exo-is/governance-reporting-on-listed-companies huggingface dataset:
Keyword: corruption
Anti-corruption
Principle 10: Businesses should work against corruption in all its forms, including extortion and 
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
Sec
Keyword: corruption
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 geographic are
Keyword: corruption
> Managing Corruption 
and Tax-Related Risks
•	 Risk Management > 
Programs and Training to 
Combat Financial Crimes
•	 Risk Management 
> Environmental and 
Social Risk Management
•	 Serving Our Customers and 
Clients Responsibly 
> Treating Customers Fairly 
External References:
•	 Citi Code of Conduct
•	 2022 TCFD Report, 
pages 11-16
Citi 2022 ESG Report
Page 120
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
Reporting and S
Keyword: tax
construction lending, tax credit equity and 
permanent financing through our balance sheet.
Citi Community Capital, the bank unit through 
which we finance all types of affordable housing 
and community development projects, reported 
approximately $6 billion of lending to finance 
affordable rental housing projects in 2022. 
In fact, for 13 consecutive years, Citi has been 
the No. 1 affordable housing lender in the U.S., 
as published in Affordable Housing Finance.
At Citi, being a leader in the affordable housing 
industry does not just mean making debt 
and equity capital available to expand the 
U.S. affordable housing supply; it also means 
being an innovator and market leader. Over the 
past several years, we have worked with our 
clients to find new ways to
Keyword: tax
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, 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 organizat
Keyword: tax
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 tax profile. We 
supplement this transparency with additional 
country-by-country reporting, which is required 
under the OECD’s action plan to address base 
erosion and profit shifting.1 Tax management is 
overseen by our Chief Tax Officer, who reports to 
the Chief Financial Officer. It is reviewed with the 
Audit Committee of the Board of Directors.
For client-related tax matters, Citi maintains
Keyword: tax
Tax Compliance Act and the Common Reporting 
Standard in all applicable countries where local 
implementing guidance has been issued. Similarly, 
we have firm-wide requirements applicable to 
customer transactions, under which Citi will 
only engage in transactions where there is a high 
degree of confidence that the tax aspects will be 
accepted by the respective taxing authorities.
For more information on how taxation impacts 
Citi, see page 185 of our 2022 Form 10-K.
Programs and Training to Combat Financial Crimes
Number of Employees and Contingent Workers
Who Completed Our 2022 Financial Crimes 
Compliance Training (by Region)*
71,667
North America
45,056
Latin America
28,957
Europe, Middle East 
and Africa
69,185
Asia Pacific
1	Citibank
Keyword: tax
•	 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 Citi
•	 Citi Code of Conduct
•	 2022 10-K pages 60-63
206-1 Legal actions for anti-
competitive behavior, anti-trust,
Keyword: tax
•	 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
Policy commitment
A1
What does the company say pu
Keyword: tax
and Tax-Related Risks
•	 Risk Management > 
Programs and Training to 
Combat Financial Crimes
•	 Risk Management 
> Environmental and 
Social Risk Management
•	 Serving Our Customers and 
Clients Responsibly 
> Treating Customers Fairly 
External References:
•	 Citi Code of Conduct
•	 2022 TCFD Report, 
pages 11-16
Citi 2022 ESG Report
Page 120
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
Reporting and Self-Asses
Keyword: governance
ESG Governance at Citi
8	
Our Material ESG Issues
10	 Stakeholder Engagement at Citi
Sustainable Finance
12	
Our $1 Trillion Goal
22	 Financing the Low-Carbon Transition
23	 Financing Social Impact
Climate Risk 
and Net Zero
25	 Our Net Zero Commitment
30	 Our Approach to Managing 
Climate Risk
32	 Reducing Climate Risk in 
Our Financing.
Sustainable Operations
34	 Operational Footprint Goals
36	 Sustainable and Healthy Buildings
37	 Efficient Travel
37	 Managing Climate Risk in 
Our Operations
38	 Environmental Performance 
for Operations
Building Equitable and 
Resilient Communities
43	 Action for Racial Equity
45	 Citi Impact Fund
46	 Strategic Philanthropy:
The Citi Foundation
48	 Global Community Day
Talent and Diversity, 
Equity & Inclusion
49	 Our
Keyword: governance
and Governance Report
Citi 2022 ESG Report
Page 2
ESG at Citi
Sustainable Finance
Climate Risk & Net Zero
Sustainable Operations
Building Equitable & Resilient Communities
Talent & DEI
Responsible Business
Appendices
About This Report
This report illustrates how we bring our 
mission of enabling growth and economic 
progress to life through our business. We 
focus on issues that we have determined 
to be of material1 importance from an 
environmental, social and governance 
(ESG) perspective, which is a broader 
standard than that used in our financial 
disclosures. For more information, see 
A Note on Materiality and Forward-
Looking Statements.
