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 will encourage clients to follow up on allega- includes an assessment of the project sponsor’s has a global approach for handling customer tions and to have established processes to offer stakeholder engagement process, as well as its Serving Our complaints and concerns in a timely and remedy or to cooperate with authorities to make operational-level grievance mechanisms that effective manner, in line with our commitment sure effective remedy is provided. allow affected communities to raise concerns Customers to provide financial services responsibly and proactively with the project developers. treat customers fairly. For example, in 2022, Citi worked alongside other lending institutions to develop an action Engaging Stakeholders and Clients In 2022, we established a centralized Financial plan for an agricultural company in Asia. To ensure that we are living up to our commitment Inclusion and Racial Equity team within U.S. That plan required, in part, an audit of labor to respect human rights and to help identify Responsibly Personal Banking. This team is developing practices, which revealed that some of the emerging risks, we regularly communicate our targeted and integrated segment strategies, company’s workers were suffering indebtedness approach externally, engage with stakeholders driving seamless customer-centric execution, as the result of unfair recruiting practices. In on their issues of concern and work to advance and championing greater financial inclusion, response to the audit and concerns identified, respect for human rights more broadly. We have policies and systems in place to help racial equity and customer protection. This will the company changed its recruiting systems ensure that we treat customers responsibly help institutionalize racial equity within our to help address the risk of this type of unfair We led an Equator Principles Association collab- and fairly, such as our Code of Conduct and the business practices and policies. practice and reimbursed the affected workers. oration with Shift to develop enhanced guidance internal checks and balances we employ when for EP financial institutions (published in 2022) creating new products. We are also working to cultivate greater diversity for evaluating adequate grievance mechanisms and inclusivity in our marketing and commu- Listening to and access to remedy. Citi is also a member of the nications. For example, Citi collaborated with Stakeholders Shift Financial Institutions Practitioners Circle. Responsible Getty Images and the research firm Kantar to Through this group, we participate in workshops Marketing develop and launch 10 market-specific Diversity, and Addressing related to skill building on human rights due Equity and Inclusion (DE&I) Imagery Toolkits diligence for ESRM practitioners and deep dives to drive authentic and multifaceted depictions Grievances We offer our clients an array of products and of people in marketing and communications. into emerging salient human rights risks. This services based on their needs, wants and Each toolkit evaluates the local landscape of Reporting Mechanisms collaboration has helped us refine our approach preferences, while adhering to our internal the market, including demographics, trends in for Stakeholders to forced labor and human rights in the Asia policies and procedures as well as applicable imagery, areas of diversity that are often missing Pacific region. laws and regulations. We work diligently to in imagery and opportunities to combat stereo- The Ethics Hotline provides different channels clearly disclose all features and terms and types. We have made the toolkits available for for employees and any third party, including In addition, we continued to pay close attention conditions, including applicable fees and members of the general public, to report to human rights issues raised by stakeholders. free as a global public good via the Getty DE&I charges, for the products and services offered, Imagery Toolkit hub, so marketers and commu- concerns about unethical behavior to our Although banks are often under pressure to so that clients can select and use the products Ethics Office. In addition to internal and public disclose specific findings related to client nicators across brands and industries can better or services best suited to them. promote authentic visual representation in their facing websites that facilitate submission of projects, we are bound by legal requirements concerns, a telephone line is available 24 hours related to confidentiality that limit our ability New products are approved by cross-functional advertising. We have also hosted market-specific a day, seven days a week, with live operators to disclose such information without client committees that include senior executives from workshops with our agency partners and Citi who can connect callers to translators in consent. We must respect the requirements for Risk, Legal, our Independent Compliance Risk colleagues across marketing, communications multiple languages. client confidentiality in the banking sector, but Management team and other relevant units. and human resources, and commissioned we always implement our ESRM Policy to guide Citi also does periodic testing or monitoring of approximately 900 custom images to fill DE&I In addition, for project-related finance, we our client engagement to help identify solutions marketing materials and disclosures. In addition, imagery gaps in our internal image library for apply the Equator Principles to assess and to human rights challenges. Personal Banking & Wealth Management use in our global creative work. manage environmental and social risks. This Citi 2022 ESG Report Page 82