Your items

No products in the cart.

RETURN TO SITE

All Projects
All stories
Directory
All Cabinetry
All Fronts
All Handles
All Worktops
  • Before we start, help us help you.

1
2
3
4
5
6
7
  • To help us tailor your appointment, we have a few simple questions.

    (Based on linear meters of cabinetry). Please include the circumference of any islands when calculating the size.
    View size guide
1
2
3
4
5
6
7
  • To help us tailor your appointment, we have a few simple questions.

    (Based on linear meters of cabinetry). Please include the circumference of any islands when calculating the size.
    View size guide
Read our Privacy Policy

Customer Terms & Conditions

1. General

1.1. These terms and conditions apply to goods and services, including design services (if applicable), supplied by HØLTE Studio, a trading name of Witlof Ltd, a company registered in England with company registration number 09572926 whose registered office is c/o Carrington Accountancy Birchin Court, 20 Birchin Lane, London, England, EC3V 9DU (HØLTE or we/us).

2. Our contract with you

2.1. By placing an order with the Company (an “Order”), meaning you have paid a deposit or confirmed in writing (including by email) that you have signed off on production drawings, or by paying a deposit to engage us to provide design services, the customer (“you”) agree to be bound by these terms and conditions. Your Order (as applicable), together with these terms and conditions, constitute our agreement with you.

2.2. To the extent there is any conflict between the terms of your Order (as agreed to by us) and these terms and conditions, your Order will prevail. Your Order and these terms and conditions supersede all previous oral / written discussions and documents relating to the Order. 

2.3. We ask that you read these terms and conditions carefully, and ensure you are happy to be bound by them from the point of confirmation of your Order. If there is anything you would like to discuss, please contact our team as soon as possible.

3. Products

3.1. Bespoke Goods

a. All our products are made to order, we do not hold stock of finished goods.

b. We make every effort to be sustainable throughout our manufacturing processes, however, we cannot guarantee retention of any offcuts arising from the production of your Order. Any such offcuts remain the property of HØLTE. Requests can be made in writing for offcuts to be supplied along with your Order, however, this cannot be guaranteed. Please discuss with your designer if this is something you are interested in.

3.2. Materials

a. Natural materials may vary in colour/expression from item to item (e.g., in grain, shade and tone), we feel this is part of their beauty. 

b. Tone and grain can vary from batch to batch across all our products. While we will endeavour to match grains and minimise the impact of any mismatching during the design and manufacturing process, matches cannot be guaranteed. Please discuss with the design team what matches can be achieved with your materials and where problems might arise. Consideration of tone variation should always be given when adding panels to Orders already in production as these will likely be using different batches of materials. 

c. Samples should be regarded as representative examples only. We cannot guarantee the finish of your final product will be identical to any sample product, showroom model or image seen on our website or any other marketing outlet. 

d. All hardwoods undergo natural colour changes and ageing processes with exposure to light and atmospheric gases. Such processes will occur over the lifetime of the wood and are part of the inherent nature of the material. The customer accepts these processes cannot be controlled and are unique to each environment. 

e. Wood veneer is a natural product. Variations in pattern and markings can occur even within a bundle and small imperfections & irregular markings in the veneer structure are very common. These can be caused by a multitude of occurrences including natural knots, branch structures, gum spots causing resin build-up, mineral streaks and general figuring caused by natural growth reactions. These imperfections represent the unique character of the tree’s growing life and cannot be avoided. We accept no liability in respect of natural markings in the materials we use and their irregularities. 

f. Worktops made from natural materials are the result of thousands of years of formation. Their inherent variations in tone, colour and markings are unavoidable and unique to each piece. Slight cracks and veins within such materials are natural occurrences which cannot be controlled.  The Customer acknowledges and accepts these characteristics of natural materials and that agrees that HØLTE shall have no liability for such inclusions.

3.3. Colour Finishes

a. All fronts can show variation in colour from board to board. The colouration of the panel is subject to a wide variety of natural variations in tonality which cannot be controlled. The Customer accepts any such variation is not a defect and HØLTE shall have no liability for such variations.

b. Images of our products seen on social media, our website or in any other marketing materials are for illustrative purposes only. While we make every effort to ensure our photos are as true to colour as possible, variations in digital screens, light sources, photography and dye lots mean we cannot guarantee on-screen portrayals will represent the true colour of our products.

