exo-is/governance-reporting-on-listed-companies huggingface dataset:
Keyword: governance
• Governance
TALENT | TECHNOLOGY AND DATA | ANALYTICS
MONITOR
CONTROL
REPORT
IDENTIFY
MEASURE
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
105
Accountability, Culture 
and Talent
Our transformation is underpinned by 
a fundamental reset of our approach to 
culture and talent, to strengthen risk 
management and our control environ­
ment. We believe this will allow us to build 
a culture of excellence in which we each 
take ownership for managing risk and 
controls and where we continue to take 
pride in working together to always do 
the right thing for our clients, colleagues 
and communities.
To achieve this, w
Keyword: governance
our governance framework, programs 
and efforts that embed our culture and 
expectations for behavior throughout 
the organization. Our approach begins 
with a strong “tone from the top,” start­
ing with our Board of Directors. With 
oversight from the Ethics, Conduct and 
Culture Committee of the Board, our 
senior leaders consistently reinforce a 
culture of ethics, appropriate conduct and 
accountability within the organization, and 
empower our employees to make ethical 
decisions, escalate issues and adhere to 
Citi’s standards of conduct.
WE ASK OUR COLLEAGUES GLOBALLY TO ENSURE THAT THEIR 
DECISIONS PASS THREE TESTS:
•	 They are in our clients’ interests.
•	 They create economic value.
•	 They are always systemically responsible.
These three tests
Keyword: governance
social and governance (ESG) issues. 
As an outcome of the roundtable 
discussions, TRAFFIC worked with GFCII 
to provide specialized training to Citi 
employees in our Europe, Middle East and 
Africa region. This included a series of 
webinars co-hosted by Citi, TRAFFIC and 
the Environmental Investigation Agency, 
a nongovernmental organization that 
investigates and campaigns against envi­
ronmental crime and abuse. The training 
series focused on how to identify red flags 
in client onboarding and transactional 
activity to disrupt the flow of income 
generated by environmental crime. 
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 202
Keyword: governance
priate level of cybersecurity governance, 
capabilities and controls are in place to 
protect Citi’s and our clients’ information 
assets, with end-to-end accountability 
across the firm. Our approach rests on 
ensuring we have the right architecture, 
technology, policies, processes and talent 
in place to prevent, detect, respond to and 
recover from cyber threats quickly.
Our Cybersecurity Program is overseen by 
Citi’s Board of Directors and is regularly 
reviewed by regulators, as well as by inter­
nal and external auditors. The program 
is managed by the Chief Enterprise 
Operations & Technology Officer and 
the Chief Information Security Officer 
on a global enterprise basis; the Chief 
Executives of each business sector and 
region are responsible for implementation 
and
Keyword: governance
escalation processes to Citi’s governance 
committees and Board of Directors 
that facilitate consistent, timely and 
appropriate identification, analysis and 
escalation of potential consumer fairness 
and reputational and franchise risk issues. 
In relation to designing variable incentive 
plans, we consider a number of factors, 
including whether plans align with our 
Treating Customers Fairly principles. For 
example, we leverage client satisfaction 
metrics, where available, along with other 
product-based metrics, to incentivize 
achieving business results that adhere to 
internal policies and our Code of Conduct. 
We routinely evaluate incentive plans, 
training content, controls, monitoring 
results and oversight activities to maintain 
a sales force that delivers on Citi’
Keyword: governance
about our governance of ESG issues, 
including human rights, see the ESG 
Governance at Citi section. 
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
126
Salient Human Rights Risks: Stakeholder Impacts
This table illustrates which stakeholders could be impacted by the human rights risks we have identified as most salient 
to our company. Rows shaded in gray indicate risks related to the Areas of High Caution defined in our ESRM Policy and 
trigger additional due diligence for project transactions, general corporate purpose transactions and regular reviews of 
client relationships. Additional context about our approach to
Keyword: governance
about our governance and 
policies related to modern 
slavery, risk assessment and due 
diligence processes, and training. 
In 2021, we released our first 
Modern Slavery Statement 
specific to Australia.
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
129
Respecting Human 
Rights in Our 
Financing Decisions
Effectively evaluating human rights risks 
related to our clients and the projects we 
finance is challenging. We work diligently 
to meet this challenge and respect the 
human rights of the individuals and 
communities impacted by the clients we 
finance and their projects.
We have established policies and practices
Keyword: governance
governance that guide Citi employees 
to make sourcing decisions that support 
inclusive processes and increase our roster 
of diverse suppliers. Additionally, the 
SCDIS Program works across our supply 
chain to enhance sustainability practices, 
while mitigating social and environmental 
risks for all suppliers.
Supplier Diversity
Citi is committed to integrating supplier 
diversity across our entire business. Our 
SCDIS team sets clear supplier diversity 
goals and embeds them in our sourcing 
processes. Every bid over $250,000 
requires the consideration of diverse firms. 
Promoting the inclusion of diverse suppli­
ers in the bidding process helps us to build 
a supplier base that more fully represents 
the communities we serve.
