Citigroup

"REPORTING TO THE CITI ETHICS OFFICE You may report your concern to the Citi Ethics Office, located in the U.S., by: Calling the Citi Ethics Hotline (available 24/7 in multiple languages) by: Looking up the dialing options available in your location in the Country Dialing Instructions; or Dialing 1-866-ETHIC-99 (1-866-384-4299); or Dialing 1-212-559-5842 (international collect/reverse charge number). Calls made with a mobile phone may result in charges from your carrier. Please check with your carrier before dialing. Reporting online through website submission at: https://www.citigroup.com/citi/investor/ethics_hotline.html Reports to the Ethics Office about human resources-related matters are forwarded to Human Resources and Employee Relations for review and follow-up."

"This chart provides an illustrative summary of steps taken in a typical Citi project-related finance transaction; 1. Client seeks competitive financing terms from banks --> When appropriate, earlystage “heads-up” memo sent to risk units including Environmental and Social Risk Management (“ESRM”) to notify of early-stage client discussions prior to formal approval ; 2. Receives and reviews marketing letter from Citi --> Approval required from appropriate Citi Independent Risk heads as well as ESRM unit • Project screened for potential environmental and social risks, including human rights risks • ESRM Category assigned along with ESRM Policy or Equator Principles requirements" ESRM Policy includes Palm Oil Policy.

"Citi lends and mobilizes billions of dollars of capital towards a variety of companies and projects, including sectors that may be associated with environmental and social impacts and risks. Before making a financing decision, we carefully assess the extent of these impacts and work with our clients to apply a clearly defined set of international standards and good practice to mitigate and manage environmental and social risks and impacts. This policy is regularly updated in response to emerging risks. "

"Following either ESRM internal review or independent review, if gaps are identified between a client’s current plans or operations and ESRM Policy requirements, an Environmental and Social Action Plan (ESAP) is developed. The ESAP contains targeted environmental and social actions with timelines and deliverables to demonstrate completion that bring the project into compliance with the ESRM Policy over a reasonable timeframe. In project-related loans, the ESAP becomes a binding covenant of the loan agreement and compliance with it is monitored, either by an independent consultant or by the client’s environmental team members, with results reported to Citi on a regular basis to confirm compliance.[...] Citi ESRM monitors progress annually on alignment with RSPO Principles and Criteria to ensure palm oil clients’ operations are consistent with the principle of No Deforestation, No Peat and No Exploitation (NDPE). We evaluate our clients’ identification and preservation of HCV areas (including peatlands and high carbon forests), implementation of best practice fire prevention and management systems, adherence to international labor standards, and the implementation of FPIC for project-affected communities. If a client leaves the RSPO or fails to progress towards RSPO certification, Citi would initiate steps to exit the relationship. Downstream clients involved in refining and trading are reviewed for zero deforestation policies as well as links to Areas of High Caution in their supply chain and encouraged to obtain RSPO certification if relevant. To further support ongoing development and adoption of the RSPO standard across the palm oil sector, Citi participates in the RSPO Financial Institution Consultative Group."

"Works with the client and/ or Independent Expert to identify and correct areas of noncompliance, if any • If significant areas of noncompliance are evident, senior approvers are notified and a corrective action plan devised to bring client back into compliance"

"REPORTING TO THE CITI ETHICS OFFICE You may report your concern to the Citi Ethics Office, located in the U.S., by: Calling the Citi Ethics Hotline (available 24/7 in multiple languages) by: Looking up the dialing options available in your location in the Country Dialing Instructions; or Dialing 1-866-ETHIC-99 (1-866-384-4299); or Dialing 1-212-559-5842 (international collect/reverse charge number). Calls made with a mobile phone may result in charges from your carrier. Please check with your carrier before dialing. Reporting online through website submission at: https://www.citigroup.com/citi/investor/ethics_hotline.html Reports to the Ethics Office about human resources-related matters are forwarded to Human Resources and Employee Relations for review and follow-up."

