Citigroup - Transition Pathway Initiative

Area 1

Commitment

25%

1: Has the bank committed to achieve net-zero emissions from its financed emissions by 2050 or sooner, consistent with a 1.5°C scenario?

25%

a. Has the bank committed to achieve net-zero emissions from its financing activities by 2050 or sooner, consistent with a 1.5°C scenario?

b. Does the net-zero emissions commitment include the bank's material portfolio-wide activities in at least one sector?

c. Does the net-zero emissions commitment cover all material financing of high-risk sectors in at least one business segment (e.g., wholesale lending, retail lending, capital market activities, etc.)?

d. Does the bank's net-zero emissions commitment cover all its material financing of high-risk sectors across all business segments?

Area 2

Targets

25%

2.1: Has the bank set short-term targets for reducing its material emissions anytime up to 2025, consistent with a 1.5°C pathway?

0%

a. Has the bank set at least one target for reducing its financed emissions up to 2025?

b. Do the targets cover the bank's material financing activities in at least one high-risk sector?

c. Do the targets cover all material financing of high-risk sectors in at least one business segment (e.g., wholesale lending, retail lending, capital market activities, etc.)?

d. Do the targets cover all material financing of high-risk sectors across all business segments?

e. Has the bank disclosed the scenarios it uses to set sector specific targets?

f. Has the bank set at least one target that is aligned with a 1.5°C scenario?

2.2: Has the bank set medium-term targets for reducing its material emissions anytime between 2026 and 2035, consistent with a 1.5°C pathway?

50%

a. Has the bank set at least one target for reducing its financed emissions between 2026 and 2035?

b. Do the targets cover the bank's material financing activities in at least one high-risk sector?

c. Do the targets cover all material financing of high-risk sectors in at least one business segment (e.g., wholesale lending, retail lending, capital market activities, etc.)?

d. Do the targets cover all material financing of high-risk sectors across all business segments?

e. Has the bank disclosed the scenarios it uses to set sector specific targets?

f. Has the bank set at least one target that is aligned with a 1.5°C scenario?

Area 3

Decarbonization Strategy

45%

3.1: Engagement and Capital Allocation

3.1.1: Does the bank disclose its engagement activities with companies on climate change matters?

50%

a. Does the bank disclose an engagement policy requiring companies to adopt transition plans consistent with the bank's emissions targets?

b. Does the bank disclose actions taken to ensure transition plans are enforced?

3.1.2: Do the bank's asset management and/or wealth management divisions disclose their engagement activities with companies on climate change matters?

0%

a. Do the bank's asset management and/or wealth management divisions disclose their engagement policy with companies on climate change matters?

b. Do the bank's asset management and/or wealth management divisions disclose the number of companies they have engaged with and relevant details, including stakeholders, focus, and outcomes of engagement?

c. Do the bank's asset management and/or wealth management divisions disclose the value of associated financing or percentage of overall financing they have engaged with?

3.1.3: Does the bank set and disclose explicit criteria for the withdrawal of financing to misaligned activities?

0%

a. Has the bank committed to phase out thermal coal related financing (mining and power) in a timeline compatible with a 1.5°C aligned pathway?

b. Has the bank committed to end financing activities which aim to explore or develop new oil and gas fields?

c. Has the bank committed to end financing deforestation no later than 2030?

d. Has the bank committed to end financing land conversion of peatlands no later than 2030?

3.1.4: Does the bank set and disclose a strategy to scale up green finance with clear goals and timelines?

100%

a. Has the bank set and disclosed a strategy to scale up green finance with specific milestones and targets?

b. Does the bank use an established external definition of green activities (e.g., EU Taxonomy)?

3.2: Exposure and Financed Emissions Disclosure

3.2.1: Does the bank disclose exposure to high-risk sectors, from all of its material financing activities, on an emissions or portfolio basis?

67%

a. Does the bank disclose exposure to high-risk sectors?

b. Does the bank disclose exposure to high-risk sectors across all its material business segments?

c. Does the bank disclose exposure to high-risk sectors across all sectors in which it has activities?

3.2.2: Does the bank disclose absolute emissions from all of its material financing activities?

33%

a. Does the bank quantify and disclose financed absolute emissions?

b. Does the bank quantify and disclose financed absolute emissions for all its material business segments?

c. Does the bank quantify and disclose absolute emissions for all high-risk sectors in which it has activities?

3.2.3: Does the bank disclose emissions intensities from all of its material financing activities?

33%

a. Does the bank quantify and disclose financed emissions intensities?

b. Does the bank quantify and disclose emissions intensities for all its material business segments?

c. Does the bank quantify and disclose emissions intensities for all high-risk sectors in which it has activities?

