Written by Graham Perry

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

1 April 2021



You are the mediator. You have had the opening session – introduced yourself; thanked everyone for coming; explained your role; explained the procedure. Now you go One-to-One with the first party.

So important to get this right. The party+advisers will be assessing you. Are you up to the task? You understand that but you also have a goal – to make the party feel comfortable with you. Their confidence in you needs to grow. So at this stage, encourage them to talk.

For example – “tell me a little more about this” – as you try to get a better understanding of their position. You want them to talk and you want them to see that you are a good listener.

You avoid head-on issues. You take them one by one + step by step. You are building up a picture. Gently – no pressure. You are showing an interest and an ability to understand all the elements of their case. They will like that. Their confidence in you will begin to grow. You move from being just a name + a cv to being a person with presence.


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