In arbitration and mediation the most important consideration is neutral. I heard story after story with good patience replied many survey with non biased answer. I have soft skills around listening and able to read people. As a neural person I always try to hear or get to know what exactly the issue? Does one side really want an apology or actually want money or specific action to be taken, that time one side does not think the award is bias. The most effective neutrals were the ones who were able to cut through all of the posturing, complaining, and reiterating of each story to reveal the essence of the dispute and what the desired outcome was. The most important criteria wasn’t the neutral being an expert in the law but was someone adept at listening and homing in on the truth. Disputing parties wanted to make sure that their decision maker had no conflicts of interest, that the neutral hadn’t worked with either party before, or if they had decided a dispute involving one of the parties in the past, that the circumstance and the details were disclosed before a neutral was chosen. Part of this neutrality criteria also included non-bias, they wanted to make sure that the neutral had not been employed, consulted for, or been an expert for either part .