Human Rights Citi’s rigorous human rights policies, standards and due diligence practices guide our business and lending decisions. We consistently engage with our employees, suppliers, peers and industry experts, as well as civil society organizations focused on our clients and the projects we finance, to advance the protection of human rights. Our Commitment to Respect Human Rights We are committed to respecting human rights wherever we do business. We engage human rights experts, clients and peers to support our efforts to respect human rights in line with the UN G uiding Principles on Business and Human Rights — a global framework for preventing and addressing the risk of adverse impacts on human rights linked to business activity. The UN Guiding Principles draw upon existing international human rights instru - ments whose principles Citi has endorsed, such as those in the UN Universal Declaration of Human Rights and the International Labour Organization’s (ILO) Core Conventions. To illustrate our imple - mentation of the UN Guiding Principles, we have mapped how this ESG Report aligns with the UN Guiding Principles Reporting Framework ( see index ). Citi r egularly u pdates o ur p olicies a nd practices t o s trengthen o ur h uman r ights due d iligence. D uring t he de velopment and su bsequent u pdates o f o ur Statement on H uman R ights , w hich w e fi rst a dopted in 2 007, w e en gaged i nternal a nd e xternal stakeholders t o h elp a ssess ou r a ctual and p otential h uman r ights i mpacts a nd to i dentify t he m ost s alient h uman r ights risks f aced b y o ur e mployees, w orkers connected t o o ur su pply c hain a nd individuals w ho m ight b e a ffected b y o ur clients’ o perations. Citi’s Environmental and Social Risk Management ( ESRM) P olicy, su mmarized in o ur Environmental and Social Policy Framework , guides our approach to assess - ing environmental and social risks related to financing o ur c lients’ b usiness a ctivities. F or more information about our ESRM Policy and our related due diligence processes, see t he Environmental and Social Risk Management s ection of this report. We regularly review and update our ESRM Policy to ensure that it reflects our most recent understanding of potential envi - ronmental and social risks. For example, during 2021, we updated the Policy to include a formal prohibition against financing for companies whose primary business is constructing or operating private prisons. Although we do not have such clients directly connected to private prisons, we decided to formalize this policy prohibition for the future in alignment with our Action for Racial Equity commitments. ELEVATING ENVIRONMENTAL JUSTICE CONCERNS FOR ENHANCED DUE DILIGENCE Over the last several years, there has been growing global acknowledgment that climate change is a human rights issue. In 2021, the UN Human Rights Council recognized the right to a healthy environment as a stand-alone human right. Citi has also recognized for many years the right to a healthy environment and the need to evaluate the potential environmental risks to communities surrounding the industrial developments we finance. For example, due diligence related to environmental justice concerns is critical for identifying projects with significant impacts to local communities from fossil-fuel-related activities, including extraction, refinement and transportation or air and water pollution due to heavy industry. Environmental justice is also important as we consider low-carbon projects with positive environmental benefits that might have negative impacts on local communities. For example, a dam construction project to create renewable hydro-electric power could threaten human rights if it is sited without consideration of the rights of Indigenous or other marginalized peoples. While we want to champion projects that help combat climate change, we need to keep our eyes open to other adverse impacts that may occur, particularly in relation to already marginalized communities. As of 2020, we formalized environmental justice as a specific risk within the Areas of High Caution section of our ESRM Policy that triggers enhanced due diligence. Contents ESGatCiti SustainableFinance SustainableProgress Equitable&ResilientCommunities Talent&DEI RiskManagement&ResponsibleBusiness Appendices CITI 2021 ESG REPORT 125