The Court of Appeal affirmed the order granting recognition and enforcement of an ICC award rendered in Geneva against Alstom, dismissing objections of violation of public policy and due process. The Court found no evidence of corruption in the case, noting in particular that the fact that representatives of Alexander Brothers (ABL) had met with the Chinese Minister of Railways during the execution of one of the parties’ contracts, and that the Minister had later been convicted for corruption unrelated to ABL, was not sufficient to constitute a serious and specific indication of bribery. The Court also held that there had been no violation of due process in the arbitration, as it appeared that Alstom had in fact discussed the Swiss law principle adopted by the arbitrators to reach their decision – according to which when the subsequent behavior of the parties is contrary to the provisions of their contract, this behavior must be considered as an implicit modification of the contract. The Court did not refer expressly to the New York Convention. (SEE ALSO the earlier decision of the Cour de Cassation in this case, dated 29 September 2021.)