Bill Barclay, Ranforest Action Network, United States Michelle Chan, Friends of the Earth US, United States
bank contact
Shawn D. Miller - Director Environmental and Social Risk Management Citigroup, United States
bank public comment:
Feedback on Sustainability Policies of Citi:
We would like to point you to our new Mountaintop Removal Mining Environmental Due Diligence process, a summary of the new process is available on our website (http://www.citigroup.com/citi/environment/mrcm.htm). The confidential internal full version of the policy goes into much further detail on the four principles we use to analyze clients in this space. The due diligence process includes 33 questions that cover general information on assets and operations, surrounding biodiversity and critical habitats, coal slurry management, regulatory compliance, and litigation. Citi is the only financial institution that has developed a due diligence process tailored to this specific practice.
As announced on p. 42 of our 2007 Citizenship Report (http://www.citigroup.com/citi/citizen/annualreport.htm) Citi's ESRM Policy was updated in January 2008 to include a section on "Areas of High Caution and Special Focus". These areas include: Critical Natural Habitat and Areas of of High Conservation Value, Areas of Significant Cultural and Heritage Value, Indigenous Peoples and Large Scale Resettlment.
About ESRM policy:
The Equator Principles require Independent Review for all Cat A and, as appropriate, Cat B projects, in order to confirm compliance with the IFC Performance Standards and EHS Guidelines. Citi goes further than this under our ESRM Policy; we reserve the right to require Independent Review for Category A projects for any financial product (beyond project finance), if needed.
Citigroup Inc., doing business as Citi, is a major American financial services company based in New York, NY. Citigroup was formed from a mergers between Citicorp and financial conglomerate Travelers Group. Citigroup is active in 107 countries with approximately 12,000 offices worldwide.
Citigroup suffered huge losses during the global financial crisis of 2008 and was rescued in November 2008 in a massive bailout by the U.S. government.
The CDP impels organisations to record their carbon footprint in daily activities. Encouraging enterprises to calculate and disclose their carbon impact, this initiative highlights the challenge for financial institutions to determine exactly how much carbon output can be attributed to financing.
Voluntary framework to guide the finance sector in tackling the challenge of climate change. They address the management of operational greenhouse gas (GHG) emissions and provide direction on managing climate change in research activities; asset management; retail banking; insurance & re-insurance; corporate banking; investment banking & markets; project finance.
The EPs are a set of guidelines, based upon the Performance Standards and guidelines from the IFC, the World Bank's private sector lending arm for private banks to asesses and mitigate risks in project finance. Banks use the Principles to guide internal operating procedures for transaction for specific projects. Although the EPs are an important step to raise overall standards of financiers and projects in the developing world, they currently fall short on transparency and governance requirements.
The verification and full publication of company payments and government revenues from oil, gas and mining is supported by the EITI. Financial institutions can participate and encourage resource-rich countries to support the initiative that aims to defeat poverty, corruption and conflict caused by weak transparency and accountability.
As the name suggests, the GRI aims to standardise good practice in transparency. GRI provides companies with guidelines to organise their annual report with reporting indices and standards addressing environmental, social and economic issues that business ought to address when telling the world about its performance.
The UN Global Compact is a set of ten principles that companies may sign voluntarily. Signatories promise to avoid complicity in human rights violations, adhere to labour standards, protect the environment and avoid corruption. The G8 countries urge companies to participate in this initiative, and with over 2900 companies signing up, the Global Compact has momentum. A voluntary and network based framework, the Global Compact actively promotes peer review and stakeholder participation.
UNEP is the 'voice of the environment' for the United Nations system, promoting international cooperation in the field of the environment. Issues concerning the financial community are addressed by the UNEP Finance Initiative which promotes investment in clean and renewable energy by financial institutions and other investors. Financial insititutions wishing to join must sign one of two Statements (for financial institutions and a separate one for the insurance industry).