Racial Equity
One
Keyword: governance
•	 ESG Governance at Citi 
•	 Our Material ESG Issues: Citi in a Global Context
•	 Our $1 Trillion Commitment
•	 Financing the Low-Carbon Transition
•	 Climate Risk and Net Zero
•	 Human Rights > Our Salient Human Rights Risks
•	 2021 10-K pages 45-59
102-16 Values, principles, standards, and norms 
of behavior
•	 Citi at a Glance
•	 Our Transformation
•	 Risk Management
•	 Citi Corporate Governance
102-17 Mechanisms for advice and concerns 
about ethics
•	 Our Transformation > Ethics and Culture at Citi
•	 Citi Code of Conduct
•	 Ethics Hotline 
102-18 Governance structure
•	 ESG Governance at Citi
•	 Citi Corporate Governance
•	 2022 Proxy Statement pages 22-24
102-19 Delegating authority
•	 ESG Governance at Citi
•	 Citigroup Board of Director’s Committe
Keyword: governance
•	 ESG Governance at Citi
102-21 Consulting stakeholders on economic, 
environmental, and social topics
•	 ESG Governance at Citi
•	 Stakeholder Engagement at Citi
•	 Climate Risk and Net Zero > Reducing Climate Risk in Our Financing
•	 Risk Management > Public Policy
•	 Risk Management > Monitoring the Changing Risk Landscape
•	 Human Rights > Our Commitment to Respect Human Rights
•	 Human Rights > Learning and Engagement
•	 2022 Proxy Statement pages 12, 85-86
102-22 Composition of the highest governance 
body and its committees
•	 2022 Proxy Statement pages 34-38
102-23 Chair of the highest governance body
The Chair of the Board is a nonexecutive, independent director.
•	 2022 Proxy Statement page 29
102-24 Nominating and selecting the highest 
governan
Keyword: governance
•	 Nomination, Governance and Public Affairs Committee Charter
•	 2022 Proxy Statement pages 47-51
102-25 Conflicts of interest
•	 2022 Proxy Statement pages 25-28, 39-42 and 98
102-26 Role of highest governance body in 
setting purpose, values, and strategy
•	 ESG Governance at Citi
•	 2022 Proxy Statement pages 47-51
102-27 Collective knowledge of highest 
governance body
•	 ESG Governance at Citi
•	 2022 Proxy Statement pages 10-11 and 52-63
102-28 Evaluating the highest governance body’s 
performance
•	 Corporate Governance Guidelines page 6 
•	 2022 Proxy Statement page 31
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
14
Keyword: governance
•	 ESG Governance at Citi
•	 Stakeholder Engagement at Citi
•	 Climate Risk and Net Zero > Citi’s Approach to Managing Climate Risk
•	 Sustainable Operations > Managing Climate Risk in Our Operations
•	 Risk Management > Environmental and Social Risk Management
•	 Human Rights > Our Commitment to Respect Human Rights
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
•	 Responsible Sourcing > Supplier Engagement and Evaluation
•	 The Principles for Responsible Banking Index > 2.1 Impact Analysis
•	 Nomination, Governance and Public Affairs Committee Charter
•	 Risk Management Committee Charter
•	 2021 10-K pages 60-61 and 118-119
•	 2022 Proxy Statement pages 32-34
102-30 Effectiveness of risk management 
processes
•	 ESG Governance at Cit
Keyword: governance
•	 Nomination, Governance and Public Affairs Committee Charter
•	 2021 10-K pages 66-73, 77-81, 92-100, 101-103 and 110-121
102-31 Review of economic, environmental, and 
social topics
•	 ESG Governance at Citi 
•	 2022 Proxy Statement pages 32-34 and 36
102-32 Highest governance body’s role in 
sustainability reporting
•	 Head of Global Public Affairs
102-33 Communicating critical concerns
•	 ESG Governance at Citi > ESG Governance
•	 Citi Code of Conduct
•	 2022 Proxy Statement pages 43-44
102-35 Remuneration policies
We compensate our executives fairly, based on individual and company performance, competitive 
benchmarking and support of our Mission and Value Proposition. 
•	 ESG Governance at Citi > Remuneration
•	 Compensation Philosophy
•	 Personnel and Compe
Keyword: governance
•	 ESG Governance at Citi > Remuneration
•	 Personnel and Compensation Committee Charter
•	 2022 Proxy Statement pages 64-67
102-37 Stakeholders’ involvement in 
remuneration
Citi incorporates shareholder and stakeholder input on executive pay into our Compensation 
Philosophy. 
