Form ADV Part 2A — Firm Brochure

Ethical Capital LLC CRD #316032 · 90 N 400 E, Provo, UT 84606 · 347-625-9000 · ethicic.com

Annual amendment: January 1, 2026 · Off-cycle amendment: February 26, 2026

This brochure provides information about the qualifications and business practices of Ethical Capital LLC. Please contact Sloane Ortel at 347-625-9000 if you have any questions about the content of this brochure.

The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or any state securities administrator. Additional information about Ethical Capital LLC is available on the SEC’s website at www.adviserinfo.sec.gov — search for “Investment Adviser Firm” using CRD #316032.

While the firm may be registered and/or licensed within a particular jurisdiction, that registration and/or licensing in itself does not imply an endorsement by any regulatory authority, nor does it imply a certain level of skill or training on the part of the firm or its associated personnel.

Item 2 — Material Changes

This item describes material changes to our Form ADV, Part 2A since our previous annual amendment filed on November 21, 2025.

Annual Update — January 1, 2026:

Updated assets under management to $3,837,843.12 (Item 4.E)
Updated client count to 56 households (Item 4.A)

Off-Cycle Amendment — February 26, 2026:

Added Rebalancing Methodology disclosure (Item 8): clarified that client portfolios are rebalanced periodically, generally monthly, and that rebalancing may be deferred when the CIO determines no material portfolio drift exists or market conditions warrant deferral.
Updated minimum account language (Item 7): changed from no strict minimum to a suggested minimum of $100,000, with CIO discretion to accept accounts below that threshold.
Added Analytical Tools and Technology disclosure (Item 8): disclosed the firm’s use of AI-assisted tools in screening, research compilation, and portfolio monitoring, and described the proprietary codebase supporting these functions.

Item 4 — Advisory Business

4.A. Description of Firm

Ethical Capital LLC is a New York-domiciled limited liability company formed in July of 2021. We operate under the business name Ethical Capital. Sloane Ortel is the firm’s Founder, serves as Chief Compliance Officer, and is the firm’s sole member.

Our firm is not a subsidiary of, nor do we control, another financial services industry entity.

As of January 1, 2026, our firm managed $3,837,843.12 on a discretionary basis for 56 client households. As of the same date, we did not manage any non-discretionary accounts.

4.B. Description of Services

An initial interview is conducted with you to discuss your current situation and goals, as well as the scope of our firm’s services that may be provided. Prior to or during this first meeting, we will provide our Form ADV Part 2 firm brochure that includes a statement involving our privacy policy (see Item 11), as well as a brochure supplement about Sloane Ortel’s personal history.

Portfolio Management

Our proprietary investment process involves the exclusion of many securities on moral grounds. You have the right to request additional exclusions in order to ensure that your assets are fully aligned with your personal ethics. However, we prefer to be notified of such exclusions at the outset of our engagement.

Our portfolio strategies and recommended investments are discussed in Item 8, and we manage portfolios on a discretionary basis (see Item 16). Portfolios we manage are rebalanced periodically — generally on a monthly basis — to ensure that the weightings of each security reflect the output of the analytical processes described in Item 8. In any period where the CIO determines that no material drift exists between target and current portfolio weightings, or where market conditions make rebalancing inadvisable, rebalancing may be deferred.

Periodic and/or Ad-Hoc Reviews

We prefer that clients schedule portfolio reviews on an annual basis, but clients set the cadence of meetings. Some clients prefer more frequent check-ins; others prefer to meet only when their circumstances change. Reviews are conducted by Sloane Ortel, and are typically aimed at ensuring that the client’s asset allocation aligns with their willingness and ability to bear risk.

Educational Workshops

From time-to-time we present in-person educational workshops involving personal finance and investing. Topics include issues related to retirement strategies, general investing, and various current economic or investment topics.

Outsourced Industry Service Provider

Ethical Capital develops investment strategies and model portfolios for institutional clients (i.e., other registered investment advisers), as well as media content creation services and strategic financial guidance to various investment advisers, exchanges, industry associations, and start-ups.

Sub-Advisory Services

Upon engagement by another registered investment adviser (“Primary Adviser”), Ethical Capital provides sub-advisory services to all or a portion of the Primary Adviser’s customers’ assets through various model portfolio marketplaces.

Research & Thought Leadership

The firm publishes original research and educational content on ethical investing topics, available at ethicic.com/content/research/. This content includes investment performance analysis, ethical screening methodologies, divestment strategies, ESG critiques, and portfolio construction insights. Published research serves both educational and marketing purposes, demonstrating our investment approach and contributing to broader discussions about values-aligned investing. This content is available to the general public and does not constitute personalized investment advice.