UNPRI is a set of six principles direct institutional investors may adopt to consider environmental, social and corporate governance issues when investing. Voluntary and aspirational in nature, UNPRI has since its inception in 2006 attracted 200 signatories, representing US$8 trillion worth of investments.
Since the turn of the century a group of twelve banks known as the Wolfsberg Group have collaborated to improve ethical standards. The principles provide guidance on money laundering, corruption and the financing of terrorism. They have been produced to address deficiencies in areas 'yet to be fully articulated by lawmakers or regulators'.
Citi has also developed additional sustainability policies. You can find them below, or under 'documents' in the menu.
bank feedback:
The CDP is designed as an inquiry from institutional investors and banks with an asset management business. Unlike many of our peers we do not serve either of those functions, so we are not a signatory, however Citi has been a CDP respondent since its founding. As Citi does not have an asset management business, the UNEP Principles for Responsible Investments are also not relevant to Citi.
Citi has reported using the GRI framework since 2002. We use the GRI G3 sustainability guidelines for our Annual Citizenship Report. For our 2008 report we self-declared a B application level. Please see pp. 84 - 95 of our 2008 report (http://www.citigroup.com/citi/citizen/annualreport08.htm) for a breakdown of the GRI disclosure.
We are in the process of organizing senior-level meetings with the UN Global Compact to formalize joining the UNGC. We will update Banktrack when that has been formalized.
last save by banker: 8 months ago (Dec 01, 2009)
sustainability policies of Citi
2010 sector and issue policies
General comments BankTrack on policies Citi
Citi's Environmental and Social Risk Management
(ESRM) Policy is based on the standards of the Equator Principles, but
covers a broader range of financing. ESRM Covered Transactions are transactions
in emerging markets that meet a certain threshold amount per product type and must
be reviewed and receive the appropriate ESRM risk category. Those transactions with
sensitive environmental and social risks, require elevated review and approval
from appropriate senior credit officers. However, the ESRM policy will be
applied to part of the transaction and the policy itself is not shared with the
public. Citi's website about the ESRM policy and Citi's Citizenship Reports do not
provide enough detail about standards for different sectors. Criteria such as the
exclusion of activities or transactions that involve
significant conversion or degradation of critical habitat or utilize forced
labor or harmful child labor do not meet all essential elements of a good bank
policy. The ESRM policy is
therefore accredited with one point at the relevant issues and sectors.
For more and detailed information about this sector, have a look at the agriculture sector page
scoring method
The bank is active in this sector but has no investment policy for this sector;
The bank: has
only adopted or signed onto a voluntary standard or initiative (relevant for
this sector); or has
developed its own policy, but it is vaguely worded without clear commitments;
The bank has developed its own policy, that includes at least half of the essential elements;
The bank has
developed its own policy and: this
includes the essential elements in its lending and investment banking; or
this
includes the essential elements in its asset management;
The bank has
developed its own policy and: this
includes the essential elements in its lending and investment banking as well
as its asset management; or
this
includes both the essential and additional elements in its lending and
investment banking; or this
includes both the essential and additional elements in its asset management;
The
bank has developed its own policy and this includes both the essential and
additional elements in its lending and investment banking as well as its asset
management
When
the bank does not have an integrated agriculture policy but has policies on
individual commodities, we will assess these policies individually and score
them as a whole as described above. It is important for the specific commodity
policies that they follow the commodity specific international standards listed under 'best practice' at the agriculture sector page and include at least the essential elements described.
For more and detailed information about this sector, please have a look at the arms trade sector page
scoring method
The bank is active in this sector but has no investment policy for this sector;
The bank: has only adopted or signed onto a voluntary standard or initiative relevant for this sector; or has developed its own policy, but it is vaguely worded without clear commitments;
The bank has developed its own policy, that includes at least half of the essential elements;
The bank has developed its own policy and this includes the essential elements in its lending and investment banking; orthis includes the essential elements in its asset management
The bank has developed its own policy and this includes the essential elements in its lending and investment banking as well as its asset management; or this includes both the essential and additional elements in its lending and investment banking; or this includes both the essential and additional elements in its asset management;
The bank has developed its own policy and this includes both the essential and additional elements in its lending and investment banking as well as its asset management.
