exo-is/governance-reporting-on-listed-companies huggingface dataset:
Keyword: governance
governance and significant policies and 
programs for sustainability and climate 
change issues and advises management 
on our engagement with investors and 
external stakeholders on sustainability 
and climate change matters. For more 
information on the roles and responsibili­
ties of the NGPAC, please see our NGPAC 
Charter. 
The RMC provides oversight of Citi’s Risk 
Management function and reviews Citi’s 
risk policies and frameworks. In 2020, 
the Head of Climate Risk and the Head 
of ESRM provided the RMC with updates 
on emerging bank regulator trends on 
climate risk and the bank’s approach 
to meeting them. For more information 
on the roles and responsibilities of this 
committee, please see our RMC Charter. 
Management of climate-related
Keyword: governance
This chart outlines the most material environmental, social and governance issues relevant to our business and our key stakeholders. We realize 
these issues are generally important to all of these stakeholders; however, we focused on areas of highest relevance for each stakeholder group.
Material ESG Topics* 	 	
	
	
 	
             Key Stakeholders
Clients and 
Customers
Employees
Suppliers
Communities 
and NGOs
Shareholders
Government 
and Regulators
Environmental
Biodiversity
Climate Change
Environmental Justice
Operational Footprint
Products and Services with 
Environmental or Social Benefits
Social
Community Investment
COVID-19
Employee Health and Well-being
Financial Inclusion
Human Rights
Racial Equity/Racial Justice
Talent Attraction, Retention and 
Development 
Workforce Diversity, Inclusion and 
Equal O
Keyword: governance
Governance
Business Ethics
Business Model Resilience
Data Security/
Financial Product Safety
ESG Governancee
Innovation and Digitization
Public Policy and Regulation Reform
Stakeholder Engagement
Systemic Risk Management
Transparency and Trust
* For issue definitions, see next page.
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
16
Citi’s Material ESG Issues (continued)
Material Topics
Definitions/Relevance to Citi
Biodiversity
Our role in preventing the decline in the number, genetic variability and variety of species essential to 
global and bioregional ecosystem resilience through our financing
Business Ethics
Following our
Keyword: governance
ESG Governance
Aligning with stakeholder interests while protecting the environment, advancing social causes and 
conducting ourselves responsibly
Financial Inclusion
Engaging with community banks and low-income stakeholders, and orienting the company’s place in the 
market to serve underserved communities
Human Rights
Respecting the basic rights and freedoms of clients, customers, employees, suppliers and Indigenous 
communities in all our banking activities
Innovation and Digitization
Problem-solving with clients, partnering with experts and fostering an environment that values 
experimentation and technological advancements
Operational Footprint
Reducing direct impacts by managing energy use, water consumption, recycling, waste and green building 
des
Keyword: governance
and Corporate Governance, as well as 
Sustainability, Government Affairs, Citi 
Foundation and other teams in Public Affairs. 
The table below includes examples of our 
recent stakeholder engagement efforts. 
America’s Most 
Responsible Companies 
In recognition of our sustained 
ESG efforts, Citi was named one 
of America’s Most Responsible 
Companies — #9 overall and #1 in 
the financial services sector —
in Newsweek’s 2021 rankings. 
Stakeholder 
Engagement 
at Citi
“Our recent $1 trillion commitment to sustainable 
finance by 2030 shows how we are focusing our 
financial resources — from those that support 
environmental finance and affordable housing, 
to racial equity and economic inclusion — to help 
ensure a more sustainable and equitable future. 
We will
Keyword: governance
Relations and Corporate Governance teams
	• Presented in person and virtually to more than 
20 investor groups at our ESG investor road­
show, focused on climate change and diversity 
— our third year of dedicated ESG engagement
Government and 
Regulators
	• Meetings, conference calls, lobbying activ­
ities, industry associations, public policy 
forums, press conferences, conferences and 
convenings
	• Membership on government councils and 
committees
	• Committed to the Office of the Comptroller 
of the Currency’s Project REACh MDI Pledge 
to continue working with Minority Depository 
Institutions to help promote fair and equal 
access to financial projects and services
	• Joined the Commodity Futures Trading 
Commission’s Climate-Related Market Risk 
Subcommittee that dev
Keyword: governance
mental, social and governance (ESG) 
considerations across key areas of our 
business — and our new strategy unifies 
and amplifies our efforts to finance 
climate solutions and reduce climate 
risk. (Learn more about Citi’s overall 
sustainability strategy and governance 
in the Our Approach to Driving Positive 
Impact section.) 
