Capricorn SIF engaged Luminis Advisors to conduct an Independent Verification of its alignment with the Operating Principles for Impact Management (“OPIM”), and to provide the accompanying Insights Table and its detailed benchmarking analysis. Together, these deliverables offer a clear view of SIF’s impact management strengths, progress since its last Independent Verification in 2023, and opportunities for targeted improvement
What’s Included in This Report
1. Independent Verification
A formal assessment of SIF’s alignment with OPIM, fulfilling Impact Principle 9. Result: Aligned, in all material respects.
2. Insights Table and Details1
A principle-by-principle benchmarking of Capricorn SIF’s impact management practices against industry norms and best practices, using OPIM Grades and Best Practice Scores.
• OPIM Grades (✓+, ✓, ✓-, X)
• Best Practice Scores (1 - 5)
What This Means for SIF
This combined finding is designed to be decision-ready, highlighting where SIF demonstrates strong, repeatable practices as well as where and how deeper formalization could unlock even greater impact management leadership opportunities.
1 See Annex IV for the full Insights Table Disclaimer, including methodology limitations and interpretation guidance.
2025 Verification & Insights Table —
IP 1. Define strategic impact objective(s), consistent with the investment strategy
IP 2. Manage strategic impact on a portfolio basis
IP 3. Establish the Manager's contribution to the achievement of impact
IP 4. Assess the expected impact of each investment, based on a systematic approach
IP 5. Assess, address, monitor, and manage potential negative impacts of each investment
IP 6. Monitor the progress of each investment in achieving impact against expectations and respond appropriately
IP 7. Conduct exits considering the effect on sustained impact
IP 8. Review, document, and improve decisions and processes based on the achievement of impact and lessons learned
IP 9. Publicly disclose alignment and have it independently verified.
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Independent Verification
Capricorn Investment Group’s Sustainable Investors Fund (“SIF”) engaged Luminis Advisors, LLC (“Verifier”) to independently verify that SIF’s impact management system (“IMS”), as described in SIF’s internal policies and procedures (collectively, the “Policies”) and summarized in its disclosure statement dated June 30, 2025 (the “Statement”), aligns with the Operating Principles for Impact Management (each, an “Impact Principle” and collectively, the “Impact Principles”) in accordance with Impact Principle 9.
SIF reports total assets under management in alignment with the Impact Principles of USD 365 million as of June 30, 2025 (the “Covered Assets”).
Methodology and Scope of Independent Verification3:
• Verify that the Policies and Covered Assets address, and are in alignment with, each of the Impact Principles.
• Assess the alignment of SIF’s IMS, as outlined in the Policies and summarized in the Statement, with the Impact Principles.
• Evaluate the effectiveness of SIF's IMS in assessing, managing, monitoring, recording, and reporting impact, considering the system's quality, completeness, reliability, neutrality, and ease of understanding.
• Interview key members of SIF’s management team responsible for the implementation of its IMS, as outlined in the Policies and summarized in the Statement.
It should be noted that Verifier’s assessment:
• does not include any appraisal of the adequacy or effectiveness of SIF’s IMS;
• does not verify actual impacts achieved;
• is based on public information as well as internal material provided by SIF;
• assumes all information provided by SIF is accurate and complete; and
• reflects Verifier’s professional judgment based on its analysis of the information provided by SIF.
Verifier Endorsement:
Based on the procedures performed and the review conducted, Verifier believes that SIF’s Statement is aligned, in all material respects, with the Impact Principles, as it pertains to the Covered Assets. Verifier is independent of the development and implementation of the Signatory’s impact strategy, management system, and investment process.
Sebastian von Stauffenberg Principal and CEO Luminis Advisors, LLC
November 20, 2025
3 Additional detail on the methodology and scope applied in this verification is provided in Annex III.
ANNEX I - Verification Scales (OPIM Grades + Best Practice Scores)
OPIM Impact Principle Grades:
Grade Label Definition
✓+ Exceeds Expectations
✓ Aligned
✓Aligned with Room for Improvement
X Not Aligned
The signatory demonstrates exceptional alignment with the Impact Principle. Practices go beyond minimum requirements, setting industry benchmarks and actively innovating in impact management.
The signatory is fully aligned with the Impact Principle. Systems, processes, and practices consistently meet expectations, with evidence of implementation and monitoring.
The signatory shows general alignment, but there are notable areas needing enhancement to strengthen consistency, depth, and/or integration of the principle into practice.
The signatory does not demonstrate meaningful alignment with the Impact Principle. Gaps in systems, processes, or evidence significantly limit credibility or implementation
OPIM Best Practice Scores:
Score Descriptor Definition
5 Excellent Exemplary performance with global best practices; fully embedded and refined processes that set a benchmark for the Impact Principle.
4 Strong Highly effective with well-documented systems and consistent execution, but some room for innovation or scale.
3 Established Solid foundations in place; processes are defined and functioning but could benefit from more consistency, depth, and/or integration.
