This doesn't surprise me as I've followed HWC. I don't think he's necessarily intentionally biased, but the possibility for subconscious bias is there. Also, HWC fails my quick and dirty check of a site's integrity--which is to see if the site included Far Cry 2 when benching GTS 450. (The test is not an absolute test and returns many false positives, as I'll explain below.)
If no, that site is *definitely* legit. (The short list includes AT, HardOCP, and Bit-Tech. Tech Report too but I despise their inconsistent and sometimes amateurish reviews where they do some pretty weird stuff like only benching at one setting at one resolution, etc.) AT and HardOCP in particular have demonstrated repeatedly that they can't be bought.
If yes, the site could still be legit (e.g., they just happen to test a ton of games, including FC2; or maybe the site is just plain old, like TPU benching some downright ancient games in its suite).
However, FC2 is THE most NV-skewed game and isn't even played much (it didn't rank high in AT and HardOCP reader polls of games that readers wanted tested), and there are so many newer and better games to bench than that, it makes me wonder. FC2 seems to ever get benched when NV releases cards, apparently because it's recommended in the reviewer guide. If a site is so out of touch or plain biased as to include FC2, especially in a small group of games where even one outlier can really skew the average, then there is at least the possibility of bias.
This is especially true if the review site is smaller, which means it has less clout and relies more on the vendor supplying equipment to review in the future. Someone on here talked about this effect in the bike industry, where smaller publications soft-pedal negatives more, whereas the larger publications could afford to be more blunt in their reviews. (Back in the IT realm, HardOCP has popularity in part because can be downright antagonistic in reviews, giving them more street cred and readers.)
It appears however that NV has given up pushing FC2 because I don't see it benched in the GTX580 reviews as much. I think this is because NV knows that Metro 2033 is also skewed but a MUCH better and defensible choice as it is a new game using DX11, and the skew is much more legitimate (highlighting their tessellation strengths). Thus I have no problem with Metro 2033 used as a bench despite the skew.
So I will need to find another quick and dirty test now. Unfortunately there hasn't been a game out yet with the same combination of skew + outdatedness that FC2 had. If there were an outdated game that skewed heavily towards AMD hardware, for instance, that'd be a great test, in my eyes.