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Procedure
CIS has adopted procedures to implement the firm’s policy and reviews to monitor and ensure the firm’s policy is
observed, implemented properly and amended or updated, as appropriate, which include the following:
• All advertisements and promotional materials must be reviewed and approved prior to use by a
designated officer, President, the Compliance Officer, or another officer of the firm. All advertisements
and promotional materials must also be reviewed by CIS outside independent compliance company.
• The initialing and dating of the advertising and marketing materials will document approval.
• Each employee is responsible for ensuring that only approved materials are used and that approved
materials are not modified without the express written approval of the designated officer.
• The designated officer must also review other written communications prepared for existing clients or
prospective clients including any quarterly letters.
• The designated officer, or a designee, is responsible for maintaining copies of any advertising and
marketing materials, including any reviews and approvals, for a total period of five years following the last
time any material is disseminated.
• All advertising and the approvals are stored on the CIS Dropbox website.

Awards, Nominations and Honors
CIS and/or it employees may be nominated and win awards in the course of doing business as a Registered
Investment Adviser. In recognition of its responsibility in providing truthful and accurate advertising CIS has
adopted the following procedures for advertising any awards that may be given;
● CIS will not participate in an award process that is predicated upon the idea that payment must be made
to the award sponsor in order to qualify for nomination.
● The award process must be fair and not deemed to be so narrowly focused as to exclude other
investment advisers from the competition who would otherwise be qualified participants based on the
terms of the nomination process
● CIS will not be involved in the structuring of the award process or deliberations that determine the winner
● CIS will disclose in any advertisement of an award obtained by Corner-stone Investment Services, LLC that
it did not make any solicitation payments to the award sponsor in order to be nominated or to qualify for
nomination of the award.
● The criteria for the award and the award determination process will be provided by CIS either by listing
the information in the advertisement, stating where the award criteria can be obtained or if the
advertisement is Internet based by providing a “hyperlink” attached to the advertisement pointing to the
award sponsor’s criteria and award process either on CIS’s website or the award sponsor’s website

Soft Dollar Arrangements Statement
Policy
CIS, as a matter of policy and practice, does not have any formal or informal arrangements or commitments to
utilize research, research-related products and other services obtained from broker-dealers, or third parties, on a
soft dollar commission basis.

Background
The Securities and Exchange Commission (SEC)/State has defined “soft dollar” practices as arrangements under
which products or services, other than execution of securities transactions, are obtained by an investment adviser
from or through a broker-dealer in exchange for the direction by the adviser of client brokerage transactions to the
broker-dealer. In the event of soft dollar arrangements, CIS has an obligation to act in the best interests of its
clients and to place client interests before its own. CIS also has an affirmative duty of full and fair disclosure of all
material facts in relation to soft dollar arrangements to its clients.

Firm Statement
CIS does not have any soft dollar arrangements of any kind.