3.4. Warping of doors

a. Sheets of natural material are prone to warping with exposure to atmospheric conditions and moisture. We strongly advise this be kept in mind when planning your project and encourage customers to discuss potential issues with their designer. We do not recommend doors of over 1.00m in plywood, or doors of over 2.00m in MDF. While we will still be able to manufacture these products, the customer accepts that HØLTE cannot be held liable for any warping on delivery. 

4. Order Process

4.1. Customer Responsibility

a. Our products and kitchen systems have been developed to remain accessible to everyone. As a result, many of our processes are carried out in collaboration with third-party suppliers (such as proprietary cabinetry supplies, hob or tap suppliers, etc.) to reduce costs for our customers. While we endeavour to communicate as accurately and efficiently as possible with these third-party suppliers, the customer accepts that it is their responsibility to ensure any Orders, including all quoted items, and applicable dimensions, sizes and specifications are correct and suitable for the customer’s project, and that all measurements and other information provided by the customer to HØLTE, to be passed on to such third party suppliers, or provided to such third party suppliers directly by the customer, are accurate and consistent. 

b. Our products are manufactured using the measurements provided by the customer. It is the responsibility of the customer to ensure all measurements provided by the customer are correct and accurate before signing off for production. Returns cannot be accepted for goods that are incorrect in size as a result of incorrect measurements provided by the customer. HØLTE accepts no liability for errors, delays or increases in cost incurred as a result of incorrect measurements or other information provided by the customer.

c. Our team will always be happy to advise and guide you regarding the practical issues of certain specifications as part of the initial product selection before you sign off on the Order. However, the majority of design decisions will be unique to your project and personal preferences. Due to the bespoke nature of our products, any amendments made to approved designs after the production drawings have been approved by you may result in additional costs and amended lead times.

d. Please take special care to consider the potential benefits and/or limitations of all elements of your specification, including for example, handle design, integrated appliance location and worktop options. Should there be any concerns, please raise them with your designer as early as possible in the design process. We do not accept any liability for any practical issues regarding the products where they have been made to your specification.

e. The customer must provide HØLTE with the correct manual for any appliances they have purchased or intend to use in their kitchen. HØLTE accepts no liability for any discrepancies which may occur as a result of the supply of incorrect information regarding your appliances or as a result of a delay in the provision of information regarding your appliances, which may delay the production of your Order.

4.2. Quotes

a. You may discuss a possible kitchen or other project with our design team, who may provide you with a quote for your potential Order (a “Quote”). Quotes are valid for 30 days from the date of issue.

b. Quotes provided will show all line items, net of VAT. Total VAT payable on your Order will be stated clearly in the Quote.  

c. Quotes are provided on an estimate-only basis. The final itemised price for your Order will not be confirmed until the final production drawings and panel drawings are complete and have been signed off by the client.

4.3. Prices

a. All prices are excluding installation costs unless expressly stated in writing. 

b. Shipping charges are additional and will be calculated upon confirmation of your Order based on the final delivery address and final order size.

c. Pricing examples detailed on our website are inclusive of 20% VAT unless otherwise stated. They are provided for illustrative purposes only. The actual price of any product you may order will be as set out in your Order, and the VAT will also be itemised.

d. HØLTE reserves the right to revise its pricing at any time, save that once an Order has been confirmed, the price as set out in that Order shall apply (subject to any adjustments to the Order which may entail price adjustments in accordance with these terms and conditions). 

e. Where it comes to HØLTE’s attention that there has been an error in the price set out in an agreed Order, we will notify you as soon as possible. If the pricing error relates to HØLTE’s cabinetry and fronts, there will be no adjustment to the price of your Order. However, where the pricing error relates to items provided by third-party suppliers, for example, worktops made by a third-party manufacturer, the customer may notify HØLTE in writing within 3 business days from the date of notice from us about the pricing error that they wish to cancel the Order. If the customer does not respond within 3 business days, they will be deemed to have accepted the price increase. 

f. The Company reserves the right to refuse to sell at a reduced VAT rate should they feel that inadequate information has been provided to them to make any such decision.