The bank is active in this sector but has no investment policy for this sector;
The bank: has only adopted or signed onto a voluntary standard or initiative relevant for this sector; or has developed its own policy, but it is vaguely worded without clear commitments;
The bank has developed its own policy, that includes at least half of the essential elements;
The bank has developed its own policy and this includes the essential elements in its lending and investment banking;or this includes the essential elements in its asset management
The bank has developed its own policy and this includes the essential elements in its lending and investment banking as well as its asset management; or this includes both the essential and additional elements in its lending and investment banking; or this includes both the essential and additional elements in its asset management;
The
bank has developed its own policy and this includes both the essential
and additional elements in its lending and investment banking as well
as its asset management.
For more and detailed information, please have a look at the forestry sector page
scoring method
The bank is active in this sector but has no investment policy for this sector;
The bank: has only adopted or signed onto a voluntary standard or initiative relevant for this sector; or has developed its own policy, but it is vaguely worded without clear commitments;
The bank has developed its own policy, that includes at least half of the essential elements;
The bank has developed its own policy and this includes the essential elements in its lending and investment banking; orthis includes the essential elements in its asset management
The bank has developed its own policy and this includes the essential elements in its lending and investment banking as well as its asset management; or this includes both the essential and additional elements in its lending and investment banking; or this includes both the essential and additional elements in its asset management;
The bank has developed its own policy and this includes both the essential and additional elements in its lending and investment banking as well as its asset management.
Citi's
ESRM Policy also includes a Sustainable
Forestry Sector Standard requires an action plan for the achievement of FSC
certification within a certain timeframe, but only for companies where a
significant threshold of concern has been raised about the legality of their
operations. For companies undertaking commercial logging in "high risk"
countries an action plan for the achievement of independent certification (not
necessarily FSC) within a certain time frame is also required. Forestry
operations that significantly degrade or convert critical natural habitat are a
precluded activities. The policy is accredited with two points.
For more and detailed information about this, please have a look at the mining sector page
scoring method
The bank is active in this sector but has no investment policy for this sector;
The bank: has only adopted or signed onto a voluntary standard or initiative relevant for this sector; or has developed its own policy, but it is vaguely worded without clear commitments;
The bank has developed its own policy, that includes at least half of the essential elements;
The bank has developed its own policy and this includes the essential elements in its lending and investment banking; orthis includes the essential elements in its asset management
The bank has developed its own policy and this includes the essential elements in its lending and investment banking as well as its asset management; or this includes both the essential and additional elements in its lending and investment banking; or this includes both the essential and additional elements in its asset management;
The bank has developed its own policy and this includes both the essential and additional elements in its lending and investment banking as well as its asset management.
additional information
This score is based on the fact that the bank has
adopted the Equator Principles
Regarding mining, Citi's Mountaintop Removal Mining Environmental Due
Diligence Process is incorporated in the evaluation of companies that
engage in MTR extraction in Central Appalachia.
But the details of this process are unknown and give no additional points.
For more and detailed information about this, please have a look at the oil and gas sector page
scoring method
The bank is active in this sector but has no investment policy for this sector;
The bank: has only adopted or signed onto a voluntary standard or initiative relevant for this sector; or has developed its own policy, but it is vaguely worded without clear commitments;
The bank has developed its own policy, that includes at least half of the essential elements;
The bank has developed its own policy and this includes the essential elements in its lending and investment banking; orthis includes the essential elements in its asset management
The bank has developed its own policy and this includes the essential elements in its lending and investment banking as well as its asset management; or this includes both the essential and additional elements in its lending and investment banking; or this includes both the essential and additional elements in its asset management;
The bank has developed its own policy and this includes both the essential and additional elements in its lending and investment banking as well as its asset management.
