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 18 September 2026 · Applies to all engagements of Haskins Capital LLC
The two rules
Project-level and client-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.
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.
- 01Conflicts registerEvery 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.
- 02Screen at intakeEvery prospective engagement is screened against the register before a proposal is issued — not after a contract is signed.
- 03Disclose counterparty overlapWhere 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.
- 04Mid-engagement discoveryIf 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.
| Owner engagements | Lender engagements | |
|---|---|---|
| Fixed engagement fee | Yes | Yes |
| Performance fee on documented savings | Yes | Never |
| Advocacy for the client's position | Yes | No — findings only |
| Compensation contingent on outcome | Partially | Never |
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.
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.