Important Disclosures

Effective Date: March 10, 2026 · Last Updated: March 10, 2026

Investment Adviser Registration

Ethical Capital LLC is a state-registered investment adviser in Utah. Registration does not imply a certain level of skill or training. Detailed information is available in our Form ADV Part 2.

All investments involve the risk of loss, including the permanent loss of principal. Past performance is not indicative of future results. No strategy can guarantee returns or eliminate risk in any market environment.

Strategy-Specific Risks

Concentration risk: Our flagship Growth Strategy typically holds 15–25 securities. This concentration results in higher price volatility than a diversified index fund. The performance of individual holdings has a disproportionate impact on overall results.

Ethical screening risk: Our screening framework excludes a substantial portion of the S&P 500 (current figures are updated quarterly on our homepage). This narrows the investable universe and may cause our performance to diverge significantly — favorably or unfavorably — from broad market benchmarks. Sector exposures will differ materially from unscreened indices.

Liquidity risk: Concentrated positions or specific security types may become difficult to sell at fair prices during periods of extreme market stress.

Exclusions Database

Ethical Capital publishes its exclusion list and related screening methodology for educational and transparency purposes. Companies appear on our exclusion list based on our investment judgment — not because they have done anything illegal. This is a difference of values and opinion, not an accusation of wrongdoing.

Exclusion does not constitute a recommendation against investing in any company. Absence from the exclusion list does not constitute a recommendation to invest. Data is drawn from independent watchdog organizations, non-governmental organizations, government registries, and Ethical Capital’s ongoing research. Companies may update their practices, and exclusion determinations may change as new information becomes available.

Information in the exclusions database is provided “as is” for informational purposes only and should not be relied upon as investment advice. For a complete list of research sources, see the Research Sources section of the exclusions database.

Performance Reporting

Performance figures presented on this website reflect the actual results of representative fee-paying client accounts. These results may not reflect the experience of every client due to differences in inception dates, cash flows, and individual fee schedules. For detailed information on our calculation methods, see our Performance Methodology page.

Fee Disclosures

Advisory fee: We charge a standard 1% annual advisory fee, deducted quarterly in advance.

Third-party costs: Clients incur additional costs not paid to Ethical Capital, including custodial fees (Altruist; or Schwab, for clients whose assets are custodied at Schwab through an independent adviser), transaction costs, and expense ratios for any external funds held in the Income or Diversification strategies.

Conflicts of Interest

Personal trading: Employees may own the same securities recommended to clients. We maintain personal trading policies to ensure client interests are prioritized.

No commissioned products: We do not receive commissions, “kickbacks,” or 12b-1 fees from any security or fund provider.

Custody and Assets

Client assets are held by Altruist Financial LLC and Charles Schwab & Co., Inc., both qualified custodians. Ethical Capital maintains limited power of attorney to manage investments but does not have physical custody of client funds or securities.

Use of Technology

Artificial Intelligence

Ethical Capital uses artificial intelligence and machine learning tools in certain aspects of its operations, which may include research assistance, data analysis, document drafting, content creation, and other business functions. All AI-assisted work product that materially affects client accounts, investment recommendations, or client communications is subject to human review and oversight by qualified personnel. AI tools are not used to make autonomous investment decisions.

Our use of AI tools is governed by an internal AI Use Policy and is subject to our compliance program. We evaluate AI tools for accuracy, security, and appropriateness before deployment. Where AI tools process client information, we maintain appropriate confidentiality protections and vendor agreements as described in our Privacy Policy.

We do not make claims about AI capabilities that exceed the actual role these tools play in our operations.

Client meetings may be recorded and transcribed using AI-powered tools for recordkeeping and service quality purposes. Clients are informed of recording practices prior to or at the commencement of the advisory relationship.

Client Portal

Ethical Capital offers a client portal for the convenience of advisory clients. The portal is designed to coordinate the client relationship and may link to third-party platforms, including our qualified custodian(s), for account-specific information. Portal data is not a substitute for official custodian records. The portal is subject to the terms described in our Terms of Use and Privacy Policy.

Ethical Capital and its personnel may maintain a presence on social media platforms for educational and informational purposes. Social media posts are not personalized investment advice and should not be relied upon as a basis for investment decisions. Social media content is subject to the same regulatory requirements as other communications by investment advisers and is archived in accordance with applicable recordkeeping rules.

We do not solicit, adopt, or endorse client testimonials or endorsements on social media. If you post a comment about Ethical Capital on a social media platform, we may respond to acknowledge your comment, but such a response does not constitute adoption or endorsement of your statement.

Electronic Signatures and Records

Advisory clients execute documents electronically through our electronic signature platform. Clients provide their consent to electronic signatures and electronic records delivery as part of the onboarding process, in accordance with the E-SIGN Act (15 U.S.C. §7001) and the Utah Uniform Electronic Transactions Act (Utah Code §46-4-101 et seq.). Clients may withdraw consent to electronic delivery at any time and request paper copies of any document at no charge. See our Terms of Use for additional information.

Contact Information

Ethical Capital LLC 90 N 400 E, Provo, UT 84606 Phone: +1 347 625 9000 Email: hello@ethicic.com

Ethical Capital LLC is a state-registered investment adviser registered with the Utah Division of Securities. Registration does not imply a certain level of skill or training. The information on this website is for informational purposes only and does not constitute investment advice. All investing involves risk, including the possible loss of principal. Past performance is not indicative of future results.

Last updated: March 10, 2026