We announced our new strategy several 
months into the global pandemic, which 
further illuminated the interconnected­
ness of economic, physical, societal and 
environmental health, resilience and 
stability. Global financial institutions 
like Citi have the opportunity — and the 
responsibility — to serve as catalysts not 
only for the recovery from the COVID-19 
pandemic, but also for the long-term 
transition to a low-carbon economy.
A Bo
Keyword: governance
provide guidance on the scope, mandate and governance of the new Taskforce.
With plans to launch in 2021, the TNFD will explore recommendations for data analysis and reporting standards related to 
nature-related risks such as biodiversity loss and negative impacts on ecosystems. It is designed to steer finance toward 
outcomes that are nature-positive, in alignment with the Paris Agreement, the Convention on Biological Diversity (CBD) 
Post-2020 Global Biodiversity Targets and the U.N. Sustainable Development Goals.
Humanity has already lost 83% of wild mammals and half of all plants and has severely altered three-quarters of ice-free 
land and two-thirds of marine environments according to the Proceedings of the National Academy of Sciences of the 
United States of America (2019). Climate c
Keyword: governance
recommendations across the four pillars of Governance, 
Strategy, Risk Management and Metrics and Targets. 
Along with the most recent information about our risks, 
governance, strategy and metrics related to climate, 
this new TCFD report offers information on additional 
scenario analysis work that covers a range of regions 
and possible climate realities. 
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
38
Existing Achievements
Current Priorities
Future Goals
Governance
	• Established Climate Risk Working 
Group and Global Sustainability 
Steering Committee 
	• Climate strategy considered 
by Citi Board of Directors, and 
oversight provided by Nomination, 
Governance
Keyword: governance
governance based on proportion­
ality and local regulatory needs
	• Establish a cross-functional Net 
Zero Task Force to guide the 
development of our Net Zero Plan 
	• Expand governance and oversight 
capacity in line with increasing 
climate regulatory requirements 
and our net zero commitment
Strategy
	• Established climate risk as a key 
pillar of Citi’s 2025 Sustainable 
Progress Strategy 
	• Analyzed Citi’s operational vulner­
abilities to physical climate risk 
and certain portfolios’ resilience 
to transition climate risks 
	• Created new business units in our 
Banking and Markets businesses 
to further integrate climate 
opportunities into banking advi­
sory, client solutions and market 
making
	• Announced, in March 2021, Citi’s 
commitment
Keyword: governance
Governance Framework
	• Develop sector-specific climate 
risk guidance, focusing on highest 
risk sectors 
	• Start to integrate climate risk into 
credit assessment processes 
	• Continue analyzing the alignment 
of relevant, high climate risk 
sectors of our loan portfolio with 
the Paris Agreement through 
frameworks such as Paris 
Agreement Capital Transition 
Assessment and Partnership for 
Carbon Accounting Financials  
	• Continue to define assessment 
tools and methodologies and 
integrate into credit assessment 
processes 
	• Develop key climate risk metrics 
and implement across various 
levels of the organization 
	• Continue to develop climate risk 
escalation and approval processes 
	• Improve distribution and integra­
tion of climate ri
Keyword: governance
Governance Framework. Within that 
framework, emerging risks are risks or 
thematic issues that are either new to 
the landscape, or in the case of climate 
risk, existing risks that are changing or 
evolving in an escalating fashion and that 
are difficult to assess due to limited data 
or other uncertainties. Given the perva­
sive, multi-dimensional and nonlinear 
nature of climate risk, we do not view it 
as a standalone risk category but as a 
transversal risk, capable of manifesting 
impacts across Citi’s seven risk cate­
gories in our risk taxonomy — Credit, 
Market, Liquidity, Strategic, Operations, 
Compliance and Reputation risks — each 
of which may be influenced by physical 
and transition climate risks.
In 2020, we elevated the focus on c
Keyword: governance
For more about Citi’s governance related 
to climate risk, see our TCFD report: 
Finance for a Climate-Resilient Future II.
