Most firms treat vetting as a precondition for engagement: a screening pass that opens the door to the work. We treat the screening as the work. The standard described below is what a principal is buying when they retain UG. The names on the engagement memo are not the deliverable. The standard the names have cleared, and continue to clear, is the deliverable.
This note describes the four tiers of the standard, the boundaries between them, and the limits we are explicit about with clients.
01.I. TIER 1 / IDENTITY AND HISTORY
The first tier covers what most firms call vetting and what we call admissions. Documented identity. Verified employment history. Confirmed academic and professional credentials. Reference interviews with named prior supervisors, conducted by a person, not a vendor portal. Background checks against criminal, civil, and regulatory registries in every jurisdiction in which the candidate has resided for more than 6 consecutive months in the past 10 years.
The threshold is uniform across all roles. We do not differentiate Tier 1 by seniority, function, or expected engagement profile. An engineer joining the Cortex platform team and a senior analyst joining the regional desk clear the same Tier 1. The reasoning is straightforward: errors at Tier 1 propagate through every subsequent tier, and the cost of those errors compounds with engagement seniority. A defective Tier 1 on a junior hire becomes a defective Tier 1 on a senior hire several years later, by which time the error has accumulated reputational mass.
The standard at Tier 1 is documentary, not interpretive. A candidate whose history cannot be reconstructed to the firm's satisfaction does not advance, regardless of the quality of their references. This is non-negotiable. We have declined Tier 1 candidates whose résumés would have been welcome at most peer firms. We will continue to do so. The firm's posture rests on the integrity of this floor.
02.II. TIER 2 / OPERATIONAL FIT
The second tier is what most firms skip. Operational fit is not the same as competence. A candidate may be highly competent in their domain and still be a poor operational fit for the firm's posture, the firm's clients, or the specific engagement type for which they are being considered. Tier 2 is designed to surface that distinction before it becomes a delivery problem.
The mechanism at Tier 2 is structured peer review. Every candidate is interviewed by 4 practitioners from the function they are joining and at least 2 practitioners from an adjacent function. The interviews are scoped against a written competence model and a written posture model, both of which are reviewed annually by the relevant function leads. The output is a panel memo, not a hire-or-decline recommendation. The panel writes what they observed; the standards committee renders the decision.
This separation between observation and decision is deliberate. It prevents individual interviewers from carrying disproportionate weight on outcomes, and it produces a paper trail that is reviewable years after the fact. When we conduct a post-mortem on an engagement that did not meet the standard, the Tier 2 panel memos for the personnel involved are part of the file. We have learned more from those memos than from any single quality-assurance instrument the firm operates.
03.III. TIER 3 / DISCRETION AND CONFLICT
The third tier is the tier most clients ask about, and the tier most candidates do not anticipate. Discretion and conflict screening covers the candidate's counterparty map: every entity, public or private, with which the candidate has had a material relationship in the prior 7 years. This includes prior employers and clients, but also family ties, professional memberships, and any retained advisory positions that survive the candidate's transition into the firm.
The objective is not to exclude candidates with complex maps. Most candidates worth hiring have complex maps. The objective is to make the map legible, both to the firm and to clients, before the candidate is staffed on engagements where the map matters. Conflict, in this framing, is not a binary. It is a surface to be characterised and then governed against.
The Tier 3 outputs are two documents. The first is the candidate's counterparty map, maintained on file and updated annually. The second is the candidate's clearance schedule: which client lines they are cleared to engage on, which they are not, and the conditions under which the schedule would be revisited. The schedule is enforced by the staffing function, not by the candidate. This is the operational mechanism that lets the firm make a public commitment to neutrality without requiring every operator to recapitulate that commitment in every engagement.
04.IV. TIER 4 / CONTINUOUS REVIEW
The fourth tier is the tier most firms do not implement at all. Annual re-screening, engagement-by-engagement clearance, and disciplined off-boarding are the components, and each is treated as a standing obligation of personnel rather than a one-time event.
Annual re-screening repeats the documentary elements of Tier 1 and the counterparty map of Tier 3 for every member of the firm, every year. The standard is not lighter for senior personnel. The current Director of Regional Analysis cleared the same Tier 1 documentation last year as the most recent associate joining her team. We treat the standard as a property of the firm, not as a property of seniority.
Engagement-by-engagement clearance is a clearance check at the moment a person is staffed onto a specific engagement, against the specific counterparties and jurisdictional context of that engagement. This is the layer that catches the cases where a candidate's clearance schedule from the prior year does not map cleanly onto a new engagement profile. It is also the layer that surfaces the small number of cases each year in which a person who was cleared at Tier 3 should be re-evaluated against an emerging counterparty relationship.
Off-boarding standards close the system. Personnel exiting the firm complete a written deconfliction protocol that governs which client engagements they may take on at their next position, which intellectual property they retain, and which post-employment counterparty relationships are subject to notification obligations. The protocol is enforced by contract, but its operational substance is the off-boarding interview, conducted by a partner of the firm, on the record.
05.V. WHAT THE STANDARD IS NOT
We are explicit with clients about what the standard does not do. The standard is not a uniform clearance regime. We do not apply the same standard for Cortex engineers and protective-detail principals. The Tier 1 documentary requirements are uniform; the Tier 2 panel composition, Tier 3 counterparty depth, and Tier 4 re-screening cadence are differentiated by role. A protective-detail principal carries a deeper Tier 3 review than a software engineer, because the consequence surface is different. A research analyst carries a more demanding Tier 2 panel on intellectual integrity than an operations manager, because the failure mode is different. The standard is internally consistent. It is not internally identical.
The standard is also not a guarantee. We have declined to hire candidates we now know would have performed well, and we have hired candidates whose tenure ended in disagreement. The standard is a discipline against systemic error, not against individual error. Its claim is to keep the rate of catastrophic personnel-driven engagement failure below a measurable threshold, not to reduce it to zero. We track the rate annually, and the standard is revised when the rate moves outside its expected band.
Vetting is not the precondition for the work. Vetting is the work, repeated daily, against a standard a principal can audit if asked.
06.VI. WHY WE PUBLISH THIS
The standard is published because the standard is a procurement artefact. A principal selecting an advisor on the basis of capability alone has selected against the wrong dimension. Capability is the easy comparison; integrity infrastructure is the hard one. By documenting the four tiers, we give principals a basis on which to ask comparable questions of every advisor they consider, including us. The standard the firm holds itself to should be a standard the firm is willing to put in writing.
