exo-is/governance-reporting-on-listed-companies huggingface dataset:
Keyword: governance
provide transparency into our environmental, social and governance (ESG) initiatives to 
respond to stakeholder requests, and to further enhance our collective understanding 
of ESG issues. Our approaches to the disclosures included in this report are different 
from those included in mandatory regulatory reporting, including under SEC regulations. 
Certain statements in this report may contain “forward-looking statements.” These state­
ments speak only as of the date they are originally made and are based on management’s 
current expectations and are subject to known and unknown risks, uncertainties, changes 
in circumstances, and assumptions that are difficult to predict and are often beyond our 
control. These statements are not guarantees of future results, occurrences, or perfor­
mance. Actual result
Keyword: bribe
Following our policies, including compliance with laws, anti-corruption and bribery, anti-competitive 
behavior, paying taxes and transparent political engagement
Business Model Resilience
Creating, developing and deploying a business model that can meet significant challenges such as 
natural disasters, health pandemics and global climate change
Climate Change
Reducing our own contribution to climate change while financing and facilitating projects that 
accelerate the transition to a low-carbon economy
Community Investment
Enabling greater cohesion with community stakeholders through public-private partnerships, 
monetary or in-kind donations, volunteer time or employee fundraising/match schemes
COVID-19
Adjusting our operations and long-term strategy to allow us to respond effectively to current and 
future global heal
Keyword: bribe
bribery topics 
	• Rolled out a new Climate Risk training for employees in Risk 
functions 
	• Featured stories on Citi’s intranet and in blog posts from Citi 
senior executives, employees and partners, highlighting our 
progress on ESG priorities 
	• Our Global Sustainability Network consists of employees from 
across Citi whose work directly relates to sustainability and ESG, 
to promote knowledge sharing and alignment on related activities 
	• Our Champions groups within our Banking, Capital Markets and 
Advisory; Global Markets; and Treasury and Trade Solutions 
businesses are comprised of employee volunteers. The Champions 
have quarterly global calls and monthly regional calls to share 
business updates and best practices for sustainable fin
Keyword: bribe
and Intelligence (GFCII), Anti-Bribery 
and Corruption, Anti-Money Laundering 
(AML) and Sanctions teams. Our Chief 
Compliance Officer, who reports directly to 
our CEO, provides regular reports on the 
performance of our compliance program, 
with regard to these areas, to our Board 
of Directors or a committee of the Board, 
as appropriate. Through our Financial 
Crimes unit, Citi works to prevent, identify 
and counteract the many and varied 
corruption-related risks that confront the 
financial sector.
For example, since its inception in 2018, 
Citi has been an active member of United 
for Wildlife’s Financial Taskforce, a collab­
oration between financial institutions and 
nongovernmental organizations to fight 
illegal wildlife trafficking. In 2021, Citi 
worked with Unit
Keyword: bribe
and Anti-Bribery and Corruption teams 
participated in a working group led by the 
Organisation for Economic Cooperation 
and Development (OECD) to develop a 
credible certification framework for eval­
uating infrastructure projects under the 
auspices of the OECD’s Blue Dot Network. 
Once implemented, this framework will 
set a standard to develop market-driven, 
transparent, financially sustainable 
development projects. The working 
group is made up of leaders and experts 
from the private sector, civil society and 
academia and is focused on the following 
core themes: investment efficiency and 
outcomes, environmental and social 
considerations, and transparency and 
integrity. Citi participants are shaping the 
framework by sharing their expertise in
Keyword: bribe
to AML and anti-bribery and corruption, 
including third-party and advisor/inter­
mediary risk management, procurement 
lobbying, controls, risk assessments, 
metrics, Financial Action Task Force guid­
ance and customer due diligence.
In 2021, Citi also contributed to a multi-
session workshop sponsored by the 
Terrorism, Transnational Crime and 
Corruption Center, in conjunction with 
the Association of Certified Anti-Money 
Laundering Specialists. Participants 
included several financial institutions 
and leading nonprofit organizations with 
expertise in environmental crimes, such 
as TRAFFIC and key U.S. government 
development agencies (e.g., USAID). The 
workshops were designed to address key 
aspects of global environmental crime 
and corruption. GFCII pro
Keyword: bribe
Anti-Bribery Program
Citi has policies, procedures and internal controls to comply with anti-bribery laws, and we conduct an annual bribery risk assessment of all global 
business lines. We provide our staff with anti-bribery training annually and supplement it with targeted training and communications as needed. For 
more information, see the Citi Anti-Bribery Program Statement, which is updated at least annually.
