Mediation “Game Plan”

Mediation “Game Plan”


How do you prepare for mediation? Ensure you have a game plan.Every professional sportsman has a “game plan” – a plan to get the best possible outcome from their next performance.  Mediation is no different – to get the best possible outcome you need to prepare in advance.

The “game plan” for a mediation is very simple:



  • Have you objectively reviewed your position in advance of the mediation?
  • What can you realistically hope to achieve at the mediation?
  • Do you know what the key issues at the mediation are likely to be?
  • What key risks do you/your opponent face?
  • Have you produced a breakdown of your costs to the end of the mediation?
  • Remember – you are preparing for peace, not war.



  • How am I going to craft my first offer to make it attractive to my opponent?
  • What key messages do I want to get across?
  • Don’t pursue hopeless points – it merely undermines the good points you have.
  • Tantrums and bad manners do not help.
  • Have an open mind – you might find out something at the mediation which has a material impact on your previously held views.
  • Make the most of your mediator – they are there to help.


So, if you are attending a mediation have a “game plan”, but be flexible enough to adapt your “game plan” if new risks or issues emerge during the course of the mediation.


Charles Powell

Hexagon Mediation

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