Regulatory Oversight
Interest in the management of climate 
risk continues to grow with bank regula­
tors around the world. The Network for 
Greening the Financial System (NGFS) is 
a network of central banks and supervi­
sors that are working to strengthen the 
global response on climate. As of the end 
of 2020, the NGFS included 77 central 
banks and supervisors and 13 observers, 
covering much of our global footprint. In 
addition, our subsidiaries are supervised 
by local financial regulators in many 
jurisdictions where we operate. 
As climate-specific regulatory guidelines 
and expectations have increased globally, 
we are tracking and respondi
Keyword: governance
governance frameworks. In particular, 
we have updated our ESRM Policy sector 
standards for carbon-intensive sectors to 
incorporate emerging best practices.
One area where we have made 
significant progress pertains to our 
fossil fuel sector standards for thermal 
coal mining and the generation of 
coal-fired power. For more details on 
our targets and policy see the following 
page. For information about additional 
environmentally focused sector standard 
updates, see the Environmental and 
Social Risk Management section. Our 
ESRM Policy, including our sector 
standards, is summarized publicly in 
our Environmental and Social Policy 
Framework.
Portfolio Analysis and 
Measurement
Citi undertakes climate scenario analysis 
and testing of certain
Keyword: governance
that impact our risk and control environment: risk management, data quality and governance, internal controls and 
compliance. What ties these areas together is the need to modernize our infrastructure, governance and banking 
processes. These orders do not impact our ability to serve our clients. 
While we have made progress on our remediation efforts, the consent orders made it clear that we are not where 
we need to be. We are disappointed that we fell short of our regulators’ expectations, and we are working hard to 
thoroughly address the issues identified in the consent orders.
The work we have put in since the financial crisis, whether it was to de-risk our balance sheet or improve our 
efficiency and business performance to close the gap with our competitors, has put us in a position for our 
transformation to succeed. O
Keyword: governance
and consistent approach to accessible data. Improved data governance and 
data quality will create new opportunities, innovation and business value.
Contents 
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Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
101
To encourage enterprise-wide 
engagement, each of these groups 
includes team members from across our 
businesses and functions. The executives 
in charge of these programs are held 
accountable for their group’s success, 
and compensation will be linked to 
results achieved in these areas.
Accountability, Culture and Talent
Our transformation is underpinned 
by a fundamental reset of our culture 
and talent model to strengthen 
risk management and our control 
environment. We believe thi
Keyword: governance
prioritizing strong governance and 
decision-making and requiring our 
colleagues to speak with candor and 
welcome challenges from each other, as 
well as make decisions with the whole 
enterprise in mind. Our focus is on seeking 
out diverse perspectives to help us spot 
new opportunities and manage risks.
We are working to ensure that we have 
the right number of employees with 
the right skills in place to achieve risk 
and control excellence, and that we use 
our employee development programs, 
promotion and performance manage­
ment processes and compensation to 
reinforce and incentivize that excellence.
We will continue to invest in employees 
from all backgrounds and show empathy 
for our clients, colleagues and commu­
nities. As we make these changes and 
build
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” starting 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 and empower our employees 
to make ethical decisions and adhere to 
Citi’s standards of conduct.
Empowering Employees
We empower our employees to do 
what’s right by setting clear expecta­
tions through our Mission and Value 
Proposition, Code of Conduct and 
Leadership Principles, as well as by 
providing the tools our employees need 
to act ethically and clear information 
about the various
Keyword: governance
Corporate Governance webpage. That 
page also includes extensive disclosure 
about our practices pertaining to 
political contributions and lobbying 
activities, as well as a regularly updated 
list of our significant trade and business 
associations. Our disclosures and contri­
butions are overseen by the Nomination, 
Governance and Public Affairs 
Committee of our Board of Directors.
Managing Corruption 
and Tax-Related Risks
Anti-Corruption Activities
Through the work of a range of teams 
focused on Citi’s anti-corruption efforts 
— including Anti-Bribery, Anti-Money 
Laundering (AML), Sanctions and the 
Ethics Office — we work to counteract the 
many and varied threats of corruption 
facing the financial sector. Citi’s Chief 
Compliance Officer, who report
Keyword: governance
ronmental, social and governance (ESG) 
issues. In 2020, the COVID-19 pandemic 
led to an even greater reliance on digital 
technologies, which made safeguarding 
data and customer information that 
much more important.
Cybersecurity
Citi’s Chief Information Security Office 
(CISO) organization ensures that an appro­
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 
regular
Keyword: governance
by the Citi Global Privacy Governance 
Council. The program provides a frame­
work for managing privacy and confidenti­
ality risks for the company.
