海外建築プロジェクトにおける指定下請制度に関する比較研究:シンガポールの標準契約約款を中心に

概要

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Over the past decades many Japanese contractors have tried to extend their business area into the overseas construction market, mainly as a result of a reduction in their domestic construction market. However in terms of risk, overseas construction projects are likely to face a number of unpredictable problems, many of which occur as a result of differences in contract cultures and construction environments between Japan and other countries. One key issue facing overseas construction projects in particular, is that of sub-contracting and control, and the way in which many southeast Asian, Australian and African countries operate a unique subcontracting method known as a nominated sub-contracting (NSC). This paper introduces the NSC contracting system and it is associated problems through a comparison between Singapores standard construction contract forms, such as SIA and REDAS, and international contract forms, such as FIDIC and JCT. We also attempt to clarify the unilateralism of the NSC contract by a detailed analysis of the NSC clauses of each of the Singapore standard contract forms for nomination, contact, payment and termination respectively. Lastly, we will discuss the asymmetrical relationship among project participants, taken from a unilateral contract.
日本建築学会の論文