A fund must not include misleading statements in its sales communications about the ESG performance or ESG-related outcomes of the fund.51
Examples of such sales communications may include those that do any of the following:
- make inaccurate claims about the fund’s ESG performance or results
- make inaccurate claims about the existence of a direct causal link between the fund’s investment strategies and ESG performance or results
- manipulate elements of disclosure to present the fund’s ESG performance or results in a positive light, such as cherry-picking data.
51 See Footnote 43.