Voluntary Application for Imposition of Requirements

Barclays Bank UK plc (“Barclays”)

Firm Reference No. 759676

To:
The Financial Conduct Authority (the “FCA”).

FAO: Laura Dawes, Head of Department.

Barclays hereby applies to the FCA under section 55L of the Financial Services and
Markets Act 2000 for the imposition of requirements on its Part 4A authorisation in the
terms set out below:

1. In respect of each of the calendar years 2018, 2019 and 2020, Barclays must
provide the Authority with written confirmation of:
(a) the number of whistleblowing cases opened and/or investigated in the
relevant year that involve allegations against a Senior Conduct Rules Staff
Member and/or Director of the Group (the “Subject”). For each case so
identified, Barclays must also provide the Authority with:
i. a written overview setting out the Subject’s identity, the nature of
the allegations made, the steps taken by Barclays to investigate
the allegations, including the management oversight and reporting
structure of that investigation, any conclusions reached and any
resulting outcome;
ii. a copy of GCWT’s records evidencing the matters in (i);
(b) the number of instances in that year where the Group has sought to
identify an anonymous Whistleblower. For each instance so identified,
Barclays must also provide the Authority with:
i. a written overview setting out the steps taken by it to follow the
process set out in the Whistleblowing Policy in relation to
identifying an anonymous Whistleblower;
ii. a copy of GCWT’s records evidencing the matters in (i);
(c) the number of instances in which a person has in that year alleged to the
Group that, as a Whistleblower, they were the subject of retaliation or
other detrimental action by the Group. For each instance so identified,
Barclays must also provide the Authority with:
i. a written overview setting out the steps taken by it to investigate
those allegations, the conclusions reached in that investigation and
any resulting outcome; and
ii. a copy of GCWT’s records evidencing the matters in (i).

If in relation to a given instance/case Barclays is unable to provide all of the
material required (e.g. as its investigations have not yet concluded), Barclays
shall confirm the material it cannot provide and shall provide it as soon as
reasonably possible.

2. Barclays must provide the Authority with the material required by paragraph (1) in
a single submission by 5pm on 31 March of the calendar year following the year to
which that material relates.

3. Barclays must by 5pm on 31 March of each of 2019, 2020 and 2021 provide the
Authority with a signed attestation confirming that:
(a) it has complied fully with the requirements of paragraph (1) and the
material provided thereunder in relation to the previous calendar year is
accurate and complete;
(b) its systems and controls in the preceding calendar year complied with the
requirements of SYSC 18 or, in the event Barclays cannot attest such

compliance, specifying all of the deficiencies that have been identified and
explaining the steps Barclays will take to resolve them; and
(c) all Senior Conduct Rules Staff Members and Directors of the Group have
completed training in the preceding calendar year on Barclays’ internal
whistleblowing arrangements, such to include (but not be limited to) how
to recognise and respond to a disclosure by a Whistleblower.

4. As regards the attestation required under paragraph (3) above, Barclays must
ensure that:
(a) it is provided to the Authority in the form of a certificate containing the
matters required by that paragraph;
(b) it is signed by its Whistleblowers’ Champion or, in his absence, the Group
Head of Compliance or an executive member of Barclays’ Board of
Directors and prior to its submission to the FCA is provided to the Group
Whistleblowers’ Champion.; and
(c) the attestor undertakes all reasonable due diligence (with the benefit of
such assistance as they may require from Barclays) in order to satisfy
themselves that the attestation provides an accurate and complete account
of the matters in paragraph (3) above.

5. In Barclays’ view, the material provided under paragraph 1 may contain
confidential information relating to the Group and its employees.

6. For the purposes of paragraphs (1) to (5) of this document, the following terms
shall have the following meanings:

(a) “Director” means any executive or non-executive director.
(b) “GCWT” means the Group’s Global Compliance Whistleblowing Team or
such other team within the Group that has responsibility from time to time
for investigating concerns raised/allegations made by Whistleblowers in
connection with Barclays.
(c) “the Group” means Barclays Bank plc for the period up to March 2018; and
Barclays Bank plc, Barclays Bank UK plc, Barclays Services Ltd and
Barclays plc from 1 April 2018.
(d) “the Handbook” means the Authority’s Handbook of rules and guidance as
in force from time to time.
(e) “Senior Conduct Rules Staff Member” has, in relation to Barclays, the
meaning given to that term in the Authority’s Handbook from time to time.
(f) “SYSC 18” means chapter 18 of the ‘Senior Management Arrangements,
Systems and Controls’ sourcebook in the Authority’s Handbook, as in force
from time to time.
(g) “Whistleblowers” has the meaning given to that term in the Authority’s
Handbook from time to time (and the singular term ‘Whistleblower’ shall
be interpreted accordingly).

(h) “Whistleblowing Policy” means the policy (including any and all procedures
and/or guidance supporting that policy) that applies to Barclays from time
to time, which relates to disclosures by Whistleblowers and/or the
requirements of SYSC 18 more generally.

Signed:
……………………………… for and on behalf of Barclays