The scholars were judging the action, not the actor, and there may be mitigating circumstances for the actor, i.e. he might be ignorant or compelled to do so.

CENTERFORSECURITYPOLICY: Center For Security Policy

One note: Because of the way financial and utility companies are financed (i.e. with large amounts of debt), Greenblatt excludes them from his screening process, so I do the same.

FORBES: Four Magic Formula Buys