Cromwell Funds - 1792 Exchange

Rating Overview

Cromwell Funds is Lower Risk.

Cromwell Funds does not yield to political activism in shaping corporate governance, preventing initiatives that potentially alienate consumers, divide employees, and harm shareholders. The company elevates merit, excellence, and integrity ahead of race and identity-based policies. Cromwell Funds does not embrace corporate initiatives that redirect its central focus from business goals to partisan policies and divisive issues. This approach protects free exercise, free speech, and free enterprise.

Rating Criteria

Corporate Weaponization Risk Levels
Criteria	Risk Level
Cancellations	Medium Risk
Discriminatory Philanthropy	Lower Risk
Employment Protection	Medium Risk

Corporate Weaponization ⓘ

Corporate Governance and Public Policy Risk Levels
Criteria	Risk Level
Advocacy Bias	Lower Risk
Funding	Lower Risk
Political Actions	No Data

Corporate Governance and Public Policy ⓘ

Rating Criteria Detail

Criteria Risk Level Rationale

Corporate Weaponization

Criteria:

Has canceled customers, suppliers, or vendors due to their political views or religious beliefs OR corporately boycotts, divests, or sanctions regions, people groups, or industries.

Risk Level:

Medium

Rationale:

Cromwell Funds promotes divisive sex and gender policies. Its Supplier Code of Conduct require[s] international vendors to include sexual orientation and gender identity in their nondiscrimination policy (1). However, the company has not canceled customers, suppliers, or vendors based on political views or religious beliefs (2).

Criteria:

Charitable giving (including employee matching programs) policies or practices discriminate against charitable organizations based on views or religious beliefs.

Risk Level:

Lower

Rationale:

Cromwell Funds does not publish charitable giving guidelines (1).

Criteria:

Employment policies fail to protect against viewpoint or other discrimination and/or are ideological in nature.

Risk Level:

Medium

Rationale:

Cromwell Funds does not publish a nondiscrimination policy (1).

Corporate Governance and Public Policy

Criteria:

Uses corporate reputation to support causes, organizations, or policies hostile to freedom of expression.

Risk Level:

Lower

Rationale:

Cromwell Funds states that there “is no assurance that employing ESG and Sustainable strategies will result in more favorable investment performance” (1)(2).

Criteria:

Uses corporate funds to advance ideological causes, organizations, or policies hostile to freedom of expression.

Risk Level:

Lower

Rationale:

Cromwell Funds has not used corporate funds to advance ideological causes, organizations, or policies (1).

Criteria:

Uses corporate political actions and/or financial contributions for ideological, non-business purposes.

Risk Level:

N/A

Rationale:

Cromwell does not operate a PAC or engage in lobbying at this time (1)(2)(3).