UvA-DARE (Digital Water property rights in investor-state contracts on extractive activities, affects water governance: An empirical assessment of 80 contracts in Africa and Asia

In view of increasing globalization, the ongoing promotion of foreign direct investment and the lack of comparative literature on how water property rights are changing in the global South, this article asks: How have property rights in water evolved through investor-State contracts on mineral, petroleum and land issues in Africa and Asia? We analyse 80 publicly available contracts — 22 minerals, 40 petroleum and 18 land — of 34 African and 19 Asian countries. We find that: (i) in addition to a State's water law, water allocation is also implicitly governed by contracts and international investment treaties; (ii) States de facto privatize water by allocating quasi-property rights through the granting of contracts to foreign international investors; (iii) such waters exploited by virtue of contracts reduce the ability of States to regulate water during the term of the contract especially as investors' water use is protected by bilateral investment treaties and potential compensation claims; and (iv) the need of the State to increasingly adaptively govern water as the impacts of climate change on water become more noticeable will be challenged by the long-term quasi property rights granted by States to investors in such contracts.

are protected by a global network of about 3,000 bilateral investment treaties (BITs) (see Figure 1). For foreign investors, BITs create a 'sound, secure, and predictable investment climate' which protects their investments. 6 While the literature assesses case studies and theories, there is little comparative analysis on property rights in water and the role of contracts in them, especially in the global South.
Hence, we ask: How have property rights in water evolved through investor-State contracts on minerals, petroleum and land in Africa and Asia? By conducting a comparative analysis of investment contracts, we assess how these contracts affect water rights. We do not assess whether water included in contracts is considered de jure property in water, as this is determined by legislation and case law and most States avoid mention of property in relation to water. Instead, we show how implicitly and explicitly these contracts often lead to the creation of 'quasi-property rights', transferring some control over water resources to private sector actors. 7 With 'quasi', we mean, 'As if; as it were; analogous to. … [Indicating] that one subject resembles another, with certain characteristics, but that there are also intrinsic differences between them.' 8 In the 195 national legal regimes today, a water right is defined 'in terms of the relationship of the use to the water source'. 9 It is property in terms of a right to use a certain quantity of water, 10 rather than owning the molecule of water, and it 'constitutes a possessory interest in the right to use water'. 11 An investor-State contract is a contractual agreement by a State (or State entity) and a foreign investor, 12 which can be seen as a 'tenure relationship whereby rights to use water resources are created on the basis of investment contracts'. 13 Contracts have reciprocity: the exchange of goods, services and values, in which there is a correlation between the obligations of the parties. The transfer or allocation of rights may be unilateral depending on the contract. This article analyses contracts on minerals, petroleum and land between host governments and investors for large-scale projects.
Investor-State contracts confer rights on foreign investors, subject to obligations. We analyse such contracts on minerals, petroleum and land focusing on 13 elements, 14 clustered into six quasi-property rights. These are as follows: 1. The temporal dimension: (i) the period for which the contracts are valid and (ii) the possibility to extend this period.
2. The right to use and operate, including the right to: (i) operate an economic activity; (ii) use water in the operation, through a water use permit, right or authorization; and (iii) use the land on which the operation takes place. The period for which a contract is valid specifies for how long the investor can enjoy, and benefit from the allocated rights. The longer the contract period, the more security it gives to the investor to be able to recoup a return on investment and make a profit. The right to use and operate determines the economic activity and the boundaries in respect to an exploitable resource. The clearer this right is defined, for instance by granting exclusive use, the more it resembles actual property. The right to dispute resolution and litigation is a proxy of the protection and security an investor enjoys. It allows investors to protect their rights and investment through suing the host State. This right is closely related to the right of compensation, which allows investors to claim compensation when their rights are expropriated resulting in damages. The right of stability protects the investor against a change of legislation that would adversely affect the (economic) interest of the investor, adding to the protection and security of the investment. The right of alienation, as with property, allows the investor to transfer the rights it holds to another actor.
Water property rights may affect adaptive water governancethe ability of a State to adapt to the increasing uncertainties caused by climate change and the rapidly changing socio-economic conditions. 15 The increasing pressure on freshwater availability in many parts of the world 16 requires flexibility in the (re)allocation of water among competing uses and users. 17 Actors holding quasiwater property rights may hinder the State in the (re)allocation of water for the period covered by the contract, which is secured by the rights to dispute settlement, litigation and compensation. Moreover, water rights are not returned to the public domain when transferred to a different actor and therefore cannot be reallocated.  A and B; Tables A1 and B1-B3).
We chose land, mining and petroleum because water is crucial in all three industries-for mineral extraction (e.g., dust suppression, transport of waste in slurries and suspension, and separation of minerals through chemical processes), 18 for petroleum operations (e.g., drilling, cooling and discharging waste) 19 and on land (e.g., irrigation, livestock and afforestation). While mining consumes small volumes of water, at the regional and local level, it impacts freshwater quality. 20 Water pollution is important (e.g., in Ghanauntreated mine discharge polluting waterbodies 21 ; South Africasulphuric acid flowing into streams and groundwater 22 ; Nigeria-oil pollution in Nigeria's Niger Delta 23 ; and Bangladesh-water pollution by the petroleum refining industry), 24 and 'indirect' water use is generally much larger than 'direct' water use. However, the issues of pollution and indirect water use are beyond the scope of this article, and we specifically focus on the 'direct' entitled use of water. We focus on Africa and Asia because water is getting scarcer, 25 and the freshwater demand will grow consequent to population growth of 1.1 billion people (equal to 86%) 26 by 2050, and industrial growth by 800% in Africa and 250% in Asia, respectively. 27 Moreover, Africa holds 30% of global mineral reserves, and mineral exploitation will likely rise, 28