When preparing this report, we referenced 
the Global Reporting Initiative Universal 
Standards, the Task For
Keyword: governance
Governance Report v1.4, February 2024
Citi 2022 ESG Report
Page 3
ESG at Citi
Sustainable Finance
Climate Risk & Net Zero
Sustainable Operations
Building Equitable & Resilient Communities
Talent & DEI
Responsible Business
Appendices
Letter from Our CEO
We are living through a period defined by 
unprecedented change. Every company I know 
is continually assessing its strategies, because 
it is abundantly clear that the geopolitical, 
social, environmental and technological devel­
opments of the next decade will have impacts 
for generations to come. 
At Citi, helping our clients navigate the 
challenges and embrace the opportunities of 
our rapidly changing world is fundamental to 
our mission of enabling growth and economic 
progress. Importantly, it
Keyword: governance
ESG Governance at Citi
ESG Across Citi
Our Material ESG Issues
Stakeholder Engagement at Citi
ESG at Citi
Citi’s mission is to serve as a trusted partner to our 
clients by responsibly providing financial services 
that enable growth and economic progress. Our 
core activities are safeguarding assets, lending 
money, making payments and accessing the 
capital markets on behalf of our clients.
As a global financial institution, Citi connects 
millions of people across countries and cities 
worldwide. For over 200 years, we have been 
helping our clients to meet some of the world’s 
toughest challenges and embrace its greatest 
opportunities. 
Our commitments, considerations and priorities 
around environmental, social and governance 
(ESG) issues are part
Keyword: governance
governance fundamentals contribute to the 
strength and performance of our company.
We believe that effective management of our ESG 
priorities helps to improve business resiliency, 
risk mitigation and value generation. The same 
is true for our clients, with whom we partner to 
support and finance their key ESG objectives.
With this approach in mind, we have identified 
ESG priorities related to climate change; 
sustainable finance; strengthening commu­
nities; racial equity and employee diversity, 
equity & inclusion, as discussed below and 
throughout this report.
In 2022, we made progress on advancing 
diversity, equity & inclusion (DEI) throughout 
our firm, exceeded our aspirational diversity 
representation goals for 2018 and set new, 
more i
Keyword: governance
ESG Governance at Citi
 Our Material ESG Issues
Citi 2022 ESG Report
Page 6
Sustainable Finance
Climate Risk & Net Zero
Sustainable Operations
Building Equitable & Resilient Communities
Talent & DEI
Responsible Business
Appendices
ESG at Citi
Citi 2022 ESG Report
Page 6
ESG Governance at Citi
ESG Across Citi
Our Material ESG Issues
Stakeholder Engagement at Citi
Some highlights of our approach for 
2022 include:
•	Expanding and realigning our Climate 
Risk team to be part of the Enterprise Risk 
Management function within Risk, further 
adding expertise and embedding climate 
within our risk management policies and 
practices
•	Building out our Clean Energy Transitions 
team (formed in 2021 and expanded in 2022 
to include Corporate Banking), which focus
Keyword: governance
Governance 
at Citi
Good governance is a fundamental principle 
at Citi, and we strive to be at the leading edge 
of best practices. We strive to report on our 
activities with accuracy and transparency and 
comply with the laws, rules and regulations 
that govern our businesses. Our corporate 
governance structures, policies and processes 
promote a culture of accountability and ethical 
conduct across our firm.
The Citi Board of Directors has ultimate oversight 
of our work to identify, assess and integrate 
ESG and sustainability-related risks and 
opportunities throughout Citi, including our 
climate-related work and talent and DEI efforts. 
The Board receives reports from key personnel on 
our progress and key issues on a periodic basis. 
Standi
Keyword: governance
•	Nomination, Governance and Public Affairs 
Committee
•	Risk Management Committee
•	Technology Committee
In addition to oversight by the full Board, the 
Nomination, Governance and Public Affairs 
Committee oversees the company’s ESG 
activity, including reviewing our policies and 
programs for sustainability, climate change, 
human rights, diversity and other ESG matters, 
as well as advising on engagement with external 
stakeholders. For more information on the roles 
and responsibilities of this committee, see the 
Nomination, Governance and Public Affairs 
Committee charter.
