In contrast to most civil law jurisdictions, and indeed some common law ones, English law does not currently recognise a general implied duty requiring the parties to a contract to perform the obligations under it in good faith. There are some exceptions to this general rule. For example, an agent owes a duty of good faith to his or her principal, and a fiduciary owes the duty to the counterparty to the fiduciary relationship. In these situations, trust, honesty and transparency are an essential and integral part of the agreement.