Written by Graham Perry

Graham Perry M.A. Cantab FCIArb Experienced Arbitration Lawyer | China & Chinese Business Affairs | Public Speaker/Lecturer

12 May 2021



The words “private + confidential” are spoken so often that the real meaning is often lost. In mediation, you have your first private one on one with Party A – there will be more as you gradually strip away the leaves of the artichoke. So you trot out the term – “private and confidential” but do you get the importance of the term across to Party A?

What you are saying is “this goes no further…this is between you and me… you can say things to me which stay in this room…you can trust me…you have to trust me if we are to make progress…do you trust me?

Get to the core question – “Talk To Me”. None of this is confrontational or harsh. It is designed to put Party A’s mind at rest. Can you do this? Are you able to convey sincerity and reliability and confidentiality? If you can, you will succeed. If you can’t you will fail.

Confide in me, +44 20 8954 1001


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