Anti-Money Laundering Program
Citi’s Anti-Money Laundering (AML) Program protects our clients, our franchise and the global financial system from the risks of money laundering 
and terrorist financing. The program includes more than 5,600 employees globally, including 225 designated AML Country Officers covering every 
Citi business, functio
Keyword: bribe
* This combined online training incorporates multiple anti-corruption efforts, including AML, sanctions and anti-bribery training. Numbers include all Citi staff who had completed the
2021 training as of December 2021. (Employees and contingent workers generally have 30 days to complete it.)
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
111
Taxation Policies 
and Standards
Citi does business in more than 160 
countries and jurisdictions, and maintains 
strong review and escalation processes 
that enable us to adhere to high standards 
of compliance with applicable tax laws. We 
are a current income taxpayer, both within 
and outside the United States. Our tax 
profile is consistent with the locations of 
our business o
Keyword: bribe
•	 Anti-Bribery Program Statement
205-2 Communication and training about anti-
corruption policies and procedures
•	 Our Transformation > Ethics and Culture at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery Program Statement
•	 Anti-Money Laundering Program
•	 Citi Code of Conduct
GRI 206: Anti-competitive Behavior 2016
103-1 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
•	 Citi Code of Conduct
•	 2021 10-K pages 66-69
103-3 Evaluation of the management approach
•	 ESG Governance at Citi
•	 2021 10-K pages 66-69
206-1 Legal actions for anti-competitive behavior, 
anti-trust, and monop
Keyword: bribe
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. 
Citi’s Anti-Money Laundering (AML) Program protects our clients, our 
franchise and the global financial system from the risks of money laundering 
and terrorist financing. The program includes more than 5,600 employees 
globally, including 225 designated AML Country Officers covering every Citi 
business, function and geographic area. 
Global Financial Crimes Investigations and Intelligence (GFCII) tackles 
financial crime and provides a globally consistent approach to the prevention 
and detection of risk. GFCII leverages pa
Keyword: bribe
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
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
171
United Nations Guiding Principles Reporting 
Framework Index
We have included information and disclosures in this report aligned with the United Nations Guiding Principles reporting framework. This reflects 
our support of the UN Guiding Principles on Business and Human Rights and our commitment to transparency and accountability reg
Keyword: corruption
Following our policies, including compliance with laws, anti-corruption and bribery, anti-competitive 
behavior, paying taxes and transparent political engagement
Business Model Resilience
Creating, developing and deploying a business model that can meet significant challenges such as 
natural disasters, health pandemics and global climate change
Climate Change
Reducing our own contribution to climate change while financing and facilitating projects that 
accelerate the transition to a low-carbon economy
Community Investment
Enabling greater cohesion with community stakeholders through public-private partnerships, 
monetary or in-kind donations, volunteer time or employee fundraising/match schemes
COVID-19
Adjusting our operations and long-term strategy to allow us to respond effectively to current and 
future
Keyword: corruption
labor, environment and anti-corruption, 
and take actions that advance societal 
goals. We report on our progress to 
implement the 10 UNGC principles.   
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress 
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
16
Stakeholder Engagement at Citi 
As a signatory to the Business 
Roundtable’s Statement on the 
Purpose of a Corporation, Citi 
is committed to ongoing and 
extensive engagement with our 
stakeholders. 
We subscribe to a broad stakeholder capi­
talism approach, believing that we are best 
able to create business value when we serve 
the interests of a wide array of stakeholders, 
including our shareholders. We made a 
deliberate effort to c
Keyword: corruption
practices to thwart corruption, 
address potential environmental 
and social risks in our portfolio, 
and safeguard data and customer 
privacy. These rigorous practices 
enable us to grow a successful, 
respected business that delivers 
the best possible results for 
our clients, customers and 
communities.
Managing Corruption 
and Tax-Related Risks
Anti-Corruption Activities
Citi’s Financial Crimes Unit 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 CEO, provides regular reports on the 
performance of our compliance program, 
with regard to these areas, to our Board 
of Directors or a committee of t
Keyword: corruption
corruption-related risks that confront the 
financial sector.
For example, since its inception in 2018, 
Citi has been an active member of United 
for Wildlife’s Financial Taskforce, a collab­
oration between financial institutions and 
nongovernmental organizations to fight 
illegal wildlife trafficking. In 2021, Citi 
worked with United for Wildlife, TRAFFIC 
and two telecommunications companies 
to create an illegal wildlife trade country 
threat profile outlining critical risk scenarios 
and indicators for countries in sub-Saharan 
Africa, beginning with Kenya as a pilot. 
In addition, during 2021, Citi’s GFCII 
and Anti-Bribery and Corruption teams 
participated in a working group led by the 
Organisation for Economic Cooperation 
and Developmen
Keyword: corruption
to AML and anti-bribery and corruption, 
including third-party and advisor/inter­
mediary risk management, procurement 
lobbying, controls, risk assessments, 
metrics, Financial Action Task Force guid­
ance and customer due diligence.
