PRI Due Diligence Questionnaire
Comprehensive Responsible Investment Framework
Principles for Responsible Investment Framework Response
Last Updated: July 2025
Executive Summary
Ethical Capital Investment Management is a Utah-registered investment adviser (CRD #316032) specializing in values-based equity investing. We align capital with companies that avoid preventable harm while creating positive impact through their core business operations.
Key Statistics: - 57% of S&P 500 excluded through proprietary ethical screening - Equity-focused investment approach with concentrated portfolios - Signatory to the Plant Based Treaty - Open-source screening criteria available on GitHub - Direct engagement with portfolio company management
1. Strategy & Governance
Investment Philosophy
Our investment philosophy centers on the principle that ethics and performance are synergistic, not competing objectives. We believe that companies creating positive impact through their core revenue streams represent superior long-term investments.
Governance Structure
- Chief Investment Officer: Sloane Ortel
- Investment Committee: Reviews all investment decisions and ethical assessments
- Compliance Framework: Annual third-party audits and SEC oversight
- Fiduciary Standard: Legal obligation to prioritize client interests
ESG Integration Approach
ESG integration is not a separate overlay—it is our investment process. We do not have a separate “responsible investment policy” because responsible investing defines our entire methodology.
2. ESG Integration
Screening Methodology
Exclusion Criteria: - Fossil Fuels: Oil, gas, coal extraction and infrastructure - Weapons Systems: Military contractors and weapons manufacturing - Factory Farming: Industrial animal agriculture operations - Tobacco & Gambling: Production, distribution, and related services - Poor Governance: Companies with systematic ESG failures
Research Process
- Ethical Screening: Comprehensive review of business model and practices
- Fundamental Analysis: Financial health and competitive position assessment
- Impact Evaluation: Real-world outcomes analysis beyond marketing claims
- Ongoing Monitoring: Continuous assessment of portfolio companies
Investment Universe
Our screening process reduces the investable universe by approximately 57% of the S&P 500, creating a focused opportunity set of companies aligned with our ethical standards.
3. Stewardship & Engagement
Escalation Process
When companies fail to meet our standards: 1. Direct dialogue with management and board members 2. Collaborative engagement with other shareholders 3. Public advocacy through shareholder proposals 4. Divestment when engagement fails to drive change
4. Transparency
Public Disclosure
Available Information: - Complete screening methodology published on our website - Portfolio holdings disclosed in quarterly reports - Investment rationale documented for all positions - Performance attribution analysis provided to clients
Open Source Approach: - Screening criteria available on GitHub for public review - Research methodology published and regularly updated - Educational resources freely available through our blog - Speaking engagements and industry participation
Client Communication
- Quarterly Reports: Performance, holdings, and attribution analysis
- Annual Summaries: Comprehensive review including tax documentation
- Real-time Access: Client portal for account monitoring
- Direct Communication: Personal consultation availability
5. Climate & Environment
Climate Strategy
Investment Approach: - Zero tolerance for fossil fuel investments across all strategies - Positive screening for climate solutions and renewable energy - Transition finance support for companies reducing carbon intensity - Physical risk assessment for all portfolio companies
Portfolio Climate Impact: - Systematic exclusion of high-carbon industries - Investment in companies driving decarbonization - Support for corporate climate commitments and science-based targets - Integration of climate risk into fundamental analysis
Environmental Considerations
Beyond climate, we evaluate:
- Water usage and pollution prevention
- Waste management and circular economy principles
- Biodiversity impact and ecosystem protection
- Resource efficiency and sustainable sourcing
6. Reporting and Verification
Performance Measurement
Financial Metrics: - Risk-adjusted returns (Sharpe ratio, alpha, beta) - Benchmark comparison against relevant indices - Attribution analysis identifying performance drivers - Long-term track record documentation
Impact Measurement: - ESG integration effectiveness assessment - Portfolio company impact outcomes tracking - Exclusion screening verification and validation - Stakeholder value creation measurement
Third-Party Verification
- Annual compliance audits by independent third parties
- SEC registration and regulatory oversight
- Custodial verification through Altruist (independent custodian)
- Performance verification by qualified third-party administrators
7. Additional Information
Unique Differentiators
Truth-Seeking Analysis™: Our proprietary methodology emphasizes evidence over ideology, acknowledging limitations and uncertainties while maintaining rigorous analytical standards.
Manual Screening Process: We do not rely on third-party ESG ratings but conduct comprehensive in-house analysis of every potential investment.
Concentrated Portfolios: Typically holding 15-25 positions allows for deep research and meaningful engagement with portfolio companies.
Values Integration: Our screening process aligns with social movements including BDS, climate justice, and animal rights advocacy.
Industry Involvement
- Signatory: Principles for Responsible Investment (PRI)
- Signatory: Plant Based Treaty
- Member: Sustainable Finance community organizations
- Speaker: ESG conferences and educational forums
Technology & Innovation
- Open-source screening criteria available on GitHub
- Transparent methodology published and regularly updated
- Data-driven analysis combining quantitative and qualitative factors
- Continuous improvement based on stakeholder feedback
Contact Information
For institutional inquiries: - Website: ethicic.com - Email: hello@ethicic.com - Registration: Utah CRD #316032 - Custodian: Altruist Financial
For detailed discussion of our PRI framework: - Chief Investment Officer: Sloane Ortel - Direct Email: hello@ethicic.com - Consultation: Schedule a meeting
This document represents our comprehensive response to Principles for Responsible Investment due diligence requirements. We welcome questions about any aspect of our responsible investment approach and are committed to continuous improvement based on stakeholder feedback and evolving best practices.
Document Version: July 2025
Next Review: January 2026