•	 Compensation Philosophy
•	 Personnel and Compensation Committee Charter
102-40 List of stakeholder groups
•	 Stakeholder Engagement at Citi
102-41 Collective bargaining agreements
•	 Human Rights > Respecting the Human Rights of Our Employees
102-42 Identifying and selecting stakeholders
•	 Stakeholder Engagement at Citi
•	 Human Rights > Learning and Engagement
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Ris
Keyword: governance
•	 ESG Governance at Citi 
•	 Risk Management > Managing Corruption and Tax-Related Risks
103-3 Evaluation of the management approach
•	 ESG Governance at Citi 
•	 Our Transformation > Ethics and Culture at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
205-1 Operations assessed for risks related to 
corruption
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery Program Statement
205-2 Communication and training about anti-
corruption policies and procedures
•	 Our Transformation > Ethics and Culture at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery Program Statement
•	 Anti-Money Laundering Program
•	 Citi Code of Conduct
GRI 206: Anti-competitive Behavior 2016
103-1 Expla
Keyword: governance
•	 ESG Governance at Citi
•	 Citi Code of Conduct
•	 2021 10-K pages 66-69
103-3 Evaluation of the management approach
•	 ESG Governance at Citi
•	 2021 10-K pages 66-69
206-1 Legal actions for anti-competitive behavior, 
anti-trust, and monopoly practices
•	 2021 10-K pages 296-303
GRI 302: Energy 2016
103-1 Explanation of the material topic and its 
Boundary
•	 Our Material ESG Issues: Citi in a Global Context 
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
143
103-2 The management approach and its 
components 
•	 ESG Governance at Citi
•	 Our $1 Trillion Commitment
•	 Financing the Low-Carbon Transition
•	 Climate R
Keyword: governance
•	 ESG Governance at Citi
•	 Financing the Low-Carbon Transition > Climate and Biodiversity
•	 Risk Management > Environmental and Social Risk Management
103-3 Evaluation of the management approach
•	 Risk Management > Environmental and Social Risk Management
304-2 Significant impacts of activities, products, 
and services on biodiversity
•	 Financing the Low-Carbon Transition > Climate and Biodiversity
•	 Risk Management > Environmental and Social Risk Management
304-3 Habitats protected or restored
•	 Risk Management > Protecting Biodiversity and Addressing Resettlement Concerns in Panama City
GRI 305: Emissions 2016
103-1 Explanation of the material topic and its 
Boundary
•	 Our Material ESG Issues: Citi in a Global Context 
•	 2021 TCFD Report
103-2 Th
Keyword: governance
•	 ESG Governance at Citi
•	 Climate Risk and Net Zero > Our Net Zero Commitment
•	 Sustainable Operations > Operational Footprint Goals
•	 Sustainable Progress Strategy 
103-3 Evaluation of the management approach
•	 Sustainable Operations > Operational Footprint Goals
305-1 Direct (Scope 1) GHG emissions
•	 Sustainable Operations > Environmental Performance for Operations
•	 Sustainable Operations > Environmental Impact Report
305-2 Energy indirect (Scope 2) GHG emissions
•	 Sustainable Operations > Environmental Performance for Operations
•	 Sustainable Operations > Environmental Impact Report
305-3 Other indirect (Scope 3) GHG emissions
•	 Sustainable Operations > Environmental Impact Report
305-4 GHG emissions intensity
•	 Sustainable Operations > Envi
Keyword: governance
•	 ESG Governance at Citi
•	 Sustainable Operations > Operational Footprint Goals
•	 Sustainable Progress Strategy
103-3 Evaluation of the management approach
•	 Sustainable Operations > Operational Footprint Goals
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
144
306-2 Management of significant waste-related 
impacts
•	 Sustainable Operations > Operational Footprint Goals
•	 Sustainable Operations > Sustainable Building Principles in Action
306-3 Waste generated
Citi did not generate any hazardous waste during the reporting period.
•	 Sustainable Operations > Environmental Performance for Operations
•	 Sustainable Op
Keyword: governance
•	 ESG Governance at Citi
•	 Diversity, Equity & Inclusion
103-3 Evaluation of the management approach
•	 Diversity, Equity & Inclusion
401-1 New employee hires and employee turnover
•	 Employment Data
401-2 Benefits provided to full-time employees 
that are not provided to temporary or part-time 
employees
•	 Return to Office and the Future of Work
•	 Citi Benefits Handbook
GRI 403: Occupational Health and Safety 2018
103-1 Explanation of the material topic and its 
Boundary
•	 Our Material ESG Issues: Citi in a Global Context 
•	 Sustainable Operations > Employee and Customer Well-Being
•	 Return to Office and the Future of Work
103-2 The management approach and its 
components 
•	 ESG Governance at Citi
•	 Sustainable Operations > Sustainable Building Pr
Keyword: governance
•	 ESG Governance at Citi
•	 Diversity, Equity & Inclusion > Recruit, Retain and Promote
103-3 Evaluation of the management approach
•	 Diversity, Equity & Inclusion > Recruit, Retain and Promote
404-2 Programs for upgrading employee skills 
and transition assistance programs
•	 Diversity, Equity & Inclusion > Recruit, Retain and Promote
404-3 Percentage of employees receiving regular 
performance and career development reviews
Employees receive formal feedback from their managers through mid-year and year-end reviews. 
Citi encourages employees and their managers to create individual plans that consider the skills, 
strategic development opportunities and behaviors needed to enhance current performance and 
prepare for future roles. These plans are discuss
Keyword: governance
•	 ESG Governance at Citi
•	 Diversity, Equity & Inclusion
•	 Human Rights > Our Commitment to Respect Human Rights
•	 Human Rights > Respecting the Human Rights of Our Employees
103-3 Evaluation of the management approach
•	 Diversity, Equity & Inclusion
405-1 Diversity of governance bodies and 
employees
•	 Employment Data
•	 Board of Directors
•	 2022 Proxy Statement page 30
GRI 407: Freedom of Association and Collective Bargaining 2016
103-1 Explanation of the material topic and its 
Boundary
•	 Our Material ESG Issues: Citi in a Global Context
•	 Human Rights > Respecting the Human Rights of Our Employees
103-2 The management approach and its 
components 
•	 ESG Governance at Citi
•	 Human Rights > Respecting the Human Rights of Our Employees
103-3 Eva
Keyword: governance
•	 ESG Governance at Citi
•	 Human Rights > Extending Respect for Human Rights Through Our Suppliers
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
•	 Citi Statement of Supplier Principles
•	 Citi Statement on Human Rights
103-3 Evaluation of the management approach
•	 Human Rights > Respecting Human Rights in Our Financing Decisions 
408-1 Operations and suppliers at significant risk 
for incidents of child labor
We have not identified any operations as having significant risk for incidents of child labor. Our 
business overall is not at high risk because of the nature of work in the financial services industry. In 
addition, we do not directly source high-risk agricultural commodities, conflict minerals or any other 
raw materials, g
Keyword: governance
•	 ESG Governance at Citi
•	 Human Rights > Extending Respect for Human Rights Through Our Suppliers
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
•	 Responsible Sourcing > Supplier Engagement and Evaluation
•	 Citi Statement of Supplier Principles
•	 Citi Statement on Human Rights
•	 Citi Modern Slavery Disclosures
103-3 Evaluation of the management approach
•	 Human Rights > Extending Respect for Human Rights Through Our Suppliers
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
•	 Responsible Sourcing > Supplier Engagement and Evaluation
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021
Keyword: governance
•	 ESG Governance at Citi
•	 Human Rights > Our Commitment to Respect Human Rights
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
103-3 Evaluation of the management approach
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
411-1 Incidents of violations involving rights of 
indigenous peoples
•	 Human Rights > Identifying Human Rights Risks in Transactions
GRI 412: Human Rights Assessment 2016
103-1 Explanation of the material topic and its 
Boundary
•	 Our Material ESG Issues: Citi in a Global Context
•	 Human Rights > Our Commitment to Respect Human Rights
•	 Responsible Sourcing 
103-2 The management approach and its 
components 
•	 ESG Governance at Citi
•	 Human Rights
•	 Responsible Sourcing > Supplier Engageme
Keyword: governance
•	 ESG Governance at Citi
•	 Our Commitment to Social Finance
•	 Risk Management > Our ESRM Policy
•	 Citi’s Environmental and Social Policy Framework
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
147
103-3 Evaluation of the management approach
•	 Our Commitment to Social Finance
•	 Risk Management > Policy Implementation
413-1 Operations with local community 
engagement, impact assessments, and 
development programs
•	 Stakeholder Engagement at Citi
•	 Action for Racial Equity
•	 Citi Impact Fund
•	 COVID-19 Relief and Recovery
•	 Affordable Housing
•	 Strategic Philanthropy
•	 Risk Management > Environmental and Soc
Keyword: governance
•	 ESG Governance at Citi
•	 Risk Management > Public Policy
•	 Citi Political Activities Statement
103-3 Evaluation of the management approach
•	 Risk Management > Public Policy
•	 Citi Political Activities Statement
415-1 Political contributions
•	 Citi U.S. Political Contributions
GRI 417: Marketing and Labeling 2016
103-1 Explanation of the material topic and its 
Boundary
•	 Our Material ESG Issues: Citi in a Global Context
•	 Serving Our Customers and Clients Responsibly
103-2 The management approach and its 
components 
•	 ESG Governance at Citi
•	 Serving Our Customers and Clients Responsibly
103-3 Evaluation of the management approach
•	 Our Material ESG Issues: Citi in a Global Context
•	 Serving Our Customers and Clients Responsibly
417-1 Require
Keyword: governance
•	 ESG Governance at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Serving Our Customers and Clients Responsibly
•	 2021 10-K pages 66-69
103-3 Evaluation of the management approach
•	 Risk Management > Managing Corruption and Tax-Related Risks 
•	 Serving Our Customers and Clients Responsibly
•	 2021 10-K pages 66-69
419-1 Non-compliance with laws and regulations 
in the social and economic area
•	 2021 10-K pages 66-69, 116-117
•	 2021 Annual Report
FINANCIAL SERVICES SECTOR SUPPLEMENT
FS6 Percentage of the portfolio for business lines 
by specific region, size (e.g., micro/SME/large) and 
by sector
•	 2021 10-K pages 7-28
FS8 Monetary value of products and services 
designed to deliver a specific environmental 
benefit for each b
Keyword: governance
Social and Governance (ESG) Report. 
•	 Equitable and Resilient Communities > Investing in Our Communities: 
2021 Highlights
•	 Our Commitment to Social Finance
•	 Action for Racial Equity
•	 Citi Impact Fund
•	 COVID-19 Relief and Recovery
•	 Affordable Housing
•	 Strategic Philanthropy
•	 Citi Community Capital Website 
(1) Number and (2) amount of 
past due and nonaccrual loans 
qualified to programs designed 
to promote small business and 
community development
Quantitative
FN-CB-
240a.2
Citi does not report this information.
Number of no-cost retail 
checking accounts provided 
to previously unbanked or 
underbanked customers 
Quantitative
FN-CB-
240a.3
In 2014, Citi launched the Access Account — a simple, checkless bank 
account with low or no monthly fee
Keyword: governance
social, and governance (ESG) 
factors in credit analysis
Discussion 
and Analysis
FN-CB-
410a.2
•	 Risk Management > Environmental and Social Risk Management
•	 Environmental and Social Policy Framework
•	 2021 10-K pages 118-119
Business 
Ethics
Total amount of monetary 
losses as a result of legal 
proceedings associated 
with fraud, insider trading, 
anti-trust, anti-competitive 
behavior, market manipulation, 
malpractice, or other related 
financial industry laws or 
regulations
Quantitative
FN-CB-
510a.1
Citi discloses all material legal and regulatory proceedings in its 10-
K, including when a suit was filed, the court, the parties involved, the 
allegations and the relief sought. Citi also discloses information regarding 
material inquiries or investigat
Keyword: governance
Governance 
Factors in 
Investment 
Banking & 
Brokerage 
Activities
Revenue from (1) underwriting, 
(2) advisory, and (3) 
securitization transactions 
incorporating integration of 
environmental, social, and 
governance (ESG) factors, by 
industry
Quantitative
FN-IB-
410a.1
Citi does not report this information.