In 2021, Citi also contributed to a multi-
session workshop sponsored by the 
Terrorism, Transnational Crime and 
Corruption Center, in conjunction with 
the Association of Certified Anti-Money 
Laundering Specialists. Participants 
included several financial institutions 
and leading nonprofit organizations with 
expertise in environmental crimes, such 
as TRAFFIC and key U.S. government 
development agencies (e.g., USAID). The 
workshops were designed to address key 
aspects of global environmental crime 
and corruption. GFCII provided several
Keyword: corruption
* This combined online training incorporates multiple anti-corruption efforts, including AML, sanctions and anti-bribery training. Numbers include all Citi staff who had completed the
2021 training as of December 2021. (Employees and contingent workers generally have 30 days to complete it.)
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
111
Taxation Policies 
and Standards
Citi does business in more than 160 
countries and jurisdictions, and maintains 
strong review and escalation processes 
that enable us to adhere to high standards 
of compliance with applicable tax laws. We 
are a current income taxpayer, both within 
and outside the United States. Our tax 
profile
Keyword: corruption
illicit proceeds tied to corruption or human 
rights violations are effective ways to 
undermine their efforts.
Additionally, under our U.S. Commercial 
Firearms Policy, adopted in 2018, we 
require clients or partners that are 
U.S. firearms retailers or firearms 
manufacturers that sell through U.S. 
retail channels to adhere to a set of best 
practices regarding the sale of firearms. 
For retailers, these practices include 
selling firearms only to individuals who 
have completed a background check, not 
selling high-capacity magazines or bump 
stocks (which modify semiautomatic 
firearms to fire faster, at rates comparable 
to fully automatic firearms), and selling 
firearms to individuals under age 21 only if 
they have received firearms safety training 
(e.g., as part
Keyword: corruption
GRI 205: Anti-corruption 2016
103-1 Explanation of the material topic and its 
Boundary
•	 Our Material ESG Issues: Citi in a Global Context 
•	 Risk Management > Managing Corruption and Tax-Related Risks
103-2 The management approach and its 
components 
•	 ESG Governance at Citi 
•	 Risk Management > Managing Corruption and Tax-Related Risks
103-3 Evaluation of the management approach
•	 ESG Governance at Citi 
•	 Our Transformation > Ethics and Culture at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
205-1 Operations assessed for risks related to 
corruption
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery Program Statement
205-2 Communication and training about anti-
corruption policies and procedures
•	 Our
Keyword: corruption
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery Program Statement
•	 Anti-Money Laundering Program
•	 Citi Code of Conduct
GRI 206: Anti-competitive Behavior 2016
103-1 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
•	 Citi Code of Conduct
•	 2021 10-K pages 66-69
103-3 Evaluation of the management approach
•	 ESG Governance at Citi
•	 2021 10-K pages 66-69
206-1 Legal actions for anti-competitive behavior, 
anti-trust, and monopoly practices
•	 2021 10-K pages 296-303
GRI 302: Energy 2016
103-1 Explanation of the material topic and its 
Boundary
•	 Our Material ESG Issues: Citi in a Global Context 
Contents 
ESG at
Keyword: corruption
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Serving Our Customers and Clients Responsibly
•	 2021 10-K pages 66-69
103-3 Evaluation of the management approach
•	 Risk Management > Managing Corruption and Tax-Related Risks 
•	 Serving Our Customers and Clients Responsibly
•	 2021 10-K pages 66-69
419-1 Non-compliance with laws and regulations 
in the social and economic area
•	 2021 10-K pages 66-69, 116-117
•	 2021 Annual Report
FINANCIAL SERVICES SECTOR SUPPLEMENT
FS6 Percentage of the portfolio for business lines 
by specific region, size (e.g., micro/SME/large) and 
by sector
•	 2021 10-K pages 7-28
FS8 Monetary value of products and services 
designed to deliver a specific environmental 
benefit for each business line broken down by 
purpose
•	 Our $1 Tr
Keyword: corruption
For more information, please see Managing Corruption and Tax-Related Risks 
section of this report.
ESRM Training: 
Key risk and banking personnel are provided with annual training on our ESRM 
Policy to help them identify triggers for engagement with our specialist ESRM 
team. For more information, please see the ESRM Management section of this 
report. 
Serving Our Customers and Clients Responsibly: 
We have policies and systems in place to help ensure that we treat customers 
responsibly and fairly including our Code of Conduct, responsible marketing 
practices, our Treating Customers Fairly Principles, our Global Financial 
Access Policy and our Global Consumer Fairness Policy. 