2 Emerging Partial implementation; efforts are underway but not yet systematic or fully aligned with best practices.
1 Nascent Very early stage or minimal development; lacks structured approach or documentation.
ANNEX II - About Luminis Advisors
About Luminis Advisors, LLC
Luminis Advisors, LLC (“Luminis”) is an independent impact-investing advisory and verification firm based in the Washington, D.C. area. Founded in 2014 as a spin-off of MicroRate the first international microfinance rating agency Luminis brings more than two decades of analytical experience and a rigorous, field-tested approach to evaluating financial, social, and impact performance.
Luminis specializes in impact fund evaluations, risk analysis, impact measurement and management (“IMM”), and independent verification of alignment with the Operating Principles for Impact Management (“OPIM”). With 600+ evaluations across more than 170 impact funds collectively managing over USD 30 billion, Luminis provides objective, evidence-based insights to asset managers, Development Finance Institutions, foundations, family offices, NGOs, and institutional investors worldwide.
Using proprietary assessment frameworks such as the PRSM™ (Performance | Risk | Social | Management) Methodology, OPIM Insights Table benchmarking tools, and Analytical and Reporting Methodology, Luminis integrates rigorous financial analysis with social performance and impact diagnostics. Luminis has worked with clients and conducted assessments of impact funds across every global region, including Latin America and the Caribbean, Africa, Asia, Europe, and North America.
Guided by independence, analytical rigor, and professional integrity, Luminis helps clients strengthen their impact management systems, enhance transparency, and align with global standards such as OPIM, IRIS+, the SDGs, and IFC Performance Standards.
For more information, please visit www.luminisadvisors.com
ANNEX III - Methodology & Scope
Scope of Engagement
This engagement assesses the Signatory’s impact management system in relation to the Impact Principles and provides a complementary benchmarking analysis to support continuous improvement. The scope covers the policies, processes, governance structures, and implementation practices applied to the Covered Assets during the review period.
The assessment examines the Signatory’s approach across all nine Impact Principles, including strategic intent, portfolio-level impact management, contribution, ex-ante impact assessment, management of environmental and social risks, monitoring of impact performance, responsible exits, review and learning processes, and public disclosure and verification.
The verification evaluates the design and implementation of the Signatory’s impact management system rather than the impacts achieved. Conclusions are based on documentation, discussions with relevant staff and management, and publicly available information provided to Luminis.
Each Impact Principle is evaluated using two complementary lenses:
• OPIM Verification Impact Grade, which assesses alignment with the OPIM standards; and
• OPIM Best Practice Score, which benchmarks the Signatory’s impact management practices against peer best practices.
Together, these assessments highlight areas of strong alignment, opportunities for improvement, and any notable changes since a previous evaluation (where applicable).
Luminis Advisors applies an independent and structured assessment framework grounded in OPIM, IRIS+, SDG alignment, IFC Performance Standards, and global IMM practice. The verification process includes:
1. Document Review - Assessment of policies, templates, IC materials, due diligence documentation, monitoring tools, reporting frameworks, and governance records to evaluate clarity, consistency, and implementation.
2. Interviews - Interviews with relevant staff and management to understand how processes operate in practice and how responsibilities and decision-making are structured.
3. Sampling & Process Testing - Review of selected transactions to test the application of impact processes at key stages of the investment lifecycle.
4. OPIM Verification Impact Grades - Each Principle receives a grade that reflects the Signatory’s alignment with OPIM standards. These grades provide a clear and consistent view of the extent to which systems and practices meet the requirements of the Impact Principles.
Insights Table Methodology (Best Practice Benchmarking)
The Luminis Insights Table provides a complementary analysis focused on benchmarking and continuous improvement.
1. OPIM Best Practice Scores - Each Principle is scored using the OPIM Best Practice scale, which benchmarks the Signatory’s impact management practices against peer best practices and recognized global norms not maturity or age. These scores reflect the quality, sophistication, and consistency of implementation relative to peers.
2. Peer Benchmarking - The Insights Table positions the Signatory within the spectrum of market practice, highlighting relative strengths and areas where peers demonstrate more advanced or systematic approaches.
3. Strengths, Weaknesses & Opportunities for Improvement - The benchmarking analysis identifies areas where the Signatory demonstrates strong practice, areas with potential for enhanced alignment, and actionable opportunities for improvement.
4. Comparison to Previous Assessments (where applicable) - The Insights Table documents any material changes, progress, or regressions since the prior assessment, supporting accountability and informed planning for continuous improvement.
ANNEX IV - Disclaimer
Disclosure
This Insights Table reflects Luminis’ independent benchmarking of the Signatory’s impact management practices against peer best practices and industry standards. The analysis is based on documentation and information provided by the Signatory’s, together with publicly available materials. The benchmarking assesses systems and processes and does not verify impact results. Findings represent Luminis’ professional judgment and are intended solely to support the Signatory’s continuous improvement efforts.