Citi’s Privacy and Confidentiality Policy 
articulates principles relating to the 
collection and processing of personal 
information, requiring, in part, that 
personal information only be collected 
and used as necessary for the perfor­
mance of the services offered and for the 
purposes disclosed in a privacy notice. 
Citi is transparent in our collection and 
use practices and offers customers 
choices with respect to how their 
personal information may be collected 
or otherwise used (as required by law), 
including opting out of marketing or 
other communications or reviewing and 
correcting information. Citi employees 
are
Keyword: governance
about our governance of ESG issues, 
including human rights, see the ESG 
Governance at Citi section.
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. Light blue rows indicate risks related to the Areas of High Caution defined in our ESRM Policy 
and trigger additional due diligence for project transactions. Additional context about our approach to mitigate these 
risks and related due diligence processes can be found throughout this report, in our Statement on Human Rights and 
in our Environmental and Social Policy Framework. 
Human Rights Risks
Citi’s Employees
Suppliers’ 
Employees
Customers 
and Clients
Those Affected by
Keyword: governance
governance and policies related to modern slavery, risk assessment and 
due diligence processes, and training. 
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
124
outcomes are consistent with Citi’s values. 
In these instances, we work to improve 
our clients’ awareness and business prac­
tices. In addition, where a transaction’s 
financial and legal structure allows it, we 
put loan covenants in place and monitor 
mitigation efforts through our ESRM 
systems and corrective action plans.
Due Diligence in Client 
Transactions
Citi has thousands of corporate and 
institutional clients. The UN Guiding 
Principles acknowledge the c
Keyword: governance
the framework and governance for Citi 
employees involved in supplier sourcing 
and selection decisions to foster inclusive 
processes and increase our roster of 
diverse suppliers. Additionally, the SCDIS 
Program works across our supply chain 
to enhance sustainability practices and 
mitigate social and environmental risks 
for all suppliers.  
In 2020, we made strides toward 
greater supplier diversity, including its 
relationship to our company’s Action 
for Racial Equity commitments. We 
continued our supplier capability building 
efforts despite the impact of COVID-19 
on in-person events, and we rolled out 
an improved and expanded Corporate 
Responsibility Questionnaire (CRQ), a 
supplier assessment tool that helps us 
evaluate the performance of suppliers in
Keyword: governance
• ESG Governance at Citi 
	• Our Material ESG Issues: Citi in a Global Context 
	• Financing the Low-Carbon Transition
	• Climate Risk
	• Human Rights > Our Salient Human Rights Risks
	• 2020 10-K pages 49-61
102-16 Values, principles, standards, 
and norms of behavior
	• About This Report
	• Risk Management
	• Citi Corporate Governance
102-17 Mechanisms for advice and 
concerns about ethics
Citi strictly prohibits any form of unlawful discrimination or harassment, as set forth in our widely disseminated 
and consistently enforced policies. Employees who believe they have been discriminated against or harassed are 
encouraged to report any incidents that violate Citi’s policies to their managers, another member of the employ­
ee’s management chain, Human R
Keyword: governance
102-18 Governance structure
	• ESG Governance at Citi 
	• Citi Corporate Governance
	• 2021 Proxy Statement pages 27-36
102-19 Delegating authority
	• ESG Governance at Citi 
	• Citigroup Board of Director’s Committee Charters
	• 2021 Proxy Statement pages 32-36
102-20 Executive-level responsibility 
for economic, environmental, and social 
topics
	• ESG Governance at Citi  
	• 2021 Proxy Statement pages 45-49
102-21 Consulting stakeholders on 
economic, environmental, and social 
topics
	• ESG Governance at Citi 
	• Stakeholder Engagement at Citi 
	• Climate Risk > Reducing Climate Risk in Our Financing
	• Risk Management > Public Policy
	• Human Rights > Our Commitment to Respect Human Rights
	• Human Rights > Learning and Engagement
	• 2021 Proxy Stateme
Keyword: governance
governance body and its committees
	• 2021 Proxy Statement pages 32-36
102-23 Chair of the highest governance 
body
The Chair of the Board is a nonexecutive, independent director.
