discrimination, harassment and retaliation. Managers are expected to reinforce the importance of following our Leadership Principles, Code of Conduct and Mission and Value Proposition, as well as to encourage employees to speak up and raise any concerns about potential legal or ethical issues. Managers must properly resolve or promptly escalate concerns through appropriate channels, promote awareness of all resources available for reporting concerns and neither engage in, nor tolerate, retaliation of any kind. Escalating Business and Ethical Concerns Each member of our workforce plays a crit - ical role in escalating business and ethical concerns so that they can be addressed quickly a nd e ffectively. C iti’s Co de o f Conduct e mphasizes t he p rinciple t hat, when in doubt, employees should always err on the side of escalation. Our Code provides an overview of the types of misconduct and concerns that require escalation and the resources available to employees for prompt escalation of concerns, as well as a l ink t o t he fu ll C iti E scalation P olicy, which provides even more information for employees a bout e scalation r equirements and r esources. As part of Citi’s escalation resources, the Ethics Hotline p rovides m ultiple c hannels for employees and any third party, includ - ing members of the general public, to report c oncerns a bout u nethical b ehavior to Citi’s Ethics Office. In addition to internal and public-facing websites (enhanced in January 2022 with upgraded features) that f acilitate su bmission o f c oncerns, a telephone line is available 24 hours a day, seven days a week, with live operators who can connect to translators in multiple languages. We believe it is essential that individuals feel secure when raising a concern. All contacts to the Ethics Office and Ethics Office i nvestigations a re t reated a s confidentially a s p ossible, c onsistent w ith the need to investigate and address the matter, a nd su bject t o a pplicable l aws a nd regulations. Concerns may be raised either anonymously o r w ith a ttribution, su bject to applicable laws and regulations. Further, Citi prohibits any form of retaliation against anyone w ho r aises a c oncern or q uestion regarding e thics, d iscrimination o r h arass - ment m atters, as w ell as a gainst a nyone who p articipates i n a su bsequent i nvestiga - tion. Employees who engage in retaliation against a c olleague b ecause t hey r aised a concern or q uestion, a sked f or a r easonable accommodation, r eported a v iolation or was i nvolved i n a n i nvestigation a re su bject to disciplinary action, up to and including termination of employment or other rela - tionship with Citi. ASSESSING OUR CULTURE OF ETHICS Hearing from employees is one important way we assess the strength of ethics and accountability across our company. As part of Citi’s annual Voice of the Employee survey, we include an Ethical Culture Index to gather feedback from employees about the following items: • Comfort with reporting unethical practices without fear of reprisal • A feeling of accountability to identify and escalate issues • Confidence that Citi will act upon reported legal or ethical violations • A belief that colleagues act with integrity • Manager encouragement of ethical conduct even in the face of pressure In dex results stayed stable in 2021, with 91% of our employees responding positively to the index. We will continue to listen to our employees and raise the bar in this area. Staying on Top of Your Ethical Game Through our global Ethical Fitness Challenge, led by our Executive Management Team, we provided employees with the equipment they needed to get in their best ethical shape. Through this campaign, we released a series of eight modules over three years, incorporating senior leader videos, case studies and knowledge checks, as well as support to help managers guide conversations around each topic. Each part in the series highlighted a different element of ethical fitness, such as behavior rationalization, the importance of speaking up, misplaced loyalty and finding clarity in ethical situations. This campaign concluded in 2021, with a required training for all employees to consolidate and reinforce key themes presented over the course of the campaign. Contents ESGatCiti SustainableFinance SustainableProgress Equitable&ResilientCommunities Talent&DEI RiskManagement&ResponsibleBusiness Appendices CITI 2021 ESG REPORT 108