Introduction

Today marks a significant milestone in the evolution of Wahed and Islamic finance. We are introducing two flagship UCITS ETFs. What’s special is that we’re now applying additional Islamic values based ethical screening that complements our standard Shariah compliance, creating a more holistic and morally aligned portfolio. Instead of only looking at what companies sell, we’re now looking at what they do on the global stage.

The Evolution of Responsibility

Historically, Islamic finance has been defined by what it is not. It is not interest-based. It does not involve gambling, alcohol, or tobacco. For many of us, this level of screening was the only option available. Now we want to bring something new to the world. Additional screening for human rights violations. We’re all more informed. We all know more about where our money is going and the injustices many companies are complicit in. Using the knowledge we have today, we can make a difference. And at Wahed, we’re doing just that. We are proud to introduce our first steps in integrating traditional Shariah compliance with a proactive, Islamic values informed human-rights review of companies our funds invest in, so we can react to humanitarian crises and do the right thing.

The Facts

Let’s talk about the funds themselves and then we’ll dive deep into what makes them special. We are launching two new flagship UCITS ETFs. One tracks the S&P 500 Shariah Index, and the other tracks the Dow Jones Islamic Market International Titans 100 Index. A UCITS fund is widely recognised as a global benchmark for fund governance. These funds are Ireland-domiciled and approved by the Central Bank of Ireland. This means they are highly regulated, and eligible for your ISA and pension. We believe that investing with Islamic values in mind shouldn’t require you to compromise on the quality of investment products available to you. 

By utilising the UCITS framework, we are providing you with access to an institutional-grade vehicle that meets the most rigorous quality standards in the world. The quality of these new funds can comfortably sit at the heart of any sophisticated portfolio - Islamic or not.

Our funds provide a competitive fee of 49 basis points (“bps”), we’ve built these to be the building blocks of a diversified global portfolio. You’re getting exposure to roughly 350 of the world’s leading companies across 15+ markets.

While these funds are categorised as actively managed, they are still index-referencing funds first. This "active" status doesn't mean we are trying to "beat the market" through trading; instead, it gives us the limited discretion needed to:

• Filter for Ethics: We manually screen out companies that are involved in Human Rights Violations.
• Access Difficult Markets: We can invest in ADRs that are tough to reach in the local markets.
• Stay Compliant: We ensure that these funds comply with the UCITS diversification rules.

In short, "active" management allows us to follow a benchmark while ensuring every investment stays true to both regulatory standards and our screens.

The Methodology

Now, what exactly is our methodology? And how do we decide which companies meet our standards and which fall short? 

At Wahed, we don't (and can’t) rely on political lists, social media trends, or regional boycotts. We rely on a structured methodology that serves as a bridge between financial decisions and Islamic values.

To do this with total integrity, we screen our investments against globally respected, independent resources:

The UN OHCHR Database. This comes from the United Nations (“UN”). It is a highly structured mandate that identifies companies involved in specific activities within the Occupied Palestinian Territory. It is impartial, authoritative, and gives companies the right to respond. It provides the legal and international legitimacy we require.

AFSC Investigate. While the UN provides the authority, AFSC provides the on-the-ground details. This independent NGO research project surfaces corporate involvement in military, security services, and settlement infrastructure. It gives us the narrative context and on-the-ground evidence that raw financial data often misses.

The UFLPA Entity List. Managed by the U.S. Department of Homeland Security, this focuses on the Uyghur Forced Labour Prevention Act. It is a legally binding, evidence-based list. If there is credible evidence that a company is participating in forced labour, they are flagged.

The KLP Council on Ethics. As Norway’s largest pension fund, KLP’s exclusion list is a benchmark for institutional best practices. By referencing their decisions, we ensure our exclusions align with the world’s most sophisticated ethical investors.

We take the flags from such credible sources and apply our own internal review based on universally recognised and Islamic-values aligned principles of Human Dignity, Justice, Accountability, and the Avoidance of Harm.

Our internal review weighs three critical dimensions:

1. Salience: What is the severity and scale of human harm?
2. Responsibility: Is the company directly enabling the harm or profiting from it?
3. Responsiveness: Is the company actively engaging, improving, or ignoring the issue?

This is all on top of our rigorous Shariah screening, where we already:

1. Exclude impermissible industries
2. Screen financial ratios
3. Set impermissible income thresholds
4. And transparently publish purification amounts per unit of ETF on our website

This layered approach reduces blind spots and ensures that your investment is grounded in objective, published evidence.

Why it Matters

Why does this matter? Because Islamic values are universal. When we talk about justice - Adl - and human dignity - Karama - we’re showing we care about all oppressed people, in all places.

Our screens address causes from around the world from forced labour camps, refugee crises, illegal occupations and systemic oppression in places you’ve heard of - and in places that don’t make it on to the news. As Muslims, we are taught that if we see an injustice, we should change it with our hands, our speech, or at the very least, feel it in our hearts. In the modern world, we can change it with our capital. By choosing to exclude companies that profit from these harms, we’re sending a message to the financial world that human dignity is non-negotiable and shouldn’t be profited from.

The Path Forward

Finally, let’s address the questions which we know are important to you.

First, why are these funds 'actively managed'? Active management allows us to follow a benchmark while ensuring every investment stays true to both regulatory standards and our screens.

Second, why don't we use political boycott lists? As responsible asset managers, we must follow a neutral, replicable methodology. We focus on evidence-based resources that maintain a global focus. We are values-aligned, not political.

Third, how do exclusions actually work? We reference trusted independent research, we evaluate it against our criteria, and we decide internally. Our process is objective and consistent.

You might ask: 'Will the fund exclude Company X?' or 'Why does it still include Company Y?' Our answer is always rooted in our principles. We make decisions based on published evidence and continuous review, not whimsical or region-specific shifts.

This is a new chapter for Wahed. It is a commitment to a globally diversified, tax-efficient, and deeply ethical way of investing. We invite you to join us in this journey.

Disclaimer: Sustainable Finance Disclosure Regulation, Article 6 disclosure