-

Sustainable Finance Disclosure Regulation (SFDR)

REGULATION (EU) 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

The aim of the SFDR is to increase transparency in relation to sustainability amongst financial institutions and market participants so that clients can make informed investment decisions. It consists of disclosure requirements at firm and service and/or product level to standardise sustainability disclosures, which aims to improve industry-wide comparability and help prevent greenwashing.

The information available to you on this page provides an overview of:

  • How “sustainability risks” (which we refer to as Environmental, Social and Governance (ESG) Risks) are integrated into our investment decision processes where we provide portfolio management services to clients, and into the investment advice that is provided to clients. Our Sustainability Risk Policy (below) provides you with an overview of the ESG Risks management processes adopted and the due diligence conducted on in-scope financial products by Barclays Bank Ireland (BBI) when we provide portfolio management services or investment advice to clients
  • How we consider principal adverse impacts of investment decisions on sustainability factors and the due diligence policies with respect to these impacts when making investment decisions. This provides you with information on how we identify and prioritise adverse sustainability impacts and indicators in our investment due diligence processes, and apply these to our sustainable investment offerings
  • How we consider principal adverse impacts when providing investment advice to clients
  • Product level sustainability through a product classification disclosure. The SFDR requires financial products to be divided into three categories. This provides you with information that allows you to differentiate between the three product categories:
     - Those products that have an intended sustainability target, such as reduction of CO2 emissions (Article 9 products)
     - Those products that promote environmental or social characteristics (Article 8 products) and;
     - Other products without specific sustainability considerations 
  • How we integrate ESG Risks into our remuneration policies and processes to promote sound and effective risk management with respect to ESG Risks. 

Integration of sustainability (ESG) risks in Barclays Bank Ireland's remuneration policy

The implementation of Barclays Bank Ireland’s remuneration policy ensures that remuneration is consistent with the integration of risk, including:

  • Barclays’ remuneration philosophy, which has been adopted by the Barclays Bank Ireland Remuneration Committee, links remuneration to achieving sustained high performance and creating long-term value. The objectives of Barclays’ remuneration philosophy include rewarding sustainable performance, and aligning remuneration with risk appetite, risk exposure and conduct expectations
  • Individual performance assessment includes the consideration of core job responsibilities, behaviours towards risk and control, colleague and stakeholder feedback as well as input from the Risk and Compliance functions, where appropriate
  • Remuneration is aligned with our risk appetite and with the conduct expectations of Barclays, our regulators and other stakeholders
  • We have robust processes in place for considering risk and conduct as part of individual performance management processes with outcomes reflected in individual remuneration decisions
  • Actions  may be taken on variable remuneration (including reduction of in-year bonuses, malus and clawback) where risk management and conduct fall below required standards
  • Adjustments to the incentive pool take account of an assessment of a wide range of future risks.

References to risk in this context are references to a wide range of risks (including market, credit, operational and conduct risk, and from 2021 includes ESG risks).

In particular, Barclays Bank Ireland has robust processes in place for considering risk and conduct as part of individual performance management processes with outcomes reflected in individual remuneration decisions.

Line managers have primary accountability for ensuring that risk and conduct issues are considered when assessing performance and making remuneration decisions. In addition, there is a secondary review by the control functions for individuals involved in significant failures of risk management, conduct issues, regulatory actions or other major incidents which impact either the Group or business to ensure these issues are also considered.

This includes consideration of breaches of Barclays risk and conduct policies, and from 2021 includes consideration of breaches of the Barclays Bank Ireland Sustainability Risk Policy.