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Stewardship Code

Disclosure Statement relating to the UK Stewardship Code

Barclays Private Bank offers private banking, credit and investment solutions in a number of jurisdictions. This statement relates to the Private Bank’s operations in the UK and references to “Barclays Private Bank”, “we” or “our” are limited to activity undertaken by the UK business in the UK through Barclays Bank PLC and its subsidiary companies.

The UK Stewardship Code 2020 (the “Code”) is a voluntary code published by the UK’s Financial Reporting Council, which came into effect on 1 January 2020. Barclays Private Bank welcomes the revised Code, which builds upon the initial UK Stewardship Code and sets a higher standard of Stewardship expectations. The Code’s aim is to improve the way in which institutional investors interact with the management of companies in which they invest across all asset classes.

While not currently a signatory of the Code, we support its aims and this statement outlines Barclays Private Bank’s views in relation to the principles.

Our approach to Stewardship involves looking deep into our investment process and investments to protect and enhance long-term value for clients and to society and all key stakeholders. This should lead to sustainable benefits for the economy, the environment and society. Therefore, in line with the Code, we seek to apply stewardship across all asset classes.

Barclays Private Bank is committed to acting in the best long-term financial interests of its clients. In this fiduciary role, we believe that environmental, social and corporate governance (ESG) issues can affect the performance of investment portfolios. We believe in integrating ESG considerations and ownership practices into our investment processes, as ESG factors can have an impact on financial performance. By behaving as a long-term investor, we seek to generate superior sustainable returns for our clients as well as to create long-term value for all stakeholders.

Where Barclays Private Bank exercises its discretion to vote on a particular management or shareholder proposal, it will do so in a manner consistent with our clients’ long-term interests.

Any actual or potential conflict of interest that may arise would be managed in line with the documented Barclays Group-Wide Conflicts of Interest Policy and Standard, which is updated on an annual basis. All employees are expected to adhere to this Policy and Standard and receive training on this. Each division maintains a register of conflicts of interest, which is updated regularly.