The Audit Committee has oversight over the 
controls and procedures related to Citi group 
level ESG and climate-related reporting. See the 
Audit Committee charter for more information o
Keyword: governance
ESG Governance at Citi
ESG Across Citi
Our Material ESG Issues
Stakeholder Engagement at Citi
The Risk Management Committee provides 
oversight of and reviews key risk policies, 
including those related to environmental, social 
and climate risk. For more information on the 
roles and responsibilities of this committee, see 
the Risk Management Committee charter.
Although not a standing committee of the Board, 
the Transformation Oversight Committee 
provides oversight of management’s remediation 
of the issues identified in the October 2020 
consent orders with the Federal Reserve Board 
and Office of the Comptroller of the Currency. 
The changes being made through the 
Transformation process will continue to improve 
our overall governance processes.
T
Keyword: governance
progress, climate data governance, updates 
on progress toward our net zero operations 
goal and our sector target-setting process for 
emissions reductions in our lending portfolio. 
Council members also oversaw our progress 
on workforce DEI representation goals and our 
Action for Racial Equity external audit results.
In 2022, we expanded oversight by our Board of 
Directors and codified alignment of ESG issues 
to certain Board Committees, such as our 
Net Zero Plan, climate risk management and 
the controls and processes around climate and 
ESG disclosures.
Ethics and Business Practices
We work to maintain the public’s trust by 
adhering to the highest standards of ethical 
conduct. We ask our colleagues to ensure that 
their decisions pass three tests: they are in ou
Keyword: governance
ESG Governance at Citi
ESG Across Citi
Our Material ESG Issues
Stakeholder Engagement at Citi
Our Material ESG Issues
In 2022, we conducted a materiality assessment to identify our most relevant (or “material”) reporting 
topics from an ESG perspective — which is a broader standard than the one used in our financial 
disclosures. (For more information, see A Note on Materiality and Forward-Looking Statements.) 
These topics, which were identified based on internal stakeholder interviews and external research, 
are provided in the material issues table below. Our materiality assessment incorporated a “double 
materiality” approach, meaning that it focused on understanding topics that could represent risks and 
opportunities to Citi, as well as topics thro
Keyword: governance
diversity and social justice; and business ethics and governance.
Material ESG Topics*	
Key Stakeholders**
Clients and 
Customers
Employees
Suppliers
Communities
and NGOs
Investors
Governments
and Regulators
Environmental
Biodiversity: Our role in supporting the number, genetic variability and variety of species essential to global and 
bioregional ecosystem resilience
Climate Change: Reducing our own contribution to climate change, while financing and facilitating projects 
that accelerate the transition to a low-carbon economy
Environmental Justice: Enacting environmental policies and practices that support the fair treatment and 
involvement of people of all races, national origins and income
Operational Footprint: Reducing direct impacts by managing energy use, water consumption, recycling, 
waste a
Keyword: governance
ESG Governance at Citi
ESG Across Citi
Our Material ESG Issues
Stakeholder Engagement at Citi
Material ESG Topics*	
Key Stakeholders**
Clients and 
Customers
Employees
Suppliers
Communities
and NGOs
Investors
Governments
and Regulators
Social (continued)
Racial Equity/Racial Justice: Implementing policies and programs that promote equal opportunity and 
treatment for people of all races and/or ethnicities
Talent Attraction, Retention and Development: Adopting an approach to recruiting, 
hiring, developing and retaining employees to create positive working conditions so that our employees can thrive
Workforce Diversity, Inclusion and Equal Opportunity: Enhancing our efforts to 
promote equal opportunities for all people and supporting a culture of diversi
Keyword: governance
Governance
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, partne
Keyword: governance
ESG Governance at Citi
ESG Across Citi
Our Material ESG Issues
Stakeholder Engagement at Citi
Examples of ESG Stakeholder Engagement in 2022
Stakeholder Group
How We Engage
Examples from 2022
Clients and 
Customers
•	 Meetings to share our ESG performance and to understand our clients’ 
approaches to climate change as well as managing environmental and 
social risks 
•	 Social media, including our Customer Service Twitter handle (@ AskCiti) 
•	 Customer satisfaction survey 
•	 Citi Blog 
•	 Supported clients in financing or facilitating environmental and social finance activities, including those 
that are counted toward our $1 Trillion Sustainable Finance Goal 
•	 Engaged with our clients to discuss how they evaluate carbon-intensive assets and discuss
Keyword: governance
ESG Governance at Citi
ESG Across Citi
Our Material ESG Issues
Stakeholder Engagement at Citi
Stakeholder Group
How We Engage
Examples from 2022
Governments and 
Regulators
•	 Meetings, briefings, letters, conference calls, hearings, industry associ­
ation events, public policy forums, public conferences and convenings 
