Kluwer: Clear Consent at Sea: Arbitration Clauses by Reference after The Polar and NBCC

International trade rarely moves through one contract. It moves through documentary chains: charterparties, bills of lading, sale contracts, guarantees, letters of indemnity, insurance policies, standard terms, electronic confirmations and platform rules. Within that chain, arbitration clauses are often incorporated not by direct signature, but by reference.

That is efficient. It is also jurisdictionally sensitive.