Case study: How Barclays is setting clear and consistent expectations of behaviour for its employees, making sure societal and environmental considerations are taken into account in decision-making
In 2012 Barclays was fined £290m to settle claims that it manipulated the London Interbank Offered Rate (Libor). A former Barclays banker, accused of manipulating the Libor interest rate, said he only did what he was told to do by his boss, without realizing it was wrong. The trial of five former Barclays employees charged with conspiracy to defraud by rigging US dollar Libor rates began in April 2016.
This case study is based on the 2015 Citizenship Data Supplement by Barclays published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate that CSR/ sustainability reporting done responsibly is achieved by identifying a company’s most important impacts on the environment and stakeholders and by measuring, managing and changing.
Abstract
In the aftermath of the Libor scandal, a key material issue for Barclays is ensuring proper governance and conduct, with a clear, accessible and well-communicated global code of conduct for all its employees. In order to set clear and consistent expectations of behaviour for its employees, ensuring societal and environmental considerations are taken into account in decision-making, Barclays took action to:
- implement a global code of conduct by launching The Barclays Way
- develop tools that help employees consider broader societal impacts and opportunities in business decisions, such as the Barclays Lens, a values based decision-making tool piloted in 2013 and
- update the Raising Concerns (Whistleblowing) Policy, introducing mandatory whistleblowing training for employees
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With this case study you will see:
- Which are the most important impacts (material issues) Barclays has identified;
- How Barclays proceeded with stakeholder engagement, and
- What actions were taken by Barclays to set clear and consistent expectations of behaviour for its employees, making sure societal and environmental considerations are taken into account in decision-making
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What are the material issues the company has identified?
In its 2015 Citizenship Data Supplement Barclays identifies a range of material issues, such as financial performance, risk to the financial system, regulatory compliance and remuneration. However, following the Ribor scandal, the £290m paid by Barclays in fines to settle claims that it manipulated the London Interbank Offered Rate and the trial of five former Barclays bankers charged with conspiracy to defraud by rigging US dollar Libor rates, setting clear and consistent expectations of behaviour for its employees has become a major concern for Barclays.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups Barclays engages with:
| Stakeholder Group | Method of engagement (in 2014) |
| Customers and Clients | • Stakeholder Dialogue Day • Barclays Debates • Barclays Asia Forum |
| Employees | • Employee Opinion Survey |
| Shareholders | • Stakeholder Dialogue Day • Barclays Debates |
| Government and Regulators | • Stakeholder Dialogue Day • Barclays Debates |
| Suppliers | • Stakeholder Dialogue Day • Barclays Debates |
| NGOs and Interest Groups | • Stakeholder Dialogue Day • Barclays Debates |
How stakeholder engagement was made to identify material issues
- In 2015 Barclays reviewed the existing materiality matrix based on the outcomes of an internal desktop study, which included a review of the engagement outcomes with external stakeholders.
- In addition to its regular stakeholder engagement activity, in 2015 Barclays conducted a reporting review in order to gain feedback on its integrated approach to reporting and Citizenship – a series of stakeholder interviews carried out by a third party. This review informed its materiality process and served as a basis for developing the content of its 2015 Citizenship Supplement.
What actions were taken to set clear and consistent expectations of behaviour for Barclays employees, making sure societal and environmental considerations are taken into account in decision-making?
In its 2015 Citizenship Data Supplement Barclays reports that it took the following actions for setting clear and consistent expectations of behaviour for its employees:
- Implementing a global Code of Conduct
- In 2013 The Barclays Way was launched, replacing several existing codes of conduct with one unifying document.
- The Barclays Way was updated in 2015 and a revised learning module and attestation process were introduced, based on a pass requirement to test understanding. [tweetthis]As at end 2015, 99% of Barclays employees had attested to The Barclays Way[/tweetthis].
- Barclays also supported the creation of a banking code of conduct governed by a body to oversee standards, with a Register of Approved Bankers.