•	 Membership on government councils and committees and industry 
association boards 
•	 Submitted comment letters on the SEC’s proposed climate disclosure rule and the the Basel Committee on 
Banking Supervision’s proposed principles for the risk management of climate-related financial risks 
•	 Became a founding member of the Biden-Harris administration’s Economic Opportunity Coalition, which aims 
to catalyze and align public and priva
Keyword: governance
Governance teams 
•	 Held Fall ESG investor roadshow to discuss our ESG-related performance
•	 Participated on panels at ESG-related conferences, discussing our sustainable debt issuance, climate 
strategy and cultural transformation 
•	 Added a new ESG section to the Investor Relations website 
Stakeholder 
Groups and 
Nongovernmental 
Organizations (NGOs)
•	 Working groups 
•	 Joint business ventures
•	 Industry groups, roundtables, workshops and events 
•	 Participated in a working group facilitated by RMI, formerly Rocky Mountain Institute, to design and develop 
the Sustainable STEEL Principles (SSP), a solution for measuring and disclosing the climate alignment of steel 
lending portfolios with 1.5˚C climate targets
Suppliers
•	 Meetings, calls
Keyword: governance
Governance, Strategy, Risk Management, and 
Metrics and Targets. It describes how Citi 
identifies and manages climate-related 
financial risks and opportunities, and it 
provides an update on progress toward our 
net zero commitment, including additional 
details about our interim 2030 emissions 
reduction targets. 
Our 2022 TCFD Report 
is our fourth stand-
alone TCFD report since 
2018, when we were the 
first major U.S. bank to 
publish a TCFD report.
1	 Financed emissions are the GHG emissions generated by the operations and entities that financial institutions lend money to or invest in.
PARTICIPATION IN 
FRAMEWORKS THAT SUPPORT 
NET ZERO
Citi is a member of multiple voluntary 
industry groups that enhance our 
understanding of — and ability to
Keyword: governance
An overview of our Net Zero Plan, including our approach to governance, implementation 
strategies and engagement, is outlined in the graphic below. 
GOVERNANCE
FOUNDATIONS
IMPLEMENTATION STRATEGY ENGAGEMENT STRATEGY
METRICS AND TARGETS
ESG Council
Investor and stakeholder
engagement
Regulator and policymaker 
engagement
Client engagement and review
Net Zero emissions by 2050
commitment for financing
Climate Risk
Steering Group
Board of Directors
and relevant Board
Committees
$1 Trillion Sustainable
Finance Goal
Internal policy development
and implementation
Internal training and
capacity building
Business unit restructuring
Net Zero emissions by 2030
commitment for operations
Climate and
Sustainability
Council
2030 sectoral targets
Absolute emissions and
emissions intensity metrics
(including baselines)
Sect
Keyword: governance
factors such as governance, scope (what 
emissions categories are included), capital 
expenditure plans and asset retirement 
schedules (where available/applicable), among 
others. The results of this analysis will help to 
guide our strategy and prioritization for client 
engagement. During 2022, we began piloting 
this tool for our Energy and Power portfolios, 
and we plan to have Net Zero Review Templates 
for additional sectors as we set more interim 
emissions reduction targets.
Developing Sector Targets
The PCAF methodology informs our calculation 
of absolute financed emissions. We calculate 
absolute financed emissions metrics in two ways: 
•	Committed funds: the capital available to 
a client for a certain use 
•	Outstanding funds: the funds actually 
drawn
Keyword: governance
In 2022, our climate governance structure 
continued to evolve as we advanced our Net 
Zero Plan and made progress on our climate 
goals. Highlights include the following:
•	Expanded our Board of Directors’ oversight 
by incorporating oversight for our climate 
disclosure risk and controls environment 
into the charter for the Board of Directors’ 
Audit Committee and climate risk oversight 
into the charter for the Risk Management 
Committee 
•	Expanded our Climate Risk team and 
realigned it to be part of the Enterprise Risk 
Management Function 
•	Expanded our Clean Energy Transitions team 
to include Corporate Banking 
•	Established a Head of Net Zero Operations 
to provide leadership and expertise for our 
net zero operations commitment
Climate Risk Training 
Achievi
Keyword: governance
Nomination, Governance and Public Affairs Committee
Audit Committee
Risk Management Committee
CEO
Board of Directors
Location & Realty Services
Environmental and Social Risk 
Management Team
Sustainability & ESG Team
Climate Risk Team
Banking, Capital Markets and Advisory (BCMA)
Global Markets
Sustainability 
& Corporate 
Transitions Team
Natural Resources 
& Clean Energy 
Transition Team
Sustainable Debt 
Capital Markets 
& Loans Team
Markets ESG 
Team
Institutional Clients Group
Enterprise Services
and Public Affairs
Independent Risk
Management
Head of Enterprise Services
and Public Affairs
Climate Risk Steering Group
Chief Risk Officer
Climate Risk Working Group
Climate and Sustainability Council
CEO of Institutional Clients Group
Climate Change Governance
Th
Keyword: governance
e following climate change governance diagram illustrates our governance structure as of April 2023. For more about our governance related to climate risk, see our 2022 TCFD Report.