additional information
This score is based on the fact that the bank has
adopted the Equator Principles
The bank is active in this sector but has no investment policy for this sector;
The bank: has only adopted or signed onto a voluntary standard or initiative relevant for this sector; or has developed its own policy, but it is vaguely worded without clear commitments;
The bank has developed its own policy, that includes at least half of the essential elements;
The bank has developed its own policy and this includes the essential elements in its lending and investment banking;or this includes the essential elements in its asset management
The bank has developed its own policy and this includes the essential elements in its lending and investment banking as well as its asset management; or this includes both the essential and additional elements in its lending and investment banking; or this includes both the essential and additional elements in its asset management;
The bank has developed its own policy and this includes both the essential and additional elements in its lending and investment banking as well as its asset management.
The bank: has only adopted or signed onto a voluntary standard or
initiative relevant; or has developed its own policy,
but it is vaguely worded without clear commitments;
The bank has developed its own policy,
that includes at least half of the essential elements;
The bank has developed its own policy
and this includes the
essential elements in its lending and investment banking; or this
includes the essential elements in its asset management
The bank has developed its own policy
and this includes the essential elements in its lending and
investment banking as well as its asset management; or this includes
both the essential and additional elements in its lending and investment
banking; or this includes both the essential and additional elements
in its asset management;
The bank has developed its own policy
and this includes both the essential and additional elements in its
lending and investment banking as well as its asset management.
additional information
This score is based on the fact that the bank has
adopted the Equator Principles
The bank: has only adopted or signed onto a voluntary standard or
initiative relevant; or has developed its own policy,
but it is vaguely worded without clear commitments;
The bank has developed its own policy,
that includes at least half of the essential elements;
The bank has developed its own policy
and this includes the
essential elements in its lending and investment banking; or this
includes the essential elements in its asset management
The bank has developed its own policy
and this includes the essential elements in its lending and
investment banking as well as its asset management; or this includes
both the essential and additional elements in its lending and investment
banking; or this includes both the essential and additional elements
in its asset management;
The bank has developed its own policy
and this includes both the essential and additional elements in its
lending and investment banking as well as its asset management.
Citi's
Statement on Climate Change is merely focused on what government policies
should look like instead of assuming responsibility as a company. Furthermore,
in its comments Citi stresses that it has a number of robust climate
risk-assessment criteria as outlined in the Carbon Principles, Equator
Principles and via the IFC Performance Standards and EHS Guidelines. These
documents and comments give no additional points.
For more and detailed information about this issue please have a look at the corruption sector page
scoring method
The bank has no investment policy for this issue;
The bank: has only adopted or signed onto a voluntary standard or
initiative relevant; or has developed its own policy,
but it is vaguely worded without clear commitments;
The bank has developed its own policy,
that includes at least half of the essential elements;
The bank has developed its own policy
and this includes the
essential elements in its lending and investment banking; or this
includes the essential elements in its asset management
The bank has developed its own policy
and this includes the essential elements in its lending and
investment banking as well as its asset management; or this includes
both the essential and additional elements in its lending and investment
banking; or this includes both the essential and additional elements
in its asset management;
The bank has developed its own policy
and this includes both the essential and additional elements in its
lending and investment banking as well as its asset management.
For more and detailed information about this issue please have a look at the close the gap issue page on human rights. This page also informs about the difference between essential and additional elements.
scoring method
The bank has no investment policy for this issue;
The bank: has only adopted or signed onto a voluntary standard or
initiative relevant; or has developed its own policy,
but it is vaguely worded without clear commitments;
The bank has developed its own policy,
that includes at least half of the essential elements;
The bank has developed its own policy
and this includes the
essential elements in its lending and investment banking; or this
includes the essential elements in its asset management
The bank has developed its own policy
and this includes the essential elements in its lending and
investment banking as well as its asset management; or this includes
both the essential and additional elements in its lending and investment
banking; or this includes both the essential and additional elements
in its asset management;
The bank has developed its own policy
and this includes both the essential and additional elements in its
lending and investment banking as well as its asset management.