	• 2021 Proxy Statement page 27
102-24 Nominating and selecting the 
highest governance body
	• Nomination, Governance and Public Affairs Committee Charter
	• 2021 Proxy Statement pages 45-49
102-25 Conflicts of interest
	• 2021 Proxy Statement pages 24, 40 and 100
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
136
Disclosure Number and Title Report Section or Other Documentation
102-26 Role of highest governance body 
in setting purpose, values, and
Keyword: governance
• ESG Governance at Citi 
	• 2021 Proxy Statement page 20
102-27 Collective knowledge of highest 
governance body
	• ESG Governance at Citi 
	• 2021 Proxy Statement pages 10-11
102-28 Evaluating the highest 
governance body’s performance
	• Corporate Governance Guidelines page 6
	• 2021 Proxy Statement pages 45-49
102-29 Identifying and managing 
economic, environmental, and social 
impacts
	• ESG Governance at Citi 
	• Stakeholder Engagement at Citi
	• Risk Management > Environmental and Social Risk Management
	• Human Rights > Our Commitment to Respect Human Rights
	• Human Rights > Respecting Human Rights in Our Financing Decisions
	• Nomination, Governance and Public Affairs Committee Charter
	• Risk Management Committee Charter
	• 2020 10-K pages 118-
Keyword: governance
• ESG Governance at Citi 
	• Risk Management > Environmental and Social Risk Management
	• Human Rights > Respecting Human Rights in Our Financing Decisions
	• Risk Management Committee Charter
	• Nomination, Governance and Public Affairs Committee Charter
	• 2020 10-K pages 66-68
102-31 Review of economic, 
environmental, and social topics
	• ESG Governance at Citi 
	• 2021 Proxy Statement page 34
102-32 Highest governance body’s role 
in sustainability reporting
Executive Vice President, Global Public Affairs
102-33 Communicating critical concerns
	• ESG Governance at Citi > ESG Governance
	• Citi Code of Conduct
	• 2021 Proxy Statement page 41-42
102-35 Remuneration policies
We compensate our executives fairly, based on individual and company performanc
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 
	• 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
	• Risk Management > Managing Corruption and Tax-Related Risks
	• Anti-Bribery Program Statement
	• Anti-Money Laundering Program
	• Citi Code of Conduct
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Keyword: governance
• ESG Governance at Citi 
	• Citi Code of Conduct
	• 2020 10-K pages 59-61, 291-298
103-3 Evaluation of the management 
approach
	• ESG Governance at Citi
	• 2020 10-K pages 59-61, 291-298
206-1 Legal actions for anti-competitive 
behavior, anti-trust, and monopoly 
practices
	• 2020 10-K pages 59-61, 291-298
GRI 302: Energy 2016
103-1 Explanation of the material topic 
and its Boundary
	• Our Material ESG Issues: Citi in a Global Context 
103-2 The management approach and its 
components 
	• ESG Governance at Citi 
	• Financing the Low-Carbon Transition
	• Sustainable Operations > Operational Footprint Goals
	• Citi’s 2025 Sustainable Progress Strategy
103-3 Evaluation of the management 
approach
	• Financing the Low-Carbon Transition > Transforming Our B
Keyword: governance
• ESG Governance at Citi
	• Financing the Low-Carbon Transition > Addressing Biodiversity Loss
	• Risk Management > Environmental and Social Risk Management
103-3 Evaluation of the management 
approach
	• Risk Management > Monitoring the Changing Risk Landscape
304-2 Significant impacts of activities, 
products, and services on biodiversity
	• Financing the Low-Carbon Transition > Addressing Biodiversity Loss
	• Risk Management > Environmental and Social Risk Management
	• Risk Management > Monitoring the Changing Risk Landscape
304-3 Habitats protected or restored
	• Risk Management > Engagement Leads to Improved Client Practices
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsib
Keyword: governance
• ESG Governance at Citi 
	• Climate Risk > Citi’s Commitment to Net Zero
	• Sustainable Operations > Operational Footprint Goals
	• Citi’s 2025 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 Operation
Keyword: governance
• ESG Governance at Citi
	• Sustainable Operations > Operational Footprint Goals
	• Citi’s 2025 Sustainable Progress Strategy
103-3 Evaluation of the management 
approach
	• Sustainable Operations > Operational Footprint Goals
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 Operations > Environmental Impact Report
GRI 308: Supplier Environmental Assessment 2016
308-1 New suppliers that were screened 
using environmental criteria
	• Responsible Sourcing
Keyword: governance
• ESG Governance at Citi
	• Our Ongoing Talent and Diversity Priorities
103-3 Evaluation of the management 
approach
	• Our Ongoing Talent and Diversity Priorities
401-1 New employee hires and employee 
turnover
	• Citi’s Global Workforce
401-2 Benefits provided to full-time 
employees that are not provided to 
temporary or part-time employees
	• Protecting the Health and Safety of Our People During COVID-19 > Expanding Benefits in a Pandemic
	• 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 
	• Protecting the Health and Safety of Our People During COVID-19
103-2 The management approach and its 
components 
	• ESG Governance a