Citi 2022 ESG Report
Page 32
ESG at Citi
Sustainable Finance
Sustainable Operations
Building Equitable & Resilient Communities
Talent & DEI
Responsible Business
Appendices
Climate Risk & Net Zero
Our Net Zero Commitment
Our Approach to Managing Climate Risk
Reducing Climate Risk in Our Financing
Challenges and 
Emerging Issues
We continue to be aware of evolving challenges 
and emerging issues, some of which include:
The availability and quality of climate-related 
data: As discussed elsewhere in this section, our 
reliance on data that is based on estimated or 
unverified figures makes precision difficult and 
creates challenges for many of our climate-
related activities, including scena
Keyword: governance
and governance. We will continue to advance 
our data improvement work in parallel with 
our decarbonization efforts, with the intention 
of incorporating additional insights as they 
become available.
Transition obstacles faced by developing 
countries: Less robust socioeconomic insti­
tutional capacity constrains implementation 
of low-carbon transition pathways across 
emerging markets. In addition, developing 
countries often have more limited capacity 
to transition, due to unequal and challenged 
access to climate finance. They also frequently 
lack the investment capital necessary to fund 
adaptation and mitigation solutions, including 
renewable energy and technology-driven clean 
energy alternatives. 
Increased regulatory requirements and lack o
Keyword: governance
Governance Strategy to drive improvements in 
our technology and processes. 
Our Transformation is underpinned by a funda­
mental reset of our approach to culture and 
talent. Aligned with our Leadership Principles, 
we have undertaken a multiyear, firm-wide 
program, designed to change the way we work by 
introducing everyday habits that all colleagues 
can adopt to make Citi a stronger, simpler and 
more enjoyable place to work. We are focused 
on ownership and building a culture where 
colleagues hold each other accountable. This 
ensures we establish and work within clear roles 
and responsibilities. 
The culture change program is supported by our 
senior leadership and includes communications, 
workshops and other resources to empower 
employees
Keyword: governance
governance framework, programs and efforts 
that embed our expectations for behavior 
throughout the organization. This starts with 
our Board of Directors. With oversight from the 
Compensation, Performance Management and 
Culture Committee, our senior leaders reinforce 
appropriate conduct and accountability within 
the organization, and empower our employees 
to make ethical decisions, escalate issues and 
adhere to our standards of conduct.
We expect managers to lead by example, inspire 
their employees to live our values, and create 
a work environment that is free from discrimi­
nation, harassment or retaliation. Managers are 
expected to promote awareness of resources 
available for reporting concerns, encourage 
employees to speak up about al
Keyword: governance
PROGRAM GOVERNANCE 
•	 Oversight from our Board of Directors 
•	 Regular reviews by regulators and by 
internal and external auditors 
•	 Globally managed by the Chief 
Enterprise Operations & Technology 
Officer and the Chief Information 
Security Officer 
•	 Chief Executive Officers of each 
business sector and region are 
responsible for implementation 
and compliance with program 
requirements
THIRD-PARTY CERTIFICATION
Certified compliance with the ISO 27001 
standard for our global information 
security and technology infrastructure 
programs 
TRAINING
Training provided annually to employees 
on how to properly handle and maintain 
the security and privacy of Citi’s and our 
clients’ assets and information
SECURE SOLUTIONS
Investment in and development
Keyword: governance
cover information about our governance 
and policies related to modern slavery, risk 
assessment and due diligence processes, 
and training.
GENERAL CORPORATE PURPOSES FINANCE
IN THE MINING SECTOR 
Along with several other banks, Citi is providing financing 
for a gold-mining company in a non-OECD country. This 
financing is not tied to a specific project, but rather will be 
used for general corporate purposes, including working 
capital and operational expenditures. Understanding and 
working to mitigate potential human rights concerns in this 
company’s operations has been an important element of 
our financing decision process. 
•	 Our role: The Citi ESRM team proposed including an envi­
ronmental and social requirement to the loan agreement 
that would provide a framework
Keyword: governance
governance committees and Board of Directors, 
to facilitate consistent, timely and appro­
priate identification, analysis and escalation of 
potential consumer fairness and reputational 
and franchise risk issues. 
