The Supreme Court has made labor arbitration a key aspect of federal labor policy in three cases known as the Steelmaker Trilogy. The Court held that appeal arbitration was a preferred dispute resolution technique and that the courts could not set aside arbitrators` arbitral awards unless the arbitral award did not derive its essence from the collective agreement. State and federal laws may permit the expulsion of an arbitral award on narrow grounds (e.g. B fraud). This protection of arbitral awards is based on the trade union management system, which provides both parties with due process. In this context, due process means that both parties have been represented throughout the process and that arbitrators act only as neutral. See the National Academy of Referees. All jurisdictions that favour arbitration accept, to some extent, the presumption of separation, whether by customary or civil law.6 23.2 For this purpose, an arbitration clause that is or should be part of another agreement is treated as an arbitration agreement independent of that other agreement. A decision of the Court of Arbitration that such another agreement does not exist, invalidates or is invalid does not (in itself) lead to the non-existence, invalidity or ineffectiveness of the arbitration clause. . . .