Citigroup

Red LineText of policiesCommentsScore
Regulatory requirements
Ensure LegalitySustainable Forestry Standard
Citi will not make loans to companies whom we know to be in violation of local or national laws regarding illegal logging.

Environmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC Performance Standards and sector-specific Environmental, Health and Safety (EHS) Guidelines, which address topics including, but not limited to, pollution prevention and abatement, and worker and community health and safety.
Policy Prohibitions
Citi does not do business with companies when our due diligence indicates that they are active in the following activities:
 Illegal logging;
 Production or trade in any product or activity deemed illegal under the host country laws or regulations (including those ratified by host countries under international conventions and agreements);
Policies require compliance with national and international laws and regulationswell
No Corruption and Tax EvasionAnti-Bribary policy - Apr 2019
Bribery has no place at Citi. Employees are prohibited from offering (or agreeing to give), soliciting, or accepting (or agreeing to accept) bribes and other improper financial advantages;

Code of conduct
Anti-money laundering
Apply the appropriate level of due diligence when entering into client relationships and, where applicable, individual transactions, because no client relationship is worth compromising our commitment to combating money laundering, terrorist financing, and other crimes.
The policy has due diligence requirements for clients and their supply chains, regarding financial crimes. There are no clear requirements regaring tax avoidance.partly
Ensure ESIA for mills and plantationsEnvironmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC Performance Standards and sector-specific Environmental, Health and Safety (EHS) Guidelines, which address topics including, but not limited to, pollution prevention and abatement, and worker and community health and safety.
Areas of High Caution - In these cases, Independent Review of social and environmental assessment documentation by a qualified independent consultant with the relevant expertise may be required.
For non OECD countries IFC stanards are applied, which require an ESIA in certain cases. In OECD countries there is no clear ESIA requirementpartly
Social requirements
Ensure FPICHuman Rights Statement - Nov 2018
Citi will treat transactions with extra caution and conduct enhanced due diligence (which may require Independent Review by a qualified social expert) when the company’s assets may pose adverse effects to: an area used or traditionally claimed by an indigenous community; the community’s self-preservation based on traditional ways of life; or their use or enjoyment of critical cultural heritage that is essential to their identity and/or the cultural, ceremonial or spiritual aspects of their lives. Building upon government efforts, we expect our clients to avoid infringing upon the rights and protections for Indigenous Peoples contained in relevant national law, including those laws implementing host country obligations under international law. Globally, in project-related lending for projects involving involuntary resettlement of indigenous communities, significant impacts on land and natural resources traditionally used by the community, or significant impacts on critical cultural heritage, project sponsors are expected to have engaged in meaningful consultation with directly affected Indigenous Peoples, with the goal of achieving Free Prior and Informed Consent (FPIC).
The policy encourages FPIC when indigenous people are impacted, but it is not a requirement. The policy does not cover other, non-indigenous, affected communities.partly
Respect Human RightsHuman Rights Statement - Nov 2018
Prohibited activities - (...) We (...) prohibit financing client activities that are likely to involve forced labor, human trafficking or harmful child labor in their own operations.

Environmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC PS and sector-specific EHS Guidelines (...)
Policy Prohibitions
 Production or activities involving human trafficking or harmful or exploitative forms of forced labor (..)
 Production or activities involving harmful or exploitative forms of child labor. (...)
Elevated Human Rights Risks
(...) If a transaction involves a project with any of the following risk factors, it receives enhanced human rights due diligence:
 Projects in countries or regions with both the presence of significant vulnerable populations and with a history of known human rights abuses relevant to the sector. (...)
 Projects in countries or regions with a history of known human rights abuses relevant to the sector and weak enforcement of labor laws, especially occupational health and safety and freedom of association;
 Projects involving in-migration of large labor forces, which can lead to a higher risk of human trafficking or forced labor.
The policy provides good protection for human rights, based on respect for international conventions.well
Respect Indigenous rights and customary land use rightsHuman Rights Statement - Nov 2018 &
Environmental and Social Policy Framework 2020
Indigenous Peoples
Citi recognizes and respects the unique historical treatment and collective rights of Indigenous Peoples, and understands that these communities’ languages, beliefs, cultural values and lands are often under threat representing a higher degree of vulnerability than other project-affected communities. Citi will treat transactions with extra caution and conduct enhanced due diligence (which may require Independent Review by a qualified social expert) when the company’s assets may pose adverse effects to:
 an area used or traditionally claimed by an indigenous community;
 their communal self-preservation based on traditional ways of life; or
 their use or enjoyment of critical cultural heritage that is essential to their identity and/or the cultural, ceremonial or spiritual aspects of their lives.
Building upon government efforts, companies must not infringe upon the rights and protections for Indigenous Peoples contained in relevant national law, including those laws implementing host country obligations under international law. Globally in project-related lending for projects involving involuntary resettlement of indigenous communities, significant impacts on land and natural resources traditionally used by the community, or significant impacts on critical cultural heritage, project sponsors are expected to have engaged in meaningful consultation with directly affected Indigenous Peoples, with the goal of achieving Free Prior and Informed Consent (FPIC).
The policy encourages FPIC when indigenous people are impacted, but it is not a requirement. The policy does not cover other, non-indigenous, affected communities.partly
No forced resettlementHuman Rights Statement - Nov 2018
Citi will treat transactions with extra caution and conduct enhanced due diligence (which may require Independent Review by a qualified social expert) when the company’s assets may pose adverse effects to: an area used or traditionally claimed by an indigenous community; the community’s self-preservation based on traditional ways of life; or their use or enjoyment of critical cultural heritage that is essential to their identity and/or the cultural, ceremonial or spiritual aspects of their lives. Building upon government efforts, we expect our clients to avoid infringing upon the rights and protections for Indigenous Peoples contained in relevant national law, including those laws implementing host country obligations under international law. Globally, in project-related lending for projects involving involuntary resettlement of indigenous communities, significant impacts on land and natural resources traditionally used by the community, or significant impacts on critical cultural heritage, project sponsors are expected to have engaged in meaningful consultation with directly affected Indigenous Peoples, with the goal of achieving Free Prior and Informed Consent (FPIC).
Large-scale Resettlement
All transactions involving large-scale resettlement or displacement of people require special attention and enhanced due diligence.
The policy encourages FPIC when indigenous people are impacted, but it is not a requirement. The policy does not cover other, non-indigenous, affected communities.partly
Environmental Requirements
No forest degradation and deforestationSustainable Forestry Standard
Citi will not make loans to companies whom we know to be in violation of local or national laws regarding illegal logging.
The commitment not to execute transactions that significantly convert or degrade a critical habitat constitutes Citi’s approach to “Areas of High Caution and Special Focus” within the forestry sector.

Environmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC Performance Standards and sector-specific Environmental, Health and Safety (EHS) Guidelines, which address topics including, but not limited to, pollution prevention and abatement, and worker and community health and safety.
Critical Habitat, Areas of High Conservation Value and Significant Cultural Heritage Value - Citi recognizes that protecting and conserving areas of critical habitat, areas of significant biodiversity and/or areas of high conservation value, including legally protected areas, is key to high-quality environmental and social risk management. (...) require clients to avoid or mitigate threats to biodiversity (...)
Policy Prohibitions
* Projects that negatively impact the Outstanding Universal Value of UNESCO World Heritage Sites.
WB EHS and IFC protect partly against forest degradation and deforestation, for non OECD countries. The policy also protects UNESCO World heritage sites.partly
Protect endangered speciesEnvironmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC Performance Standards and sector-specific Environmental, Health and Safety (EHS) Guidelines, which address topics including, but not limited to, pollution prevention and abatement, and worker and community health and safety.
Policy Prohibitions
Citi does not provide financing when our due diligence indicates that the client is active in the following types of projects or activities:
 Production or trade in wildlife or products regulated under CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora);
Large-scale Resettlement
All transactions involving large-scale resettlement or displacement of people require special attention and enhanced due diligence.

The policy protects against trade in CITES species, but does not mention IUCN Red list speciespartly
No high-risk speciesEnvironmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC Performance Standards and sector-specific Environmental, Health and Safety (EHS) Guidelines, which address topics including, but not limited to, pollution prevention and abatement, and worker and community health and safety.
WB EHS and IFC protect partly against forest degradation and deforestation, for non OECD countries.partly
No fireEnvironmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC Performance Standards and sector-specific Environmental, Health and Safety (EHS) Guidelines, which address topics including, but not limited to, pollution prevention and abatement, and worker and community health and safety.
Not covered in the applicable policies and documents. IFC and WB EHS do not cover this eithernot
Protect peatEnvironmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC Performance Standards and sector-specific Environmental, Health and Safety (EHS) Guidelines, which address topics including, but not limited to, pollution prevention and abatement, and worker and community health and safety.
Not covered in the applicable policies and documents. IFC and WB EHS do not cover this eithernot
No persistent pollutionEnvironmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC Performance Standards and sector-specific Environmental, Health and Safety (EHS) Guidelines, which address topics including, but not limited to, pollution prevention and abatement, and worker and community health and safety.
WB EHS and IFC protect partly, for non OECD countriespartly
Corporate association / scope of the policy
Corporate association / scope of the policyEnvironmental and Social Policy Framework 2020
For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws;
For projects in non-OECD countries, Citi requires adherence to the issue-based IFC Performance Standards and sector-specific Environmental, Health and Safety (EHS) Guidelines, which address topics including, but not limited to, pollution prevention and abatement, and worker and community health and safety.
IFC protect partly, for non OECD countriespartly