We consider alignment with our Treating 
Customers Fairly principles when developing 
our employees’ variable incentive plans. For 
example, we use client satisfaction metrics, 
where available, along with other product-based 
metrics, to encourage achievement of business 
results that adhere to internal policies and our 
Code of Conduct. We also routinely evaluate 
incentive plans, training content, controls, 
monitoring results and oversight activities 
to maintain a sales force that delivers on our 
commitment to serving our customers
Keyword: governance
formal complaint handling and governance 
program to ensure proper controls around 
identification, capturing and monitoring 
of consumer complaints, including those 
submitted to regulators. A global complaint 
forum assesses complaint volume trends, 
issues and appropriate actions needed to 
address areas of potential risk. Allegations 
of discrimination or complaints that meet 
specific fairness triggers are escalated for 
review, to determine whether the allegations 
are substantiated. Additionally, complaints 
metrics are used to identify where there may be 
an emerging fairness risk related to a business, 
product or service, or to the adequacy of 
handling complaints.
We hold a Fair and Inclusive Banking off-site 
training with senior management from across 
the company to
Keyword: governance
2-9 Governance structure and 
composition
•	 ESG Governance at Citi
•	 Citi Corporate Governance
•	 2023 Proxy Statement pages 20–31, 32–36 
2-10 Nomination and selection of 
the highest governance body
•	 Nomination, Governance and Public Affairs Committee Charter
•	 2023 Proxy Statement pages 45–49
2-11 Chair of the highest 
governance body
The Chair of the Board is a nonexecutive, independent director.
•	 2023 Proxy Statement page 27
2-12 Role of the highest 
governance body in overseeing the 
management of impacts
•	 ESG Governance at Citi
•	 Our Material ESG Issues
•	 Our Approach to Managing Climate Risk
•	 Transforming Our Risk and Controls Environment
•	 Ethics and Culture at Citi
•	 Risk Management
•	 Audit Committee Charter
•	 Nomination, Gover
Keyword: governance
•	 ESG Governance at Citi 
•	 Citigroup Board of Director’s Committee Charters
•	 2023 Proxy Statement pages 32–36
Disclosure Number and Title
Report Section or Other Documentation
2-14 Role of the highest 
governance body in sustainability 
reporting
Our Board-level Audit Committee has oversight of controls and 
procedures related to Our ESG and climate-related reporting, including 
both voluntary disclosures and regulatory filings. The Global ESG 
Council provides senior management oversight of the workstreams 
discussed in the report.
•	 ESG Governance at Citi
•	 Our Material ESG Issues
2-15 Conflicts of interest
•	 2023 Proxy Statement pages 24–26, 37–40 and 98–99 
2-16 Communication of critical 
concerns
•	 ESG Governance at Citi
•	 Citi Code of Conduc
Keyword: governance
highest governance body
•	 ESG Governance at Citi 
•	 2023 Proxy Statement pages 10–11 and 52–62
2-18 Evaluation of the 
performance of the highest 
governance body
•	 Corporate Governance Guidelines page 6
•	 2023 Proxy Statement page 29
2-19 Remuneration policies
•	 ESG Governance at Citi > Remuneration
•	 Compensation Philosophy
•	 Compensation, Performance Management and Culture Committee 
Charter
•	 2023 Proxy Statement pages 63–66
2-20 Process to determine 
remuneration
•	 ESG Governance at Citi > Remuneration
2-21 Annual total compensation 
ratio
•	 2023 Proxy Statement pages 109-110
2-22 Statement on sustainable 
development strategy
•	 Letter from Our CEO
2-23 Policy commitments
•	 Ethics and Culture at Citi
•	 Risk Management > Environmental and So
Keyword: governance
•	 Citi Corporate Governance
•	 Environmental & Social Policies
Citi 2022 ESG Report
Page 89
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
Disclosure Number and Title
Report Section or Other Documentation
2-24 Embedding policy 
commitments
•	 ESG at Citi
•	 ESG Governance at Citi
•	 Ethics and Culture at Citi
•	 Risk Management > Environmental and Social Risk Management
•	 Citi Code of Conduct
•	 Environmental and Social Policy Framew
Keyword: governance
•	 Citi Corporate Governance
•	 Environmental & Social Policies
2-25 Processes to remediate 
negative impacts
•	 Stakeholder Engagement at Citi
•	 Reducing Climate Risk in Our Financing
•	 Risk Management > Environmental and Social Risk Management
•	 Human Rights > Our Commitment to Respect Human Rights
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
•	 Human Rights > Listening to Stakeholders and Addressing Grievances 
•	 Responsible Sourcing
2-26 Mechanisms for seeking 
advice and raising concerns
