Settlement Form - this is a template for creating a complete, all-inclusive Settlement Agreement. The following are basic sample clauses providing for mediation or arbitration in an employment contract.Employment Arbitration Rules and Mediation Procedures. . . . . . . . . . . . . . . . . . . . . 10. 1. Applicable Rules of Arbitration . That the dispute arises out of an individually-negotiated employment agreement, the filing fee for a counterclaim will be charged in accordance with the fee. Scope of Disputes: It defines the types of disputes subject to arbitration, such as contract disputes, employment disputes, or other specific matters. A forced arbitration agreement in which employees waived their right to participate in collective legal claims constituted an unfair labor practice. But does that mean that the employer must agree to arbitrate any and all disputes with its employee? Nothing in the FAA suggests that it does. Provided in the Employer's Agreement with OCSEA.