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 Respecting the principle of nondiscrimination. Learn more We have established policies and practices that about our diversity, equity and inclusion efforts help us consider the respect of human rights. DISCLOSURES RELATED TO Human Rights of for employees in the Talent and Diversity, Equity For example, our anti-money laundering policies MODERN SLAVERY & Inclusion section. and practices support our ability to avoid Our Employees business transactions with potential adverse Our ESRM Policy prohibits financing any Freedom of Association impacts on human rights. However, there are project for which our due diligence identifies Citi has identified workplace discrimination Citi has employees who are represented by times when the link is less direct between our the use of forced labor, harmful or exploit- and threats to diversity and inclusion as salient unions and works councils in a number of financial services and human rights impacts. ative child labor, or when the relevant labor human rights risks for our company. As such, countries where we operate. In addition, a In these instances, we work to improve our forces have been subjected to human traf- respect for diversity and inclusion is a high clients’ awareness and business practices. In ficking. Each year, we disclose our approach priority wherever we operate. It can become portion of our employee population is covered to identifying and mitigating the risks of by collective bargaining agreements. We engage addition, where a transaction’s financial and modern slavery in our operations (including a particular concern in countries where there directly with our employees and through these legal structure allow it, and Citi has identified is no legal protection against discrimination client transactions) and in our supply chain. associations to discuss issues such as health a concern, we may put loan covenants in place These disclosures, for the UK and Australia, based on gender, gender identity, race, ethnicity, and safety, remuneration, work hours, training, and monitor mitigation efforts through our cover information about our governance age, religion, physical or mental disability or career development, work time flexibility and ESRM systems and corrective action plans. and policies related to modern slavery, risk medical condition, or sexual orientation, in equal opportunity. Information related to assessment and due diligence processes, addition to a range of other essential charac- freedom of association is communicated to Human rights concerns related to a particular and training. teristics inherent to identity and personhood. employees through various mediums, including client or transaction may be escalated to the Citi prohibits discrimination and harassment employee handbooks, our intranet and specialist ESRM team for review and consul- of our employees in all forms, regardless of employee emails. tation, regardless of sector or financial product. whether or not individual protections are legally Our ESRM team may further escalate human mandated in the countries and communities rights risks identified to relevant reputation risk where we operate. In fact, we know that even in Respecting Human forums, which might include Reputation Risk locations with anti-discrimination laws, there is teams, relevant regional or global committees, still a need for companies to ensure that they are Rights in Our or a designated human rights working group or doing their part to respect individual rights. Financing Decisions task force. We expect every Citi employee to adhere to our Code of Conduct, which includes a commitment Effectively evaluating human rights risks related to human rights, and to participate in relevant to our clients and the projects we finance is a training. Our Code of Conduct prohibits sensitive and important challenge. We work unlawful discrimination, harassment and other diligently to meet this challenge and respect behavior that infringes on individual rights. human rights. As stated in our Code of Conduct, Citi expects all employees, as well as suppliers, clients and community partners globally, to respect the Citi 2022 ESG Report Page 79

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