| RIGHT TO USE AND OPERATE
States grant foreign investors a 'right to operate', which enables them to perform a specified economic activity (e.g., mining, extracting and farming) subject to specific conditions within a certain timeframe.
They grant companies the 'right to use' including land and water.

| Right to operate
The analysis of constitutions, mining and petroleum laws show that all studied States have put minerals and petroleum deposits in the public domain, subject to State allocation. An exploitation right is granted through a permit following a prescribed application process. The permit and the ensuing rights are subsequently included in investor-State contracts. Companies can apply for an exploration (reconnaissance, prospecting or research) permit, which, if successful, confers priority in accessing a mining right for the exclusive exploitation of the discovered deposits. An exclusive exploration permit means the State authorizes the contractor to exclusively work in the designated area to discover minerals or petroleum, subject to specified rights, obligations and timeframe. the exclusive right 51 to exploit mineral deposits covered by the permit, or (ii) an exclusive exploration permit for the right of priority for obtaining an exploitation permit if economically exploitable deposits within the perimeter of the permit area are found (4 out of 22 contracts). 52 The national mining laws often specify the legal status of the granted mining right. For example, some contracts 53 state that an exploitation and mining permit constitutes a real property right that may be mortgaged. 54

| Agricultural contracts
As with mining rights, through selling or leasing land, States grant contractors a right to operate and a land right. However, these rights are less homogeneous as States lease the allocated land to contractors for exclusive use for palm oil production, 57 agriculture, livestock, 58 cotton, 59 and so on, and sometimes for production plants, such as ethanol plants, processing facilities or oil extraction mills. 60

| Land use rights
A land right implies defining the area in coordinates and hectares.
Some contracts elaborate on the land rights, which is a proxy of how 'strong' the rights are. For a contractor to exercise the right to operate, a right to occupy and use the land surface is needed. The right to operate is included in the contract to enable the contractor to carry out the operation on the land.

| Petroleum contracts
As with mineral mining, petroleum contracts grant the contractor a 'basic' and implicit land right, by allowing the contractor to operate in a specified area. In most contracts (25 out of 40), the States allows the contractor to occupy the land necessary for the petroleum operations and connected activities. A Kenyan contract states that '[t]he Government may at the request of the Contractor, make available to the Contractor such land as the Contractor may reasonably require for the conduct of Petroleum Operations', and a Senegalese contract states that '[s]ubject to the Minister's approval, which shall not be withheld without a reason, the Contractor shall have the right to construct at its own expense any and all installation(s) which may be required to be built in the area necessary for Petroleum Operations'.
According to a Liberian contract, when the contractor cannot reach an agreement with the landowners, the State must expropriate the land against compensation. An Ethiopian contract requires the contractor to negotiate a compensation settlement if executing the contract involves displacing people. In case residents refuse to resettle, the Minister can evict them and determine the payment of reasonable compensation. 68

