Risk Management We employ robust policies and 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 F inancial C rimes U nit i ncludes t he Global F inancial C rimes I nvestigations and I ntelligence ( GFCII), A nti-Bribery and C orruption, A nti-Money L aundering (AML) a nd S anctions t eams. O ur C hief Compliance O fficer, w ho r eports d irectly t o our C EO, p rovides r egular r eports o n t he performance o f ou r c ompliance p rogram, with r egard t o t hese a reas, t o o ur B oard of D irectors o r a c ommittee o f t he B oard, as a ppropriate. T hrough o ur F inancial Crimes u nit, C iti w orks t o p revent, i dentify and c ounteract t he m any a nd v aried corruption-related r isks t hat c onfront t he financial s ector. For e xample, s ince i ts i nception i n 2 018, Citi h as b een a n a ctive m ember o f United for Wildlife’s Financial Taskforce , a collab - oration b etween fi nancial i nstitutions a nd nongovernmental o rganizations t o fi ght illegal w ildlife t rafficking. I n 2 021, C iti worked with United for Wildlife, TRAFFIC and t wo t elecommunications c ompanies to c reate a n i llegal w ildlife t rade c ountry threat p rofile o utlining c ritical ri sk s cenarios and i ndicators f or c ountries i n su b-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 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 standards, guidelines and practices related to AML and anti-bribery and corruption, including t hird-party a nd a dvisor/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 presentations and led discussions on the capability of financial institutions and the importance of information-sharing regarding typologies and red flags, to address crimes related to environmental, social and governance (ESG) issues. As an outcome of the roundtable discussions, TRAFFIC worked with GFCII to provide specialized training to Citi employees in our Europe, Middle East and Africa region. This included a series of webinars co-hosted by Citi, TRAFFIC and the Environmental Investigation Agency, a nongovernmental organization that investigates and campaigns against envi - ronmental crime and abuse. The training series focused on how to identify red flags in client onboarding and transactional activity to disrupt the flow of income generated by environmental crime. Contents ESGatCiti SustainableFinance SustainableProgress Equitable&ResilientCommunities Talent&DEI RiskManagement&ResponsibleBusiness Appendices CITI 2021 ESG REPORT 110