(1) Number and (2) total value 
of investments and loans 
incorporating integration of
environmental, social, and 
governance (ESG) factors, by 
industry
Quantitative
FN-IB-
410a.2
•	 Our $1 Trillion Commitment
•	 Risk Management > ESRM Consultation Data
Citi also incorporates environmental and social criteria for transactions 
that contribute to our $1 trillion sustainable finance commitment. 
Description of approach to 
incorporation of e
Keyword: governance
social, and governance (ESG)
factors in investment banking 
and brokerage activities
Discussion 
and Analysis
FN-IB-
410a.3
•	 Risk Management > Environmental and Social Risk Management
•	 Citi’s Environmental and Social Policy Framework
Business 
Ethics
Total amount of monetary 
losses as a result of legal 
proceedings associated 
with fraud, insider trading, 
anti-trust, anti-competitive 
behavior, market manipulation, 
malpractice, or other related 
financial industry laws or 
regulations
Quantitative
FN-IB-
510a.1
See response to FN-CB-510a.1.
Description of whistleblower 
policies and procedures
Discussion 
and Analysis
FN-IB-
510a.2
See response to FN-CB-510a.2.
Professional 
Integrity
(1) Number and (2) percentage 
of covered employees with a 
record of i
Keyword: governance
Governance (ESG) Report:
•	 Citi at a Glance
External References:
•	 About Citi
•	 Consumer Businesses
•	 Institutional Businesses
•	 2021 10-K, pp. 4-6
The Principles for Responsible Banking Index
The Principles for Responsible Banking (PRB) are a framework for ensuring that signatory banks’ strategy and practice align with Sustainable 
Development Goals (SDGs) and the Paris Climate Agreement (Paris Agreement). The Principles encourage a sustainable banking system and help 
the industry demonstrate how it makes a positive contribution to society. They embed sustainability at the strategic, portfolio and transactional 
levels and across all business areas.
Following the guidance provided by UN Environment Programme Finance Initiative (UNEP FI), we ma
Keyword: governance
Corporate Governance as well as Sustainability; Government Affairs and other 
teams in Public Affairs. Examples of our stakeholder engagements from 2021 
are highlighted in the Stakeholder Engagement at Citi section of this report. 
Furthermore, we periodically have feedback sessions for stakeholders 
including clients, investors and NGOs facilitated by the nonprofit sustainability 
advocacy organization Ceres. These sessions focus on areas such as our 
Sustainable Progress Strategy and approach to addressing climate change 
including, most recently, our setting of net zero targets and measurement of 
baseline emissions. For more information, please see pages 26-27 of our 2021 
TCFD Report. 
b) Partnerships with trade organizations: 
Becoming a signatory to gl
Keyword: governance
Investor Relations, Human Resources and Corporate Governance, as well as 
Sustainability & ESG, Government Affairs and other teams in Public Affairs.
A summary of the groups we have engaged with, the topics addressed, and 
results achieved is provided in Stakeholder Engagement section of this report. 
We also highlight our climate-related engagement with clients and trade 
associations in our 2021 TCFD Report.
2021 ESG Report:
•	 Stakeholder Engagement
•	 Climate Risk and Net Zero > 
Participation in Net Zero 
Frameworks
•	 Climate Risk and Net Zero > 
Engagement
•	 Risk Management > Client 
Engagement
External References:
•	 2021 TCFD Report
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
App
Keyword: governance
Principle 5: Governance & Culture
We will implement our commitment to these Principles through effective governance and a culture of responsible banking.
5.1 Describe the relevant governance 
structures, policies and procedures 
your bank has in place/is planning 
to put in place to manage significant 
positive and negative (potential) 
impacts and support effective 
implementation of the Principles. 
Citi’s Board of Directors plays an important role in providing oversight of our 
efforts to ensure responsible business practices. For example, the Nomination, 
Governance and Public Affairs Committee (NGPAC) of the Board oversees Citi’s 
global ESG activities and performance, and the Risk Management Committee 
(RMC) provides oversight of Citi’s Risk Management func
Keyword: governance
For more details on governance for ESG and sustainability issues, please refer 
to the ESG Governance section of this report. For more details on Citi’s climate 
change governance, please see our 2021 TCFD Report.
2021 ESG Report: 
•	 ESG Governance at Citi
External References:
•	 2021 TCFD Report
•	 Ethics, Conduct and Culture 
Committee Charter
•	 Nomination, Governance and 
Public Affairs Committee Charter
•	 Risk Management Committee 
Charter
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
164
Reporting and Self-
Assessment Requirements 
High-Level Summary of Bank’s Response
References
5.2 Describe the initiatives and 
measures
Keyword: governance
•	 ESG Governance at Citi > 
Remuneration
•	 Our Transformation > Ethics and 
Culture at Citi
•	 Risk Management > Managing 
Corruption and Tax-Related Risks
•	 Risk Management > ESRM Training
•	 Serving Our Customers and 
Clients Responsibly

External References:
•	 Citi Code of Conduct
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
165
Reporting and Self-
Assessment Requirements 
High-Level Summary of Bank’s Response
References
5.3 Governance Structure for 
Implementation of the Principles
Show that your bank has a 
governance structure in place for the 
implementation of the PRB, including: 
a) target-setting and ac
Keyword: governance
•	 ESG Governance at Citi
•	 Our Transformation > Ethics and 
Culture at Citi
We have progressed substantially in fulfilling this requirement. The firm has a governance structure with oversight of ESG issues and will ensure that 
the Principles are implemented, managing significant impacts and setting and monitoring targets. The Sustainability & ESG team leads day-to-day 
implementation of the Principles in concert with other teams throughout the organization.