Keyword: governance
• ESG Governance at Citi 
	• Our Ongoing Talent and Diversity Priorities > Retention and Development
103-3 Evaluation of the management 
approach
	• Our Ongoing Talent and Diversity Priorities > Retention and Development
404-2 Programs for upgrading 
employee skills and transition assistance 
programs
	• Our Ongoing Talent and Diversity Priorities > Retention and Development
404-3 Percentage of employees 
receiving regular performance and 
career development reviews
	• Our Ongoing Talent and Diversity Priorities > Learning and Evaluation
Contents 
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Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
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Disclosure Number and Title Report Section or
Keyword: governance
• ESG Governance at Citi 
	• Advancing Racial Equity
	• Our Ongoing Talent and Diversity Priorities
	• Human Rights > Our Commitment to Respect Human Rights 
	• Human Rights > Respecting the Human Rights of Our Employees
103-3 Evaluation of the management 
approach
	• Advancing Racial Equity 
	• Our Ongoing Talent and Diversity Priorities
405-1 Diversity of governance bodies 
and employees
	• Citi’s Global Workforce
	• Board of Directors
	• 2021 Proxy Statement page 28
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 
	• E
Keyword: governance
SG Governance at Citi 
	• Human Rights > Respecting the Human Rights of Our Employees
103-3 Evaluation of the management 
approach
	• Human Rights > Respecting the Human Rights of Our Employees
407-1 Operations and suppliers in which 
the right to freedom of association and 
collective bargaining may be at risk
	• Human Rights > Respecting the Human Rights of Our Employees
GRI 408: Child Labor 2016
103-1 Explanation of the material topic 
and its Boundary
	• Our Material ESG Issues: Citi in a Global Context 
	• Human Rights > Extending Respect for Human Rights Through Our Suppliers and Partners
	• Human Rights > Respecting Human Rights in Our Financing Decisions  
103-2 The management approach and its 
components 
	• ESG Governance at Citi 
	• Human Rig
Keyword: governance
• ESG Governance at Citi 
	• Human Rights > Extending Respect for Human Rights Through Our Suppliers and Partners
	• 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 and Partners
	• Human Rights > Respecting Human Rights in Our Financing Decisions
	• Responsible Sourcing > Supplier Engagement and Evaluation
409-1 Operations and suppliers at 
significant risk for incidents of forced or 
compulsory labor
We have not identified any operations as having sig
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
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Busi
Keyword: governance
• ESG Governance at Citi 
	• Human Rights > Our Commitment to Respect Human Rights
	• Human Rights > Respecting the Human Rights of Our Employees
	• Human Rights > Extending Respect for Human Rights Through Our Suppliers and Partners
	• Human Rights > Respecting Human Rights in Our Financing Decisions 
	• Citi Statement on Human Rights
	• Citi Requirements for Suppliers 
	• Citi Statement of Supplier Principles
	• Citi Modern Slavery Disclosures
103-3 Evaluation of the management 
approach
	• Human Rights > Respecting the Human Rights of Our Employees
	• Human Rights > Extending Respect for Human Rights Through Our Suppliers and Partners
	• Human Rights > Respecting Human Rights in Our Financing Decisions
	• Responsible Sourcing > Supplier Engagement and E
Keyword: governance
• ESG Governance at Citi
	• 2020: An Unprecedented Year
	• Risk Management > Our ESRM Policy
103-3 Evaluation of the management 
approach
	• 2020: An Unprecedented Year 
	• 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
	• Long-Term Community Priorities
	• Risk Management > Environmental and Social Risk Management
	• Human Rights > Learning and Engagement
	• Responsible Sourcing > Supplier Engagement and Evaluation
413-2 Operations with significant actual 
and potential negative impacts on local 
communities
	• Human Rights > Our Commitment to Respect Human Rights
	• Human Rights > Extend
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 
	• Risk Management > Serving Our Customers and Clients Responsibly
103-2 The management approach and its 
components 
	• ESG Governance at Citi
	• Risk Management > Serving Our Customers and Clients Responsibly
103-3 Evaluation of the management 
approach
	• Our Material ESG Issues: Citi in a Global Context 
	• Risk Management >
Keyword: governance
• ESG Governance at Citi 
	• Risk Management > Managing Corruption and Tax-Related Risks
	• Risk Management > Serving Our Customers and Clients Responsibly
	• 2020 10-K pages 66-69
103-3 Evaluation of the management 
approach
	• Risk Management > Managing Corruption and Tax-Related Risks 
	• Risk Management > Serving Our Customers and Clients Responsibly
	• 2020 10-K pages 66-69
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
146
Disclosure Number and Title Report Section or Other Documentation
419-1 Non-compliance with laws and 
regulations in the social and economic 
area
	• 2020 10-K pages 66-69, 116-117
	• 2020 Annual Report
Finan
Keyword: governance
Governance (ESG) Report. 