| Agricultural contracts
The right to operate farmland is linked to a specified land on which the contractor can operate. The contract area ranges from less than 10,000 69 to 100,000 ha, 70 to even beyond. 71 Moreover, most contracts 72 specify what the land should be used for, implying water use to produce palm oil, 73 forest resource exploitation, 74 cotton farming, 75 agricultural activities 76 and/or cattle industry. 77 Most contracts do not have provisions on the displacement of people. Only two contracts 78 address the resettlement of people. A Liberian contract states that an investor 'may by Notice to Government request that certain settlements be relocated if … such existing settlements and its inhabitants would impede Investor's development of the Concession Area'.

| Water use rights
States may entitle foreign investors to abstract a specified volume or percentage of water subject to specified conditions (e.g., time, obligation not to pollute, taking into account the rights of others). The studied contracts show that different language is used to denote this entitlement-water is included either as a right to use water or subject to State authorization, for instance via a water use permit or authorization. Moreover, one contract may grant multiple water use rights.
The legal status of the water use entitlements would have to be confirmed by courts. Whether as a right in a contract, by law, under a permit, and/or to construct infrastructure, most studied contracts (mineral 16 out of 22; petroleum 24 out of 40, land 8 out of 10) contain a provision on water. In case a permit is required, most contracts required that the government support the contractor in application or even guarantees the permit (thus making the granting of the permit just a formality).

Right to use water
In some mineral contracts, the contractor has the right to take and use water needed for the agreed activities in accordance with the regulations 79 and subject to the rights of third parties. 80 A Liberian contract grants the contractor the right to abstract water if it is reasonable in relation to its activities and does not affect the surrounding population or if the population is compensated by providing water from an alternative source. Two countries guarantee a contractor a water right: a Nigerian contract guarantees the contractor the use of groundwater reserves, within and outside the perimeter, and a Sierra Leonean contract allows the contractor to use the water from any natural water course, within or outside the mining area. A Mauritanian contract guarantees the contractor all rights to extract, convey and use sufficient quantities of water from sources discovered and developed. In Senegal, a contractor is authorized to use water, and in Mali, the contractor has a right (in accordance with legislation) to use unused or reserved waterfalls for mining works. A Mongolian contract states that '[t]he Investor is granted the right to access and use its self-discovered water resources for purposes connected with the project'. A Burkina Faso contract refers to the Mining Code, which states that land occupation allows the right to water from waterfalls, surface and groundwater within the perimeter.

Right to water subject to permit application
Other contracts require mining contractors to acquire State authorization to exploit, or enable exploitation on its behalf, of water resources in the project area pursuant to a water usage agreement in compliance with the legislation. 82 According to a Guinean contract, the contractor must obtain approval from the competent authority for exploiting unused waterfalls that are not reserved for mining activities. Based on a Papua New Guinea contract, the State must grant the contractor water use permits allowing water extraction to enable mining. A Mongolian contact states that the State 'shall ensure that a contract [30 years, extendable for 20 years] on water utilization is awarded upon request of the Investor in accordance with the Water Law, the Law on Fees for Use of Water and Mineral Water and other laws and regulations'. And according to a Malawian contract, the contractor can take the necessary water subject to a permit from the relevant minister.

Right to use water from public water provision
A Cameroonian contract allows the contractor to either negotiate drawing from the water facilities available in the relevant project area or negotiate to receive running water supplies through a contract with any entity entitled to distribute water. A Tunisian contract states that the licensing authority shall 'facilitate to the Licensee, if it so requests, the subscription to temporary or permanent subscription policies to the public drinking or industrial water distribution networks, within the limit of its legitimate needs, and within the limit of the flows available to these networks, in accordance with the provisions of the Water Code'. A Zambian contract states that the government 'will procure the provision of municipal water infrastructure the areas in which the contractor will operate'.

