The Mediator’s Playbook: How to Prepare Your Team for a Successful Session
As we move toward the end of 2025, many HR leaders and managers are taking stock of the year’s challenges. For some, that means resolving lingering disputes that have been simmering beneath the surface. Mediation often becomes the turning point, the space where teams can finally resolve workplace conflicts without the expense and disruption of formal litigation. But here’s the truth: the outcome of a mediation session is often determined before anyone even steps into the room. Preparation is what separates a frustrating, drawn-out process from a session that moves smoothly and leads to real solutions.
At its core, mediation is about dialogue and compromise. But without clear goals, the right documents, and a realistic strategy, both employees and management teams risk entering the process unprepared. That not only slows down progress but also increases the chance of leaving issues unresolved. A little planning on the front end, knowing what to say, what to bring, and what pitfalls to avoid, goes a long way toward ensuring the session is productive and fair. That’s where a structured mediation preparation plan becomes essential.
Why Preparation Matters in Mediation
Unlike litigation, where rigid rules of evidence dictate what can and cannot be presented, mediation is a flexible process. That flexibility is both an opportunity and a risk. When teams arrive without focus, mediators must spend valuable time sorting out confusion and clarifying basics that should have been addressed beforehand. By contrast, when parties come in with well-defined objectives, clear documents, and an understanding of the process, the mediator can dedicate their energy to building solutions rather than untangling misunderstandings.
Preparation also helps ease emotions. Workplace disputes often carry strong feelings, frustration, disappointment, or even distrust. A pre-mediation plan gives each side structure: what to expect, how to frame their concerns, and what realistic resolutions could look like. That structure alone can lower anxiety and make participants more open to compromise.
What to Prepare Before Mediation
1. Position Statement
Every participant should come with a concise position statement. This is not a full legal brief but rather a clear summary of your perspective: what happened, why it matters, and what you hope to achieve. A good position statement avoids blame-filled language and instead highlights priorities. For example:
“We recognize the communication breakdown that occurred regarding workload expectations. Our goal is to reach an agreement that balances operational needs with employee well-being.”
This kind of statement frames the issue constructively and sets the tone for dialogue.
2. Key Documents to Bring
A mediator cannot work effectively without facts. Be sure to gather:
Payroll or HR records related to the dispute.
Relevant emails, memos, or written communications.
Policy documents, performance reviews, or contracts.
Any proposed remedies, draft settlement language, or notes on potential solutions.
Having these documents ready avoids “I’ll get back to you” delays and ensures that decisions can be made in real time.
3. Draft Settlement Language
It might feel premature, but drafting potential settlement terms before mediation speeds up negotiations. Even if the draft is only a starting point, it signals that you are serious about finding common ground. Think in terms of practical solutions, adjustments to schedules, updated communication processes, or financial terms, written in plain language.
4. Team Alignment and Communication
For HR and management, scheduling a prep meeting with counsel or internal stakeholders is invaluable. This allows the team to align expectations and clarify boundaries before the session. For employees, a prep call with a representative or coach can reduce uncertainty and encourage open communication. Alignment minimizes surprises in the mediation room and makes it easier to move toward resolution.
A Pre-Mediation Checklist
Here’s a suggested checklist you can use with your team:
Write a short position statement.
Gather HR records, payroll data, and relevant communications.
Print or bring policy documents and contracts tied to the dispute.
Prepare a draft settlement proposal or talking points.
Meet internally (management) or with a representative (employee) to set expectations.
Decide on your “must-haves” and your “flex points.”
Practice your opening statement in advance.
Scripts for Opening Statements
It helps to start the session with a calm, respectful tone. Here are short examples you can adapt:
Manager’s Opening Statement:
“We value the contributions of our employees and want to resolve this issue in a way that restores trust and strengthens our team. Our goal is to listen, understand, and explore solutions that allow everyone to move forward productively.”
Employee’s Opening Statement:
“I appreciate the chance to be heard in this process. My hope is to clarify my concerns, discuss how this situation has impacted me, and work toward an agreement that supports both my role and the company’s needs.”
These statements keep the focus on collaboration rather than conflict.
What to Avoid in Mediation
Preparation also means knowing what not to do. Common mistakes include:
Arriving without key documents, forcing delays.
Using the session to rehash old grievances rather than focusing on solutions.
Making unrealistic demands that stall progress.
Speaking in absolutes—“never” or “always”—only fuels defensiveness.
Failing to clarify authority: participants must know whether they have decision-making power to finalize agreements.
Avoiding these pitfalls keeps the process constructive and efficient.
How Moxie Mediation Supports Preparation
At Moxie Mediation, we understand that walking into mediation without a plan can leave everyone feeling unsettled. That’s why we work with clients in advance to make the process smoother. Our mediators help participants clarify their position statements, identify which documents will be most useful, and even think through potential settlement terms. This proactive approach gives both employees and managers a sense of readiness, lowering stress and increasing the chance of reaching a fair agreement.
We also focus on more than just the immediate dispute. Mediation with Moxie is designed to help repair workplace relationships and strengthen communication practices that prevent future conflicts. Preparation is key, and with the right support, mediation can be both efficient and transformative.
FAQ
What documents should I bring to mediation?
Position statements, payroll and HR records, relevant communications, policy documents, and any proposed remedies.
Should employees and managers meet before mediation?
Yes. A prep meeting helps align expectations, and mediator-led preparation can reduce surprises during the session.
Can counsel attend mediation?
Yes. Counsel can attend, and their involvement often improves efficiency by clarifying legal considerations and helping draft settlement language.
Need help preparing your team or resolving a workplace dispute? Moxie Mediation offers confidential and professional mediation services that streamline the process, making it smoother, faster, and more productive for everyone involved. Contact Moxie today!