Remuneration: 
The Personnel and Compensation Committee of the Board holds senior 
executives responsible, and
Keyword: corruption
Corruption and Tax-Related Risks
•	 Risk Management > ESRM Training
•	 Serving Our Customers and 
Clients Responsibly

External References:
•	 Citi Code of Conduct
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
165
Reporting and Self-
Assessment Requirements 
High-Level Summary of Bank’s Response
References
5.3 Governance Structure for 
Implementation of the Principles
Show that your bank has a 
governance structure in place for the 
implementation of the PRB, including: 
a) target-setting and actions to achieve 
targets set 
b) remedial action in the event of 
targets or milestones not being 
achieved or unexpe
Keyword: corruption
and anti-corruption.
“Citi’s ongoing support and participation in the United Nations Global Compact reinforce our ESG agenda and work to 
support our clients, colleagues and communities. From enabling the transition to a net zero economy, to supporting 
the equitable growth of underserved communities around the world, we’re committed to continue playing our part to 
build a better world.”
JANE FRASER, CHIEF EXECUTIVE OFFICER
UNGC Principle
Report section or other documentation
Human Rights
Principle 1: Businesses should support and 
respect the protection of internationally 
proclaimed human rights; 
and
•	 Human Rights > Our Commitment to Respect Human Rights
•	 Human Rights > Identifying Human Rights Risks in Transactions
•	 Citi Code of Conduct 
•	 Citi St
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
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
171
United Nations Guiding Principles Reporting 
Framework Index
We have included information and disclosures in this report aligned with the United Nations Guiding Principles reporting framework. This reflects 
our support of the
Keyword: tax
behavior, paying taxes and transparent political engagement
Business Model Resilience
Creating, developing and deploying a business model that can meet significant challenges such as 
natural disasters, health pandemics and global climate change
Climate Change
Reducing our own contribution to climate change while financing and facilitating projects that 
accelerate the transition to a low-carbon economy
Community Investment
Enabling greater cohesion with community stakeholders through public-private partnerships, 
monetary or in-kind donations, volunteer time or employee fundraising/match schemes
COVID-19
Adjusting our operations and long-term strategy to allow us to respond effectively to current and 
future global health crises
Data Security/Financial Product
Keyword: tax
(e.g., carbon taxes) 
relating to the sector’s 
carbon intensity; direct 
impact with noticeable 
economic implications 
on the sector through 
impacted asset valuation, 
increased expenditure 
(e.g., compliance costs) 
and/or revenue loss
Major impact to the 
sector expected due to 
expected regulatory/ 
policy changes relating 
to the sector’s carbon 
intensity; significant shift 
expected in the business 
model or economics of 
the sector impacting 
asset valuation, 
expenditures (e.g., 
increased compliance 
costs) and/or revenue
Technology
Outside of general 
modernization of tech­
nology, no technology 
shifts are expected for 
the sector
Minor impact to the sector 
expected from technology 
changes (i.e., impact only 
on a small subset of the 
sector,
Keyword: tax
at Unity with the mandate of supporting revenue generation through the New Markets Tax Credit Program and expanding their 
affordable housing work.
Lack of wealth generation opportunities and access to 
affordable housing continue to plague Black and Brown 
communities, and our mission is to create equitable access 
to capital to help fill that void. We’re thrilled to have the 
continued support and partnership of Citi, including their 
equity investment and embedded senior counsel, to help grow 
our business. Together, we can find more opportunities to drive 
economic value and impact in the communities we serve.” 
DR. KASE LAWAL, 
CHAIRMAN, UNITY NATIONAL BANK
“
* Federal Deposit Insurance Corporation, “2019 Minority Depository Institutions: Structure, Performance, and Social Impact.”  
** Federal Deposit Insurance Corpora
Keyword: tax
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 devel­
opment projects, reported approximately 
$5.64 billion of lending to finance afford­
able rental housing projects in 2021. In 
fact, for 12 consecutive years, Citi has been 
the No. 1 affordable housing lender in the 
United States, as published by 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
Keyword: tax
and Tax-Related Risks
Anti-Corruption Activities
Citi’s Financial Crimes Unit 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 CEO, provides regular reports on the 
performance of our compliance program, 
with regard to these areas, to our Board 
of Directors or a committee of the Board, 
as appropriate. Through our Financial 
Crimes unit, Citi works to prevent, identify 
and counteract the many and varied 
corruption-related risks that confront the 
financial sector.
For example, since its inception in 2018, 
Citi has been an active member of United 
for Wildlife’s Financial Tas
Keyword: tax
of compliance with applicable tax laws. We 
are a current income taxpayer, both within 
and outside the United States. Our tax 
profile is consistent with the locations of 
our business operations.
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 report­
ing, which is required under the OECD’s 
action plan to address base erosion and 
profit shifting. Our tax policy is overseen 
by our Chief Tax Officer, who reports to 
the Chief Financial Officer. Tax policies and 
related matters are reviewed by the Audit 
Committee of the Board of Directors.
