Answer ... Where an arbitration agreement has an international connection, the agreement shall, pursuant to the Arbitration Act, be governed by the law agreed upon by the parties. Where the parties have not reached such an agreement, the arbitration agreement shall be governed by the law of the country in which, by virtue of the agreement, the proceedings have taken place or shall take place.
Answer ... If the parties have made a choice regarding substantive law, it will be upheld. If there is no agreement regarding choice of substantive law, it will be for the arbitrators to decide. There is no provision in the Arbitration Act regarding the grounds on which the arbitrators shall decide which substantive law to apply to the arbitration. They will typically look at the conflict of laws rules applicable in Sweden. If the proceedings are governed by the Stockholm Chamber of Commerce Rules, the arbitrators need not consider the conflicts of law rules, but can make a direct decision to apply the law that they find appropriate.