country. Consequently; contracts of carriage, maritime insurance contracts, and other contracts related to maritime transportation are subject to a distinct legal system derived from English admiralty law. In Ordon Estate v. Grail, the Supreme Court of Canada stated that "the substantive content of Canadian maritime law is...the body of law administered in England by the High Court on its Admiralty side in 1934, as that body of law has been amended by the Canadian Parliament and as it has developed by judicial precedent", and that "most of Canadian maritime law with respect to issues of tort, contract, agency and bailment is founded upon the English common law" but nevertheless that "English admiralty law as incorporated into Canadian law in 1934 was an amalgam of principles deriving in large part from both the common law and the civilian tradition". The formation of contracts under Canadian maritime law thus functions similarly but not identically to the formation of contracts in the country's common law provinces; furthermore, the implementation of rules derived from international conventions subject maritime contracts to distinct rules often derived from international norms. Bills of exchange and promissory notes Bills of exchange and promissory notes are two distinct types of contractual instrument subject to a distinct legal framework under which the rules governing their formation, validity, and nature is governed by federal rather than provincial law, and are thus harmonised between Québec and the common law provinces. A bill of exchange is "an unconditional order in writing, addressed by one person to another, signed by the person giving it, requiring the person to whom it is addressed to pay, on demand or at a fixed or determinable future time, a sum certain in money to or to the order of a specified person or to bearer". A bill of exchange requires three parties: the drawer, the drawee, and the payee. The drawer gives the order to pay money to the third party while the drawee, whose identity must be "indicated...with reasonable certainty", is the person to whom the bill is addressed and who is ordered to pay. The drawee becomes an acceptor when they indicate their willingness to pay the bill, and the drawee's acceptance is required in order for the contract represented by the bill of exchange to come into existence. The payee is the person in whose favour the bill is drawn or is payable. The parties need