Citi maintains a strong system of controls 
to facilitate reporting and with
Keyword: tax
Account Tax Compliance Act, and we are 
in compliance with the Common Reporting 
Standard in all applicable countries where 
local implementing guidance has been 
issued. Similarly, we have a firm-wide policy 
applicable to customer transactions under 
which Citi will only engage in transactions 
where there is a high degree of certainty 
that any tax aspects will be accepted by the 
respective taxing authorities.
For more information on how taxation 
impacts Citi, see page 128 of our 
2021 Form 10-K.
Public Policy
Being a responsible corporate citizen 
includes engagement in the political 
process as a part of our strong ESG prac­
tice. The potential impact of public policy 
on our business, employees, communities 
and customers is an important reaso
Keyword: tax
data localization, tax and financial reform. 
Guided by Citi’s Political Engagement 
Statement, company political activities are 
performed in compliance with applicable 
laws and regulations.
Under U.S. Federal Election Commission 
rules, Citi’s Political Action Committee (Citi 
PAC) pools the voluntary contributions of 
eligible employees to support U.S. political 
candidates and campaigns that support 
the financial industry and complementary 
pro-business policies. In 2021, we reviewed 
and strengthened our principles for deter­
mining future support by Citi PAC. The 
updated criteria include: 
 •
Support of business issues important 
to Citi 
 •
Position on a committee with jurisdic­
tion over policy issues important to Citi, 
or elected leadership position
Keyword: tax
•	 Risk Management > Managing Corruption and Tax-Related Risks
103-2 The management approach and its 
components 
•	 ESG Governance at Citi 
•	 Risk Management > Managing Corruption and Tax-Related Risks
103-3 Evaluation of the management approach
•	 ESG Governance at Citi 
•	 Our Transformation > Ethics and Culture at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
205-1 Operations assessed for risks related to 
corruption
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery Program Statement
205-2 Communication and training about anti-
corruption policies and procedures
•	 Our Transformation > Ethics and Culture at Citi
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Anti-Bribery Program Statement
•	 Anti-Money Laundering
Keyword: tax
•	 Risk Management > Managing Corruption and Tax-Related Risks
•	 Serving Our Customers and Clients Responsibly
•	 2021 10-K pages 66-69
103-3 Evaluation of the management approach
•	 Risk Management > Managing Corruption and Tax-Related Risks 
•	 Serving Our Customers and Clients Responsibly
•	 2021 10-K pages 66-69
419-1 Non-compliance with laws and regulations 
in the social and economic area
•	 2021 10-K pages 66-69, 116-117
•	 2021 Annual Report
FINANCIAL SERVICES SECTOR SUPPLEMENT
FS6 Percentage of the portfolio for business lines 
by specific region, size (e.g., micro/SME/large) and 
by sector
•	 2021 10-K pages 7-28
FS8 Monetary value of products and services 
designed to deliver a specific environmental 
benefit for each business line broken down by 
purpose
•	 Our $1 Trillion C
Keyword: tax
For more information, please see Managing Corruption and Tax-Related Risks 
section of this report.
ESRM Training: 
Key risk and banking personnel are provided with annual training on our ESRM 
Policy to help them identify triggers for engagement with our specialist ESRM 
team. For more information, please see the ESRM Management section of this 
report. 
Serving Our Customers and Clients Responsibly: 
We have policies and systems in place to help ensure that we treat customers 
responsibly and fairly including our Code of Conduct, responsible marketing 
practices, our Treating Customers Fairly Principles, our Global Financial 
Access Policy and our Global Consumer Fairness Policy. 
Remuneration: 
The Personnel and Compensation Committee of the Board holds senior 
executives responsible, and in turn
Keyword: tax
Corruption and Tax-Related Risks
•	 Risk Management > ESRM Training
•	 Serving Our Customers and 
Clients Responsibly

External References:
•	 Citi Code of Conduct
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
165
Reporting and Self-
Assessment Requirements 
High-Level Summary of Bank’s Response
References
5.3 Governance Structure for 
Implementation of the Principles
Show that your bank has a 
governance structure in place for the 
implementation of the PRB, including: 
a) target-setting and actions to achieve 
targets set 
b) remedial action in the event of 
targets or milestones not being 
achieved or unexpected neg
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
Contents 
ESG at Citi 
Sustainable Finance 
Sustainable Progress  
Equitable & Resilient Communities 
Talent & DEI 
Risk Management & Responsible Business 
Appendices
CITI 2021 ESG REPORT
171
United Nations Guiding Principles Reporting 
Framework Index
We have included information and disclosures in this report aligned with the United Nations Guiding Principles reporting framework. This reflects 
our support of the UN Guiding Principles on Business and Human Rights and our commitment to transparency and accountability regarding our hu­
man rights-related activities and p
Keyword: governance
& Governance Report
ESG at Citi
5 
Letter from Our CEO
8 
Our ESG Strategy
10 
ESG Governance at Citi
13 
Our Material ESG Issues: Citi in a Global Context
16 
Citi and the Sustainable Development Goals
17 
Stakeholder Engagement at Citi
Sustainable Finance
20 
Our $1 Trillion Commitment
Sustainable Progress
33 
Financing the Low-Carbon Transition
37 
Climate Risk and Net Zero
50 
Sustainable Operations
Equitable and Resilient Communities
62 
Our Commitment to Social Finance
66 
Action for Racial Equity
70 
Citi Impact Fund
72 
COVID-19 Relief and Recovery
75 
Affordable Housing
78 
Strategic Philanthropy
Talent and Diversity, Equity & Inclusion
81 
Return to Office and the Future of Work
83 
Diversity, Equity & Inclusion
97 
Using Our Corporate Voice
Keyword: governance
our environmental, social and governance (ESG) activities, performance and approach 
for calendar year 2021, focusing on the issues we have determined to be of material1 
importance from an ESG perspective, which is a broader standard than that used in our 
financial disclosures. 