3.2.4: Does the bank disclose its approach to offsetting in the accounting of financed emissions, including explicit disclosure in case offsetting is included in financed emissions reduction targets?

100%

a. Does the bank disclose its approach to offsetting in the accounting of financed emissions, including explicit disclosure in case offsetting is included in financed emissions reduction targets?

3.3: Climate Scenario Analysis

3.3: Does the bank undertake 1.5°C climate scenario planning?

20%

a. Has the bank conducted a climate-related scenario analysis for transition risks, including quantitative elements, and disclosed its results?

b. Has the bank conducted a climate-related scenario analysis for physical risks, including quantitative elements, and disclosed its results?

c. Has the bank conducted a climate-related scenario analysis for all its material business segments and disclosed its results?

d. Does the quantitative scenario analysis explicitly cover all of the high-risk sectors the bank has activities in?

e. Does the scenario analysis explicitly include a 1.5°C scenario, cover the entire portfolio, disclose key assumptions and variables used, and report on the key risks and opportunities identified?

Area 4

Climate Policy Engagement

0%

4.1: Does the bank have a Paris Agreement-aligned climate lobbying position, and are all of its direct lobbying activities aligned with this?

0%

a. Does the bank have a specific position statement to conduct its lobbying in line with the goals of the Paris Agreement?

b. Does the bank list all of its climate-related lobbying activities (e.g., meetings, policy submissions, etc.)?

4.2: Does the bank align its trade association memberships with the goals of the Paris Agreement, and does it disclose its trade association memberships?

0%

a. Does the bank have a specific commitment to ensure that the trade associations it is a member of lobby in line with the goals of the Paris Agreement?

b. Does the bank disclose all of its trade associations memberships?

4.3: Does the bank have a process to ensure its trade associations lobby in accordance with the Paris Agreement?

0%

a. Has the bank conducted and published a review of its trade associations' climate positions/alignment with the Paris Agreement?

b. Does the bank explain what actions it took as a result of this review?

Area 5

Climate Governance

75%

5.1: Has the bank nominated a board member or board committee with explicit responsibility for oversight of the climate change policy?

100%

a. Has the bank nominated a board member or board committee with explicit responsibility for oversight of the climate change policy?

b. Has the bank nominated a board member or board committee with explicit responsibility for oversight of the net zero strategy?

5.2: Does the bank's risk committee explicitly discuss and consider the impacts of climate related risks?

100%

a. Has the bank's risk committee explicitly included physical and transition as a key risk category?

b. Does the bank's risk committee explicitly discuss how the impacts of risks associated with the transition to net zero are integrated in the bank's key risk categories?

5.3: Does the bank's remuneration for senior executives incorporate climate change performance aligned with a 1.5°C transition?

0%

a. Does the banks CEO and/or at least one other senior executives' remuneration arrangements specifically incorporate climate change performance based on material Scope 3 emissions as a KPI determining performance-linked compensation?

b. Are the bank's CEO and/or at least one other senior executives' remuneration arrangements explicitly aligned with a 1.5°C pathway?

5.4: Does the bank commit to implement the recommendations of the Task Force on Climate related Financial Disclosures (TCFD)?

100%

a. Is the bank listed as a supporter on the TCFD website or does it explicitly commit to align its disclosures with the TCFD recommendations?

b. Does the bank explicitly sign-post TCFD aligned disclosures in its annual reporting or publish them in a TCFD report?

Area 6

Audit and Accounts

0%

6.1: Do the bank's audited financial statements and notes thereto incorporate material climate-related matters?

0%

a. Do the financial statements demonstrate how material climate-related matters are incorporated?

b. Do the financial statements disclose the quantitative climate-related assumptions and estimates?

c. Are the financial statements consistent with the bank's other reporting?

6.2: Does the audit report demonstrate that the auditor considered the effects of material climate-related matters in its audit?

0%

a. Does the audit report identify how the auditor has assessed the material impacts of climate-related matters?

b. Does the audit report identify inconsistencies between the financial statements and 'other information'?

6.3: Do the audited financial statements and notes thereto incorporate the material impacts of the global drive to net zero emissions by 2050 (or sooner), equivalent to achieving the Paris Agreement goal of limiting global warming to no more than 1.5°C?

0%

a. Do the financial statements use, or disclose a sensitivity to, assumptions and estimates that are aligned with achieving net zero emissions by 2050 (or sooner)?

b. Does the audit report identify that the assumptions and estimates that the bank used were aligned with achieving net zero emissions by 2050 (or sooner) or does it provide a sensitivity analysis on the potential implications?