Citizens Financial Group

In terms of senior leadership accountability, the responsibility for sustainability issues within Citizens lies with the board-level Nominating & Corporate Governance Committee. Moreover, the financial institution has identified and prioritised its impacts through a materiality assessment process which included feedback from external stakeholders. Regarding trade associations, the financial institution discloses a list of associations of which it is a member including sustainability- and non-sustainability-related organisations. In addition, Citizens discloses actions it takes to address any pay gaps, such as adjusting pay if job related factors do not explain a pay disparity.

Citizens discloses the aggregate amount and share of finance it devotes to climate solutions and specifies what these solutions are.

Citizens has a publicly available policy statement committing it to respect human rights and the ILO core labour rights. It also has a grievance mechanism accessible to all workers to raise human rights concerns or complaints. In terms of workforce diversity, the financial institution discloses a breakdown of its total direct operations workforce for each employee category by gender and race and provides evidence regarding the proportion of its workforce covered by collective bargaining agreements. Moreover, Citizens discloses the amount of lending it directs towards small- and medium-sized enterprises.

While Citizens links the remuneration of individuals whose roles are related to climate change to climate-related performance criteria, it could link the remuneration of its executive or management teams to sustainability performance criteria. In terms of female representation in leadership positions, women are underrepresented on the board of directors where only 31% board members are women. Moreover, there is no evidence that the financial institution has a public commitment to gender equality and women’s empowerment. Citizens has an opportunity to reach at least 40% female representation in senior leadership positions. Regarding engagement, the financial institution has an opportunity to describe its engagement approach on sustainability themes and impact topics with clients and investees, across its financing activities.

There is no evidence that Citizens discloses a target to reach net-zero financed emissions by 2050. In terms of engagement on the topic of climate change, the financial institution has an opportunity to disclose the key sectors and companies it has identified as priorities to engage with, specifically on alignment with the Paris Agreement. No evidence of an approach to fossil fuels, which covers the entire fossil fuel value chain and all of the financial institution’s financing activities, was found in the public domain. This could include the amount or share of finance directed towards fossil fuels or the financial institution’s stance on financing companies with new fossil fuel projects. Regarding nature and biodiversity, no evidence was found that Citizens is committed to minimising its negative impacts or financing regenerative solutions.

Citizens has an opportunity to describe the process for identifying its human rights risks and impacts through its relevant financing activities. Moreover, there is no evidence that the financial institution has a mechanism to raise human rights concerns and complaints that is accessible to all external individuals and communities who may be adversely impacted by the financial institution. The financial institution’s current grievance mechanism can only be used by workers. Furthermore, Citizens could disclose the amount of finance directed towards usually excluded groups or low-income developing countries.