- Developing tools that help employees consider broader societal impacts and opportunities in business decisions
- Such a tool is the Barclays Lens, a values based decision-making tool piloted in 2013. The Barclays Lens was developed as an assessment tool intended to ensure societal and environmental considerations were taken into consideration in decision-making.
- Training on the Lens has reached over 50,000 employees – more than one-third of Barclays’ workforce. Focus has been on senior leaders and key influencers across business units and Functions and in 2015 a ‘train the trainer’ method was introduced and an Online Module created, to help roll this out at scale across the business. The training combines discussion and case studies to help bring the tool to life and challenges employees to think about what they would do when dealing with an ethical dilemma. After the training, employees are encouraged to use the Barclays Lens in their everyday role and challenge proposals or propositions they think wouldn’t pass the ‘Lens test’.
- Updating the Raising Concerns (Whistleblowing) Policy
- On 30 April 2015 the Raising Concerns (Whistleblowing) Policy was updated, which sets out Barclays’ Whistleblowing process, encouraging employees to raise concerns about behaviour and practices that are contrary to Barclays’ Values and Behaviours.
- Barclays offers internal and external gateways for employees and others connected with the Bank to report confidentially and, where permissible, anonymously – if a person raising a concern wishes to remain anonymous, no effort will be made to identify them.
- Mandatory whistleblowing training was introduced to promote awareness of the process and the gateways, which has been completed by more than 84,000 employees globally.
- Arrangements have also been made for employees to obtain free, independent and confidential advice on whether or how to make a whistleblowing report by calling the Public Concern at Work advice line or by visiting their website. Employees are also informed that they can raise their concerns directly with a regulator.
- When a concern is raised, provided there is sufficient information, a case is created and the specific concern(s) independently reviewed. Concerns may be escalated to senior management and regulators.
- Barclays implements a strict no retaliation policy, in order to protect employees raising concerns and others helping in a subsequent investigation.
- Barclays also has a dedicated Whistleblowing Team consisting of seven specialist operatives based in London, Birmingham and New York and three more employees in Mumbai and Tokyo.
- 2015: 347 concerns were raised through the whistleblowing process.
Which GRI indicators/Standards have been addressed?
The GRI indicators/Standards addressed in this case are:
1) G4-56: Describe the organization’s values, principles, standards and norms of behaviour such as codes of conduct and codes of ethics – the updated GRI Standard is: Disclosure 102-16 Values, principles, standards, and norms of behavior
2) G4-57: Report the internal and external mechanisms for seeking advice on ethical and lawful behaviour, and matters related to organizational integrity, such as helplines or advice lines – the updated GRI Standard is: Disclosure 102-17 Mechanisms for advice and concerns about ethics
3) G4-58: Report the internal and external mechanisms for reporting concerns about unethical or unlawful behavior, and matters related to organizational integrity, such as escalation through line management, whistleblowing mechanisms or hotlines – the updated GRI Standard is: Disclosure 102-17 Mechanisms for advice and concerns about ethics
4) G4-SO4: Communication and training on anti-corruption policies and procedures – the updated GRI Standard is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures
References:
1) This case study was compiled using published information by Barclays Bank which is located at the links below. For the sake of readability, we did not use brackets or ellipses but made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original please revert to the following links:
https://www.home.barclays/content/dam/barclayspublic/docs/InvestorRelations/AnnualReports/AR2015/Barclays_PLC_Citizenship_Data_Supplement_2015.pdf (2015 Citizenship Data Supplement by Barclays)
https://www.home.barclays/content/dam/barclayspublic/docs/InvestorRelations/AnnualReports/AR2015/Barclays_PLC_Annual_Report_%202015.pdf (February 2016)
http://www.bbc.com/news/business-35999456 (April 2016)
Barclays Lens: https://www.home.barclays/citizenship/our-approach/enhancing-decision-making.html
2) http://www.fbrh.co.uk/en/global-reporting-initiative-gri-g4-guidelines-download-page
3) https://g4.globalreporting.org/Pages/default.aspx
4) https://www.globalreporting.org/standards/gri-standards-download-center/
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