Thank you for your inquiry regarding the findings of your “Digging in the Shadows” report and the human rights policies and performance of extractives companies in Eastern Europe and Central Asia. As you noted, Citi has had a stated commitment to respect human rights across our value chain since we first published our Statement on Human Rights in 2007. Human rights risks including labor concerns and community impacts are also addressed in our Environmental and Social Risk Management (ESRM) Policy...

However, our ability to conduct due diligence and use our leverage with clients is closely related to the type of financing provided - with project finance and other project-related lending providing the ability for closer due diligence and more leverage, general corporate lending or bonds providing less opportunity, and activities such as cash management or holding shares in a company on behalf of an investor client providing the least.

We have looked into the concerns that you raised. While we have a policy of not commenting on specific companies, to the extent the companies referenced are clients, we will consider whether additional client engagement is appropriate...