4.4. Payment

a. Unless agreed otherwise in writing  by HØLTE, the total price of your Order must be paid as follows:

(i) 50% of Order cost must be paid as a deposit at the time the Order is placed. HØLTE cannot begin production of your Order until this deposit payment has been received; and

(ii) We will notify you when your Order is close to completion, and the remaining total balance of the Order cost must be received before shipping of your Order can be arranged.

b. Any delay in payment of the deposit may delay the estimated delivery date. If you fail to pay the remaining balance of your Order within 30 days of being notified that your Order is ready, we reserve the right to cancel your Order, at our sole discretion. You will remain liable for storage costs up to the date of cancellation (in accordance with paragraph 6.5).

c. We accept payment via BACS transfer and most major credit cards. All payment options will be provided to you upon Order confirmation. 

d. If you choose one of our payment providers (e.g., Go Cardless or Stripe), you accept their terms and conditions of service. Any issues arising during the processing of payments are not the responsibility of HØLTE, and you should contact the respective payment provider should any issues occur. We do not consider payments to have been made until we have actually received the funds.

4.5. Minimum Order Value

a. All orders are subject to a minimum order value of £3,000 (exclusive of VAT). This value is for HØLTE-supplied products only and does not include any third-party products such as IKEA cabinetry or Quooker/Bora appliances.

4.6. Site visits

a. You may request that a member of the HØLTE team or a third-party supplier visits your site to survey or for templating (a “Site Visit”). Please refer to the section on templating in our worktop guidelines for further information. 

b. Costs associated with templating in the Greater London area are included in the price of the Order. Where a Templating Visit is to a location outside the Greater London area,  the cost of the Site Visit will be agreed with the customer.

c. Prior to all Site Visits the customer is required to ensure that the site must be prepared and in a safe and suitable state for the HØLTE team and applicable third-party suppliers to carry out the Site Visit. 

d. If the customer requests a Site Visit earlier than deemed suitable by HØLTE, the customer accepts that HØLTE shall have no liability for any assumptions that have to be made about the site prior to completion. Including but not limited to; wall finishes, final dimensions, doorway depths and appliance location.

5. Production

5.1. Production drawings

a. Prior to commencing production of an Order, the customer will be issued with final production drawings showing all panels for customer approval and sign off. As set out at paragraph 4.1.b above, it is the customer’s responsibility to confirm that the measurements used in the production drawings are correct. 

b. Production lead time does not begin until confirmation of all product details are confirmed, the production drawings have been signed off by the customer, and we have received payment of any deposits required.

5.2. Late Amendments

a. Due to the nature of made-to-order products, any changes required after the Order has been approved shall be liable to a late amendment administration charge. 

b. The late amendment administration charge is a flat rate of £100, in addition to any amendment to the price of the Order that may arise as a result of the changes. 

c. If the Order has already been processed (meaning the purchase order for your Order has been sent to our manufacturing facility), any additional items will be treated as separate Orders and shall be subject to a production set up fee. This fee will be £180 inc. VAT for fewer than 3 panels. 3 panels or more (up to the minimum order value) will be charged at £150 inc VAT. There will be no production set up fee where the cost of additional items meets the minimum order value.

5.3. Lead Times

a. All lead times provided are exclusive of time required to produce and confirm production drawings. Lead times only begin once we have received all approvals, sign offs and deposits as set out at paragraph 5.1.b.

b. Lead times will vary depending on the Order. All lead times provided are based on prevailing conditions and given as an approximate guide only. While all reasonable efforts will be made to meet the estimated delivery date, these dates cannot be guaranteed and may be subject to change for various reasons, including, for example, public holidays in relevant manufacturer locations, shipment routes, or location of delivery address. We will notify you as soon as reasonably practicable upon becoming aware of any change in anticipated delivery dates for any reason. For the avoidance of doubt, time is not of the essence in these terms and conditions, and HØLTE’s only liability with respect to lead times is as set out in this paragraph.

c. HØLTE accepts no liability for any delay in delivery, regardless of duration for any circumstances beyond our reasonable control, including, for example, delays arising from labour disputes, transportation complications, failure or delay of sources and their supply chains to supply, accidents, acts of war or international conflict, pandemics, natural disasters or any occurrence which hinders our normal business operations.

d. As set out at paragraph 4.4.a, the payment of the full outstanding balance of the Order must be received by us prior to your Order being dispatched from our production facility for delivery to you.

