A company ( hereinafter B) incorporated under Malaysian law, specialized in ship management and maritime transport, entered into a contract with a French company A (hereinafter A). A had the obligation of providing the principal’s clients with certain services and developing the scope of its activities in France, in two other EU Member states, as well as in Switzerland and in three North African states. The contract included a choice of law clause under Malaysian law and an arbitration agreement with the Kuala Lumpur Arbitration Centre. B, the principal, initiated arbitration proceedings following the breach of the contract . The award rendered in Kuala Lumpur ordered the French agent A, which had meanwhile been facing a winding-up proceedings, to pay the principal a sum of more than 3 million euros. B obtained the enforcement (exequatur) of this sentence in France, the order having been appealed by A and the ad hoc agent appointed to represent it. A is alleging the annulment of the enforcement order on the basis of the award’s violation of international public policy. The award applied Malaysian law, which does not know any equivalent to the mandatory regime laid down by the 1986 EU Directive, which guarantees a right to compensation to the agent practicing in Europe. The appellant considers there is infringement of a public policy by the award. Please solve the case considering, in particular but not only, that the appellant asks you a few questions : 1/ Has he any arguments to justify that the arbitration clause is manifestly void or unenforceable considering its inclusion in an international commercial agency contract ? 2/ Can he invoke the French provisions protecting the agent against the arbitral award itself ? 3/ Can the position adopted by the EU Court of Justice in Ingmar and Unamar cases be of any utility for him ? Please note: 1/ The French Supreme Court (Cour de cassation Commercial court 28 Nov. 2000, Allium) has considered the law of June 25, 1991, codified in articles L. 134-1 et seq. of the French Commercial Code as not internationally mandatory, but only a “law protecting internal public policy”. The agency agreement fell within the material scope of the 1986 Directive and the agent was performing his duties in part on European territory. 2/The French law of June 25, 1991, which implemented the 1986 directive into French law, extended the protection granted by the directive to service contracts, especially to maritime agency contract, which do not fall within the scope ratione materiae of the Directive. 3/ The French court seized of the appeal against an order for enforcement of an international award is not bound by the definition of mandatory rules laid down in article 9 of the Rome I Regulation 4/ Article 1520- 5° of the French Code of Civil Procedure allows appeal if recognition or enforcement of an award would not be consistent with international public