Sample Ground Rules for Mediation


  1. We will take turns speaking and not interrupt each other.
  2. We will remain focused on the issues at hand and avoid being sidetracked into other non-relevant areas.
  3. We will not demean, belittle, blame or attack each other, nor will we engage in put-downs, and will ask questions of each other for the purposes of gaining clarity and understanding only.
  4. We will stay away from establishing hard positions and express ourselves in terms of our personal needs and the outcomes we wish to realize.
  5. We will listen respectfully, and sincerely try to understand the other person’s needs. We will not make assumptions about the other person’s motives or needs.
  6. We recognize that even if we do not agree with the other person’s perspective, each of us is entitled to our own perspective.
  7. We will not dwell on things that did not work in the past but instead will focus on the future we would like to create.
  8. We will make a conscious, sincere effort to refrain from unproductive arguing, venting and defensiveness.
  9. We agree to work hard towards what we perceive to be the fairest and most creative agreement possible.
  10. We will speak up if something is not working for us in mediation. In particular, we will point out if we feel the mediator is not being neutral and impartial