Effective Date: 2026-05-29 · Version 1.0
1. Definition
A conflict of interest exists when our professional judgment, objectivity, or independence on behalf of one client may be improperly influenced by an interest in another client, a personal interest of a staff member, a financial relationship, or a vendor relationship.
2. Identification
We perform a conflicts check at the start of each engagement and re-check when a new related party emerges. Staff members are required to disclose personal investments, family employment, board service, and other relationships that could create real or perceived conflicts.
3. Disclosure
When a potential conflict is identified, we disclose it in writing to all affected clients with sufficient detail for them to understand the nature of the conflict and any mitigation we propose.
4. Resolution
Resolution may include: (a) declining or withdrawing from an engagement; (b) erecting an information barrier with appropriate access controls; (c) obtaining informed written consent from all affected clients; (d) referral to another firm.
5. Independence
For audit-readiness, attest-coordination, and similar work, we apply AICPA independence standards as a baseline regardless of whether the engagement legally requires a CPA license. We refuse engagements where independence cannot be maintained.
6. Staff Restrictions
Staff and immediate family members may not hold material financial interests in client businesses (other than passive investments through index funds), may not accept gifts above nominal value from clients, and may not perform paid work for clients outside the firm without written approval.