Individual participation in trade body working groups must be approved by line managers, and reviewed on a regular basis.
No new memberships of trade and other industry groups are permitted without the approval of Barclays’ Chief Operations Office. COO hold the full list of all associations (many of which do not conduct proactive advocacy work), which is kept under regular review.
Barclays is a politically neutral organisation and does not engage in party political campaigning or make party political donations.
Barclays does not give any money for political purposes in the UK, the rest of the EU or outside of the EU, nor does it make any 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 USA 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. Contributions to political organisations reported by the PAC are disclosed in Barclays Annual Report and Accounts. They are also available publically 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 each of the jurisdictions in which we operate.
Barclays’ lobbying expenditure in the EU and US can be accessed below: