• CONFLICTS OF INTEREST POLICY

The rule, in public

Haskins Capital advises project owners and, separately, the institutions that finance capital projects. Both practices run out of one firm under one policy. This page states the rule so no client has to ask for it.
  • Policy version 1.0 · Effective September 18, 2026. Applies to all engagements of Haskins Capital LLC
  • THE TWO RULES

Project-level and client-level.

  • RULE ONE · PROJECT LEVEL

Never both sides of the same project.

If we advise the owner on a project, we will not accept a lender engagement on that project. If we review a project for a lender, we will not accept owner-side work on it. This holds regardless of timing, and it survives the end of either engagement.
  • RULE TWO · CLIENT LEVEL

Never paid by a borrower we are reporting on.

We will not accept owner-side work from a company whose loan we are currently reviewing for a lender — even on a different, unrelated project. Being paid by the borrower while opining to their lender is a client-level conflict, not merely a project-level one.

SCREENING

How a conflict actually gets caught.

A stated rule is worthless without a process that surfaces the conflict at intake. Ours has four steps.
1

Conflicts register

Every engagement records the owner, the general contractor, and the major vendors and suppliers. The register spans both practices and is maintained continuously, not per project.
2

Screen at intake

Every prospective engagement is screened against the register before a proposal is issued — not after a contract is signed.
3

Disclose counterparty overlap

Where the same contractor, vendor, or parent company appears on another active engagement without triggering either rule above, we disclose it in writing and let the client decide. Disclosed and accepted is acceptable. Discovered later is not.
4

Mid-engagement discovery

If a conflict surfaces after work has begun, we notify all affected clients immediately, complete the existing engagement, and decline the newer one. We do not resign mid-file without notice.

COMPENSATION

Two practices, two fee models.

The performance fee that defines our owner practice is prohibited on the lender side precisely because it would compromise the independence a lender is paying for. The two models are not blended and never overlap on a single file.

Affiliated entities

Haskins Capital’s principal owns Haskins Real Estate Development LLC, a real estate development company. Haskins Capital will not accept lender engagements from any institution that is a current or prospective lender to an affiliated entity, and will not review any project in which an affiliated entity holds an ownership interest.

The principal also holds a full-time executive role at Virginia Transformer Corporation. Engagements involving Virginia Transformer as owner, contractor, supplier, or borrower are not accepted.

CONFIDENTIALITY

Information does not cross the wall.

Documents, pricing, and findings from any engagement are used solely for that engagement. Information obtained on one side of the practice is never applied, referenced, or disclosed on the other. Market rate data and general professional experience are not client information and are not restricted by this paragraph.

Questions about this policy, or a request for it in signed form for a vendor onboarding file, go to slhaskins@haskinscapital.com.