Can family office staff accept a referral reward under the office's conflict policy?

It depends on your office's conflict of interest policy, and often the office itself, not the employee, should register as the partner. Before introducing a direct-investment or portfolio company to SourceX, staff should read the code of conduct, disclose the possible reward to the principal or investment committee, and get a written decision on who is paid.

The short answer: settle it in writing before anyone is introduced

Family office staff can sometimes accept a referral reward, but only where the office's conflict of interest policy allows it, and the cleaner route is often for the office itself to register as the partner. The reason is simple: SourceX pays the reward, yet it is tied to a licensing deal by a company the family may own, fund or advise, and that is the kind of outside payment a conduct code exists to surface.

So treat it as a governance decision, not a personal one. Read the code, take the question to whoever approves exceptions, and get the answer in writing before the company's CEO hears the word SourceX.

Why the reward raises a conflict question at a family office

A single-family office serves one family's interests. When a staff member introduces a direct investment, a co-investment or a business owned by a family member to an outside platform, three interests meet: the family's as owner, the company's as the party that would sign a license, and the employee's if a reward follows. Even an honest introduction can look as if it was made for the reward.

Multi-family offices add a fourth interest: the client family that owns the business. There, the question widens to whether the client knows about, and agrees to, any payment the office or its staff could receive. The separate question of sharing a referral fee with the client who owns the business has its own page.

What is actually true about the SourceX reward

Get the facts straight before the policy discussion, because several common worries do not apply.

Concern you may hear	What is actually true
The reward comes out of the company's price	It is a share of SourceX's own fee and is never deducted from what the company receives
Staff get paid for setting up a meeting	Rewards become payable only after the buyer pays and SourceX receives its fee; a lead, meeting or signed agreement alone triggers nothing
The amount is open-ended	Partners earn 25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, capped at $100,000 per referred company
The family gives up its data	The company keeps ownership, licenses rather than sells, and nothing binds it until it agrees price and terms and signs
Whoever mentions it first gets paid	Credit goes to the first valid referrer whose introduction leads to a verified company application within the attribution window

None of this removes the conflict question, and no reward is guaranteed. It narrows the issue to one point: whether the office lets an employee receive outside money connected to a company the family is involved with.

The 3P settlement: policy, principal, payee

Work through three areas with the office's general counsel, chief operating officer or whoever administers the code. Every box should end with a written answer.

Policy

Does the code of conduct or employment agreement address outside compensation, finder's fees or payments from counterparties?
Does it treat opportunities and fees that arise from office relationships as belonging to the office?
Is pre-approval required, or only annual disclosure?

Principal

Who approves an exception: the principal, the family council, the investment committee or the chief investment officer?
Does a family member sit on the company's board, and should that person step back from the licensing decision?

Payee

Will the office, the employee or nobody register as the partner?
If the office registers, whose name is on the account and who receives the tax form?
If the employee leaves before a deal closes, who keeps the introduction?

If your code is silent on these points, the conflict of interest policy template for consultants and advisors has model wording for the disclosure and approval clauses.

Office or employee: who should be the partner?

The answer usually follows where the relationship came from.

Situation	Partner to discuss first	Reasoning
Company is a direct investment of the family	The office, or no one	The access exists because of the family's capital
A staff member is the family's designee on the company board	The office, or no one	Board duties to the company come before any outside payment
Co-investment led by a private equity sponsor	Agree with the sponsor before anyone registers	The lead sponsor's team may already be screening portfolio data; see the operating partner playbook
Company owned by a client family of a multi-family office	The office, with the client's informed consent	The client, not the office, owns the asset
Company known from the employee's earlier career, unrelated to any holding	The employee, if the code allows it after disclosure	The relationship predates the office and touches no family asset

Staff who hold the CFP certification carry their own disclosure duties on top of the office's code; the guide to CFP Board standards on conflicts and referral compensation explains them.

How to raise it with the principal

Bring the question before the introduction, with a recommendation attached.

That framing shows you read the policy, separates the company's decision from the reward and gives the principal an easy choice.

If the concern is valid

Sometimes the honest answer is that no one at the office should take the reward. The introduction can still happen: the company can apply directly at sourcex.si/apply, and its owner decides whether licensing makes sense.

Where the office or an employee does register, settle the paperwork early. A US payee is generally asked for a Form W-9 so payments can be reported, and IRS Publication 525 explains that income is taxable unless a law specifically exempts it. Staff who hold a securities registration through a broker-dealer should tell their firm's compliance team: FINRA has announced SEC approval of Rule 3290 on outside activities, replacing Rules 3270 and 3280, with the effective date still to be set. This is general information, not legal, tax or financial advice. Confirm with your own counsel, tax adviser or professional body before acting.

The program terms govern attribution and payment, so share them with whoever signs off.

Next step

Screen the company first with the company fit checker. SourceX looks for US companies that reached 50+ full-time employees at peak (contractors excluded), have run and recorded their operations for several years, hold the rights to those records and have an owner or executive ready to sponsor the decision. If the company passes and the office has decided who the partner is, register as a partner in that name.

Step 1Share your linkSend your personal link to a company you know.
Step 2Company appliesThe company applies itself at /apply.
Step 3Buyer selects and paysThe buyer selects and pays for the data and SourceX receives its fee.
Step 4You get your rewardYour share of SourceX fees becomes payable.

Common questions

Can a family office register as a SourceX partner instead of an employee?

Yes. Anyone can join the program from any supported country, and a firm can be the partner as well as an individual. When the office registers, it accepts the partner terms, receives any reward and provides the tax form. That route keeps the payment with the party whose capital created the relationship, which is often what the office's conflict policy points to anyway.

Does the company pay more because someone earned a referral reward?

No. The company receives one all-in price with SourceX's fee included and no separate charges, and the partner reward is a share of SourceX's fee. It is never deducted from what the company receives. The family should still be told about the reward, because the open question is the employee's loyalty to the office, not the company's price.

What if a family member made the introduction rather than staff?

Then the question moves to family governance. A family member who owns or directs the company is effectively introducing their own business, which raises fewer loyalty concerns but may still matter under a family constitution or shareholder agreement. Decide in advance whether the family member, the office or no one registers, since credit goes to the first valid referrer within the attribution window.

Should the portfolio company's management be told about the reward?

It is good practice. Tell the CEO or owner that the introducer may receive a share of SourceX's fee if a deal closes and the buyer pays, and that the payment does not reduce the company's proceeds. Disclosure keeps the licensing decision with management, avoids surprises if the arrangement surfaces later and puts the arrangement on the record.

Is a referral reward taxable to a family office employee?

Referral income is generally taxable to whoever receives it, and US recipients are usually asked for a Form W-9 so payments can be reported. Whether the office or the employee receives the payment changes who reports the income. Ask the office's tax adviser before registering, because the answer depends on the office's structure and the employee's arrangement with it.

Free resources

Profit margin calculator — Profit and margin across three scenarios.
Client opportunity brief generator — An editable intro email, summary and checklist.
Days sales outstanding calculator — How many days customers take to pay.
All free tools · MCP resource center

By SourceX Partnerships Team · Published 2026-10-09 · Updated 2026-10-09

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