This report has been prepared in accordance with the GRI Standards: Core option. We also used three relevant 
sector standards from the Sustainability Accounting Standards Board, the Principles for Responsible Banking, 
the United Nations (UN) Global Compact and the UN Guiding Principles on Business and Human Rights 
frameworks to guide our reporting. (See related indexes.) 
We have embedded the UN Sustainable Development Goals into relevant sections of the report where Citi plays 
a direct role in maki
Keyword: governance
ESG Governance at Citi
13 
Our Material ESG Issues: Citi in a Global Context
16 
Citi and the Sustainable Development Goals
17 
Stakeholder Engagement at Citi
ESG at Citi
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Appendices
CITI 2021 ESG REPORT
4
Letter from Our CEO
As I write this note in late April, a war is raging 
in Ukraine with significant global ramifications.
From the beginning, we have prioritized the 
humanitarian crisis, doing everything we can 
to help the people in Ukraine, including our 
own colleagues, whilst keeping our business 
there operating so we can support critical 
supply chains and the NGOs delivering essen­
tial aid.
Keyword: governance
and governance (ESG) strategy 
and approach to managing 
ESG issues and opportunities. 
Helping to close the racial wealth gap 
in the United States ranks among our 
top priorities, and in 2021, we made 
tremendous progress on our Action for 
Racial Equity commitment, working across 
our businesses to identify ways we can 
help address the racial wealth gap. As 
of November 2021 — one year into our 
three-year commitment — Citi and the Citi 
Foundation had already invested $1 billion 
in strategic initiatives to help close the 
racial wealth gap and increase economic 
mobility in the United States. We committed 
to conduct a third-party racial equity audit 
to evaluate our Action for Racial Equity 
goals and launched the Diverse Financial 
Institutions G
Keyword: governance
ESG Governance at Citi
Good governance is a fundamental 
principle at Citi, and we work to 
ensure that we are at the leading 
edge of best practices. We strive 
to maintain the highest standards 
of ethical conduct — reporting 
with accuracy and transparency 
and complying with the laws, rules 
and regulations that govern Citi’s 
businesses. 
Corporate Governance
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. 
Citi’s Board of Directors plays an 
important role in providing oversight of 
our efforts to ensure responsible business 
practices. For exa
Keyword: governance
Governance and Public Affairs Committee 
(NGPAC) oversees Citi’s global ESG 
activities and performance. Our Ethics, 
Conduct and Culture Committee reflects 
our commitment to promote a strong 
culture of ethical conduct. The Risk 
Management Committee also provides 
oversight of climate risk.
Standing committees of our Board include: 
 •
Audit 
 •
Ethics, Conduct and Culture 
 •
Executive 
 •
Nomination, Governance and 
Public Affairs 
 •
Personnel and Compensation
 •
Risk Management 
In addition, the Board formed the 
Transformation Oversight Committee, an 
ad hoc committee to provide oversight of 
management’s remediation of the issues 
identified in the consent orders with the 
Federal Reserve Board and Office of the 
Comptroller of the Currency.
Keyword: governance
about Citi’s corporate governance, includ­
ing our Board committee charters. See our 
2021 TCFD Report for details on our gover­
nance for climate change specifically. 
ESG Governance 
The NGPAC oversees our ESG activities. 
This committee’s responsibilities include 
reviewing our policies and programs for 
sustainability, climate change, human 
rights, diversity and other material ESG 
issues, as well as advising on engage­
ment with external stakeholders. For 
more information on the roles and 
responsibilities of this committee, see 
the Nomination, Governance and Public 
Affairs Committee charter. 
