the UNCITRAL model law of arbitration has two options in its amended article 7, incorporating these, Finally, in Section 6, a reference in a contract to another document containing an arbitration clause satisfies the writing requirement as long as the reference makes the clause in the other document part of the contract (an incorporation by reference). This is an area that comes up regularly in practice, but is not dealt with specifically in the New York Convention. As a result, courts in different jurisdictions have reached different conclusions about when an arbitration agreement can be incorporated by reference, and how it must be done. Section 6 simply requires that the reference in a contract to another document containing an arbitration clause must establish that the arbitration clause becomes part of the contract.

Section 5 provides that if parties have exchanged statements of claims and defenses in which one party alleges an arbitration agreement and the other party does not deny it, then the writing requirement is met. This prevents parties from trying to assert a technical defense at a later point after the parties have essentially admitted there was an agreement to arbitrate. explain using relevant case laws and this info to explain In depth how option 1 is better