Strategic Shareholder Climate and Risk Financial Financial Barclays PLC 260 report information sustainability report Governance review review statements Annual Report 2022 ESG: Governance (continued) Financial crime Barclays recognises that economic crimes have an adverse effect on individuals and communities wherever they occur. Endemic economic crime can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Barclays recognises that financial crimes Anti-Bribery & Corruption Anti-Tax Evasion Facilitation have an adverse effect on individuals and Bribery and corruption constitutes of: Tax evasion is a financial crime and a communities wherever they occur. predicate offence to money laundering in a. improperly obtaining or retaining Endemic financial crime (particularly when the UK and many other countries in which business; and/or associated with organised crime and we operate. Barclays takes a zero- terrorist financing) can threaten laws, b. improperly securing a business or tolerance approach to deliberate democratic processes and basic human personal advantage; and/or facilitation of tax evasion in any country freedoms, impoverishing states and and has procedures in place to prevent it. c. inducing another person to perform distorting free trade and competition. We also expect the same from our their role in breach of an expectation of Barclays is committed to conducting its employees and third parties providing good faith, impartiality or trust. global activities with integrity and services for or on our behalf. Barclays is respecting its regulatory, ethical and social Barclays and its employees are prohibited committed to: responsibilities to: from engaging in or facilitating any form of a. dealing only with customers who have a. protect employees, customers, and bribery and corruption (giving and appropriately declared their assets to others with whom we do business receiving, directly or indirectly). The the relevant tax authorities; and Financial Crime Policy contains the b. support governments, regulators and b. preventing tax evasion facilitation by our minimum risk-based control requirements law enforcement in wider financial crime employees or third parties acting for or that all our businesses, legal entities and prevention. on our behalf. employees must follow. The Financial Crime Policy is designed to ensure that Sanctions We will not tolerate any deliberate breach Barclays’ employees know how to identify of financial crime laws and regulations that Sanctions are restrictions on activity with and manage the legal, regulatory and apply to our business and the transactions targeted countries, regions, governments, reputational risks associated with all forms we undertake. entities, individuals and industries that are of bribery and corruption. imposed by bodies such as the European Barclays has adopted a holistic approach Union, the United Nations, groups of to financial crime and has one Group-wide Anti-Money Laundering countries, or individual countries, such as Financial Crime Policy that sets the control Money laundering (including terrorist the United Kingdom and the United States. requirements in four key risk areas. The financing and the proliferation of nuclear, In order to protect its reputation and other Financial Crime Policy applies to all our chemical or biological weapons) has been legitimate business interests, in certain businesses, legal entities and employees. identified as a major threat to the circumstances, Barclays' risk appetite for Employees receive training on financial international financial services community sanctions may be stricter than its legal crime risk management and are made and therefore to Barclays. The Financial obligations. aware that failure to comply with the Crime Policy is designed to ensure that all Financial Crime Policy may give rise to The Financial Crime Policy is designed to our businesses and legal entities have disciplinary action, up to and including ensure that all our businesses, legal adequate systems and controls in place to dismissal. entities and employees know how to mitigate the risk of the firm being used to identify and manage the risks associated facilitate money laundering. As a with sanctions, including the risk that transatlantic bank, the Financial Crime activity is undertaken through Barclays in Policy takes into account EU and US anti- breach of sanctions regulations. money laundering requirements, as well as For further details of the Barclays approach to guidance issued by bodies such as the + Financial Crime compliance and prevention, please Wolfsberg Group and the European see our Financial Crime Compliance Statement in the ESG Resource Hub at home.barclays/esg-resource- Banking Authority. hub/reporting-and-disclosures/