23.2 All disputes arising from the interpretation, performance or non-performance of this Agreement or any transactions related to this Agreement including, but not limited to , the validity, scope and enforceability of this arbitration provision , if not settled amicably within thirty (30) days from the date that the dispute arose, shall be finally settled in accordance with the Rules of Arbitration of the International Chamber of Commerce by three arbitrators to be appointed in accordance with those rules. The language of the arbitration proceedings shall be English and its place shall be [ INSERT ]. The arbitral award shall be final and subject to no appeal and shall deal with the question of costs of arbitration and all matters related thereto. The arbitral tribunal shall have power to order interim relief without prejudice to the right of either Party to seek interim relief from any court of competent jurisdiction , either before the institution of any arbitration proceedings pursuant to this Section 23 or thereafter.