Citi's Statement on Human Rights requires its
clients to adhere to the Human Rights Declaration but mentions the ILO core
conventions with regard to its employees only. The Statement furthermore refers
to the ESRM Policy standards which includes application of the IFC Performance
Standard on Indigenous Peoples. Citi does not mention other important
international conventions that are part of the International Bill of Human
Rights and pays attention to women's rights explicitly. As said earlier the
ESRM Policy is not public and applies to part of the transactions. The issues
Human Rights, Labour and Indigenous Peoples are accredited with one point.
The bank: has only adopted or signed onto a voluntary standard or
initiative relevant; or has developed its own policy,
but it is vaguely worded without clear commitments;
The bank has developed its own policy,
that includes at least half of the essential elements;
The bank has developed its own policy
and this includes the
essential elements in its lending and investment banking; or this
includes the essential elements in its asset management
The bank has developed its own policy
and this includes the essential elements in its lending and
investment banking as well as its asset management; or this includes
both the essential and additional elements in its lending and investment
banking; or this includes both the essential and additional elements
in its asset management;
The bank has developed its own policy
and this includes both the essential and additional elements in its
lending and investment banking as well as its asset management.
additional information
This score is based on the fact that the bank has
adopted the Equator Principles
Citi's
Statement on Human Rights requires
its clients to adhere to the human rights declaration and the ILO core
conventions. The Statement furthermore refers to the ESRM Policy standards which includes application of the IFC Performance Standard on
Indigenous Peoples. Citi does not mention other important international
conventions that are part of the International Bill of Human Rights and pays
attention to women's rights explicitly. As said earlier the ESRM Policy is not
public and applies to part of the transactions. The issues Human Rights and Indigenous
Peoples are accredited with one point.
For more and detailed information about this issue please have a look at the labour issue page
scoring method
The bank has no investment policy for this issue;
The bank: has only adopted or signed onto a voluntary standard or
initiative relevant; or has developed its own policy,
but it is vaguely worded without clear commitments;
The bank has developed its own policy,
that includes at least half of the essential elements;
The bank has developed its own policy
and this includes the
essential elements in its lending and investment banking; or this
includes the essential elements in its asset management
The bank has developed its own policy
and this includes the essential elements in its lending and
investment banking as well as its asset management; or this includes
both the essential and additional elements in its lending and investment
banking; or this includes both the essential and additional elements
in its asset management;
The bank has developed its own policy
and this includes both the essential and additional elements in its
lending and investment banking as well as its asset management.
The bank: has only adopted or signed onto a voluntary standard or
initiative relevant; or has developed its own policy,
but it is vaguely worded without clear commitments;
The bank has developed its own policy,
that includes at least half of the essential elements;
The bank has developed its own policy
and this includes the
essential elements in its lending and investment banking; or this
includes the essential elements in its asset management
The bank has developed its own policy
and this includes the essential elements in its lending and
investment banking as well as its asset management; or this includes
both the essential and additional elements in its lending and investment
banking; or this includes both the essential and additional elements
in its asset management;
The bank has developed its own policy
and this includes both the essential and additional elements in its
lending and investment banking as well as its asset management.
For more and detailed information about this issue, please have a look at the taxation issue page
scoring method
The bank has no investment policy for this issue;
The bank: has only adopted or signed onto a voluntary standard or
initiative relevant; or has developed its own policy,
but it is vaguely worded without clear commitments;
The bank has developed its own policy,
that includes at least half of the essential elements;
The bank has developed its own policy
and this includes the
essential elements in its lending and investment banking; or this
includes the essential elements in its asset management
The bank has developed its own policy
and this includes the essential elements in its lending and
investment banking as well as its asset management; or this includes
both the essential and additional elements in its lending and investment
banking; or this includes both the essential and additional elements
in its asset management;
The bank has developed its own policy
and this includes both the essential and additional elements in its
lending and investment banking as well as its asset management.
