CNS-Responsible-Investing 2024 - Flipbook - Page 52
Ethical Conduct and Integrity
Managing Con昀氀icts of Interest
We believe that acting with integrity is essential to
protecting client trust and long-term value. Our ethical
framework is supported by 昀椀rmwide governance
processes designed to ensure fairness in investment
management, administration, and client service.
Employees are expected to uphold our 昀椀duciary
standards in every aspect of their work, and our Code
of Ethics serves as the foundation for this commitment.
Managing actual and potential con昀氀icts of interest
is a critical element of our business ethics program.
We recognize that con昀氀icts can arise in a number of
circumstances, including between clients, investment
portfolios, or between employees and clients. Our
approach is to identify, manage, and manage these
con昀氀icts proactively and transparently.
Our Code of Ethics which all employees must
acknowledge upon joining and rea昀케rm annually,
outlines key 昀椀duciary principles, including:
• Acting solely in the best interests of clients
• Ensuring personal securities transactions do not
con昀氀ict with client investments
• Avoiding the use of one’s role for personal gain at
the expense of clients
• Complying fully with applicable securities laws and
regulations
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COHEN & STEERS | RESPONSIBLE INVESTING
Our con昀氀ict of interest policies are reviewed and
enhanced regularly to ensure they remain e昀昀ective
and re昀氀ect evolving regulatory standards. These
policies are outlined in our Code of Business Conduct
and Ethics, and additional transparency is provided
through our SEC Form ADV, which discloses potential
and actual con昀氀icts and the controls we implement to
mitigate them.
Through these practices, we rea昀케rm our commitment
to ethical decision-making and our responsibility to act
in the best interests of our clients, at all times.
