Public policy engagement

As a major economic contributor, Barclays has an important role to play in the public policy debate.  We engage with policymakers in jurisdictions where we operate, including with governments, legislatures, regulators, trade associations, consumer groups and other organisations like think tanks and NGOs.

Responsible corporate citizenship requires active engagement in legislative processes and policy discussion. Our engagement with policymakers and advocacy on public policy issues is led by Barclays’ Strategic Policy Group, and is guided by both ‘The Barclays Way’, our Code of Conduct, and the following procedural rules and controls. In our discussions, we have a responsibility to make contributions that are accurate, honest and evidence based. Barclays’ advocacy and engagement activities, including direct and indirect advocacy, must also be undertaken in line with our internal controls, including Barclays’ Code of Conduct (The Barclays Way) which requires that 'where we engage with governments and regulators on issues relevant to our business, we are honest and transparent in our communication with them’. The Barclays Way also provides detailed guidance on speaking up and raising concerns, directing employees to speak up if they see ‘behaviours and practices that are not in line with our Barclays Values’; making clear that speaking up, whether formally or informally, will not come at a consequence to them. We also believe that Barclays should only engage on issues where we have a legitimate interest (for example, where there is a consequence for our business, our customers and clients, or our colleagues). Barclays’ Group Head of Strategic Policy is responsible for the coordination and oversight of public policy advocacy.

Members of the team work closely with Barclays’ businesses to identify public policy and legislative priorities, regionally (in the UK, EU, Asia Pacific and US) and globally, that impact our ability to help customers and clients.

Responsibility for the coordination and oversight of public policy advocacy rests with the Group Head of Strategic Policy, working in partnership with the regional heads of the Strategic Policy Group.

Barclays is committed to responsible public policy engagement.  Our  public policy activity is underpinned by the following principles:

Integrity: We are committed to ethical behaviour, integrity and responsibility in our public policy activities. All colleagues are bound by the Barclays Way Code of Conduct.

Legitimacy: Our engagement must align with business objectives, serve the interests of the company and comply with relevant laws.  We seek to ensure that positions presented to policymakers are rooted in evidence and insight.

Accountability and oversight: The Group Head of Strategic Policy is accountable for setting the principles and scope for public policy advocacy, agreeing the objectives and strategy and providing direction and guidance to management.  This is reviewed regularly by the Group Executive Committee and Board.

Consistency: The Strategic Policy Group plays a key role in ensuring consistency across all public policy activity undertaken in the company’s name, or in relation to its objectives. This includes activity across the corporate group, but also activity being undertaken by third parties such as agencies and trade bodies in partnership with Barclays.

Transparency: Barclays is open about the guiding principles, objectives, policies and procedures of its public policy activities.

Material information on how we deliver against these principles is available below.

As part of our commitment to transparency and legitimacy we publish details of Barclays’ bilateral responses to material government consultations on certain issues with which we are principally engaged, in the UK and EU, either in full, summary or part. In other jurisdictions, including across Asia Pacific and the US, responses to public consultations are published on the respective government websites.

Barclays retains the services of public affairs agencies in a number of locations. They are employed for the purposes of political monitoring and strategic advice - they are prohibited from making representations to governments or policymakers on our behalf, except in the US.

In order to meet our accountability and oversight commitments in relation to agencies, we work very closely with them on a day-to-day basis to ensure the Strategic Policy Group has oversight of the work being undertaken for us.  This includes weekly calls to agree priorities for the week, documented lists of completed actions and ad hoc phone counsel. We also have work orders in place with each of our agencies to set out the parameters for and the remit of their work.

A list of the agencies we work with in each jurisdiction is below. We do not currently retain the support of any agencies in Asia Pacific.

Barclays is a member of a number of trade associations globally. These associations work to represent their members, and for many this includes undertaking work to shape industry’s collective response to public policy issues.

We seek to be an engaged and constructive member of all associations in which we participate.  The main mechanism for achieving this is through the committees and working group structures that exist within each trade association.

Barclays’ methodology for listing trade association memberships on this page is based on the following criteria:

·      Barclays is a direct member*

·      Barclays paid a membership fee of over £100,000 (or jurisdictional currency equivalent)*

·      the organisation is likely to take a position on matters material to Barclays; or

·      Barclays held a seat on the board or provided funding beyond membership fees* such as funding a campaign or research programme.

*in the calendar year 2023.

Below is a list of the trade associations in which we participate that undertake active public policy engagement.  

Barclays is a politically neutral organisation and does not engage in party political campaigning or make party political donations.

Barclays does not give money for political purposes in the UK, the EU or outside of the EU, nor does it make political donations to political parties or other political organisations, or to any independent election candidates, or incur any political expenditure.

To note: The definitions of political donations and political expenditure used in the United Kingdom Companies Act 2006 are very wide. They may cover activities that are an accepted part of engaging with stakeholders, ensuring that issues and concerns affecting our operations are considered and addressed. However, these may not be considered as political donations or political expenditure as they are commonly understood. These activities are not designed to support any political party nor to influence public support for any political party.

As a result, Barclays typically seeks authority from its shareholders, by way of a resolution passed at its Annual General Meeting, to make political donations and to incur political expenditure, within specified maximum amounts. This resolution also applies to Barclays’ subsidiaries. This is a precautionary measure, to ensure that Barclays does not inadvertently breach the United Kingdom Companies Act 2006.

In accordance with the US Federal Election Campaign Act, Barclays provides administrative support to a federal Political Action Committee (PAC) in the US funded by the voluntary political contributions of eligible Barclays’ employees. The PAC is not controlled by Barclays and all decisions regarding the amounts and recipients of contributions are directed by a steering committee comprising employees eligible to contribute to the PAC. Total contributions to political organisations reported by the PAC are aggregated in Barclays Annual Report and Accounts. They are also available publicly on the Federal Election Commission’s website.

Colleagues involved in political activity in a personal capacity have a responsibility to make sure that this is kept entirely separate from their duties as an employee and that Barclays’ funds or resources (including time) are not used for political purposes. It is not permitted for any colleague to coerce or pressurise other employees to make political contributions. This is set out clearly in our Code of Conduct on which all employees undergo annual training.

Barclays complies with applicable laws and requirements in relation to the disclosure and publication of lobbying expenditure. We also comply with requirements in relation to disclosure of participation in registers of lobbyists in the jurisdictions in which we operate.

Barclays’ lobbying expenditure in the EU and US can be accessed below:

Barclays does not employ the services of serving politicians for lobbying/political engagement on behalf of the organisation. The Barclays speaker policy also prohibits paying standing officials and politicians for any speaker appearances, and applies for 12 months after the individual has left office.

Colleagues involved in political activity in a personal capacity have a responsibility to make sure that this is kept entirely separate from their duties as an employee and that Barclays’ funds or resources (including time) are not used for political purposes.

All potential conflicts stemming from relationships must be registered annually with the Chief Operations Office on the ‘Conflicts of Interest’ register, and flagged to line managers.

Barclays does not provide funding for All Party Parliamentary Groups.  Any support for the work of these groups is limited to insights and expertise.