	• 2020: An Unprecedented Year > Investing in Our Communities
	• Action for Racial Equity
	• COVID-19: Responding to Vulnerable Communities
	• Long-Term Community Priorities > Affordable Housing Impact
	• Long-Term Community Priorities > International Inclusive 
Finance by The Numbers
(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 under­
banked customers
Quantitative
FN-CB-240a.3
In 2014, Citi launched the Access Account — a simple, checkless 
bank account with low or no monthly fees a
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
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 investigations by 
regulators, including
Keyword: governance
Governance 
Factors in 
Investment 
Banking & 
Brokerage 
Activities
Revenue from (1) underwriting, 
(2) advisory, and (3) securitiza­
tion 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
	• Risk Management > Transactions Receiving ESRM Review
	• Financing the Low-Carbon Transition
Citi also incorporates environmental criteria for transactions that 
contribute to our $250 Billion Environmental Finance Goal.
Description of approach to 
incorporation
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
	• Environmental and Social Policy Framework pages 12-22
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.
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diver
Keyword: governance
Governance (ESG) Report:
	• Citi at a Glance
External References: 
	• About Citi
	• Consumer Businesses
	• Institutional Businesses
	• 2020 10-K, pp. 4-5
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
154
Reporting and Self-Assessment 
Requirements 
High-Level Summary of Bank’s Response
References
1.2 Describe how your bank has 
aligned and/or is planning to align 
its strategy to be consistent with 
and contribute to society’s goals, 
as expressed in the SDGs, the Paris 
Agreement, and relevant national and 
regional frameworks.
     Many of our activities support the SDGs, including sustainable finance such 
as renewable ener
Keyword: governance
Resources, and Corporate Governance, as well as Sustainability, Government 
Affairs, Citi Foundation and other teams in Public Affairs. 
     In 2020, we engaged the following stakeholder groups: clients and custom­
ers, employees, suppliers, communities and NGOs, shareholders, government 
and regulators and other financial institutions. 
     Topics addressed included fossil fuel finance, climate change, diversity, ESG 
governance, sustainable development, inclusion, supplier capacity and sustain­
ability efforts, volunteer engagement, training, sustainability-linked finance and 
sustainable supply chain finance, materiality assessment for ESG reporting and 
financial disclosure practices.
Noteworthy outcomes: 
	• In 2021, we announced our commitment to net zero emissions b
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 imple­
mentation of the Principles.
     Our governance structures, policies and processes serve employee, client 
and community needs; promote a culture of accountability and ethical conduct 
across our firm; and support our commitment to address global challenges 
through our core business.
     Our Board plays a role in providing oversight of our efforts to ensure respon­
sible business practices.
Keyword: governance
For example, the Nomination, Governance and Public 
Affairs Committee (NGPAC) oversees Citi’s global ESG activities and perfor­
mance. This committee’s responsibilities include reviewing our policies and 
programs for sustainability, climate change, human rights, diversity and other 
ESG issues, as well as advising on engagement with external stakeholders. The 
Board and NGPAC receive reports from Citi’s Chief Sustainability Officer and 
the Head of Community Investing and Development on Citi’s progress and key 
issues on a periodic basis.
