Tax compliance and regulatory information

CRS requires natural persons that control the accounts be identified, irrespective of whether they are direct account holders (individual accounts) or controlling persons behind structures or companies that are not transparent for tax purposes (entity accounts). Entity clients are also required to complete CRS Self-Certification Forms. Please review Citi Private Bank's CRS At a Glance to help answer some frequently asked questions related to CRS. Below are Citi's CRS Forms which clients may be required to complete in compliance with these rules:

Translated versions of select forms may be available in Portuguese and Spanish. Please contact your Private Banker or Banker Team to assess if a specific form is available in a language you may prefer.

FATCA is a US tax law aimed to reduce or elimate US tax evasion by US taxpayers who maintain financial accounts outside the United States or invest offshore through non-US entities. Please review Citi Private Bank's What is FATCA? At a Glance to help answer some frequently asked questions related to FATCA. 

FATCA related resource available for Citi Private Bank clients:

• W-8BEN-E and FATCA Classification Guide: This guide is geared for non-U.S. entity clients required to complete a W-8BEN-E and to determine their FATCA Classification. 
• U.S. Tax Form Information: Provides an overview of the various U.S. tax forms with embedded links to the forms and instructions on the IRS website.

IRS approved Tax forms: These forms are accessible from the IRS website, www.irs.gov by clicking the direct links below for the repsective form:

Translated versions of select forms may be available in Portuguese and Spanish. Please contact your Private Banker or Banker Team to assess if a specific form is available in a language you may prefer. This information is made available for general reference only. It does not constitute legal or tax advice. Citigroup Inc. (Citi), its affiliates, and its employees are not in the business of providing tax or legal advice to any taxpayer outside of Citi and its affiliates. These materials are not intended or written to be used, and cannot be used or relied upon, by any such taxpayer for the purpose of avoiding tax penalties. Citi and its affiliates comply with applicable laws and regulations. We encourage you to seek third-party professional advice regarding your personal tax situation. Citi and its affiliates make no representation, recommendation or warranty, express or implied, regarding the accuracy, adequacy, reasonableness or completeness of the information contained herein.

The original Payment Service Directive ("PSD") was adopted in 2007. This legislation provided a legal framework for the EU's Single Euro Payments Area ("SEPA"). The main objective of PSD was to unify the EU e-payment market by creating rules and guidelines for payment institutions within the EU and to make cross-border payments as easy and efficient as local payments. PSD2 aims to widen the scope of the regulatory framework of PSD to cover new services and players (including payment initiation service providers and account information service providers) and additional geographies and currencies. It attempts to fix legal uncertainties and to enhance customer protection and payment services and to provide customers and retailers with effective, convenient and secure payment methods within the European Union. PSD2 comes into force on 13 January 2018.

Engagement Policy

We set out below the Engagement Policy of Citi Investment Management (‘CIM’), acting through Citibank N.A., London Branch, published in accordance with Article 3g1(a) of the Shareholders Rights Directive (2007/36/EC) as amended by Directive (EU) 2017/828.

Integration of shareholder engagement in our investment strategy

CIM’s portfolio management team are continuously monitoring companies and holdings to ensure that they remain appropriate and aligned with their investment mandates. The team may engage with management or investor relations of investee companies, but not other stakeholders, as we do not hold significant positions. Meetings may be held with companies to discuss specific results or events as well as more informal dialogue incorporating site visits and other research initiatives. These meetings may cover a range of topics from corporate strategy, risk management, corporate governance, board composition and remuneration issues.

Third party managers utilised in investment strategies may engage on matters relating to environmental, social and corporate governance (ESG) developments; enhancements or clarifications to company analysis or process improvements.

Where any material issues occur, either financial or non-financial, we would review the investment thesis to see if this has affected our investment rationale.

Monitoring of investee companies on relevant matters (including strategy; financial and non-financial performance and risk; capital structure; social and environmental impact and corporate governance)

Where direct stocks are selected, analysis is carried out on these companies including the financial and non-financial performance, risk, capital structure and corporate strategy. We use a wide variety of sources including company meetings, company reporting, broker research, industry reports and in-house research. The portfolio management team monitor the public statements of investee companies through financial information platforms like Bloomberg and Factset, financial statements and regulatory announcements, reports and accounts. Citi Investment Management’s portfolio managers access to a specialist research provider for environmental, social and governance (‘ESG’) issues, is the main tool for monitoring these risks.