"REPORTING TO THE CITI ETHICS OFFICE You may report your concern to the Citi Ethics Office, located in the U.S., by: Calling the Citi Ethics Hotline (available 24/7 in multiple languages) by: Looking up the dialing options available in your location in the Country Dialing Instructions; or Dialing 1-866-ETHIC-99 (1-866-384-4299); or Dialing 1-212-559-5842 (international collect/reverse charge number). Calls made with a mobile phone may result in charges from your carrier. Please check with your carrier before dialing. Reporting online through website submission at: https://www.citigroup.com/citi/investor/ethics_hotline.html Reports to the Ethics Office about human resources-related matters are forwarded to Human Resources and Employee Relations for review and follow-up."

"We review all forestry clients’ policies, practices, and track record on forestry management to evaluate alignment with industry best practice, including labor, community engagement, systems to avoid deforestation or land conservation of HCV areas or high carbon stock landscapes, and proper prevention of fire risk. All forestry clients operating in tropical forests are required to be members of the Forestry Stewardship Council (FSC) and pursue certification, which includes establishing management systems consistent with the principles of No Deforestation, No Peat and No Exploitation (NDPE). FSC certification may be required in other geographies if concerns of HCV impacts are identified. These clients are reviewed annually by Citi to confirm ongoing management practices. "

"Citi lends and mobilizes billions of dollars of capital towards a variety of companies and projects, including sectors that may be associated with environmental and social impacts and risks. Before making a financing decision, we carefully assess the extent of these impacts and work with our clients to apply a clearly defined set of international standards and good practice to mitigate and manage environmental and social risks and impacts. This policy is regularly updated in response to emerging risks. "

"Following either ESRM internal review or independent review, if gaps are identified between a client’s current plans or operations and ESRM Policy requirements, an Environmental and Social Action Plan (ESAP) is developed. The ESAP contains targeted environmental and social actions with timelines and deliverables to demonstrate completion that bring the project into compliance with the ESRM Policy over a reasonable timeframe. In project-related loans, the ESAP becomes a binding covenant of the loan agreement and compliance with it is monitored, either by an independent consultant or by the client’s environmental team members, with results reported to Citi on a regular basis to confirm compliance."[...]"These clients (Forestry) are reviewed annually by Citi to confirm ongoing management practices. Citi has a long-standing public commitment not to engage in business with companies that we know to be in violation of local or national forestry and logging laws. If a client refuses to pursue FSC certification, or if they fail to make progress towards certification, or credible concerns of illegal logging are identified and not remediated, Citi would initiate steps to exit the relationship."

"We review all forestry clients’ policies, practices, and track record on forestry management to evaluate alignment with industry best practice, including labor, community engagement, systems to avoid deforestation or land conservation of HCV areas or high carbon stock landscapes, and proper prevention of fire risk. All forestry clients operating in tropical forests are required to be members of the Forestry Stewardship Council (FSC) and pursue certification, which includes establishing management systems consistent with the principles of No Deforestation, No Peat and No Exploitation (NDPE). FSC certification may be required in other geographies if concerns of HCV impacts are identified. These clients are reviewed annually by Citi to confirm ongoing management practices. Citi has a long-standing public commitment not to engage in business with companies that we know to be in violation of local or national forestry and logging laws. If a client refuses to pursue FSC certification, or if they fail to make progress towards certification, or credible concerns of illegal logging are identified and not remediated, Citi would initiate steps to exit the relationship."

"REPORTING TO THE CITI ETHICS OFFICE You may report your concern to the Citi Ethics Office, located in the U.S., by: Calling the Citi Ethics Hotline (available 24/7 in multiple languages) by: Looking up the dialing options available in your location in the Country Dialing Instructions; or Dialing 1-866-ETHIC-99 (1-866-384-4299); or Dialing 1-212-559-5842 (international collect/reverse charge number). Calls made with a mobile phone may result in charges from your carrier. Please check with your carrier before dialing. Reporting online through website submission at: https://www.citigroup.com/citi/investor/ethics_hotline.html Reports to the Ethics Office about human resources-related matters are forwarded to Human Resources and Employee Relations for review and follow-up."