Barclays PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Barclays PLC demonstrates a very high level of transparency about its climate-policy lobbying. It names a wide array of concrete rule-makings and consultations it has engaged with, including the “European Securities and Markets Authority Call for Evidence on ESG ratings”, the UK “Government Net Zero Review: Call for Evidence”, HM Treasury’s “UK Green Taxonomy Consultations”, the “Transition Plans Task Force Consultation on a Sector-Neutral Framework for Private-Sector Transition Plans”, and bilateral submissions to the FCA on Sustainability Disclosure Requirements, among many others. The bank also explains how it lobbies and whom it targets: it “submitted bilateral responses” to regulators, “exchanged views with Members of the European Parliament and Financial Attachés of EU member states”, held “meetings with the Clean Growth and Energy Minister”, and engages “via trade organisations (Association for Financial Markets in Europe) and (American Chamber of Commerce to the European Union)”, providing a clear picture of both direct and indirect mechanisms and the specific authorities (ESMA, European Commission, BEIS, HMT, FCA, PRA, ISSB) it seeks to influence. Finally, Barclays is explicit about the concrete outcomes it pursues, advocating for measures such as “re-introduce capital allowance incentives” to drive energy-efficiency upgrades in SME premises, issuance of a UK Sovereign Green/Sustainability Bond, a “detailed hydrogen roadmap” backed by demand-side support and revenue-certainty mechanisms, a principles-based UK green taxonomy aligned with the EU framework, and bringing ESG ratings providers “into the regulatory perimeter”. Together these disclosures provide granular insight into the policies addressed, the methods used, and the precise legislative or regulatory changes Barclays seeks, illustrating comprehensive transparency over its climate-related lobbying activity.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Barclays embeds its public policy advocacy within senior oversight roles but stops short of a dedicated climate-lobbying governance regime. “Responsibility for the coordination and oversight of public policy advocacy lies with the Group Head of Public Policy and Corporate Responsibility,” working via an “internal Group Public and Regulatory Policy Steering Group,” and the Barclays PLC Board receives “regular updates on Public Policy and Corporate Responsibility matters (together with Group Reputation Risk Reports)” as well as “four updates … covering progress on our climate strategy, policy updates, industry trends, stakeholder engagement and target-setting,” demonstrating high-level monitoring. The bank’s Strategic Policy Group also “plays a key role in ensuring consistency across all public policy activity undertaken in the company’s name, and in relation to its objectives. This includes activity across the corporate group, as well as activity undertaken by third parties such as agencies and trade bodies,” indicating scope over direct and indirect lobbying channels. However, the company does not disclose a formal process for aligning the positions of trade associations with its climate commitments, no requirement for board sign-off on a climate-advocacy plan, nor a published climate-lobbying audit or review to manage alignment.	2