Citigroup Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Citigroup discloses that its “Government Affairs team works closely with Citi’s core businesses and functions to advocate the company’s interests through direct contact with government officials or indirectly through trade and business associations,” and notes that “a third party provides on-going monitoring of social media and news activities of the individuals we have identified for contributions during the calendar year,” indicating some oversight of political engagement. Board-level responsibility is named, as the Nomination, Governance and Public Affairs Committee (NGPAC) “oversees many of Citi’s ESG activities, including receiving reports from management on climate-related matters” and “reviews Citi’s strategy for engagement with external stakeholders,” while the statement that the NGPAC “advises on engagement with external stakeholders” shows a formal body that at least reviews aspects of lobbying activity. The company also acknowledges its indirect lobbying and offers limited transparency by stating, “Citi is also a member of trade and business associations that may lobby on different issues, including climate change… Below is a summary of certain trade and business associations that Citi is a member of, and how Citi has engaged with them on climate-related issues.” However, the evidence does not describe a dedicated procedure for assessing whether either direct lobbying positions or those of trade associations align with Citi’s climate goals, nor does it reference a periodic climate-lobbying review, escalation criteria, or any published alignment report; statements such as “Constructive engagement with the public sector is one of our Net Zero Transition Principles” outline intent but not governance mechanics. The disclosures focus mainly on climate-risk governance and general political-contribution controls, so the process for systematically monitoring, managing, or correcting lobbying misalignment—particularly on climate policy—“is not clearly defined,” and we found no evidence of board-approved climate-lobbying audits or criteria for disengaging from misaligned associations. Overall, Citi demonstrates limited but identifiable governance elements, principally the existence of a named committee that receives reports on external engagement and a brief acknowledgement of trade-association interactions, yet it has not publicly detailed a robust climate-lobbying governance framework. View Sources	D

Overall Assessment

Analysis

Score

Limited

Citigroup discloses that its “Government Affairs team works closely with Citi’s core businesses and functions to advocate the company’s interests through direct contact with government officials or indirectly through trade and business associations,” and notes that “a third party provides on-going monitoring of social media and news activities of the individuals we have identified for contributions during the calendar year,” indicating some oversight of political engagement. Board-level responsibility is named, as the Nomination, Governance and Public Affairs Committee (NGPAC) “oversees many of Citi’s ESG activities, including receiving reports from management on climate-related matters” and “reviews Citi’s strategy for engagement with external stakeholders,” while the statement that the NGPAC “advises on engagement with external stakeholders” shows a formal body that at least reviews aspects of lobbying activity. The company also acknowledges its indirect lobbying and offers limited transparency by stating, “Citi is also a member of trade and business associations that may lobby on different issues, including climate change… Below is a summary of certain trade and business associations that Citi is a member of, and how Citi has engaged with them on climate-related issues.” However, the evidence does not describe a dedicated procedure for assessing whether either direct lobbying positions or those of trade associations align with Citi’s climate goals, nor does it reference a periodic climate-lobbying review, escalation criteria, or any published alignment report; statements such as “Constructive engagement with the public sector is one of our Net Zero Transition Principles” outline intent but not governance mechanics. The disclosures focus mainly on climate-risk governance and general political-contribution controls, so the process for systematically monitoring, managing, or correcting lobbying misalignment—particularly on climate policy—“is not clearly defined,” and we found no evidence of board-approved climate-lobbying audits or criteria for disengaging from misaligned associations. Overall, Citi demonstrates limited but identifiable governance elements, principally the existence of a named committee that receives reports on external engagement and a brief acknowledgement of trade-association interactions, yet it has not publicly detailed a robust climate-lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Citigroup Inc. provides extensive, concrete information on its climate-policy advocacy. It names multiple specific policies and regulatory processes it has worked on, including consultations with the UK Prudential Regulation Authority that led to the supervisory statement on managing climate-related financial risks, the UK Financial Conduct Authority’s consultation on Climate Change and Green Finance, engagement with U.S. initiatives such as Property Assessed Clean Energy (PACE) and Utility On-Bill Repayment (OBR) programmes, work on Community Reinvestment Act (CRA) applicability to clean energy, and participation in joint statements urging the Biden Administration to strengthen the U.S. Nationally Determined Contribution and Congress to pass low-carbon infrastructure legislation. The company also explains how it lobbies and who it targets. It refers to “direct participation in consultations” with specific regulators (e.g., Bank of Mexico, Hong Kong Monetary Authority, Monetary Authority of Singapore), “serving as a technical resource to policymakers,” and signing collective policy letters through coalitions such as the CEO Climate Dialogue and the Center for Climate and Energy Solutions. These disclosures clearly identify both the mechanisms (consultations, technical briefings, policy letters, trade-association advocacy) and the targets (national finance ministries, financial regulators, and the U.S. Congress). Citigroup is similarly explicit about what it wants to achieve. It supports “an economy-wide price on carbon,” seeks “net-zero emissions across the economy by 2050,” calls for “Congressional action on low-carbon infrastructure,” encourages the SEC and other regulators to adopt robust climate-disclosure rules, and promotes standards that “overcome barriers to inclusion and scaling of distributed generation and energy-efficiency projects” while unlocking underserved markets through CRA alignment. Taken together, these detailed disclosures on the specific policies addressed, the lobbying channels employed, and the concrete outcomes pursued demonstrate a high level of transparency around the company’s climate-related lobbying activities.	A