For more and detailed information about this issue, please have a look at the toxics issue page
scoring method
The bank has no investment policy for this issue;
The bank: has only adopted or signed onto a voluntary standard or
initiative relevant; or has developed its own policy,
but it is vaguely worded without clear commitments;
The bank has developed its own policy,
that includes at least half of the essential elements;
The bank has developed its own policy
and this includes the
essential elements in its lending and investment banking; or this
includes the essential elements in its asset management
The bank has developed its own policy
and this includes the essential elements in its lending and
investment banking as well as its asset management; or this includes
both the essential and additional elements in its lending and investment
banking; or this includes both the essential and additional elements
in its asset management;
The bank has developed its own policy
and this includes both the essential and additional elements in its
lending and investment banking as well as its asset management.
For more and detailed information about this issue please have a look at the close the gap page on accountability. This page also informs about the difference between essential and additional elements.
scoring method
The bank has no procedures regarding transparency and
accountability;
The bank has an internal and/or external audit system in
place to audit its Environmental and
Social Risk Management System and its sector and issue investment policies,
but does not publish the results of these audits; or performs
stakeholder engagement but not in accordance with AA1000
The bank's procedures include half of the essential
elements;
The bank's procedures include all of the essential
elements;
The bank's procedures include the essential elements and include the additional elements in its lending and investment banking; or include the additional elements in its
asset management
The bank's procedures include both the essential and
additional elements in its lending and investment banking as well as its asset
management.
additional information
This score is based on the following procedures within
the bank: Internal
audits by ESRM Unit and Audit and Risk Review Unit. Stakeholder engagement. Only handling of client complaints
For more and detailed information about this issue please have a look at the close the gap page on transparency. This page also informs about the difference between essential and additional elements.
scoring method
The bank has no procedures regarding transparency;
The bank has signed onto the Global Reporting Initiative
(GRI), but does not use its framework for reporting;
The bank's procedures include half of the essential
elements;
The bank's procedures include all of the essential
elements;
The bank's procedures include the essential elements and:
include the additional elements in its
lending and investment banking; or
include the additional elements in its
asset management;
The bank's procedures include both the essential and
additional elements in its lending and investment banking as well as its asset
management.
additional information
This score is based on the following procedures within
the bank: Non-verified
Citi Citizenship Report using GRI / No policies disclosed / No deal
transparency
print
We would like to point you to our new Mountaintop Removal Mining Environmental Due Diligence process, a summary of the new process is available on our website (http://www.citigroup.com/citi/environment/mrcm.htm). The confidential internal full version of the policy goes into much further detail on the four principles we use to analyze clients in this space. The due diligence process includes 33 questions that cover general information on assets and operations, surrounding biodiversity and critical habitats, coal slurry management, regulatory compliance, and litigation. Citi is the only financial institution that has developed a due diligence process tailored to this specific practice.
As announced on p. 42 of our 2007 Citizenship Report (http://www.citigroup.com/citi/citizen/annualreport.htm) Citi's ESRM Policy was updated in January 2008 to include a section on "Areas of High Caution and Special Focus". These areas include: Critical Natural Habitat and Areas of of High Conservation Value, Areas of Significant Cultural and Heritage Value, Indigenous Peoples and Large Scale Resettlment.
About ESRM policy:
The Equator Principles require Independent Review for all Cat A and, as appropriate, Cat B projects, in order to confirm compliance with the IFC Performance Standards and EHS Guidelines. Citi goes further than this under our ESRM Policy; we reserve the right to require Independent Review for Category A projects for any financial product (beyond project finance), if needed.
8 months ago (Dec 02, 2009)