CNS-Responsible-Investing 2024 - Flipbook - Page 53
Responsible Product Governance
and Marketing
responsible for data accuracy and substantiation of
statements prior to dissemination.
Cohen & Steers is committed to maintaining high
standards of integrity, transparency, and compliance
in how we communicate with current and prospective
investors. Our global advertising and marketing
practices are governed by a robust policy framework
that ensures all advertisements are accurate, fair, and
not misleading. This applies across formats, including
presentations, emails, websites, videos, and social
media, and is informed by both U.S. and non-U.S.
regulatory requirements, such as the SEC’s
Advertising Rule.
Our advertising policy outlines what quali昀椀es as an
advertisement and establishes clear criteria for what
is not, such as one-on-one oral communications and
regulatory disclosures that meet speci昀椀c conditions.
Advertisements that include hypothetical performance
or endorsements are subject to speci昀椀c requirements.
Content is prohibited from containing misleading
implications, unsubstantiated claims, or cherry-picked
performance.
To support these standards, we have implemented a
formal review and approval process overseen by our
Legal & Compliance team. All advertisements must be
submitted through a centralized platform, AdMaster,
which helps ensure appropriate documentation,
approval and compliance with internal policies
and applicable regulations. Content creators are
Through this structured framework, Cohen & Steers
ensures that communications used to inform
investors about our products and services uphold
our 昀椀duciary responsibilities. This includes creating
marketing materials that re昀氀ect a clear, balanced
view of investment o昀昀erings, providing meaningful
disclosures, and using advertising to engage
responsibly with the market.
COHEN & STEERS | RESPONSIBLE INVESTING 53
