Business Integrity

We are committed to maintaining the highest ethical standards in conducting business with our suppliers. Consequently, all of our employees involved with committing or influencing expenditure, sourcing or supplier management will conduct themselves to the highest personal and professional standards, and in such a way that will not compromise Group values and standards. We expect our suppliers to apply the same standards.

Contents List
1. Conflict of Interest
2. Reciprocity
3. Gifts and Hospitality
4. Raising Concerns
5. Confidentiality

1. Conflict of Interest
We will avoid or declare conflicts of interest that may lead (or be seen to lead) to divided personal loyalties.

We will not grant any favour or special treatment to a supplier who is also a current or prospective client.

2. Reciprocity
A supplier or prospective supplier whose relationship with the Group is that of customer or prospective customer shall enjoy no special favour or treatment, over and above that applied to any other supplier or prospective supplier during the bidding process.

Reciprocal trading is generally unacceptable business practice. It is acceptable only when: there is no coercion; both parties are in agreement; and there is mutual benefit and transparency.

3. Gifts and Hospitality
Barclays staff will not accept gifts, hospitality or any other inducements which encourage or reward a decision and will not engage in any form of bribery.

4. Raising Concerns
Sourcing decisions will take in to account the suppliers provision for employees raising concerns ("whistle blowing") As a minimum these provisions needs to comply with Public Interest Disclosure Act 1998, FSA Policy requirements and the Sarbanes-Oxley Act 2002.

5. Confidentiality
We will only seek confidential information from suppliers or potential suppliers where necessary and when obtained, shall not be disclosed without the supplier's prior written consent.

In all instances where Barclays confidential information is to be disclosed to a supplier, or other external party, it is mandatory to execute a confidentiality agreement or NDA prior to disclosure.