싱가포르조정협약 비준을 위한 중국법상 대응방안에 관한 연구

China signed the Singapore Convention on Mediation on August 7, 2019, and is in the process of ratifying it. However, as there are many differences between the provisions of the Singapore Convention on Mediation and the current Chinese mediation law, the current provisions are not sufficient to implement the Convention immediately. Therefore, it is expected that the ratification of the Convention will be carried out after China’s domestic legal system is further improved. This paper analyzes the differences between the Singapore Convention on Mediation and China’s current mediation law system and proposes measures under Chinese law to ratify the Convention. Firstly, regarding the recognition of the internationality and commerciality of mediation agreements subject to the Singapore Convention, it is necessary to utilize the place of business as a criterion for determining internationality and to clarify the criteria for commerciality. Secondly, the direct enforcement of mediation agreements as required by the Convention should be followed, but judicial review should be strengthened to prevent other problems arising from the enforcement of mediation agreements. Finally, establishing a private mediation system and with a mediator’s conduct code to ensure his or her independence and impartiality.