You will need to lay out the ‘ground rules’ for the mediation process. Usually some basic rules of communication and confidentiality will be essential, but there may also be others pertinent to that situation. For example, you might want to set out that only one person talks at a time, and while someone is talking, the others listen in silence, that there is to be no verbal abuse at any time, and that all that happens remains confidential unless both parties agree to speak about it outside mediation. You may also wish to set out the mediator’s role: to be impartial and help the parties to reach their solution, but also to protect the parties from each other if necessary.

You should also consider whether you should have separate meetings with each party to develop a better understanding of the issues before mediating a joint meeting.