Principle 6: Transparency & Accountability
We will periodically review our individual and collective implementation of these Principles and be transparent about and accountable for our positive 
and negative impacts and our contribution to society’s goals.
6.1 Progress on Implementing the 
Principles
Keyword: governance
our overall business strategy and efforts. Additionally, during 2021, we expanded our climate change governance through the formation of a Global ESG Council, 
consisting of senior members of management. We also grew our dedicated Climate Risk team to accommodate additional areas of expertise. For more information, 
please see our 2021 TCFD Report.
Action for Racial Equity: 
By November 2021 — one year into our three-year pledge — Citi and the Citi Foundation had already invested $1 billion into initiatives expanding economic 
opportunity for communities of color, putting us on track to exceed our original $1.1 billion commitment set in 2020. In 2021, we created a Diverse Financial 
Institutions Group, a dedicated team within Citi that is serving as a hub to lead and expand firmwide engagement with MDIs, diverse broker-dealers and diverse 
asset man
Keyword: governance
Governance
a) Describe the Board’s oversight 
of climate-related risks and 
opportunities.
•	 2021 TCFD Report
•	 Nomination, Governance and Public Affairs Committee Charter 
b) Describe management’s role in 
assessing and managing climate-
related risks and opportunities.
•	 Climate Risk and Net Zero
•	 2021 TCFD Report
Strategy
a) Describe the climate-related 
risks and opportunities the 
organization has identified over the 
short, medium and long term.
•	 Our $1 Trillion Commitment
•	 Financing the Low-Carbon Transition
•	 Climate Risk and Net Zero
•	 2021 TCFD Report
•	 Citi’s Environmental and Social Policy Framework 
b) Describe the impact of climate-
related risks and opportunities 
on the organization’s businesses, 
strategy and financial pl
Keyword: governance
Part A: Governance of Respect for Human Rights
Policy 
commitment
A1
What does the company say publicly about its commitment to respect human rights?
A1.1
How has the public commitment 
been developed?
•	 Human Rights > Our Commitment to Respect Human Rights
A1.2
Whose human rights does the 
public commitment address?
•	 Human Rights > Our Commitment to Respect Human Rights
•	 Citi Statement on Human Rights
A1.3
How is the public commitment 
disseminated?
•	 Our Transformation > Code of Conduct
The following documents, which state Citi’s commitment to respect human rights and 
our expectations about the commitment of others, are posted publicly: 
•	 Citi Code of Conduct  
•	 Citi Requirements for Suppliers   
•	 Citi Statement of Supplier Principles  
•	 Cit
Keyword: governance
•	 ESG Governance at Citi
•	 Diversity, Equity & Inclusion
•	 Risk Management > Safeguarding Data and Protecting Customer Information
•	 Risk Management > Policy Implementation
•	 Human Rights > Due Diligence in Client Transactions
•	 Responsible Sourcing
A2.2
What kinds of human rights issues 
are discussed by senior management 
and by the Board, and why?
•	 Human Rights > Our Salient Human Rights Risks
A2.3
How are employees and contract 
workers made aware of the ways 
in which respect for human rights 
should inform their decisions and 
actions?
•	 Our Transformation > Code of Conduct
•	 Risk Management > ESRM Training
•	 Human Rights > Respecting the Human Rights of Our Employees
•	 Human Rights > Learning and Engagement
•	 Citi Code of Conduct  
A2.4
Keyword: governance
•	 ESG Governance at Citi
•	 Risk Management > Environmental and Social Risk Management
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
C4.2
When tensions arise between the 
prevention or mitigation of impacts 
related to a salient issue and other 
business objectives, how are these 
tensions addressed?
•	 Risk Management > Policy Implementation
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
C4.3
During the reporting period, what 
action has the company taken 
to prevent or mitigate potential 
impacts related to each salient 
issue?
•	 Action for Racial Equity > Action for Racial Equity: An Update on Our Progress
•	 Affordable Housing
•	 Diversity, Equity & Inclusion
•	 Risk Management > Safeguarding Data and Prote
Keyword: governance
relationships in others. In particular, we enhanced our governance of human rights 
risks in the Asia Pacific region with a special Human Rights Task Force and also 
initiated a portfolio review of the Malaysia franchise, to evaluate forced labor 
concerns in clients’ operations across different industries.
In addition, see the case studies below.  
•	 Our $1 Trillion Commitment > Sustainable Finance in Action
•	 Human Rights > Addressing Forced Labor in Malaysia
•	 Human Rights > Protection of Indigenous Rights in Latin America
•	 Human Rights > Identifying Human Rights Risks in Transactions
•	 Responsible Sourcing > Supplier Engagement and Evaluation
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business
Keyword: governance
provide transparency into our environmental, social and governance (ESG) initiatives to 
respond to stakeholder requests, and to further enhance our collective understanding 
of ESG issues. Our approaches to the disclosures included in this report are different 
from those included in mandatory regulatory reporting, including under SEC regulations. 