Right to develop infrastructure
A Sierra Leonean contract grants a company the right to construct and operate, within or outside the contract area, infrastructures or facilities needed for the mining operations, including for example water supply systems, subject to State approval. A Senegalese contract authorizes the contractor to carry out work required for the supply of water to works and facilities.

| Petroleum contracts
Right to use water Some petroleum contracts have provisions in place that state that contractors can use water for petroleum operations, 83 or have a right to use water, 84 subject to the provision that people, livestock watering places, homes and/or flora and fauna are not deprived from water and/or that water is adversely affected, 85 that existing irrigation or navigation is not disturbed 86 or efforts are taken to minimize adverse effects. 87 Right to use water subject to approval or permit application Some contracts state that the water use is subject to State approval or authorization. 88 In other contracts, water use is subject to obtaining a water use permit. For example, a Kenyan and Malawian contract state that the Minister or Ministry 'shall facilitate on behalf of the Contractor any permit necessary to enable the Contractor to use the water in the Contract Area for the purpose of the Petroleum Operations'. This is subject to other water uses not unreasonably being deprived of their supply of water. Similarly, a contract in Jordan states that the government will assist in obtaining the permission to use water. According to contracts in Azerbaijan, Cameroon and Nigeria, although not specifically mentioning water, the contractor shall acquire the authorization required for or in connection with the petroleum operations.
Other contracts describe the facilitating role of the State. For example, a Mozambican contract states that the government must authorize the contractor the right to use, drill for and/or impound water and establish water supply systems, for the petroleum operations. And a Tunisian contract shall give the contractor the facilities that cover the supply of water.

Right to construct water infrastructure
A few contracts grant the right to construct water works needed for their activities. 89 For example, a Ugandan contract states that the government shall assist the contractor in obtaining the right to contract facilities related to the operations, which includes water well drilling.
A Chadian contract allows contractors to make the necessary boreholes and water works and/or divert watercourses provided that the water supply to people, livestock, fauna and flora is not adversely affected. Similarly, a Mauritanian contract grants the contractor the right to carry out works for the supply of water for petroleum operations, subject to legislation.

| Agriculture contracts
About half of land contracts (8 out of 18) include water provisions.
Four contracts allow the construction of water infrastructure: an Ethiopia contract grants a contractor a right to build infrastructure including dams, boreholes and water reservoirs subject to government approval; a Liberian contract grants a similar right 'free of charge', subject to legislation and approval which shall not be unreasonably withheld, and the water use shall not deprive others (tribes, villages, 82 e.g., Cameroon. towns, houses or animals) from the reasonable supply of water. And a Cambodian contract states that the contractor needs a permit to construct a dam on canals.
Based on a Liberian contract, a lease of 220,000 ha of government land includes bodies of water, streams, creeks and rivers on such land. And a Cameroonian contract states that the government grants a contractor the right to exclusively take and use water as necessary for the activities, without obtaining authorization. In Sierra Leone, a contract guarantees no restriction on the volume of water abstracted.
The analysis shows that water rights are explicitly included in most mineral (16 out of 22) and petroleum (26 out of 40) contracts and half of the land (8 out of 18) contracts. States grant contractors (i) a right to use water, (ii) a water right subject to State authorization, (iii) a right of the use of water service provision, and/or (iv) a right to develop water infrastructure. Including water use rights in contracts may have implications, since the right to use water is inextricably linked to the right to use land and the right to operate, taking away the right to use water infringes on the right to operate. With contracts possibly falling under BITs (see Section 4), this can be seen as indirect expropriation of the right to operate, which can be subject to compensation claims (see Section 5). This implies that in addition to a State's water law, water allocations are implicitly also governed by contracts and international law, 90 as water rights are embedded in the current existing legal constructs. This undermines and bypasses a State's water law and water governance regime, which requires water use to be subject to permits. 91

| DISPUTE RESOLUTION MECHANISMS
Contracts generally have a provision in place on dispute resolution instruments, to solve a dispute, disagreement, controversy, claim or difference of whatsoever nature arising under, out of, in connection with, or relating (in any manner whatsoever) to the agreement. Investors are granted the right to dispute resolution, and the contracts specify the instruments that are available to them, including the: (i) amicable settlement of disputes within a specified timeframe, (ii) settlement of technical matters by an expert, and (iii) settlement of disputes through arbitration.