When we appoint third party managers in our investment strategies, they monitor investee companies on their strategy, capital structure, financial and non-financial performance and risk. We review the third party managers’ research process, portfolio construction, sell discipline and risk management process to ensure that these processes incorporate monitoring of investee companies’ strategy, capital structure, financial and non-financial performance and risk. Third party managers are assessed and researched by Citi Investment Management’s Global Manager Research Group and approved (for use in discretionary portfolios) by the Forum for the Review and Approval of Managers.

Our approach for third party managers in relation to ESG is to add, via Citi Investment Management’s Global Manager Research Group, what we believe are best in class ESG-oriented or focused strategies, by asking associated ESG questions during our due diligence process.

The responses to these questions are a key consideration in ESG manager searches. We also ask these questions in non-ESG orientated manager searches although the related responses are not a critical decision parameter in these cases. We believe that incorporating ESG considerations in a manager’s approach is likely to enhance returns and reduce risk in addition to producing better outcomes for society and the planet.

Conducting dialogue with investee companies and communicating with relevant stakeholders of the investee companies

We assess the information third party managers gather to make their investment decisions, its quality and depth and the judgement the managers use in making investment decisions. This may include dialogue with the investee companies depending on the nature of the investment strategy, number of holdings and structure of the manager.

We do not currently liaise directly with other stakeholders because CIM does not currently hold significant positions in any companies. However, we do support the principle of collaborative engagement. Where stakeholders’ rights are likely to have a significant impact on the fortunes of investee companies such factors are taken into account via our ESG analysis.

Exercising voting rights and other rights attached to shares, cooperation with other shareholders and management of actual and potential conflicts of interests in relation to the firm’s engagement

Institutional Shareholder Services is retained for the management of the voting process and acts as the voting agent for the securities held in portfolios managed by CIM.

This allows us to take advantage of the extensive research carried out by ISS and our default instruction gives ISS consent to vote on our behalf in line with their expert recommendation.

Find more information about ISS here.

Where CIM does exercise its discretion to vote for or against a particular proposal or co-operate with other shareholders, it will be in a manner consistent with its relevant underlying clients’ best interests and when not in violation of anti-trust or any other laws or CIM policies. Any actual or potential conflict of interest that may arise would be managed in line with Citibank N.A., London Branch’s conflict of interest policy and standard, which is updated on an annual basis.

The Financial Reporting Council’s Stewardship Code 2020 (‘the Code’) requires that a firm, other than a venture capital firm, which is managing investments for a professional client that is not a natural person must disclose clearly on its website, or if it does not have a website in another accessible form:

1. the nature of its commitment to the Code; or
2. where it does not commit to the Code, its alternative investment strategy.

The Code took effect on 1 January 2020.

Citi Investment Management (‘CIM’), acting through Citibank N.A., London Branch provides portfolio management services and operates a global investment decision making process.  CIM is not a signatory to the Code given the small number of professional clients that are not natural persons which it offers its services to, as well as the small volume of transactions, however we have assessed the set of 12 Principles for asset owners and asset managers and have determined that some of the  principles can be meaningfully applied to CIM as set out in the attached.

In the exceptional event that Citibank Europe Plc. identifies a shortfall and is required to set aside an amount of its own funds in a segregated account to cover the shortfall, these funds will be held in a designated third party client asset account with the following institutions

We have a regulatory obligation to provide clients with Client Assets Key Information Document (CAKID) that explains certain key aspects of the regulations that apply to the safeguarding of client’s assets, outlines information on the arrangements in place to ensure that client’s assets are protected and highlights certain risks relating to provisions of investment services provided by us (Citibank Europe Plc) to our clients.

The UK’s Financial Conduct Authority (FCA) introduced mandatory firm level and product level TCFD-aligned disclosures for UK asset management firms with more than £5bn of AUM. Portfolio management firms managing investments are in-scope of these requirements. The FCA's goal is to increase transparency around how firms consider climate-related risks and opportunities, assisting their clients to make more informed decisions about their investments.

Entity-level disclosures

This report summarises the approach taken by Citi Investment Management (“CIM”) business within Citibank, N.A. London Branch (“CBNA Ldn”) to incorporate climate risk and opportunity identification, and management, into its overall business strategy and opportunities.

Reference period

From 1 January 2023 to 31 December 2023.

Product-level disclosures

If you have reporting obligations and require product level reports specific to your own portfolio composition, contact your Citi private banker.”