental principles of French international public policy, including the prohibition of corruption. The court further clarified that it is not the role of the annulment judge to assess the validity of the underlying contracts or to determine criminal liability. Its role is limited to examining whether the recognition and/or the enforcement of the Award would allow a party to benefit from corruption. In the present case, the court found that while the arbitral tribunal had identified indicia of corruption in overbilling certain cleaning services, it had neutralised the effects of corruption, ordering the payment of services actually performed exclusively. Accordingly, the court held that recognition and enforcement of the Award did not violate international public policy, and dismissed the request for annulment. Written by Julie Spinelli, partner, and Emma Ruby, associate, at Le 16 Law.