Wording to safeguard an agreement?

[Kimon]

I'm at the point of being able, through ACAS, to offer a resolution to an employment dispute, as the claimant's representative. The dispute is related to wages and other payments owed to the claimant. The settlement to be suggested by me is for a sum of money to be paid to the claimant. At present, I have taken the process through early conciliation and have ET1, ET3 forms and a date for a tribunal hearing. https://speedtest.vet/ https://vidmate.bid/ In order to protect me from any counterclaim, is there a set of words that will do this for me? I was thinking of something like "in full and final settlement".

Any advice or suggestions would be gratefully received.