Certain statements in this report may contain “forward-looking statements.” These 
statements speak only as of the date they are originally made and are based on 
management’s current expectations and are subject to known and unknown risks, 
uncertainties, changes in circumstances, and assumptions that are difficult to predict 
and are often beyond our control. These statements are not guarantees of future results, 
occurrences, or performance. Actual results
Keyword: bribe
Business Ethics: Following our internal policies including those pertaining to anti-corruption, bribery and 
anti-competitive behavior; complying with laws; and maintaining transparency around political engagement 
Business Model Resilience: Creating, developing and deploying a business model that can 
meet significant challenges such as natural disasters, pandemics and global climate change
Data Security/Financial Product Safety: Executing the policies, procedures and programs designed to 
safeguard the privacy of information shared by employees, customers and clients
ESG Governance: Aligning with stakeholder interests with consideration for environmental and social impacts
Innovation and Digitization: Problem-solving with clients, partnering with experts and fostering an 
environment that values experimentation and technological advancemen
Keyword: bribe
Anti-Bribery and Corruption, Anti-Money 
Laundering (AML) and Sanctions teams. Our 
Chief Compliance Officer, who reports directly 
to our General Counsel, provides regular 
reports on our performance in these areas, to 
our Board of Directors or a committee of the 
Board, as appropriate. 
Our GFCII team works to prevent, identify and 
counteract the many and varied corruption-
related risks that confront the financial sector. 
Select examples of our partnerships in 2022 
include: 
•	United for Wildlife: Citi works with 
government agencies and nongovern­
mental organizations (NGOs) alongside 
other financial institutions to help fight 
illegal wildlife trafficking. We participate in 
the financial taskforce as well as regional 
chapters in East Africa
Keyword: bribe
ANTI-BRIBERY AND CORRUPTION PROGRAM 
Citi has policies, procedures and internal controls to comply with 
anti-bribery laws, and we conduct an annual bribery risk assessment 
of all global business lines. We provide our staff with anti-bribery 
training annually and supplement it with targeted training and 
communications as needed. For more information, see the Citi 
Anti-Bribery and Corruption Program Statement, which is updated 
at least annually.
ANTI-MONEY LAUNDERING (AML) PROGRAM
Our AML Program helps protect our clients, our franchise and the 
global financial system from the risks of money laundering and 
terrorist financing. The global program consists of designated 
AML Country Officers covering every Citi business, function and 
geographic ar
Keyword: bribe
* This combined online training incorporates multiple anti-corruption efforts, including AML, sanctions and anti-bribery training. Numbers include all Citi staff who had completed the 2022 training as of December 2022. 
(Employees and contingent workers generally have 30 days to complete it.)
Taxation Policies and Standards
Citi does business in nearly 160 countries and 
jurisdictions, and maintains strong review and 
escalation processes that enable us to adhere 
to high standards of compliance with applicable 
tax laws. We are a current income taxpayer, 
both within and outside the U.S. Our tax profile 
is consistent with the locations of our business 
operations, and we adhere to OECD standards 
regarding substance and transparency.
We emphasize strong internal controls and 
transparency with global tax authorities and 
share information relevant to our t
Keyword: bribe
•	 Anti-Bribery and Corruption Program Statement
205-2 Communication and 
training about anti-corruption 
policies and procedures
•	 Ethics and Culture at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery and Corruption Program Statement
•	 Anti-Money Laundering Program
•	 Citi Code of Conduct
Disclosure Number and Title
Report Section or Other Documentation
GRI 206: Anti-competitive Behavior 2016
3-3 Management of material 
topics
•	 Ethics and Culture at Citi
•	 Citi Code of Conduct
•	 2022 10-K pages 60-63
206-1 Legal actions for anti-
competitive behavior, anti-trust, 
and monopoly practices
•	 2022 10-K pages 298–304
GRI 302: Energy 2016
3-3 Management of material 
topics
•	 Our $1 Trillion Goal
•	 Financing the Low-
Keyword: bribe
bribery.
•	 Risk Management > Managing Corruption and Tax-Related Risks 
•	 Anti-Bribery Program
•	 Anti-Money Laundering Program
•	 Citi Code of Conduct
•	 Citi Requirements for Suppliers 
•	 Citi Statement of Supplier Principles
Citi 2022 ESG Report
Page 102
ESG at Citi
Sustainable Finance
Climate Risk & Net Zero
Sustainable Operations
Building Equitable & Resilient Communities
Talent & DEI
Responsible Business
Appendices
The Principles for Responsible Banking Index
Sustainability Accounting Standards Board Index
GRI Content Index
United Nations Global Compact Index
United Nations Guiding Principles Reporting Framework Index
Assurance
Section of the Framework 
Report Section or Other Documentation
Part A: Governance of Respect for Human Rights
Keyword: bribe
Anti-Bribery and Corruption: 
Citi has policies, procedures and internal controls to comply with anti-bribery laws, and we conduct an annual bribery 
risk assessment of all global business lines. We provide our staff with anti-bribery training annually and supplement 
it with targeted training and communications as needed. For more information, on this and other relevant programs, 
please see “Programs and Training to Combat Financial Crimes” on page 68 of the 2022 ESG Report.