•	 Ethics and Culture at Citi
•	 Human Rights > Listening to Stakeholders and Addressing Grievances 
•	 Citi Code of Conduct
•	 Ethics Hotline
2-27 Compliance with laws and 
regulations
•	 2022 10-K pages 298–304
•	 2022 Annual Report
2-28 Membership a
Keyword: governance
•	 ESG Governance at Citi 
•	 Our Material ESG Issues
Disclosure Number and Title
Report Section or Other Documentation
GRI 201: Economic Performance 2016
201-1 Direct economic value 
generated and distributed
•	 2022 10-K pages 3–6
201-2 Financial implications and 
other risks and opportunities due to 
climate change
•	 Financing the Low-Carbon Transition > Transforming Our Business to 
Support a Low-Carbon Economy 
•	 Our Net Zero Commitment
•	 Our Approach to Managing Climate Risk
•	 Managing Climate Risk in Our Operations
•	 2022 TCFD Report
•	 2022 10-K pages 44–45 and 54–55
201-3 Defined benefit plan 
obligations and other retirement 
plans
•	 Citi Benefits Handbook
•	 2022 10-K pages 173–184
Citi 2022 ESG Report
Page 90
ESG at Citi
Sustainable Financ
Keyword: governance
405-1 Diversity of governance 
bodies and employees
•	 Global Workforce Data
•	 Board of Directors
•	 2023 Proxy Statement page 28
•	 2022 10-K pages 57-58 
GRI 407: Freedom of Association and Collective Bargaining 2016
3-3 Management of material 
topics
•	 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
3-3 Management of material 
topics
•	 Human Rights > Respecting Human Rights in Our Financing Decisions 
•	 Responsible Sourcing > Supplier Policies
408-1 Operations and suppliers 
at significant risk for incidents of 
child labor
We have not identifie
Keyword: governance
•	 ESG Governance at Citi 
•	 Risk Management > Public Policy
•	 Citi Political Engagement Statement
415-1 Political contributions
•	 Citi U.S. Political Contributions
Citi 2022 ESG Report
Page 93
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
Disclosure Number and Title
Report Section or Other Documentation
GRI 417: Marketing and Labeling 2016
3-3 Management of material 
topics
•	 Serving Our Customers and Clients Responsib
Keyword: governance
ronmental, 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
•	 2022 10-K pages 113-114
•	 2022 TCFD Report pages 54-56
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 does not disclose total losses as a result of legal proceedings associated with financial industry 
laws or regulations. However, Citi provides information regarding material legal matters, in accor­
dance with SEC requirement
Keyword: governance
and Governance Factors 
in Investment Banking & 
Brokerage Activities
Revenue from (1) underwriting, (2) advisory, 
and (3) securitization transactions incorpo­
rating 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 Goal
•	 Risk Management > ESRM Consultation Data
Description of approach to incorporation of 
environmental, social, and governance (ESG)
factors in investment banking and brokerage 
activities
Discussion and 
Analysis
FN-IB-410a.3
•	 Risk Management >
Keyword: governance
•	 ESG Governance at Citi
•	 Risk Management > Environmental and Social Risk Management
•	 Human Rights
•	 Citi Statement on Human Rights
Labor
Principle 3: Businesses should uphold the freedom of association and the effective recognition 
of the right to collective bargaining;
•	 Human Rights > Respecting the Human Rights of Our Employees
•	 Citi Statement on Human Rights
Principle 4: the elimination of all forms of forced and compulsory labor;
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
•	 Citi Statement of Supplier Principles
•	 Citi Statement on Human Rights
•	 Citi Modern Slavery Disclosures
Principle 5: the effective abolition of child labor; 

and
•	 Human Rights > Respecting Human Rights in Our Financing Decisions
•	 Citi St
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?
•	 Ethics and Culture at Citi > Code of Conduct
The following documents, which state our 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
•	 Citi St
Keyword: governance
Part A: Governance of Respect for Human Rights
Embedding respect for 
human rights
A2
How does the company demonstrate the importance it attaches to the implementation of its human rights commitment?
A2.1
How is day-to-day responsibility for human rights performance organized 
within the company, and why?
•	 ESG Governance at Citi
•	 Our Talent and DEI Strategy
•	 Risk Management > Safeguarding Data and Protecting Customer Information
•	 Risk Management > Environmental and Social Risk Management
•	 Human Rights > Respecting Human Rights in Our Financing Decisions 
•	 Responsible Sourcing
A2.2
What kinds of human rights issues are discussed by senior management 
and by the Board, and why?
