ESG at Citi Sustainable Finance Climate Risk & Net Zero Sustainable Operations Building Equitable & Resilient Communities Talent & DEI Responsible Business Appendices Transforming Our Risk and Controls Environment Ethics and Culture at Citi Risk Management Human Rights Serving Our Customers and Clients Responsibly Responsible Sourcing interfaces to provide better guidance for those relationships, referrals to law enforcement reported a violation or were involved in an inves- Our GFCII team works to prevent, identify and submitting concerns and to improve mobile or governmental authorities, employee tigation are subject to disciplinary action, up counteract the many and varied corruption- device accessibility for the web platform. communications, additional training, control to and including termination of employment or related risks that confront the financial sector. enhancements, and changes to Citi policies, other relationship with Citi. Select examples of our partnerships in 2022 All contacts to the Ethics Office and Ethics business processes and procedures. include: Office investigations are treated as confiden- tially as possible, consistent with the need to Citi prohibits any form of retaliation against • United for Wildlife: Citi works with investigate and address the matter and subject anyone who raises a concern or question government agencies and nongovern- to applicable laws and regulations. Concerns regarding ethics, discrimination or harassment Risk mental organizations (NGOs) alongside may be raised either anonymously or with matters, as well as against anyone who partici- other financial institutions to help fight attribution. All concerns are investigated and, pates in a subsequent investigation. Employees Management illegal wildlife trafficking. We participate in where substantiated, lead to meaningful action who engage in retaliation against a colleague the financial taskforce as well as regional within our organization, which could include because they raised a concern or question, chapters in East Africa; the Middle East and disciplinary action, termination of vendor asked for a reasonable accommodation, North Africa; North America; and Hong Kong. We employ robust policies and practices In 2022, we worked through the Hong Kong to detect and prevent corruption, address chapter in support of legislation that elevates potential environmental and social risks in our wildlife-related trafficking to a serious crime portfolio, and safeguard data and customer and helped develop a financial sector toolkit Assessing Our Culture of Ethics Transparency for Employees privacy. These rigorous practices enable us to and threat profile for the region. grow a successful, respected business that Hearing from employees is one important way we Annual Ethics Hotline Summary delivers the best possible results for our clients, • Trust in Business Initiative: In 2022, Citi assess the strength of ethics and accountability To reinforce how raising concerns leads to customers and communities. joined global leaders from the private across our company. As part of our annual Voice meaningful action within Citi, the Citi Ethics and public sectors to discuss and provide of the Employee survey, we include an Ethics Office annually provides all employees with feedback on the Organisation for Economic Index to gather feedback from employees about a summary of the types of concerns received by Managing Co-operation and Development’s (OECD) the following items: the Citi Ethics Office, including those resulting Infrastructure Anti-Corruption Toolbox, • Comfort with reporting unethical practices in corrective actions. Corruption and which is designed to build trust and account- without fear of reprisal Spotlight on Ethics Tax-Related Risks ability in infrastructure. • A feeling of accountability to identify and Through this quarterly communication to • Additional activities: During the year, we escalate issues employees, we continue to share the results Anti-Corruption Activities engaged multiple nonprofits and NGOs • Confidence that Citi will act upon reported legal of Ethics Office investigations, to reinforce to to combat financial crime, including the or ethical violations our workforce that concerns are investigated The Citi Global Financial Crimes Compliance Polaris Project, Survivor Inclusion Initiative, • A belief that colleagues act with integrity and to highlight commonplace areas where Team includes the Global Financial Crimes DeliverFund, the International Centre for ethical lapses can occur. The Spotlight includes Investigations and Intelligence (GFCII), Missing & Exploited Children’s Financial • Manager encouragement of ethical conduct corrective actions that resulted from described Anti-Bribery and Corruption, Anti-Money even in the face of pressure Ethics Office investigations to again reinforce Laundering (AML) and Sanctions teams. Our Coalition Against Child Sexual Exploitation, that speaking up leads to meaningful action. Chief Compliance Officer, who reports directly the Royal United Services Institute’s Future of In 2022, 93% of our employees responded posi- Financial Intelligence Sharing program and the tively to the index, compared with 91% in 2021. to our General Counsel, provides regular United Nations Office on Drugs and Crime. We will continue to listen to our employees and reports on our performance in these areas, to raise the bar in this area. our Board of Directors or a committee of the Board, as appropriate. Citi 2022 ESG Report Page 67