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Ethical Technology · Biological capital

Welfare travels with the capital

Nineteen positions sit inside the Group Welfare Standard. Each was assessed against six criteria before commitment, each carries a welfare covenant enforceable on the same terms as the financial covenants, and each gives the group a right of inspection at the site. Welfare is a condition of the capital rather than a preference stated once the capital has gone.

Commitments

  • Every position in scope is assessed against the Group Welfare Standard before commitment.
  • Commitments above US$5 million are assessed on site rather than on paper.
  • Every investment document in scope carries a welfare covenant and a right of inspection.
  • A welfare incident reaches the group within five working days of the sponsor learning of it.
  • The excluded practices list is approved by the Board and applies wherever the capital goes.
  • A client holding a position in scope may ask for its welfare summary and receives one.

One floor for the whole group

The Group Welfare Standard is a single document applied wherever the capital lands. The Board approved it in 2023 alongside the Charter. It is reviewed every two years by the Welfare Assessment Unit with two external veterinary advisers. A local rule that is stricter displaces it. A local rule that is weaker does not.

Scope is decided by the Unit and not by the deal team. A business is in scope if it keeps, breeds, transports, treats or studies animals, if its product is made from an animal or from a cell line derived from one, or if any part of its development programme uses animals. Nineteen of the group positions met that test at 30 June 2026.

The six criteria are the same for a veterinary vaccine business in Johannesburg, a marine hatchery in Oceania and a contract laboratory serving a pharmaceutical sponsor in Mexico. Species differ and the evidence differs with them. The floor does not move with the jurisdiction, the sector or the size of the cheque.

  • Housing, stocking density and environment appropriate to the species and the stage of life.
  • Named handlers, recorded training and a documented supervision line at every site.
  • Written health plans, with treatment decisions taken by a veterinarian and recorded.
  • Humane endpoints defined for each procedure, at the earliest point that answers the question.
  • Replacement, reduction and refinement documented for each programme that uses animals.
  • Transport, handling and end of life conditions specified in writing and checked on site.

The assessment comes before the money

The Welfare Assessment Unit has four specialists, two in Brisbane and two in Johannesburg. It reports to the Head of Technology and Ethics rather than to any investment division. Its assessment is a condition of reaching the Investment Committee agenda: a position in scope that arrives without one is removed from the agenda until it has one.

An assessment reads the health plans, the training records, the veterinary agreements, the mortality and morbidity data of the previous three years and the incident history. Where the commitment exceeds US$5 million, or where the records raise a question the papers cannot answer, the Unit visits the sites. Thirty-one site visits were made in the twelve months to 30 June 2026.

Eleven welfare assessments were completed in that period: seven cleared, three cleared with conditions and one declined. The declined proposal concerned a breeding operation whose stocking arrangements could not be brought to the Standard within the investment period. The conditions imposed on the other three became covenants before signature.

Written into the term sheet

The welfare covenant sits in the same schedule as the financial covenants and carries the same remedies. It commits the sponsor to maintain the Standard for the life of the investment, to report against it within 90 days of each financial year end, and to notify the group of any welfare incident within five working days of learning of it.

The inspection right is the part that gives the covenant effect. The group may inspect any site on two business days notice, may appoint an independent veterinarian at its own cost and may attend any inspection the sponsor conducts. Two unannounced follow-up visits were made in the twelve months to 30 June 2026, each after an incident notice.

Remedies escalate. A confirmed breach requires a remediation plan within 30 days. An unremedied breach suspends further drawdown. A repeated or serious breach gives the group a right to exit at a price that does not reward the failure. Four incidents were notified in the year, three remediation plans were agreed and one drawdown was suspended for two months.

  • The sponsor maintains the Group Welfare Standard for the life of the investment.
  • The group may inspect any site on two business days notice and may bring its own veterinarian.
  • Welfare incidents are notified within five working days of the sponsor learning of them.
  • A confirmed breach requires a remediation plan within 30 days and suspends further drawdown.
  • Adopting an excluded practice after commitment is a breach with an exit remedy attached.

Practices the group will not fund

The Board keeps a list of excluded practices on the advice of the Ethics & Technology Council. Nothing on the list is funded, in any jurisdiction, at any point in a supply chain the group finances, whatever the local law permits and whatever the return on offer. The list travels with the capital in the same way the Standard does.

The list is short because every entry is absolute. Additions are made on evidence from the Unit and the external advisers rather than on sentiment. It was last extended in 2025 to cover the wild capture of broodstock where a closed-cycle alternative is available on commercial terms. A sponsor that adopts an excluded practice after commitment is in breach of its covenant.

  • Cosmetic testing on animals, at any point in a supply chain the group finances.
  • Confinement that prevents an animal turning around or extending its limbs.
  • Routine mutilation without anaesthesia or analgesia where an alternative exists.
  • Antimicrobials used prophylactically to compensate for husbandry that would otherwise fail.
  • Wild capture of broodstock where a closed-cycle alternative is available on commercial terms.

What is reported, and to whom

The Unit reports to the Ethics & Technology Council each quarter on assessments completed, conditions outstanding, incidents notified and remediation plans in progress. The Board receives the position once a year with the annual Charter report. Internal Audit tests the covenant files and the inspection records on a two-year cycle.

A client holding a position in scope may ask for its welfare summary. The summary is written in plain language and states what the business does with animals, how it was assessed, what the covenant requires and what has been notified since commitment. Nine summaries were issued in the twelve months to 30 June 2026.