In July 2021, we formed a new Global ESG 
Council to provide a senior management 
forum for oversight of our ESG commit­
ments and ambition. The formation of 
the Council hi
Keyword: governance
governance of climate risk and integrate 
climate considerations into their priorities. 
In 2021, in addition to the announcement 
of our net zero commitment and the 
creation of our new Global ESG Council, we 
accomplished the following:
 •
Grew our dedicated Climate Risk team 
with additional expertise in credit risk, 
scenario analysis, stress testing and 
regulatory engagement
 •
Rolled out our first training module on 
climate risk
 •
Created the Natural Resources & Clean 
Energy Transition team to combine 
our Energy, Power and Chemicals 
businesses in order to assist our clients 
across these sectors as they transition
 •
Established our Net Zero Task Force, a 
cross-functional group to support the 
development and launch of our net zero 
plan
Keyword: governance
Citi’s governance and significant policies 
and programs for sustainability and 
climate change issues and advises manage­
ment on our engagement with investors 
and external stakeholders on these topics. 
For more information on the roles and 
responsibilities 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. For more information on the 
roles and responsibilities of this commit­
tee, please see our RMC Charter. 
In 2020 into 2021, the NGPAC reviewed 
and discussed investor and market devel­
opments related to net zero, including a 
shareholder proposal pertaining to net 
zero, and considerations for Citi as it delib­
erated on the implications of a
Keyword: governance
calls on a variety of governance, climate 
risk and environmental and social matters.
Senior managers from Global Public 
Affairs, Risk, Finance, Legal, Operations 
& Technology and various business units 
from our Institutional Clients Group also 
contribute expertise to address the chal­
lenges presented by climate change. 
Learn more in the Climate Risk section and 
in our 2021 TCFD Report.
Community Investing
Citi Community Investing and Development 
(CID) is an integrated team that works 
across Citi’s businesses and functions to 
catalyze positive social impact in commu­
nities around the world.  
CID comprises the following teams:
 •
Citi Impact Fund invests in “double 
bottom line” companies that are 
addressing societal challenges, 
including workforce developmen
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
* These are the topics identified during the materiality assessment we conducted in 2020.  
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CITI 2021 ESG REPORT
14
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
B
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 and other 
teams in Public Affairs. 
The table below includes examples of our 
recent stakeholder engagement efforts. 
AMERICA’S MOST JUST 
COMPANIES 
In recognition of our ESG 
performance, Citi was named 
among the Top 15 companies in 
JUST Capital’s 2022 rankings.
Stakeholder 
Group
How We Engage
Examples from 2021
Clients and 
Customers
	• Meetings to share Citi’s ESG perfor­
mance 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
	• Hosted a feedback session for stakeholders including clients, 
investors and
Keyword: governance
Relations and Corporate Governance 
teams 
	• Engaged in person and virtually with more than 20 individual 
investor groups as part of our annual ESG investor roadshow, 
focused on climate change and diversity—our fourth year of 
dedicated ESG engagement 
Government and 
Regulators
	• Meetings, conference calls, lobbying 
activities, industry associations, public 
policy forums, press conferences, con­
ferences and convenings
	• Membership on government councils and 
committees
	• Engaged with trade associations, such as the United States 
Chamber of Commerce, the Business Roundtable, and financial 
industry associations to help build the case for climate policy 
and supportive regulation
	• Member of the CEO Climate Dialogue, a cross-industry effort 
committed to advancing
Keyword: governance
of Governance, Strategy, Risk Management, 
and Metrics and Targets and includes our initial 
net zero plan for our Energy and Power loan 
portfolios.
PARTICIPATION IN NET ZERO FRAMEWORKS  
Citi is a member of multiple industry groups that enhance our understanding 
of — and ability to act on — climate-related issues. These groups include the 
Partnership for Carbon Accounting Financials (PCAF), the Net-Zero Banking 
Alliance (NZBA) and the Glasgow Financial Alliance for Net Zero (GFANZ). 
Learn more about these in our 2021 TCFD Report.
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37
Our Net Zero 
Commitment
In 20
Keyword: governance
management governance, processes and 
strategies. Although these two priorities 
differ in their primary focus, they are 
related to and reinforce each other, leading 
to mutual benefits. As we execute on 
our net zero commitment, the resulting 
reduction in financed emissions will help to 
reduce our climate transition risk.  
Citi’s net zero ambition builds on our 
commitment to the UNEP FI Principles for 
Responsible Banking, our leadership in 
climate disclosure in alignment with the 
TCFD and our ESRM Policy — specifically 
our Sector Approaches related to fossil 
fuels. Transparency and accountability are 
keys to success, and we will report annu­
ally on our net zero progress. 
