An arbitration clause contained in the articles of association which refers to arbitration disputes "concerning available rights relating to the corporate relationship" does not extend to disputes concerning autonomous contractual relationships between the company and a person who also holds the office of director, where such relationships do not pertain to the corporate relationship strictly speaking but arise from a distinct contractual basis, such as a consultancy agreement.
An arbitration clause contained in the articles of association which confers upon arbitrators jurisdiction over disputes relating to the corporate relationship includes an action for liability brought by the company against a director for acts of mismanagement committed in the exercise of managerial functions, this being a dispute concerning available rights inherent in the organic relationship.