| Petroleum contracts
In most petroleum contracts, the parties agree to make a reasonable effort to solve disputes amicably. Failing such an amicable solution within specified days, the dispute can be submitted for formal settlement via an expertise procedure or arbitration.
Fifteen countries allow a 'technical dispute' to be submitted to an expertise procedure administered in accordance with the agreement or specified rules. This procedure includes appointing a sole qualified expert, or experts, jointly agreed, which is final and binding. Where a dispute persists, it has to be settled by arbitration. 104 As with mining contracts, all petroleum contract-related disputes are finally and exclusively settled by arbitration, by three arbitrators appointed in accordance with the agreement or arbitration rules. Any party may submit such a dispute to arbitration by notice to the other parties. The tribunal's award is final, irrevocable, binding and enforceable in any court with appropriate jurisdiction. Some contracts follow 90

| Agriculture contracts
In eight agricultural contracts, if an amicable solution is not reached within the specified period, the dispute can be settled by a court or by arbitration. In these eight countries, such contract- impaired. This implies that the responsible authority for water governance can lose control over the water included in investor-State contracts.

| COMPENSATION
Contractors can claim the right to compensation from the host State in case of direct or indirect expropriation. Direct expropriation occurs when an investment is nationalized, expropriated by physical seizure of assets or formal transfer of title. Indirect expropriation refers to State interference in the investment or benefits that have a similar effect to nationalization or expropriation. 121

| Mineral contracts
Most mineral contracts (14 out of 22) protect the investor against expropriation without compensation. Two contracts explicitly mention indirect expropriation. 122 Two other contracts, by Liberia and Niger, assure the investor that it has no intension to expropriate, while contracts involving Mauritania and Senegal state that they shall not expropriate or nationalize. Some contracts suggest that a State is allowed to expropriate, for example, for public necessity, interest, utility or purpose, for reasons of national or general interest, where permitted by the appropriation law, or if circumstances or a particular situation require such measures. 123 In these cases, the State promises to pay fair and equitable compensation to the injured parties.

| Petroleum contracts
Unlike mineral contracts, only four petroleum contracts mention expropriation, nationalization or other taking, stating that the capital, property, assents, rights or interests of a contractor shall not be expropriated. The exceptions are if this is for public or national purposes or interest, only in accordance with the due process of law, on a non-discriminatory basis and subject to the payment of compensation. In another contract, Mauritania guarantees the company stable conditions and advantages during the contract period.

| Petroleum contracts
Twenty-eight petroleum contracts provide State support: 18 pertain to the State 143 (government, ministry, minister, State company or agency, president) taking reasonable steps in facilitating or assisting in, granting necessary permits, licenses or authorizations for petroleum operations. Although there is no explicit reference to water, two contracts 144 explicitly ensure government support in securing water.
Eleven other contracts have more general provisions on support, indicating that the State will take all reasonable measures in facilitating or assisting in the objectives or activities of the contractor.

| Agriculture contracts
Half of the land contracts (9 out of 18) include State support provisions ranging from the government guaranteeing the investor the peaceful enjoyment and use of the land for the duration of the lease 145 to assisting in obtaining the necessary authorizations. 146 Two contracts 147 state that the government promises to facilitate, coordinate or safeguard the investor's business operations, and support the development of the project by agreeing to the main incentives, exemptions and rights.
Most contracts explicitly state that countries must facilitate the investments of contractors including facilitating the relevant permits (which may include water permits). This may result in conflicting interests: for example, while the department mandated with the governance of water is responsible for sustainable water governance, ensuring access to water and granting water use permits, the departments mandated with managing the national treasury, and mineral, oil or land may focus only on revenue generation and economic growth, without considering the availability of water and ecosystems. 148 Many developing countries depend financially on the large multinational investors, either sharing profits or receive royalties and/or taxes. 149 Economic gain tends to prevail over sustainable water governance for the benefit of the public. 150

