Example: Opening Statement for Mediation

Example: Opening Statement for Mediation
Page content

Create the Right Atmosphere

When you act as a mediator, the employees need to feel that you are unbiased and only interested in helping create a solution that is beneficial to both sides. For example, opening statements for mediation are important. But before you get to the opening statement, there are other considerations.

There are a couple of simple things a mediator can do to help create that feeling of impartiality. The first is to examine the atmosphere of the surroundings of the mediation. Where will it be held? How is the location perceived by the participants? How will the mediator arrange the seating? These are just a few of the initial considerations that can help set the stage properly and create the best possible atmosphere under the circumstances.

Set Some Basic Ground Rules

It’s vital to develop some ground rules in advance for any mediation. This will help in creating the right atmosphere and keeping the participants focused on the mediation and not each other. Controlling the mediation must be handled smoothly and professionally by the mediator. There is always the possibility that emotions can get intense and become an overriding part of the session. When personal attacks are thrown at each other by the participants, and possibly even at the mediator, having ground rules to focus on becomes even more important. Some basic ground rules include no interrupting the other person, no yelling, no abusive language and no personal attacks.

Open the Mediation

FreeDigitalPhotos, photostock 33989a82z0phcr7

With the best possible location to create the right atmosphere, and a few well thought-out ground rules prepared in advance, the mediator is now ready to open the mediation. Opening the mediation sets the tone for the remainder of the session, so, it needs to be presented confidently and directly. There should be no room for interpretation by the participants.

Example, Opening Statement for Mediation

“Thank you both for attending this morning. My role here today is to help you find some common ground and to see if we can come up with a resolution that we can all agree to. If as a group we cannot come up with a resolution, I will then decide as the mediator what the next step will be. Before we get started, there are a few ground rules.”

State your ground rules. Look at each participant and get agreement on his or her understanding of the ground rules. For example, “Bill, do you understand the ground rules?” Get his agreement and then turn to the other party, “Sharon, do you understand the ground rules?” With both sides agreeing up front to the ground rules, the session should go smoother. However, do not move beyond the ground rules if there is any hesitation by either person.

As part of the opening, you can also briefly outline the process you plan on using.

“I’m going to ask each of you individually to present your point of view. The other person must listen to what is being said. To ensure this, I’m going to ask the other person to restate what was just said. So, for example: Bill, you will complete presenting your point of view around a question I have asked; Sharon, you will have to restate what Bill just said. Is that process clear to both of you?”

Do not move off this understanding of the restating skill as it is a big part of the mediation process. Restating helps clear up any misunderstandings and forces better listening.

“In addition, as we move along today, I will also be asking each of you to present solutions to some of the problems brought up. As part of your solutions, I would like to hear what you believe are the possible consequences of your solutions being implemented. We will also follow the same restating process that I just brought up. All right, let’s get started. Bill I’ll start with you.”

This gives you a brief sense of a simple, yet effective mediation opening. Gaining participation through active listening and respectful communication will go a long way toward achieving a successful outcome.


Steinberg, Robert A. Los Angeles and San Francisco Daily Journals: Opening Statements In Mediation Talks Are Often Missed Opportunities (June 2008). Retrieved at https://www.pgpmediation.com/blog/wp-content/uploads/2008/07/opening-statement-in-mediation-talks-are-often-missed-opportunities.pdf (as uploaded to PGP Mediation website).

Image credits:

sxc.hu, Col6085

FreeDigitalPhotos, photostock