4.C. Customization

Ethical Capital typically customizes its portfolios to suit client risk tolerances by combining our strategies to add diversification or generate additional income. We are also generally able to honor reasonable restrictions on the types of securities that are included in the account to suit our clients’ inclinations.

Item 5.A — Fees and Compensation

Portfolio Management

At the beginning of each calendar quarter, our portfolio management clients pay our firm an asset-based fee based on an annualized rate as indicated in the following fee table (quarterly, in advance).

The fee is determined by the market value of account assets calculated on the last market day of each prior quarter-end, then multiplying that quotient by the applicable number of basis points set forth in the fee table (one basis point equals 1/100 of one percent). The result is then divided by four to determine the quarterly fee.

Formula: ((quarter-end market value) × (applicable number of basis points)) ÷ 4

Assets Under Management	Annualized Asset-Based Fee	Quarterly Asset-Based Fee
$0 – $∞	1.00% (100 basis points)	0.25%

Example: A portfolio under our firm’s management at our custodian maintaining $1,000,000 as of the last market day of the prior quarter’s end will be assessed $2,500 that is due at the beginning of the quarter (quarterly, in advance). Formula: ($1,000,000 × 100 bps) = $10,000 ÷ 4 = $2,500.

Educational Workshops

While some of our educational workshops may be complimentary, other events are paid for by a sponsor (e.g., employer, association, non-profit, etc.). Our workshop fee ranges from $100 to $3,000.

Sub-Advisory Services

If Ethical Capital has been engaged as a sub-advisor, an annual fee will be assessed based on a percentage of the value of the assets that are sub-advised. Fees are payable quarterly in advance:

Assets Under Management	Annualized Asset-Based Fee	Quarterly Asset-Based Fee
$0 – $∞	0.50% (50 basis points)	0.125%

Termination of Services

Either party may terminate the agreement at any time by communicating the intent to terminate in writing.

If a client of our firm does not receive our Form ADV Part 2 firm brochure at least 48 hours prior to entering into our firm’s agreement, then that client will have the right to terminate the engagement without penalty within five business days after entering into the contract.

Additional Client Fees

Fees paid by our clients to our firm for our advisory services are separate from any internal fees or charges an investor pays for mutual funds, American depositary receipts (ADRs), exchange-traded funds (ETFs), exchange-traded notes (ETNs), or other similar investments.

Any transactional (brokerage fees) or similar service fees, individual retirement account fees, qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the client per the custodian of record’s separate fee schedule.

Item 7 — Types of Clients

Ethical Capital provides its services to individuals and high net worth individuals, small business, other registered investment advisers, and other ancillary organizations supporting the securities industry.

We do not impose a strict minimum account size. However, we suggest a minimum investable account of $100,000 to allow effective implementation of our concentrated portfolio strategies. We retain full discretion to accept accounts below this threshold on a case-by-case basis.

Item 8 — Methods of Analysis, Investment Strategies, and Risk of Loss

Methods of Analysis

Ethical Screening Process

Our proprietary screening process begins with the universe of U.S. public companies with market capitalizations above $250 million (approximately 6,716 companies as of Q1 2026). Through systematic exclusion, we remove approximately 39% (2,598 companies), resulting in an eligible universe of 3,655 companies. This represents a 63% exclusion rate among S&P 500 components by count.

Exclusion Categories:

Product-Based Exclusions:

Animal-derived products (meat, dairy, eggs, leather, fur, animal testing)
Weapons and military equipment manufacturing
Addictive products (alcohol, tobacco, gambling)
Fossil fuel extraction and production
Surveillance and privacy-invasive technologies

Conduct-Based Exclusions:

Human rights violations and systematic oppression
Environmental damage and emissions failures
Corporate governance deficiencies
Financial harm to consumers or communities

Formal Commitments:

The firm maintains public commitments to:

Apartheid-Free Pledge (excluding companies complicit in systematic oppression)
Plant-Based Treaty (supporting transition to plant-based society)
PetChem Investor Declaration (addressing petrochemical risks and plastic pollution)

Our complete screening policy is published under Creative Commons license and available at /process/screening/.

Fundamental Analysis

From our eligible universe of 2,679 companies (as of Q1 2026), we conduct rigorous analysis across six dimensions to select holdings for our strategies (typically 25–55 total positions across all client portfolios):

People & Leadership — Management quality, culture, stakeholder treatment
Product & Innovation — Competitive positioning, innovation capacity
Operations — Operational efficiency, supply chain integrity
Financial Strength — Balance sheet, cash flow, profitability
Competitive Moat — Sustainable competitive advantages
Risk Assessment — Company-specific and systemic risks

This three-stage process (Avoid Preventable Harm, Seek Available Goodness, Know the Difference) reflects our belief that ethical screening and financial analysis are complementary approaches to portfolio construction.