Our commitment to net zero is significant, 
given the size and breadth of our
Keyword: governance
Governance — accountability, compensation links
Transition risk assessment
Physical risk assessment
Existing generation assets (carbon intensity analysis)
Existing reserves and assets
Comparative economics of production
Carbon-intensive asset retirement schedule
Resilience risks
PACTA Score
CA 100+ Score
World Benchmarking Alliance
Carbon Tracker Initiative
Transition Pathways Initiative
Sustainable development factors
Country/regional regulatory environment
The first step of our net zero plan involves engagement, client by client, to understand 
each client’s GHG emissions disclosure and their perspective and plans for transition. 
Additionally, we will review public disclosures, climate governance and the commit­
ments and actions they have taken t
Keyword: governance
Climate Change Governance 
Board of Directors
Steering 
Groups
EXECUTIVE MANAGEMENT TEAM
Management and 
Specialized Functions
Nomination, Governance and 
Public Affairs Committee
Risk Management Committee
CEO
Sustainability 
& ESG 
Team
Chief 
Sustainability 
Officer
Head of 
Climate 
Risk
Head of 
Environmental 
& Social Risk 
Management
(ESRM)
Banking, Capital Markets 
and Advisory (BCMA)
Global 
Markets
Climate 
Risk
Team
ESRM
Team
Sustainability 
& Corporate 
Transitions 
Team
Natural 
Resources & 
Clean Energy 
Transition 
Team
Sustainable 
Debt Capital 
Markets 
Team
Markets 
ESG 
Team
GLOBAL PUBLIC 
AFFAIRS
INSTITUTIONAL CLIENTS GROUP
INDEPENDENT RISK MANAGEMENT
Global Head of 
Public Affairs
Chief Risk Officer
CEO of Institutional 
Clients Group
The follow
Keyword: governance
ing climate change governance diagram illustrates our governance structure as of April 2022. For more 
about Citi’s governance related to climate risk, see our 2021 TCFD Report.
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43
EMPLOYEE TRAINING IN CLIMATE RISK 
We are working to create a culture of sustainability across our company and raise our colleagues’ literacy related to 
climate risk. In 2021, we created a new training module that covers key climate risk concepts, including the definition of 
climate risk, emerging climate risk standards, supervisory expectations, an overview of Citi’s efforts in this area and our 
initiatives to enhance climate risk manage
Keyword: governance
risk into Citi’s risk policies and governance 
frameworks, we have updated our ESRM 
Policy Sector Approaches for carbon-
intensive sectors to incorporate emerging 
best practices. One area where we have 
made significant progress is in our fossil 
fuel Sector Approaches for thermal coal 
mining and the generation of coal-fired 
power, which predated our net zero 
commitment. See the box on the right for 
more details on our targets and policy.
Portfolio Analysis 
and Measurement
Citi aims to understand the transition and 
physical risks that Citi and our clients are 
exposed to by conducting climate scenario 
analysis, measuring the GHG emissions 
associated with our financing portfolio 
and evaluating portfolio decarbonization 
pathways. During 2021, we conducted an 
analysis of our
Keyword: governance
GOVERNANCE
“
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Employee Network Listening Tour   
In 2021, we held our first ever “Voice of the People” listening tour to help us understand what our Affinities mean 
to our colleagues. More than 800 Citi employees attended in-person and virtual sessions to share their views on 
our Affinity Networks and to offer ideas about what we can do to make them more impactful. More than 80% of 
participants said they joined one of the Affinities for networking opportunities.
OVERVIEW
Goal
Learn about 
the DEI issues 
that are most 
important 
to you
KEY TAKEAWAYS
ADDITIONAL
Keyword: governance
Governance and 
Leadership
Putting the right teams and governance in 
place is critical to creating consistency in 
our approach across the firm and driving 
the ultimate success of our transformation.
Our Transformation Steering Committee, 
chaired by our CEO, sets the overall 
direction for our transformation efforts 
and communicates progress to our Board 
of Directors, as well as seeks input and 
feedback from the Board. In addition, 
one or more members of our Executive 
Management Team lead program groups 
that are central to our transformation. To 
encourage enterprise-wide engagement, 
each of these groups includes representa­
tion from across our businesses and func­
tions. The executives in charge of these 
programs are held accountable for
Keyword: governance
OUR DATA GOVERNANCE PROGRAM 
Data quality is one of the areas of focus for our transformation. To lead this 
effort, we have established a Data Governance Program to elevate our data 
governance and to help drive necessary improvements to our technology and 
processes. Our goal is to make it easier to locate, collect and use the infor­
mation our colleagues need to do their jobs and mitigate risk.
In 2021, we rewrote our Citi Data Governance Policy (which governs how we 
manage and use our data) to be more concise, provide greater clarity and 
embed accountability across the firm. The policy clarifies and simplifies the 
way we govern data, with a focus on achieving access to trusted, high-quality 
data in a controlled way.
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