Providing Access to Remedy The UN Guiding Principles call on governments and companies to play their respective roles in ensuring that victims of human rights abuse have access to effec - tive remedy. Remedy can take many differ - ent forms, including apologies, financial or nonfinancial compensation, or efforts to prevent future harm through policy commitments and changes in operational practice. The purpose of remedy is to help make victims whole again or to restore them, as much as possible, to their lives and enjoyment of their rights before those rights were violated. Remedy can also help ensure that they and others will not suffer similar harm in the future. When we are made aware of a potentially severe a dverse hu man r ights im pact, our a pproach t o r emedy u sually i nvolves working w ith c lients t o e nsure t hey h ave t he right policies in place and that channels are available to enable victims to lodge griev - ances. In addition, in line with our ability to p rioritize a dverse im pacts b ased o n severity, we will encourage clients to follow up on allegations and to have established processes to offer remedy or to cooperate with a uthorities t o m ake su re e ffective remedy is provided. For example, in 2021, as t he r esult o f o ur p ortfolio r eview i n Malaysia related to forced labor and related client en gagement, s everal c lients h ave improved their practices in this area, or are in the process of doing so, by providing workers c ompensation f or r ecruitment f ees and c onstructing b etter ac commodations to house those working for them. Learning and Engagement Engaging Stakeholders To ensure that we are living up to our commitment to respect human rights and anticipate emerging risks, we regularly communicate our approach externally, engage with stakeholders on their issues of concern and work to advance respect for human rights more broadly. During 2021, we led an Equator Principles Association collaboration with Shift to develop enhanced guidance for EP finan - cial institutions for evaluating adequate grievance mechanisms and access to remedy. Citi is also a member of the Shift Financial Institutions Practitioners Circle, through which we participate in workshops related to skill building on human rights due diligence for ESRM practitioners and deep dives into emerging salient human rights risks. This collaboration has helped us refine our approach to forced labor and human rights in the Asia Pacific region. In addition, we continued to pay close attention t o h uman r ights i ssues ra ised by s takeholders r egarding s pecific i ndus - tries. I n 2 021, c oncerns w ere ra ised b y stakeholders relating to the oil and gas, manufacturing, technology and palm oil sectors. We engage with these industries directly t hrough c lient r elationships, s take - holder meetings and active participation in relevant initiatives. For instance, our partic - ipation in the Roundtable on Sustainable Palm Oil enables us to engage with multiple stakeholders c onnected t o t he p alm o il value chain, to improve the collective effort to reduce human rights risks associated with this commodity. In addition, our touch points during annual reviews allow us to evaluate human rights risks and manage - ment t hrough c lient en gagements. Although banks are often under pressure to disclose specific findings related to client projects, we are bound by legal requirements related to confidentiality that limit our ability to disclose such infor - mation without client consent. As a result, addressing requests for transparency is a balancing act between protecting the confidentiality of our clients’ information and disclosing information to stakeholders as appropriate to advance the protection of human rights. Reporting Mechanisms for Stakeholders Our Ethics Hotline provides a way for our employees, suppliers and other external stakeholders, including the public, to report concerns about unethical behavior to Citi’s Ethics Office. Stakeholders and whistleblowers can report violations to the Ethics Hotline using a 24-hour phone line, email address, fax line, website or physical mailing a ddress. In addition, for project-related finance, we apply the Equator Principles to assess and manage environmental and social risks. This includes an assessment of the project sponsor’s stakeholder engagement process, as well as its operational-level grievance mechanisms that allow affected communities to raise concerns proactively with the project developers. Employee Training Human rights content is integrated into the training we provide for the employees responsible for implementing our ESRM Policy and in our Code of Conduct train - ing, which is required of all employees. In recent years, we have developed a comprehensive training module on modern slavery, which we provided to our Resource Management Organization (our employees responsible for procurement and supply chain activities). In 2021, we updated that training with the goal of expanding it to other functions globally. Contents ESGatCiti SustainableFinance SustainableProgress Equitable&ResilientCommunities Talent&DEI RiskManagement&ResponsibleBusiness Appendices CITI 2021 ESG REPORT 133