Anti-Money Laundering: 
Our AML Program helps protect our clients, our franchise and the global financial system from the risks of money 
laundering and terrorist financing. The global program consists of designated AML Country Officers covering every Citi 
business, function and
Keyword: corruption
Business Ethics: Following our internal policies including those pertaining to anti-corruption, bribery and 
anti-competitive behavior; complying with laws; and maintaining transparency around political engagement 
Business Model Resilience: Creating, developing and deploying a business model that can 
meet significant challenges such as natural disasters, pandemics and global climate change
Data Security/Financial Product Safety: Executing the policies, procedures and programs designed to 
safeguard the privacy of information shared by employees, customers and clients
ESG Governance: Aligning with stakeholder interests with consideration for environmental and social impacts
Innovation and Digitization: Problem-solving with clients, partnering with experts and fostering an 
environment that values experimentation and technological a
Keyword: corruption
to detect and prevent corruption, address 
potential environmental and social risks in our 
portfolio, and safeguard data and customer 
privacy. These rigorous practices enable us to 
grow a successful, respected business that 
delivers the best possible results for our clients, 
customers and communities.
Managing 
Corruption and 
Tax-Related Risks
Anti-Corruption Activities
The Citi Global Financial Crimes Compliance 
Team includes the Global Financial Crimes 
Investigations and Intelligence (GFCII), 
Anti-Bribery and Corruption, Anti-Money 
Laundering (AML) and Sanctions teams. Our 
Chief Compliance Officer, who reports directly 
to our General Counsel, provides regular 
reports on our performance in these areas, to 
our Board of Directors or a committee of the 
Board,
Keyword: corruption
counteract the many and varied corruption-
related risks that confront the financial sector. 
Select examples of our partnerships in 2022 
include: 
•	United for Wildlife: Citi works with 
government agencies and nongovern­
mental organizations (NGOs) alongside 
other financial institutions to help fight 
illegal wildlife trafficking. We participate in 
the financial taskforce as well as regional 
chapters in East Africa; the Middle East and 
North Africa; North America; and Hong Kong. 
In 2022, we worked through the Hong Kong 
chapter in support of legislation that elevates 
wildlife-related trafficking to a serious crime 
and helped develop a financial sector toolkit 
and threat profile for the region. 
•	Trust in Business Initiative: In 2022, Citi 
joined global leaders from th
Keyword: corruption
Infrastructure Anti-Corruption Toolbox, 
which is designed to build trust and account­
ability in infrastructure. 
•	Additional activities: During the year, we 
engaged multiple nonprofits and NGOs 
to combat financial crime, including the 
Polaris Project, Survivor Inclusion Initiative, 
DeliverFund, the International Centre for 
Missing & Exploited Children’s Financial 
Coalition Against Child Sexual Exploitation, 
the Royal United Services Institute’s Future of 
Financial Intelligence Sharing program and the 
United Nations Office on Drugs and Crime.
Assessing Our Culture of Ethics 
Hearing from employees is one important way we 
assess the strength of ethics and accountability 
across our company. As part of our annual Voice 
of the Employee survey, we include an Et
Keyword: corruption
ANTI-BRIBERY AND CORRUPTION PROGRAM 
Citi has policies, procedures and internal controls to comply with 
anti-bribery laws, and we conduct an annual bribery risk assessment 
of all global business lines. We provide our staff with anti-bribery 
training annually and supplement it with targeted training and 
communications as needed. For more information, see the Citi 
Anti-Bribery and Corruption Program Statement, which is updated 
at least annually.
ANTI-MONEY LAUNDERING (AML) PROGRAM
Our AML Program helps protect our clients, our franchise and the 
global financial system from the risks of money laundering and 
terrorist financing. The global program consists of designated 
AML Country Officers covering every Citi business, function and 
geographic area. These speci
Keyword: corruption
* This combined online training incorporates multiple anti-corruption efforts, including AML, sanctions and anti-bribery training. Numbers include all Citi staff who had completed the 2022 training as of December 2022. 
(Employees and contingent workers generally have 30 days to complete it.)
Taxation Policies and Standards
Citi does business in nearly 160 countries and 
jurisdictions, and maintains strong review and 
escalation processes that enable us to adhere 
to high standards of compliance with applicable 
tax laws. We are a current income taxpayer, 
both within and outside the U.S. Our tax profile 
is consistent with the locations of our business 
operations, and we adhere to OECD standards 
regarding substance and transparency.
We emphasize strong internal controls and 
transparency with global tax a
Keyword: corruption
GRI 205: Anti-corruption 2016
3-3 Management of material 
topics
•	 Ethics and Culture at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
205-1 Operations assessed for 
risks related to corruption
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery and Corruption Program Statement
205-2 Communication and 
training about anti-corruption 
policies and procedures
•	 Ethics and Culture at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery and Corruption Program Statement
•	 Anti-Money Laundering Program
•	 Citi Code of Conduct
Disclosure Number and Title
Report Section or Other Documentation
GRI 206: Anti-competitive Behavior 2016
3-3 Management of material 
topics
•	 Ethics and Culture at
Keyword: corruption
labor issues, the environment and anti-corruption. The following table indicates where readers can 
find information that addresses our support of the principles, either in this report or other publicly 
available documents. 
Citi 2022 ESG Report
Page 101
ESG at Citi
Sustainable Finance
Climate Risk & Net Zero
Sustainable Operations
Building Equitable & Resilient Communities
Talent & DEI
Responsible Business
Appendices
The Principles for Responsible Banking Index
Sustainability Accounting Standards Board Index
GRI Content Index
United Nations Global Compact Index
United Nations Guiding Principles Reporting Framework Index
Assurance
UNGC Principle
Report Section or Other Documentation
Labor
Principle 6: the elimination of discrimination in respect of employment and occupation.
•	 Action