Advisers are not yet required to have policies for considering environmental, social and governance (ESG) criteria in their investment processes, but if they do, they must adhere to those policies – and be able to substantiate it. The SEC recently penalized DWS Investment Management Americas, Inc. (DIMA), an indirect subsidiary of Deutsche Bank, for failing to implement its disclosed ESG integration policy, related material misrepresentations and compliance policy deficiencies. The proceeding is another potent reminder that advisers must “say what they do and do what they say.” This article discusses the alleged deficiencies in DIMA’s ESG implementation, disclosures, policies and procedures, as well as the terms of the resolution. See “SEC 2023 Exam Priorities: Key Takeaways for Private Fund Managers (Part Two of Two)” (Apr. 27, 2023); and “SEC Sanctions Goldman Sachs for Failing to Follow ESG Policies and Procedures” (Feb. 16, 2023).