5.4. Stock levels

a. While we do not hold stock of any finished product, should any materials required in the manufacturing of your Order be out of stock at time of Order, we will advise you immediately of the expected changes to the delivery schedule. 

b. While we can advise on stock levels and availability during the order process, reserves or holds on stock are not possible and therefore we cannot guarantee required stock will be available at time of Order.

6. Shipping & Delivery

6.1. Delivery

a. As set out at paragraph 4.4.a, the payment of the full outstanding balance of the Order must be received by us before delivery can be arranged. 

b. HØLTE will endeavour to confirm a final delivery date at least one week before the agreed estimated delivery date (ascertained at the time of Order). We advise that no bookings for the fitting of your kitchen are made until we have confirmed the actual delivery date with you in writing. HØLTE accepts no liability for any losses incurred as a result of late delivery.

c. It is the responsibility of the customer to provide the correct shipping and delivery address and ensure it appears correctly on all correspondence, including the Order confirmation. HØLTE accepts no liability for any additional transport costs or delays incurred as a result of the provision of an incorrect delivery address or due to the customer, or other applicable site contact, being un-contactable at the time of delivery, meaning delivery cannot take place. 

d. The customer is required to ensure the delivery unloading area/drop-off point is available and suitable. Deliveries will be curbside only unless otherwise stated in writing. Customers must ensure there is someone present at the final delivery address to assist with unpacking the delivery and moving inside the customer’s property. Our products are heavy, we recommend at least two people be present to assist with the moving of your Order. 

e. Once unloaded from the delivery vehicle curbside at the delivery address, the customer assumes liability for the products. It is the customer’s responsibility to move them inside their property. If the driver assists in any way with moving the delivery from curbside onwards, this is at the sole discretion of the driver and forms no part of  HØLTE’s agreement with the customer. For the avoidance of doubt, HØLTE accepts no liability for any damage or injury that may occur once the product has been unloaded from the delivery vehicle curbside at the delivery address. 

f. The customer is responsible for ensuring the correct disposal of all packaging materials in accordance with local guidelines. You are encouraged to recycle packaging materials where possible.

g. Where an Order has been amended after it has been approved, in accordance with paragraph 5.2, and the amendment includes additional products, this may result in multi-stage deliveries for the original Order and the additional items. Further estimated and final delivery dates will be confirmed to you as soon as reasonably practicable following confirmation of amended Order, in accordance with this paragraph 6.1

6.2. Signing for goods upon delivery

a. Customers must ensure they or an elected representative (e.g. an appointed contractor) are present at the delivery address to sign for the delivery on the agreed delivery date. Orders will not be left at the delivery address without an approved signature and re-delivery charges will be incurred if a delivery attempt fails due to the absence someone who can provide an approved signature. Redelivery charges may not be equal to that of the original delivery, as costs associated with other redeliveries could be passed on to the customer if the failed delivery of their Order also affects subsequent deliveries. Costs associated with the return of goods to origin may also be applicable. 

b. Customers are advised to check their delivery against the delivery note to check for missing items or delivery damage (i.e., damage to boxes) in the presence of the delivery driver. Should any discrepancies be noted, these must be clearly written on the delivery note. No claims for delivery-incurred damage or delivery error can be made once the delivery driver has left the delivery address. You are advised to take photographs for any delivery damage as well, as the burden of proof of delivery damage lies with the customer. Inspection of actual products after unwrapping is set out in paragraph 6.3 below.

c. Should damage prior to or during delivery occur, all efforts will be made to replace or repair damaged items as quickly as is reasonably possible, at no further cost to the customer.

6.3. Acceptance of goods

a. Goods must be unpacked and checked for production defects within 2 days of delivery (or installation where installation is being provided by HØLTE in accordance in accordance with paragraph 7.4). HØLTE must be alerted to any damage prior to the fitting of all products. HØLTE does not accept any liability for production defects notified to us after the item has been fitted.

b. The customer acknowledges and agrees that by proceeding with the fitting of our products, the condition of the products is deemed accepted by the customer. Similarly, where the customer has not notified HØLTE of any production defects within 48 hours of delivery (or installation where installation is being provided by HØLTE in accordance in accordance with paragraph 7.4), the condition of the products is deemed accepted. 

c. All issues raised with the Company with regard to production defects notified to us will be investigated on a case-by-case basis. You are requested to provide photographic evidence of the defective item to support your claim. HØLTE may request more information and/or images in order to progress the claim. Where a defective product has been provided, all efforts will be made to replace or repair defective items as quickly as is reasonably possible, at no further cost to the customer.

d. HØLTE conducts a rigorous quality control process whereby all panels and cabinetry are inspected and photographed prior to dispatch. We hold a record of these images and will refer back to them when discussing any claims. Where HØLTE acknowledges that it has supplied a defective item, the customer’s sole remedy shall be the repair or replacement of the defective item as quickly as is reasonably possible.

