ABSTRACT
This chapter focuses on the Regulation and important departures from the Convention. In English litigation relating to contracts, choice of the applicable substantive law is governed largely by EC Regulation 593/2008 on the Law Applicable to Contractual Obligations, which is usually referred to as the Rome I Regulation. The Rome I Regulation derogates from its main rule, referring most contractual issues to the proper law, by making important exceptions in favour of the public policy or overriding interests of the forum country. The Rome I Regulation indicates that the conclusion of a new contract of employment with the original employer or an employer belonging to the same group of companies as the original employer should not preclude the employee from being regarded as carrying out his work in another country temporarily. The Regulation applies both to life insurance and to non-life insurance, and also to reinsurance.
