The Nomination, Governance and Public Affairs Committee (NGPAC) of the Board of Directors provides oversight of Citi's positions and practices on public policy matters. At least once per year the NGPAC, which is composed entirely of independent outside directors, reviews relevant Citi policies and practices regarding political contributions, major lobbying priorities and principal trade association memberships, including those with continued relevance to Citi's public policy objectives. 

In addition to the Board of Directors oversight, Citi has strict internal policies and compliance processes to ensure adherence to relevant legal and regulatory requirements. We are fully committed to complying with all applicable laws regarding political contributions, such as MSRB Rule G-37, SEC Rules 206(4)-5 and 206(4)-5, CFTC Rule 23.451, as well as all international, national, state, and local limits and requirements applicable to our business. The Citi Code of Conduct and several firm-wide policies require all Citi-sponsored political activity and expenditures to be pre-approved and managed by Government Affairs (GA), with guidance from key Global Function partners as appropriate, and to comply with the Code, Citi policies and applicable law. This includes GA pre-approval to retain outside firms for legislative lobbying other than regulatory meetings and procurement lobbying. The head of GA reports to the Head of Enterprise Services and Public Affairs who in turn reports to the CEO. 

Corporate Payments

Citi may contribute corporate funds to state or local candidate campaign committees in jurisdictions where such activities are permitted. Citi may use corporate funds for independent expenditures which are contributions that expressly advocate election or defeat of candidates for office and are not made in cooperation with, or at the suggestion of, the candidate or his/her campaign or its agents or a political party or its agents. The company may also use corporate funds for ballot initiatives that may materially affect business operations. Citi will disclose any such corporate contributions in the annual Political Engagement Report.

In the U.S., Citigroup Inc., and its subsidiaries and affiliates, (collectively, “Citigroup”) are regulated by the Municipal Securities Rulemaking Board (“MSRB”) Rule G-37, Securities and Exchange Commission (SEC) Rules 206(4)- 5 (“Investment Advisor Pay-to-Play Rule”) and 15Fh-6 (“Pay-to-Play Rule for Security-Based Swap Dealers”), Commodity Futures Trading Commission (CFTC) Rule 23.451 and applicable state and local pay-to-play restrictions. The company will obtain an assurance letter from any organization that makes political campaign contributions specifying its understanding that company funds may not be used for purposes not compliant with the applicable campaign finance regulations.

Employee Political Action Committees

Citi's Political Action Committees (PACs) are funded entirely by voluntary contributions from eligible employees. The PACs support candidates, parties, and committees whose views on specific issues are consistent with the company's priorities. No single criterion or policy determines a candidate's eligibility for PAC contribution; however, candidates who advance positions or exhibit behaviors that conflict with Citi's ethos may be ineligible for PAC donations. We evaluate Citi PAC support to candidates based on the following criteria:

• Support of business issues important to Citi;
• Position on a committee with jurisdiction over policy issues important to Citi, or elected leadership position;
• Representation of a state or district where Citi has a significant employee presence;
• Character and integrity; and,
• Demonstrated commitment to bipartisanship, governing and protecting democratic institutions.

Citi makes political contributions without regard for the private political preferences of its executives. Our bipartisan GA team, with independent third-party analysis and with oversight by the Citi PAC Board made up of colleagues from across the firm, evaluates whether elected officials under consideration for contributions meet our giving criteria. 

Past Political Contributions Reports

• Political Engagement Report - 2024
• Political Engagement Report - 2023
• Political Engagement Report - 2022
• Political Engagement Report - 2021
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The GA team and contract lobbyists actively lobby on public policy issues that impact the company and our ability to do business globally. We regularly express our views to public officials and provide them with factual briefings to inform their decisions.

As outlined in the Citi Code of Conduct and Operational Expense Governance Policy Suite, only the GA team is authorized to retain legislative lobbyists on behalf of Citi. GA lobbying professionals are required to attend training on applicable laws and internal compliance policies and are expected to demonstrate the highest standards of professional integrity.

Citi complies with all international, national, state, and local laws concerning lobbying registration and reporting by GA. Quarterly lobbying disclosures are filed with the U.S. Congress disclosing Citi's federal lobbying expenditures and the issues lobbied. To review our quarterly filings, visit the Office of the Clerk of House of Representatives or the Secretary of the Senate and search for "Citigroup Washington, Inc." in the Registrant Name field. GA's international, state, and local lobbying activities and costs are disclosed where and as required by applicable law.

Citi does not engage in grassroots lobbying. If grassroots lobbying is required in the future, such activity will be disclosed where and as required by law. 

U.S. Lobbying Disclosure Websites

Following is a list of federal and state jurisdictions in which Citigroup is registered.

• Federal: House of Representatives
• Federal: Senate
• Alabama
• Arizona
• California
• Connecticut
• Delaware
• Florida
• Georgia
• Hawaii
• Illinois
• Indiana
• Kentucky
• Louisiana
• Maine
• Maryland
• Massachusetts
• Michigan
• Mississippi
• Missouri
• New Jersey
• New Mexico
• New York
• North Carolina
• Ohio
• Oklahoma
• Pennsylvania
• South Carolina
• South Dakota
• Tennessee
• Texas
• Virginia
• Washington
• West Virginia
• Wisconsin

Non-U.S. Lobbying Disclosure Websites

Following is a list of countries in which Citigroup is registered to lobby. Please note that some countries only require a disclosure filing if the requisite thresholds are met.

• Canada
• European Union
• Ireland
• Scotland

Citi belongs to trade associations globally that advocate on major public policy issues of importance to the company and the communities it serves. Participation as a member of these associations comes with the understanding that Citi may not always agree with all the positions of an association or its other members, and that we are committed to voicing our concerns as appropriate through GA and the company leaders who interact with these associations. A list of the principal trade associations, along with the portion of our membership dues attributable to lobbying, is disclosed on our Political Engagement Report.

When Citi participates in a tax-exempt organization that writes and endorses model legislation, we will disclose that information on our website.