Additional Analytical Techniques:

We employ situation-specific techniques including asset allocation, carbon footprint analysis, credit analysis, community impact analysis, momentum capture, news analysis, scenario planning, sector analysis, sum-of-the-parts valuation, and technical analysis as appropriate for each investment decision.

Investment Strategies

We manage three distinct investment strategies:

Growth — Our flagship strategy, managed for long-term capital appreciation by selecting the most compelling securities in our research universe regardless of expected statistical volatility. Overall exposures are managed to ensure that the weighting of each individual security will not exceed 25%.
Income — Our income strategy is designed to generate current income and preserve the value of capital invested. It consists exclusively of preferred stocks, bonds, closed-end funds, and other income-producing fixed-income or hybrid securities.
Diversification — Our diversification strategy complements the Growth strategy. It is composed of mutual funds, ETFs, and other externally managed investment vehicles that provide added diversification.

Portfolios that we design and manage may contain holdings that include mutual funds, closed-end funds (CEFs), ETFs, ETNs, equities, warrants, preferred stocks, Level 1 options, American Depository Receipts (ADRs), and real estate investment trusts (REITs).

Rebalancing Methodology

We rebalance client portfolios periodically, generally on a monthly basis, when the CIO determines that material drift exists between target and current portfolio weightings. In any period where no material drift exists, or where market conditions make rebalancing inadvisable, rebalancing may be deferred. Our rebalancing schedule is not a rigid obligation executed without regard to portfolio circumstances.

Analytical Tools and Technology

The firm maintains approximately 33,000 lines of proprietary Python code supporting its investment process, comprising two primary systems:

Research and screening pipeline (~18,000 lines): Automates initial exclusion screening against our product-based and conduct-based criteria; ingests and indexes company disclosures from SEC EDGAR, earnings call transcripts, and news feeds; and generates preliminary research drafts for CIO review. Large language models (LLMs) serve as the analytical engine for screening and research compilation within this pipeline.
Portfolio management tooling (~15,000 lines): Computes target security weightings from CIO-assigned scores, tracks drift between target and current allocations, manages the firm’s exclusion database and audit trail, and provides the CIO with an interactive terminal interface for research review, exclusion decisions, and rebalancing workflow.

AI assistance within these systems is used for:

Screening assistance: LLMs review company filings, news, and other disclosures to identify potential exclusion triggers across our criteria.
Research assistance: AI tools compile and summarize company information as preliminary research drafts, which are reviewed and further developed by the CIO.
Ongoing monitoring: Automated review of news and regulatory filings surfaces material events affecting current or prospective holdings.

All AI-assisted analysis serves as a preliminary input only. All final investment decisions — including exclusion determinations, security selection, and portfolio construction — are made exclusively by the Chief Investment Officer through professional judgment. AI tools do not have discretion over client assets and do not make investment decisions. The specific models and tools used may change as technology evolves; descriptions reflect practice as of the date of this brochure.

Risk of Loss

Our firm believes its strategies and investment recommendations are designed to produce the appropriate potential return for the given level of risk; however, there is no guarantee that a planning goal or investment objective will be achieved. Past performance is not necessarily indicative of future results. Investing in securities involves risk of loss that clients should be prepared to bear.

Risk factors include but are not limited to: active management risk, catastrophic risk, company risk, currency risk, equity risk, values-based screening risk, ETF/ETN risk, financial risk, financial sector risk, foreign securities risk, inflation risk, interest rate risk, issuer risk, liquidity risk, management risk, market risk, portfolio concentration risk, regulatory and legal risk, short-term trading risk, small- and mid-cap risk, and volatility risk. A full description of each risk factor is available upon request.

Item 10 — Other Financial Industry Activities and Affiliations

Ethical Capital offers investment advisory services through the custodial platforms offered by Altruist Financial LLC (“Altruist”), a self-clearing broker-dealer, and Charles Schwab & Co., Inc. (“Schwab”), a registered broker/dealer and qualified custodian. Ethical Capital’s clients establish brokerage accounts through Altruist or Schwab.

We do not receive client referrals from Altruist, Schwab, or any other source in exchange for compensation. We do not participate in any referral fee arrangement with any custodian.

Our firm maintains an institutional relationship with Altruist whereby Altruist provides certain benefits to the firm (“Support Services”). Altruist pays for or reimburses our firm for the costs of certain technology solutions to help facilitate our practices and to streamline the firm’s operations. The payments may be substantial and are based on our clients adding and/or transferring to and maintaining a certain amount (currently five million dollars ($5,000,000)) in assets on Altruist’s platform.

Item 11 — Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Ethical Capital is a fiduciary; we will act in the utmost good faith, performing in a manner believed to be in the best interest of our clients.

