The Rejection Register and Conflicts Register as Integrity Tools

A rejection register records every engagement the firm declined, the date of the decision, and a short reason that identifies the category of concern. The register is maintained continuously rather than reconstructed retrospectively, so that the pattern of declined work is visible.

Reasons in the register are categorical, not narrative. Sanctions exposure, jurisdiction outside scope, activity outside permitted categories, and conflict of interest are each their own category. The categorisation lets a later reviewer see the distribution of declined work at a glance.

The register does not record the prospective client's identity in the open file. Identifying details are held in a controlled-access sub-file so that the pattern can be reviewed without exposing the identity of every prospect that approached the firm and was declined.

A conflicts register sits alongside. Every prospective engagement is screened against existing engagements, against firm relationships, and against any restricted list maintained for the firm. The screening result is recorded with the date, the screener, and the outcome.

Where a conflict is identified, the register records the resolution: declined, accepted with information barrier, or accepted with client consent on both sides. Each resolution type is supported by a documented procedure so that the resolution is not a discretionary act.

Both registers are reviewed during supervisory signoff. The two-stage review at file release includes a check that the engagement appears on the conflicts register with a stated outcome, so that no engagement reaches the deliverable stage without conflicts having been screened.

The registers are themselves part of the integrity story. A counterparty reviewing the firm's posture can be shown that declined work is recorded and that conflicts are screened, without being shown the identity of any prospect or counterparty involved in those entries.

Our role is to maintain the registers as a continuous record. We do not disclose their contents outside the firm without legal compulsion or written client authority, and we do not amend prior entries; corrections are recorded as new entries referencing the entry they correct.