Global Citizenship Report 2017

Code of Conduct Citi’s Code of Conduct outlines the standards of ethics and professional behavior expected of employees and represen- tatives of Citi when dealing with clients, business colleagues, shareholders, communities and each other. It also provides an overview of key legal and regulatory requirements and select global policies. Individuals performing services for Citi may also be subject to the Code by contract or agreement. The Code is publicly available in 26 languages at our Investor Relations website. In October 2017, we issued a new Code of Conduct. The 2017 Code illustrates how our employees can make ethical decisions, using a decision-making guide that identifies key criteria through which a proposed choice or course of action should pass in order to align with the tests contained in our Mission and Value Proposition and our Leadership Standards. The 2017 Code also provides guidance on how employees can lead by example and emphasizes that all employees share a responsibility to promptly report and escalate actual or poten- tial misconduct, whether their own or that of others. The 2017 Code was approved by our Board of Directors. Upon joining Citi, employees must acknowledge that they have read and will comply with the Code, and we ask employees to peri- odically reaffirm this commitment through Code of Conduct training. Violations of the Code can result in disciplinary action up to and including termination of employment. Citi employees are required to complete Code of Conduct training biennially following the issuance of an updated Code of Conduct. The training serves as an essential means to connect Citi’s values and principles to expected employee behaviors and conduct. Through the use of hypothetical work-related ethical scenarios, the training enables employ- ees to better recognize when to seek guidance or report concerns about their conduct or that of others, and provides information about the various avenues through which they can do both. Code of Conduct training is offered to new hires globally on a rolling basis as well as to non-employee contin- gent workers who are performing services for Citi. Escalating Business and Ethical Concerns Throughout 2017, we continued to emphasize to our employees globally the importance of escalating issues and to reinforce the principles embedded in Citi’s global Escalation Policy. These principles include employees’ obligation to escalate violations or potential violations of law, regulation, Citi policy or the Code of Conduct. The multiple avenues through which employees can raise issues include, among others, their manager or other members of management, their Human Resources or labor relations representatives, internal legal counsel, a designated compliance officer and the Ethics Hotline. The Ethics Hotline provides five channels for employees and any third party, including members of the general public, to report concerns about unethical behavior to Citi’s Ethics Office. A telephone line is available 24 hours a day, seven days a week, with live operators who can connect to translators in multiple languages. Other reporting channels include a dedicated email address, fax line, website (both internal and public-facing), and physical mailing address. All concerns are treated as confidentially as possible, consis- tent with the need to investigate and address the matter. Concerns may be raised either anonymously or with attribu- tion, subject to applicable laws and regulations. Further, Citi prohibits any form of retaliation against anyone who raises a concern or question in good faith, or who participates in a subsequent investigation. Industry Collaboration We have made a concerted effort to partner with key stake- holders on ways that we can collectively improve the culture of the banking industry. In June 2017 for example, Citi, along with industry leaders and regulators, participated in the Federal Reserve Bank of New York’s workshop on culture and behavior in the financial services industry. The workshop focused on measuring and assessing culture and behavior within and across financial firms and explored benchmarking, the need for outside perspectives and opportunities for estab- lishing and sharing best practices. Citi is also a member firm of the Banking Standards Board (BSB) in the UK. Together with over 30 member firms, we support the BSB’s independent role to help rebuild trust and confidence across the UK banking industry by promoting high ethical and professional standards for behavior and competence. We remain engaged with the BSB directly through our UK senior management. James Bardrick, our Chief Country Officer for the UK, has been a BSB board member since its inception. GRI INDICATORS: 102-42, 102-44 18