Code of Ethics

We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. At a high level, firm policies require that all staff:

Act in a professional and ethical manner at all times
Act for the benefit of clients
Act with independence and objectivity
Act with skill, competence, and diligence
Communicate with clients in a timely and accurate manner
Uphold the applicable rules governing capital markets

Privacy Policy Statement

We respect the privacy of all clients and prospective clients (collectively termed “customers” per federal guidelines), both past and present.

The firm collects personal information about customers from the following sources:

Information provided to us to complete their plan or investment recommendation
Information provided via engagement agreements and other documents
Information customers provide verbally
Information received from service providers, such as custodians, about client transactions

The firm does not disclose nonpublic personal information about our customers to anyone, except in the following circumstances:

When required to provide services our customers have requested
When our customers have specifically authorized us to do so
When required during the course of a firm assessment (i.e., independent audit), or
When permitted or required by law (i.e., periodic regulatory examination)

Item 12 — Brokerage Practices

As noted in Item 10, our firm recommends Altruist Financial LLC (“Altruist”) as our primary custodian for most client accounts. Altruist is a registered broker/dealer and FINRA/SIPC member that self-clears client transactions.

Certain client accounts are maintained at Charles Schwab & Co., Inc. (“Schwab”), a registered broker/dealer, FINRA/SIPC member, and qualified custodian.

Research and Other Soft Dollar Benefits

Altruist LLC has arranged to make certain communications software available to our firm at no cost once our clients custody $5 million in assets on their platform. We currently pay for these services directly, and we may have an incentive to recommend Altruist LLC based on our interest in reaching the $5 million threshold.

Best Execution

“Best execution” means the most favorable terms for a transaction based on all relevant factors. We recognize our obligation in seeking best execution for our clients; however, it is our belief that the determinative factor is not always the lowest possible cost but whether the selected custodian’s transactions represent the best “qualitative execution” while taking into consideration the full range of services provided.

Aggregating Securities Transactions

Trade aggregation involves the purchase or sale of the same security for several clients/accounts at approximately the same time. Aggregated orders are attempted to obtain better execution, negotiate favorable transaction rates, or to allocate equitably among multiple client accounts.

Item 13 — Review of Accounts

Scheduled Reviews

We prefer that client-level portfolio reviews occur on an annual basis, but clients set the cadence. Some prefer more frequent meetings; others prefer to connect only when their circumstances change. Reviews are conducted by Ms. Ortel, our founder and Chief Compliance Officer.

Whether or not a direct conversation is scheduled between you and Ms. Ortel, Ethical Capital will review your account at least quarterly to ensure that no material divergence in performance is emerging between your account and other accounts we manage with similar mandates.

Client Reports

Whether you have opened and maintained an investment account on your own or with our assistance, you will receive account statements sent directly from your custodian (Altruist or Schwab) on at least a monthly basis.

Altruist clients have access to a client portal and mobile application that displays account performance updated daily, including time-weighted returns over customizable time periods. Schwab clients receive similar account information through their relationship manager or primary adviser.

Upon request, we can generate supplemental performance reports. We do not systematically deliver periodic performance reports from the firm; clients who wish to receive them should contact us.

Item 15 — Custody

Our clients’ accounts must be maintained by an unaffiliated, qualified custodian. Accounts are not to be maintained by our firm or any associate of our firm.

Although we may be deemed to have limited custody of an account since we may request the withdrawal of advisory fees from an account, we will do so only under specific terms described in Item 5.

Item 16 — Investment Discretion

We typically serve accounts on a discretionary basis. Via limited power of attorney, clients grant our firm the authority to implement investment decisions without requiring the client’s prior authorization for each transaction.

Item 17 — Voting Client Securities

Our firm does not vote proxies on your behalf, including accounts served on a discretionary basis. We do not offer guidance on how to vote proxies, nor will we offer guidance involving any claim or potential claim in any bankruptcy proceeding, class action securities litigation, or other litigation.

Bachelor of Arts (English Literature), Fordham University; New York, NY (2013)
Uniform Investment Adviser Law Examination / NASAA Series 65 (2020)

Business Experience

Ethical Capital LLC (07/2021–Present) — Founder/Managing Member, Chief Compliance Officer/Investment Adviser Representative
CityWire LLC (01/2020–12/2021) — Columnist
River Orion LLC (10/2018–08/2021) — Principal/Content Creator (Inactive as of 08/2021)
CFA Institute (05/2010–05/2018) — Content Manager

Other Business Activities

Co-Host, Free Money Podcast (currently inactive; less than 10% of time when active)
Co-founder, Woodcache Public Benefit Corporation (currently inactive; no active involvement)

Disciplinary Information

Sloane Ortel has not been the subject of any disciplinary events.

Annual amendment: January 1, 2026. Off-cycle amendment: February 26, 2026.

Available on IAPD: adviserinfo.sec.gov/firm/summary/316032