Settlement Agreement Template

This Settlement Agreement is made and entered into [insert date] by and between [party name] (hereinafter referred to as “Party A”) and [party name] (hereinafter referred to as “Party B”). Party A and Party B collectively are referred to as the parties.

With regard to the dispute arising from [Order No.], Party B hereby agrees to settle and compromise Party A’s request for an award of freight cost and goods value under the terms and conditions set forth in this Settlement Agreement.

1. Party B has refunded USD[Amount] freight cost to Party A through the Alibaba platform.

2. Party B has compensated Party A with USD[Amount] for goods value in accordance with the subject Order after this agreement has been signed by the parties, and payment will be transferred to the designated bank account by T/T as instructed by Party A.

3. Party A hereby confirms that there are no other outstanding disputes between the parties after Party A has received the payments mentioned above in Articles 1 and 2. The Parties represent that they have not filed any complaints, lawsuits, charges, arbitrations, and/or other claims against each other with any court, governmental agency, or arbitration authority or organization.

4. Party A hereby knowingly, voluntarily, irrevocably, and unconditionally expressly releases and waives, and absolutely and forever discharges Party B, individually and collectively, from any and all claims which Party A has or claims to have, now or hereafter, against Party B, arising out of any and all wrongful acts, negligence, or omissions occurring before the complete execution of this Agreement.

Party A: [Signature]                          Party B: [Signature]

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