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Responding department: Corporate Sustainability

Stock Exchange Symbol: (C:US)

Does your company have a publicly available commitment to respect human rights?

Yes, Citi has a stand-alone Statement on Human Rights, which references the UN Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, and the UN Guiding Principles on Business and Human Rights. Please provide the web-link for this policy commitment: [link]

Additional links: Citi Code of Conduct: [link]

Citi Statement of Supplier Principles: [link]

Environmental and Social Risk Management (ESRM) Policy: [link]

How are human rights governed in your company?

Respect for human rights is critical to Citi’s vision of enabling our customers, clients and global communities to make progress. In 2014, Citi updated its Statement on Human Rights (first published in 2007) to reflect current best practice, including stating our corporate responsibility to respect for human rights consistent with the UN Guiding Principles on Business and Human Rights. The Corporate Sustainability unit is responsible for the Statement on Human Rights and  coordinates as needed with the relevant business units that implement human rights related policies. Citi’s human rights approach is reviewed annually by the Nomination, Governance and Public Affairs Committee of the Board of Directors, per the committee charter ([link]).

How are human rights managed within your company?

Citi’s Corporate Sustainability unit has overarching responsibility for Citi’s Statement on Human Rights and advises business units on Citi’s human rights approach as needed. A number of other units, including Human Resources, procurement, Risk, Compliance and International Franchise Management have responsibility for specific policies related to human rights. During the process of updating our statement, we consulted a number of Citi employees from a wide variety of units. These colleagues looked critically at our statement through their unique perspectives to suggest improvements to best reflect our approach. The result is a comprehensive statement that reflects the values and universal standards that we follow and that we hope to encourage through our global businesses. An important element of our management of human rights is our due diligence related to client transactions covered by Citi’s ESRM Policy. A core component of our ESRM Policy is to ensure compliance with the Equator Principles (EPs), which were updated in 2013 to include robust and specific human rights standards. Specific social issues that may arise during our ESRM due diligence for client transactions include the protection of community health, safety and security; the protection of cultural property and heritage; land acquisition and involuntary resettlement; and Free, Prior and Informed Consent (FPIC) for projects adversely impacting indigenous peoples in emerging markets. Citi also looks at the otential for project-related conflict risk. In addition to certain safeguards related to the above issues, Citi’s ESRM Policy has a specific prohibition on harmful or exploitative forms of forced labor and child labor.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Citi engages with a broad range of stakeholders on a wide variety of issues. Our approach to stakeholder engagement and some of the issues discussed in 2013 is included in our Global Citizenship Report (p. 66-68, [link]). During the update of our Statement on Human Rights in 2014, we engaged with external human rights experts for feedback on the statement. We also engage directly with stakeholder groups to discuss priority human rights issues, concerns and trends on an as needed basis. In projects we finance, we ensure that our clients’ have done their own stakeholder engagement with local communities impacted by their activities, in keeping with our Equator Principles commitments.

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Workplace diversity / non-discrimination
  • Women

Actions on health

Below is a case study for a transaction where human rights related issues, in this case worker security, continued to be managed even after the transaction closed as part of our monitoring, due diligence and client engagement process. Monitoring an Equator Principles Transaction In 2012, Citi joined five other Equator Principles Financial Institutions (EPFIs) as a member of a $375 million project finance banking syndicate for a gas pipeline in Latin America. While financing closed in 2012, Citi and the other EPFIs continued to monitor the project’s environmental and social performance in 2013. An independent environmental and social consultant classified the project under Category B of the Equator Principles (EP) categorization system because it ran along the corridors of existing roads and transmission lines and therefore did not result in any resettlement or habitat conversion. However, part of the pipeline route traversed areas with a history of violence, leading to security concerns for construction crews. The EPFIs crafted the project’s Environmental and Social Action Plan (ESAP) to address this risk, setting a requirement for the project sponsor to update plans for construction worker safety and to ensure these plans complied with the Voluntary Principles on Security and Human Rights, a set of Principles which Citi supports. These updated plans were delivered to the EPFIs three months prior to start of construction as required by the ESAP and were found to satisfy EP requirements.

