Independence and conflicts

Independence is not a statement of intent. It is a set of things this firm is structurally unable to do. The following are commitments, and any of them may be tested against our engagement letters.

1. We hold no principal capital and take no equity in the businesses we advise.
2. We operate no lending, trading, research or investment business.
3. We do not act for a buyer on any asset we are mandated to sell, and will not do so for the duration of the mandate and for twenty-four months following its conclusion.
4. We accept no compensation, in any form, from any party other than our client. This includes buyers, lenders, brokers, and providers of professional services to the transaction.
5. We pay and receive no finder's fees, introduction fees or referral commissions.
6. Where a conflict cannot be eliminated, we decline the mandate. We do not manage conflicts that ought not to exist.

Conflicts are cleared before a mandate is accepted, not after. Every prospective engagement is checked against a standing register of current and former clients, counterparties and prohibited relationships, and no mandate may be accepted without the written clearance of the mandate acceptance committee. Where we decline on conflict grounds we say so, and we say nothing further.