•	 Risk Management > Escalation of High-Risk Transactions and Clients
•
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 relat­
ed to a salient issue and other business objectives, how are these tensions 
addressed?
•	 Risk Management > Environmental and Social Risk Management
•	 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?
•	 Financing Social Impact
•	 Action for Racial Equity
•	 Our Talent and DEI Strategy
•	 Risk Management > Safeguarding Data and Protecting Customer Information 
•	 Human
Keyword: governance
Corporate Governance, as well as Sustainability & ESG, Government Affairs and other teams in ESPA. 
A summary of the groups we have engaged with and the topics discussed is provided in the Stakeholder Engagement 
at Citi section of the 2022 ESG Report. We also highlight our climate-related engagement with clients and trade 
associations in our 2022 TCFD Report. 
2022 ESG Report
•	 Stakeholder Engagement 
at Citi
External References
•	 2022 TCFD Report, 
pages 29, 33-37
Principle 5: Governance & Culture
We will implement our commitment to these Principles through effective governance and a culture of responsible banking
5.1 Governance Structure for Implementation 
of the Principles
Does your bank have a governance system in place that incorporates 
the PRB?
Keyword: governance
Please 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 the effective implementation of the Principles. This includes 
information about 
•	 Which committee has responsibility over the sustainability strategy 
as well as targets approval and monitoring (including information 
about the highest level of governance the PRB is subjected to),
•	 Details about the chair of the committee and the process and 
frequency for the board having oversight of PRB implementation 
(including remedial action in the event of targets or milestones not 
being achieved or unexpected negative impacts being detected), 
as well as 
•	 Remuneration practic
Keyword: governance
We track our progress toward our targets, goals and commitments and provide reports to the Nomination, Governance 
and Public Affairs Committee (NGPAC) and/or the full Board of Directors. The Chief Sustainability Officer and Head of 
Community Investing and Development periodically report to the Board on progress made in achieving our targets, goals 
and commitments, as applicable. Reports are also provided to the Global ESG council on a periodic basis for progress 
toward our Action for Racial Equity commitments, $1 Trillion Sustainable Finance Goal and net zero commitment. For 
further details on our ESG governance structure, please see pages 6 to 7 of our 2022 ESG Report. 
For details on the remuneration practices linked to sustainability targets, please refer to the Remuneration section on 
page 7 of our 2022 ESG Report.  
Note: Our governance pro
Keyword: governance
•	 ESG Governance at Citi 
> Remuneration
External References
•	 2022 TCFD Report, 
pages 11-16
•	 Action for Racial Equity 
Year Two Progress Report
•	 Action for Racial Equity - 
External Audit Report
Citi 2022 ESG Report
Page 119
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
Reporting and Self-Assessment Requirements 
Response
Links and References
5.2 Promoting a culture of responsible banking:
Describe the initiatives a
Keyword: governance
•	 ESG Governance at Citi 
> Remuneration
•	 Ethics and Culture at Citi
•	 Risk Management 
> Managing Corruption 
and Tax-Related Risks
•	 Risk Management > 
Programs and Training to 
Combat Financial Crimes
•	 Risk Management 
> Environmental and 
Social Risk Management
•	 Serving Our Customers and 
Clients Responsibly 
> Treating Customers Fairly 
External References:
•	 Citi Code of Conduct
•	 2022 TCFD Report, 
pages 11-16
Citi 2022 ESG Report
Page 120
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 Comp
Keyword: governance
existing grievance mechanism, as well as the governance structures 
you have in place to oversee these risks.
Please refer to the description of our ESRM policy in section 3.1 of this index. 
The ESRM policy – including the due diligence processes – is summarized publicly in our Environmental and Social Policy 
Framework. We also discuss updates to, and implementation of, the policy on pages 71 to 76 of the 2022 ESG Report. 
2022 ESG Report
•	 Risk Management 
> Environmental and Social 
Risk Management
External References:
•	 Environmental and Social 
Policy Framework
Self-assessment summary 
Does the CEO or other C-suite officers have regular oversight over the implementation of the Principles through the bank’s governance system? 
  Yes*   
  No
Does the governance system entail structures t
Keyword: governance
*Our governance processes provide for oversight of the implementation of our key initiatives and targets. We note that while there is oversight on initiatives that align with the goals of the Principles, the Principles themselves 
are not specifically discussed in review of the issues by these individuals.
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 Assurance
Has this publicly disclosed information on your PRB commitments 
been assured by an independent assurer?
  Yes 
 
  Partially 
 
  No
If applicable, please include the link or description