6.4. Export

a. If the final delivery address is located outside the United Kingdom, all duties/taxes payable at the overseas port of entry are additional and shall be the responsibility of the customer.

6.5. Storage

a. All goods are manufactured according to current workshop schedules. 

b. If the customer chooses to delay delivery following notification that their Order has been completed, the storage of the goods is entirely at the risk of the customer. All efforts will be made to ensure products are stored carefully, however the customer accepts that natural products are subject to movement, warping, cupping and bowing during a period of storage. HØLTE cannot be held responsible for such occurrences.

c. Where the customer requests to delay delivery after an Order has been completed, storage charges will apply. Goods are stored for £100 per week (inclusive of VAT), charged weekly. All outstanding storage charges must be paid before goods will be shipped. 

d. If delivery is accepted but fitting/installation is delayed, the customer accepts responsibility for the safe and correct storage of all products. The customer is advised to refer to our storage guidelines which area available on our website.

7. Installation / Fitting

7.1. Claims

a. As soon as any work is carried out on our products, which may include, for example, cutting, shaping, fitting, finishing, varnishing/oiling or installing, HØLTE accepts no further liability for, and no claims can be made for, any defects or damage to the products. This provision applies even if work is carried out on the goods, or they are installed, within 48 hours of delivery. 

b. Installation, or any work conducted on our products, will be deemed as acceptance of the goods and any damages notified to HØLTE after installation or any work carried out, will be assumed to have occurred during the installation/works. 

7.2. Installation Drawings

a. We recommend that the products are fitted in accordance with any installation and instructional drawings supplied by HØLTE only. HØLTE accepts no liability for the misinterpretation of our drawings or any subsequent damage caused by misinterpretation, or failure to follow our installation or instructional drawings.

7.3. Appointment of Fitters

a. HØLTE strongly recommends that our products are fitted by specialist kitchen fitters. HØLTE and the customer both hereby accept that specialist carpentry and installation skills are a considerable factor in the delivery and final result of a show-stopping kitchen.

b. If the customer requests a recommendation for third-party fitters or contractors to install their HØLTE products, the customer acknowledges and agrees that it may choose to engage any third-party fitters or contractors whose contact details were provided to them by HØLTE at their own risk. Provision of contact details of any third-party fitters or contracts shall not constitute an  endorsement by HØLTE, and the appointment of such persons is done so entirely at the discretion of the customer. HØLTE accepts no liability for the acts or omissions of any third-party fitters or contractors, regardless of whether HØLTE has provided their contact details to the customer.

7.4. Orders installed by HØLTE

a. If installation services have been agreed as part of your Order, subject to the guarantee terms set out at paragraph 9 below, HØLTE guarantees that all workmanship carried out by HØLTE-provided fitters and contractors shall be free from installation defects for a period of 2 years from the date of installation.

b. Subject to this paragraph 7.4, if an installation defect is notified to HØLTE within two years of installation following a HØLTE-provided installation, HØLTE will repair or replace the defective item as soon as is reasonably possible. 

c. Defects or damage caused by normal wear and tear, extraordinary cause, neglect or misuse are not covered by the guarantee in this paragraph 7.4.

d. Where HØLTE is providing installation services, all products will be fitted to HØLTE’s discretion unless otherwise requested in writing by the customer or their architect, contractor or designer. Any such requests regarding installation must be accepted by HØLTE before installation and we cannot guarantee all requests will be accepted. 

e. Prior to installation, the customer is responsible for ensuring that each room or area where HØLTE will be installing must be clear or furniture, suitably prepped, safe and ready for installation. All services should be in position prior to install. Should HØLTE has to move/remove fittings or conduct any work not originally agreed in the scope of the install, extra charges may apply. HØLTE shall not be liable for any costs or delays incurred due to unsuitable site conditions. 

