Identifying Human Rights Risks in Transactions Citi’s ESRM team screens transactions under the ESRM Policy for potential human rights risks. The specific types of human rights risks we screen for are outlined in the table below. Further data related to ESRM Policy screening can be found in the Environmental and Social Risk Management sectio n . When human rights risks are identified for a project-related transaction during screening, the ESRM team may either decline to approve the oppor - tunity outright, if the risks are deemed too high to address, or we may outline what further due diligence would be needed for the transaction to proceed. There are a number of reasons why initial opportunities may not move forward, including a client declining to move forward with our due diligence review requirements. If an opportunity progresses to the due diligence phase, our requirements include gaining access to project information that allows us to benchmark according to relevant standards, such as the IFC Performance Standards, UN Guiding Principles on Business and Human Rights, ILO Forced Labour Indicators and the Voluntary Principles on Security and Human Rights among other international human rights norms. In project-related lending this due diligence would be supported by a qualified independent consultant. In circumstances where a project is not aligned with applicable international standards, we will not approve financing until we are satisfied that the client has appropriate plans and capacity to mitigate project risks. For example, in 2021 we declined a project-related financing opportunity for an industrial agricultural project in Africa with concerns related to involun - tary resettlement, child labor and biodiversity impacts. For general corporate-level transactions (e.g., renewing revolving credit facilities, issuing corporate bonds) that have elevated human rights risks, we have less direct leverage than in project-related financing, but we review our clients’ policies and practices relevant to human rights issues to evaluate their ability to avoid, manage and minimize these risks. We also engage our clients to understand their implementation of those policies and whether they have appropriate staffing to manage these issues, and we review and encourage strong disclosures of human rights policies. Human Rights Risks Screened During Transaction Reviews Conflict Risk: Project-induced conflict risk, which may be tied to competition for resources or land Cultural Heritage: Properties and sites of archaeological, historical, cultural, artistic and religious significance; unique environmental features and cultural knowledge; intangible forms of culture embodying traditional lifestyles Environmental Justice: Potential environmental risks to historically marginalized communities, especially surrounding industrial developments Indigenous Peoples: Concerns regarding the extent to which Indigenous communities are consulted during project development and have consented to impacts to their land, livelihood and cultural heritage Labor Risks: Risks related to labor forces used in the construction of projects or other operations, including those associated with forced labor, child labor and human trafficking by project operators and their subcontractors Resettlement: Resettlement of local communities, including Indigenous groups, as necessary for project implementation; requires resettlement action plans and should include efforts to gain the free, prior and informed consent of Indigenous communities Security Practices: Concerns about how project sponsors engage with public or private security forces protecting project sites Water: Project-related impacts that hinder access to water or negatively affect water quality for local communities Contents ESGatCiti SustainableFinance SustainableProgress Equitable&ResilientCommunities Talent&DEI RiskManagement&ResponsibleBusiness Appendices CITI 2021 ESG REPORT 132