| ALIENATION
The right to alienate includes the right to transfer assets or rights.
Most mining and petroleum contracts (19 out of 22 and 40 out of 40, respectively) grant the investor the right to alienate. In some contracts, the contractor is given a mining license-the sole right to explore, develop and produce petroleum in the contract area and to exercise other rights granted by the agreement. The contractor is also granted the right to alienate (i.e., sell, assign, transfer, convey or otherwise dispose of all or any part of the rights, interests and obligations under the agreement) subject to approval. In other contracts, the parties agree to establish a joint venture or operating company that is responsible for carrying out the exploitation works. The joint venture may be subject to consent and/or assign its entire interest or an undivided proportionate share of its interest in the project assets or its rights and obligations under the contract.
More than half the land contracts (11 out of 18) grant investors the right to transfer (i.e., assign, mortgage, charge, pledge or otherwise encumber) any or all interests or rights and obligations subject to providing notice to the government or government consent. In some contracts, the transfer of land or land use rights (by transferring shares, setting up a new company or subletting the land) is subject to prior consent, and/or on the completed level of development as agreed in the contract, for example, a percentage of land developed ranging from 30%, 151 75% 152 to 100%. 153 A contract by Congo allows the investor to partially subcontract the land subject to state approval, while a South Sudan contract grants the right to sublease any part of the land. A Gabonese contract states that the long leases constitute a real right for the lessee which is transferable and mortgageable.
Most mining, petroleum and land contracts (19 out of 22, 40 out of 40, and 11 out of 18, respectively) have a provision in place on the right to alienate. This allows the contractor to transfer any part of the rights, interests and obligations under the agreement before the contract period ends. For the contract period, the government no longer holds the granted rights and loses control over these rights. Since these rights can be alienated, the only way to get the rights back is to break up the contract, which is subject to compensation. Regarding water, this implies that when water rights are included in the con- (i) a right to use water, (ii) a water right subject to State authorization, (iii) a right of the use of water service provision, and/or (iv) the right to develop water infrastructure. The right to use water or develop water infrastructure undermines and bypasses a State's water law, which requires water use to be subject to permits. 156 Even if a water use right is granted based on a permit, by being included in an investor-State contract, it is possible that the rules of the contract override the water law's provisions or require so much compensation that States cannot really withdraw such permits easily. This affects the ability of poorer countries to adaptively govern water based on new and changing circumstances. The right to develop infrastructure may result in exclusive claims to (stored) water.
Second, the right to water is inextricably linked to the right to operate, and the right to land-bound to each other by the contract and protected by a global network of BITs. No operation can take place without water. When a water right is taken away, the right to operate is encroached on.
Third, contracts are granted for long periods, including the possibility to extend the period. Once granted, the rights that are included in a contract cannot easily be reallocated. The longer the contract period, the longer water rights are allocated, and the longer States lose control over these water rights.
Fourth, most contracts allow the investor to transfer any part of the rights before the contract period ends. With investors holding the right to alienate, water rights are not returned to the public domain when changing hands. Only when the contract ends, or when the contract is breached, can water be reallocated. This impairs adaptive water governance.
Fifth, contracts are protected by BITs and arbitration rules, which can be problematic for the host State. Dispute settlement most often involves international arbitration, which reduces the national court's mandate to a supervisory role. National courts are thus side-lined in the dispute settlement process. This affects the control over the water that is included in investor-State contracts.
Sixth, related to this, in case of expropriation of the right to operate, compensation can be claimed. While few contracts mention indirect expropriation, most (97%) BITs mention the possibility to claim compensation in case of indirect expropriation. States that have signed BITs are bound by the provisions of these agreements which create a favourable investment climate for and protect foreign investors' rights. Taking the right of water away indirectly encroaches on the right to operate as without water, no operation can take place.
This may imply an indirect expropriation of the right to operate and breach of a BIT, which may lead to compensation claims. States may be reluctant to resolve matters through arbitration because of the high costs of arbitration and possible payment of compensation, reputation damage and loss of FDI. This may result in States losing control over the water included in investor-State contracts.
Seventh, most contracts have a stabilization clause in place. While this protects the investor from any adverse impact on the economic equilibrium of the investment, it may restrict the ability of the State to amend or modify their legislation and hinder its pursuit of sustainable development. Compensation can be claimed if raising environmental and social standards would affect the economic equilibrium for the investor.
We conclude that in addition to a State's water law, water allocation is also implicitly governed by contracts and international invest- can be seen as being de facto excluded from the public domain. States further appear to have lost their regulatory power and control over the water resources, as investors' water use is protected by BITs, arbitration and compensation claims, limiting the State's ability to govern, redistribute and reallocate water. Contracts can be inconsistent with the aims of host country development policies, and since contracts are in place for long periods, they will still be in place as the effects of climate change on water availability become more noticeable and require States increasingly to reallocate the water.

DATA AVAILABILITY STATEMENT
The data that support the findings of this study are publicly available.
These data were derived from the following resources available in the public domain: the petroleum and mining contracts at <https:// resourcecontracts.org/>, and land contracts at <https://www. openlandcontracts.org/>.  c Agreement between States (Sudan and Syria).