Cohen & Steers Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Cohen & Steers Inc. discloses robust processes for proxy voting and stewardship engagement but does not provide any indication of governance over lobbying activities. The evidence shows that “The Proxy Committee is responsible for overseeing the proxy voting process and for establishing and maintaining the Proxy Voting Policy, which is reviewed and updated annually,” and that “Engagements are tracked by our portfolio managers and research analysts using an internal tracking engagement platform” to document objectives and outcomes. The firm further explains that “When an issuer is not addressing its most financially material ESG concerns ... we will take various forms of action to escalate the matter,” including “public disclosure of our concern” and “legal action.” However, we found no evidence of any internal mechanisms, oversight structures, or accountability measures for governing direct or indirect lobbying; the company does not disclose a policy for lobbying alignment, any review or monitoring process for lobbying activities, or a designated individual or committee responsible for overseeing lobbying governance. View Sources	E

Overall Assessment

Analysis

Score

None

Cohen & Steers Inc. discloses robust processes for proxy voting and stewardship engagement but does not provide any indication of governance over lobbying activities. The evidence shows that “The Proxy Committee is responsible for overseeing the proxy voting process and for establishing and maintaining the Proxy Voting Policy, which is reviewed and updated annually,” and that “Engagements are tracked by our portfolio managers and research analysts using an internal tracking engagement platform” to document objectives and outcomes. The firm further explains that “When an issuer is not addressing its most financially material ESG concerns ... we will take various forms of action to escalate the matter,” including “public disclosure of our concern” and “legal action.” However, we found no evidence of any internal mechanisms, oversight structures, or accountability measures for governing direct or indirect lobbying; the company does not disclose a policy for lobbying alignment, any review or monitoring process for lobbying activities, or a designated individual or committee responsible for overseeing lobbying governance.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Cohen & Steers offers only limited insight into its climate-related lobbying. It outlines generic methods, noting that it engages in “direct dialogues with key figures such as C-Suite members, investor relations, or boards of directors” and that it “reach[es] out to regulators, public policymakers, and underwriters,” but it does not identify which government bodies or individual officials it targets. The firm also fails to name any specific climate policies, laws, or regulatory proposals it has tried to influence, referring only to broad themes such as “environmental and social practices” and “governance issues.” Likewise, its stated objectives remain aspirational—such as a desire to “encourage companies to adopt ESG best practices” and to “advocate for industry-standard ESG disclosures”—without detailing the concrete legislative or regulatory outcomes it seeks. Collectively, these omissions mean the company discloses only a basic acknowledgement of engagement, providing little transparency on the substance, targets, or intended results of its climate-policy lobbying.	D