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409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labor We have not identified any operations as having significant risk for incidents of forced or compulsory labor. In addition, we do not directly source high-risk agricultural commodities, conflict minerals or other raw materials in significant amounts from suppliers in high-risk jurisdictions. While our own business operations and supply chain are not at high risk because of the nature of work in the financial services industry, our ESRM policy includes processes to evaluate corporate clients to determine if they present a high risk of forced labor or compulsory labor and we have taken appropriate mitigating steps. • Human Rights > Extending Respect for Human Rights Through Our Suppliers • Human Rights > Respecting Human Rights in Our Financing Decisions • Responsible Sourcing > Supplier Engagement and Evaluation GRI 411: Rights of Indigenous Peoples 2016 103-1 Explanation of the material topic and its Boundary • Our Material ESG Issues: Citi in a Global Context • Human Rights > Our Commitment to Respect Human Rights • Human Rights > Respecting Human Rights in Our Financing Decisions 103-2 The management approach and its components • ESG Governance at Citi • Human Rights > Our Commitment to Respect Human Rights • Human Rights > Respecting Human Rights in Our Financing Decisions 103-3 Evaluation of the management approach • Human Rights > Respecting Human Rights in Our Financing Decisions 411-1 Incidents of violations involving rights of indigenous peoples • Human Rights > Identifying Human Rights Risks in Transactions GRI 412: Human Rights Assessment 2016 103-1 Explanation of the material topic and its Boundary • Our Material ESG Issues: Citi in a Global Context • Human Rights > Our Commitment to Respect Human Rights • Responsible Sourcing 103-2 The management approach and its components • ESG Governance at Citi • Human Rights • Responsible Sourcing > Supplier Engagement and Evaluation • Citi Statement on Human Rights • Citi Requirements for Suppliers • Citi Statement of Supplier Principles • Citi Modern Slavery Disclosures 103-3 Evaluation of the management approach • Human Rights > Respecting the Human Rights of Our Employees • Human Rights > Extending Respect for Human Rights Through Our Suppliers • Human Rights > Respecting Human Rights in Our Financing Decisions • Responsible Sourcing > Supplier Engagement and Evaluation 412-1 Operations that have been subject to human rights reviews or impact assessments • Risk Management > Environmental and Social Risk Management • Human Rights > Identifying Human Rights Risks in Transactions • Responsible Sourcing > Supplier Engagement and Evaluation 412-2 Employee training on human rights policies or procedures • Risk Management > ESRM Training • Human Rights > Respecting the Human Rights of Our Employees • Human Rights > Employee Training 412-3 Significant investment agreements and contracts that include human rights clauses or that underwent human rights screening • Human Rights > Respecting Human Rights in Our Financing Decisions GRI 413: Local Communities 2016 103-1 Explanation of the material topic and its Boundary • Our Material ESG Issues: Citi in a Global Context • Our Commitment to Social Finance • Risk Management > Environmental and Social Risk Management 103-2 The management approach and its components • ESG Governance at Citi • Our Commitment to Social Finance • Risk Management > Our ESRM Policy • Citi’s Environmental and Social Policy Framework Contents ESGatCiti SustainableFinance SustainableProgress Equitable&ResilientCommunities Talent&DEI RiskManagement&ResponsibleBusiness Appendices ESGS ataC ius niblnG 147

Citi ESG Report - Page 147 Citi ESG Report Page 146 Page 148

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