     The Ethics, Conduct and Culture Committee of the Board oversees manage­
ment’s efforts to foster a culture of ethics within the company and receives 
regular reports from senior management on the progress of those efforts. 
     The Risk
Keyword: governance
• ESG Governance at Citi
External References: 
	• Audit Committee Charter
	• Ethics, Conduct and Culture 
Committee Charter
	• Finance for a Climate-Resilient
Future II
	• Nomination, Governance and Public 
Affairs Committee charter
	• Risk Management Committee Charter
5.2 Describe the initiatives and 
measures your bank has implemented 
or is planning to implement to foster a 
culture of responsible banking among 
its employees. This should include 
a high-level overview of capacity 
building, inclusion in remuneration 
structures and performance manage­
ment and leadership communication, 
amongst others.
     We expect every Citi employee to adhere to our Code of Conduct, which 
includes a commitment to human rights, and to participate in relevant traini
Keyword: governance
• ESG Governance at Citi
	• Risk Management > Ethics and
Culture at Citi
External References:
	• Citi Code of Conduct 
	• Environmental and Social Policy 
Framework
	• Equator Principles
	• Ethics, Conduct and Culture 
Committee Charter 
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
161
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 implementa­
tion of the PRB, including: 
a) target-setting and actions to 
achieve targets set 
b) remedial action in the event of
Keyword: governance
• ESG Governance at Citi
	• Risk Management > 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 has been assigned to lead 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
Keyword: governance
Framework, and Risk Governance Framework
     We have joined and helped to pilot several relevant frameworks and meth­
odologies pertaining to climate change. This includes the PACTA methodology 
for climate scenario analysis of corporate lending portfolios and the PCAF 
framework for measuring and disclosing the emissions of lending portfolios and 
creating a global carbon accounting standard for financial institutions. In late 
2020, we partnered with Oliver Wyman and S&P Global Market Intelligence to 
lay the groundwork for a 2021 road test of their new Climate Credit Analytics 
tool, a climate scenario analysis and credit analytics model suite. 
     Citi is also part of the GISD Alliance, which is committed to accelerating the 
financing of the SDGs. In 2020, under
Keyword: governance
• ESG Governance at Citi
	• Citi and the Sustainable Development 
Goals
	• Action for Racial Equity
	• Long-Term Community Priorities
	• Risk Management > Ethics and
Culture at Citi
External References: 
	• Action for Racial Equity
	• Citi Social Bond Framework for 
Affordable Housing
	• Environmental and Social Policy 
Framework
	• Renewed, Recharged and Reinforced: 
Urgent Actions to Harmonize and 
Scale Sustainable Finance
	• 2025 Sustainable Progress Strategy
Contents 
ESG at Citi 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & Diversity 
Risk Management & Responsible Business 
Appendices
Citi 2020 ESG Report
162
Task Force on Climate-related Financial Disclosures Index
The following table indicates where readers can find information
Keyword: governance
Governance
a) Describe the Board’s oversight of climate-related 
risks and opportunities.
	• Finance for a Climate-Resilient Future II
	• Nomination, Governance and Public Affairs Committee Charter, page 4
b) Describe management’s role in assessing and 
managing climate-related risks and opportunities.
	• Climate Risk > Citi’s Approach to Managing Climate Risk
	• Finance for a Climate-Resilient Future II
Strategy
a) Describe the climate-related risks and opportunities 
the organization has identified over the short, medium 
and long term.
	• Financing the Low-Carbon Transition
	• Climate Risk
	• Citi’s Environmental and Social Policy Framework
	• Finance for a Climate-Resilient Future II
b) Describe the impact of climate-related risks and 
opportunit
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?
	• Risk Management > Code of Conduct
The following documents, which state Citi’s commitment to 
respect human rights and our expectations about the commit­
ment of others, are posted publicly: 
	• Citi Code of Conduct  
	• Citi Requirements for Suppliers   
	• Citi Statement of Supplier Principles  
	• Citi S
Keyword: governance
• ESG Governance at Citi
	• 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?
	• Risk Management > Code of Conduct  
	• Human Rights > Respecting the Human Rights of Our 
Employees
	• Citi Code of Conduct 
A2.4
How does the company make clear in its business 
relationships the importance it places on respect for 
human rig
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 > The Four Goals of Citi’s Action for 
Racial Equity
	• Long-Term Community Priorities > Expanding Affordable 
Housing
	• Advancing Racial Equity
	• Our On