Policy positions

Bribery and corruption

Barclays operates globally and believes that best practice governance, controls and compliance are essential for maximising shareholder value. In order to achieve this, it must act with the highest standards of integrity and honesty in all it does, to give customers confidence when entrusting their business to Barclays.

Barclays recognises that bribery and corruption have an adverse affect on communities wherever they occur. Corruption can undermine the rule of law, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organised crime, money laundering and, sometimes, even the financing of terrorism.

Our policy reflects the statutory requirements applicable in the UK as derived from the United Nations (UN) and Organisation for Economic Co-operation and Development (OECD) conventions on corruption. However, all Group offices must comply with this policy, unless there is a conflict with local legislation. Barclays offices outside the UK must comply with their own local legislation in respect of anti-bribery and corruption (e.g. in the USA, the Foreign Corrupt Practices Act, which also has extra-territorial reach and implications for all Group offices).

We take our responsibilities seriously and expect all our employees, wherever they are based, to meet the requirements of our policy. Any breach of the Group's policy on bribery and corruption by any employee will be considered as grounds for disciplinary action, which may include dismissal.

Anti-money laundering

Our anti-money laundering policy has been designed to be consistent with the UK 2007 Money Laundering Regulations, legislation, Financial Services Authority (FSA) Rules, Joint Money Laundering Steering Group (JMLSG) Guidance Notes and recommendations issued by the Financial Action Task Force on money laundering and terrorist financing.

Our employees must comply with the highest standards of anti-money laundering and anti-terrorist financing practice in all jurisdictions in which we operate and co-operate with the authorities wherever possible and practicable, paying due regard to customer confidentiality and data protection obligations.

All businesses must follow the UK Joint Money Laundering Steering Group Guidance when assessing their risks and designing their risk-based systems and controls unless prohibited by local legislation.

We provide appropriate employee training to ensure colleagues can meet these requirements.

Discipline, Capability and Grievance (DC &G) Global Standard

This Global Standard establishes a set of minimum standards for dealing fairly and without discrimination with disciplinary, capability and grievance issues of all Barclays Group employees.

Harassment

It is in everyone's interest that within Barclays we promote respect and equal opportunity for all. While we make every effort to achieve this very important goal, our workplace harassment policy recognises that inappropriate behaviour can sometimes happen and aims to deal with it in a serious, sensitive and confidential manner and to resolve it as quickly as possible.

Health and Safety (H&S) Global Standard

This Global Standard establishes a set of minimum standards for H&S management across the Barclays Group. Barclays Group businesses must ensure the health, safety and welfare of employees and, so far as is reasonably practicable, provide and maintain safe working conditions. They must also meet this responsibility towards all persons on Barclays premises, such as customers, contractors and visitors.

Conformance with these standards and policies are measured by the business and monitored by relevant governance and control committees.

Redundancies

In the UK, we have a landmark agreement with Unite (Amicus section) on offshoring and site closures which offers early notification of redundancy, additional time for employees to find new roles either through internal redeployment or outplacement and a £2,000 re-training grant. Our emphasis is on avoiding compulsory redundancies where possible but in the event these do occur we have a generous redundancy pay policy.

Whistleblowing

Barclays has a 'Raising Concerns' policy which employees can read on our intranets. It is also publicised widely across Barclays sites using an annual poster campaign and other communications.

There is a confidential telephone line and email account for employees to use if they feel they cannot resolve concerns with their own manager. Employees are encouraged to raise genuine concerns with the assurance that they will not be discriminated against in any way.

Financial Sanctions and Prohibition of Business Activity

The Barclays Group Policy for Financial Sanctions and Prohibition of Business Activity is designed to ensure that all Barclays business areas comply with applicable financial sanctions in jurisdictions in which they operate. We provide appropriate staff training to ensure staff are able to meet these requirements.

Sudan

Barclays does not engage in business operations in Sudan nor do we deal with the Sudanese government.

Burma/Myanmar

We have a policy of non-engagement with Burma/Myanmar. However, in May 2008 we donated £50,000 to the Red Cross to help support the relief effort in Burma following Cyclone Nargis.

Group Environmental Management

Our policy was updated in April 2008 and applies to all our businesses. The policy is sponsored by the Group Operating Committee and the policy owner is the Group Head of Environmental Sustainability. The policy places requirements on Business Units to meet a number of essential Group-wide requirements including managing environmental impacts via our Environmental Management Systems, integrating environmental considerations into business decisions and managing the indirect impacts in our supply chain.