f. If HØLTE’s installation team has to wait to gain access to the site on an agreed installation date, or if the installation is delayed by other contractors, or the designated installation area otherwise not being ready and available for installation, additional charges may be applied. 

g. If the customer cancels an agreed installation within 7 days of the scheduled installation date, the customer shall be required to pay installation crew cancellation charges, to be determined by HØLTE at that time. These charges will be payable before any subsequently rearranged installation or delivery of the products.

h. While all HØLTE installers will work as efficiently as is reasonably possible while maintaining the quality and integrity of their work, we cannot guarantee any quoted installation schedules will be accurate. The customer accepts that all given installation schedules are to be interpreted as estimates only.

7.5. Installation of appliances

a. Where the customer purchases an appliance from one of our third-party supplier partners as part of their Order, and the purchase of such appliance includes installation by the third-party supplier, HØLTE accepts no liability with respect to the delivery and installation of such appliance, and the customer acknowledges and agrees that the third party supplier’s terms and conditions shall apply to such delivery and installation.

8. Cancellations and returns

8.1. No refund after Order placed

a. All our products are made-to-order, therefore no returns, cancellations or refunds cannot be accepted once an Order has been confirmed.

8.2. Consumer rights & Distance selling

a. Under the UK’s Consumer Contracts Regulations 2013 (previously the Distance Selling Regulations) consumers have a right to return standard goods ordered by phone or online within 14 days of the goods of delivery if they change their mind. However, these regulations do not apply to goods which are made-to-order and therefore our Orders are not subject to 14-day right of return set out in these regulations.

9. Guarantee

9.1. Guarantee periods

a. Subject to this paragraph 9, HØLTE guarantees each of their products for the following time periods:

Cabinetry (Cabinets/shelves)
Guarantee duration: 10 yrs
Inner storage (Drawers/Pullouts)
Guarantee duration: 10 yrs
Fronts (Doors/Cover panels/Fillers/Drawer fronts)
Guarantee duration: 3 yrs
Any fronts installed on a dishwasher or in a bathroom are not covered.
Hinges / other hardware
Guarantee duration: 25 yrs
Worktops
Guarantee duration: As per guarantee provided by applicable supplier
Third party appliances sold as part of an Order
Guarantee duration:
As per guarantee provided by applicable supplier
For example: Bora – 2yrs, Quooker – 2yrs
Third party manufacturers’ warranties can be found on their websites

b. The above guarantees do not cover damage to any goods caused by everyday occurrences and normal wear and tear, including but not limited to; heat exposure, water damage, scratches, colour change. 

c. Damage caused to any products that have been misused, or deliberately or negligently damaged by the customer or any other person, is not covered by these guarantees. Misuse includes, for example, products exposed to force, overload, lack of maintenance and care, incorrect or abnormal fitting or storage, or any use not as intended.

d. Our obligations in respect of our guarantee will include the repair or exchange of defective goods only. We do not offer refunds, and HØLTE does not accept any liability for any indirect or consequential losses,  loss of profit, loss of business, business interruption, or loss of business opportunity or any other losses or delays incurred in relation to our products. Customer’s only remedy is as set out in these terms and conditions. 

e. For the avoidance of doubt, our guarantees do not cover, and we do not accept any liability in respect of, any issues that arise as a result of any planning errors or issues arising from decisions made, or actions taken, by the customer or any of their third party suppliers.

10. Copyright

a. Our products are designed by our team and we are very proud of the skill and effort that goes into creating our designs and products. For this reason, it is important that we protect our intellectual property rights in our designs and products. You hereby acknowledge that all patents, copyright, database right, trade secrets, trade names, trademarks (whether registered or unregistered), or any other rights or licences or intellectual property rights in respect of our designs and products, including in relation to your Order shall remain our exclusive property and the purchase of your kitchen shall not result in the transfer of any intellectual property rights to you.

11. Changes to terms

We reserve the right to update these Terms and Conditions from time to time. Where appropriate, we will endeavour to provide you with reasonable notice of any changes to these terms and conditions.

12. Complaints

Please contact us at hello@holte.studio in writing with any questions, concerns or issues.

13. Governing law and jurisdiction

These terms and conditions, together with your Order, are governed and interpreted in accordance with the laws of England and Wales. Any dispute between us that cannot be amicably resolved will be determined by the English Courts.