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Citi communicates internally and externally on its human rights commitments and performance in in the following publications and resources:

1. Citi reports annually on its human rights performance as well as on ethics and antibribery and corruption, which can be associated with human rights abuses. Our annual Global Citizenship reporting includes quantitative reporting on ESRM-covered transactions where we conducted due diligence on specific human rights risks: [link]

2. In Citi’s Statement on Human Rights, Citi publicly states its support for the key international human rights instruments, including the Universal Declaration on Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, and the UN Guiding Principles on Business and Human Rights. Citi’s Statement provides a summary of our policies and practices that help us fulfill our corporate responsibility to respect human rights across the value chain, to our employees, suppliers, clients and communities, and countries where we do business. [link]

3. Citi’s Code of Conduct sets forth a range of standards and principles, including, but not limited to, fair treatment, privacy and information security, bribery and corruption, money laundering, gifts and entertainment, and respect for human rights. [link]

4. Citi’s Environmental and Social Risk Management (ESRM) Policy includes guidelines for due diligence on a range of human rights issues related to projects that we finance: [link]

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

Citi maintains multiple channels through which employees and others may raise concerns, questions and grievances,including a global Ethics Hotline ([link]). In relevant ESRM-covered transactions, we also work with clients through our due diligence processes to ensure that access to grievance mechanisms and a process for seeking effective remedy are available. Under our ESRM Policy and the Equator Principles, community and human rights related issues are addressed, where relevant, in a client’s Environmental and Social Assessment documentation. In relevant ESRM-covered transactions, we work with clients through our due diligence processes to ensure that access to grievance mechanisms and a process for seeking effective remedy are available.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

Equator Principles: The Equator Principles are a risk framework for banks to use in determining, assessing and managing environmental and social risk for project finance and infrastructure projects. . The Equator Principles include specific reference to the “Guiding Principles on Business and Human Rights: Implementing the United Nations‘Protect, Respect and Remedy’ Framework”. In certain high risk situations, they also require the client to complement its Assessment Documentation with specific human rights due diligence.

Citi was a co-founder of the Equator Principles (EP) and continues to lead in their evolution and development by serving on the EP Association Steering Committee, including being elected and serving two elected terms as Chair of the Steering Committee (2010-2012). Considered the gold standard for managing environmental and social risk in project finance, the EP Association membership has grown from 10 initial members at the 2003 launch to more than 77 financial institutions from around the world. In adopting the Equator Principles, a financial institution agrees to provide loans only to those projects whose borrowers can demonstrate their ability and willingness to comply with comprehensive processes aimed at ensuring that projects are developed in a socially responsible manner and according to sound environmental management practices. UN Global Compact – Citi joined the Global Compact in 2010, and was the first major US-based bank to join the Compact. Citi hosted the annual Global Compact U.S. Network meeting in fall 2014.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

In early 2014, Citi updated its Statement on Human Rights to include a statement of support for the UN Guiding Principles. The process of updating the statement involved extensive internal engagement with colleagues in Human Resources, Procurement, Risk and International Franchise Management, among others, to discuss the Guiding Principles and the implications for Citi. We also engaged with external human rights experts to get input on our Statement on Human Rights prior to re-publishing it. In addition to these engagement processes, Citi has been active in discussions in the banking community on human rights, and has participated in the SHIFT Project’s convenings to discuss its Human Rights Reporting and Assurance Frameworks Initiative (RAFI).

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

With operations in more than 100 countries, Citi is well positioned to be a constructive influence for human rights in the countries where we do business. In some instances, however, the laws of some countries where we do business differ from some of the global standards of human rights noted above. In such cases, we seek ways to promote respect for human rights in a manner consistent with our own global internal policies and standards while remaining mindful of the local context. At the same time, we know that our example can help elevate the local standards in the markets where we do business. We carefully evaluate the strategy in each country in which we operate so that Citi can do business while maintaining high ethical standards.