Barclays PLC

Changes to our Climate Change Statement are informed by engagement with our stakeholders, including shareholders, clients, climate experts and civil society groups. Our climate strategy is overseen by the Barclays Board, and continues to evolve, taking into account market, technological, regulatory and geopolitical developments, as well as all relevant risks we face as a result of climate change, including financial, credit and market risk. [...] As our climate strategy continues to evolve in light of the external environment in which Barclays operates, we are committed to continue to engage with our stakeholders.

At the Private Bank DPM, the Private Bank Wealth Management Forum (PBWM ManFo)[11] is the senior executive oversight body within PBWM. It comprises the PBWM CEO, the Global Head of Investments PBWM and other senior management. The forum is responsible for setting and ensuring the effective execution of Private Bank DPM's business strategy, inclusive of oversight of its Responsible Investing vision and goals. The PBWM ManFo meets monthly. Climate was discussed once at the PBWM ManFo in 2023. The PBWM ManFo has delegated climate change and Responsible Investing related matters to the Responsible Investing and Climate Change (RICC) Forum, which is attended by Global Head of Investments PBWM, who is also a member of the PBWM ManFo. The RICC Forum allows the senior executives of the Private Bank DPM to have oversight and visibility of climate‑related matters. Accountability for all investment management activities, including Responsible Investing, lies with the Global Head of Investments PBWM including Private Bank DPM. The RICC Forum met four times during 2023 and discussed topics including, but not limited to, climate change strategy, climate risk management and metrics. [...] The Responsible Investing team has a climate change specialist leading and supporting climate-related work. Two dedicated ESG analysts also joined the Private Bank DPM investment team in 2023 to support ESG integration into the investment process. The role of the Responsible Investing team is to advise, guide and upskill a number of different teams on Responsible Investing practices and to provide subject matter expertise. [...] Climate-related metrics are presented to the RICC Forum for quarterly management oversight. Whilst Private Bank DPM has made progress in enhancing its ESG-related data and metrics, it recognises further progress is needed. Private Bank DPM continues reviewing data requirements and will seek improvements to its data capabilities for risk management and oversight of climate-related matters. [...] For product governance and transaction approvals, the BIM Fund Review Panel (FRP) is comprised of senior business individuals, as well as representation from Legal, Compliance and Risk, and receives delegated authority from the Global Markets Product Governance Oversight Forum (PGOF). The FRP also refers certain proposals with ESG considerations to the Markets ESG Review Forum (MERF). MERF also acts as a point of escalation for material issues and matters relevant to the Markets ESG Framework, including having oversight of the control environment related to ESG within Markets. [...] The BIM governance structure aims to ensure that its approach to Climate Risk, as a Principal Risk in the Group's ERMF, as set out in the Barclays integrated TCFD report [58], is aligned to the frameworks and procedures within the wider Global Markets division. The BIM business is accountable for implementing Barclays policies, standards, and procedures (PSP) to consider various Principal Risks, including Climate Risk, as part of the investment process across its funds and mandates. Senior business accountability for BIM adhering to Barclays PSP resides with the Global Head of BIM, with oversight achieved through the governance modules highlighted above and through supervisory responsibility for BIM. The Global Head of BIM in turn reports into the Co-Head of Global Markets. [...] Climate-related responsibilities for principal equity investments are assigned to the PI Equity Committee (the Equity Committee). PI's focus is on investing in a responsible way, integrating relevant ESG risks and opportunities throughout the whole investment process, from preinvestment due diligence, through each investment's life and to ultimate exit. PI believes in the potential of ESG and climate change matters to either pose financial risks or to create value. The Equity Committee undertakes the senior approval responsibilities relating to the execution and management of all principal strategic equity and workout equity transactions managed on behalf of Barclays and all Group entities. The co-investment portfolio is included in the remit of matters for the Equity Committee to consider, with the ability to veto a proposed investment or asset purchase recommended by BBPLC (in its capacity as asset manager) or the right to require BBPLC (in its capacity as asset manager) to reconsider a recommendation by it to sell, to not invest or to not purchase an asset. [...] At a portfolio level (a subset of which is the co-investment portfolio), the risk management department carry out climate monitoring and reporting activities to senior management stakeholders.

Barclays puts considerable effort into both the expansion of its green and sustainable financing activities and the diminution in its fossil fuel financing. We also seek to contribute meaningfully to the improvement of policy and data capture and measurement. These are issues owned by the Board and discussed at the majority of Board meetings in 2021. They are also owned by senior management (10% of Executive Director remuneration is now tied to our progress in this field). [...] Oversight and management of climate-related issues are embedded within our governance structure. The Board and senior management have visibility of climate-related issues and are able to set climate-related strategy and oversee its implementation. [...] The Barclays PLC Board sets the strategic direction and risk appetite of the Group and is the ultimate decision-making body for matters of Group-wide strategic, financial, regulatory or reputational significance. The Board is also responsible for the oversight of social and environmental matters, including climate-related risks and opportunities. During 2021, the Board received four updates from the Group Head of Public Policy and Corporate Responsibility and Group Head of Sustainability, covering matters including progress on our climate strategy, policy updates, industry trends, stakeholder engagement and target-setting. The Board also received regular updates on Public Policy and Corporate Responsibility matters (together with Group Reputation Risk Reports) from the Group Head of Public Policy and Corporate Responsibility. These updates covered matters such as key government and regulatory policy, regulatory engagement and ESG matters including climate. In addition to these Board briefings, the Group Head of Public Policy and Corporate Responsibility regularly engaged with the Barclays Group Chief Executive, Chairman and Non-Executive Directors on a range of matters relating to the Group's climate strategy.

Barclays' Group Policy Development team creates public policy thought leadership content on behalf of Barclays. The work draws on the bank's expertise, data and insights, and is intended to inform the design and application of public policy solutions in response to pressing economic and societal challenges.

###### Governance structure Oversight and management of climate-related issues are embedded within our governance structure. The Board and senior management have visibility of climate-related issues and set climate-related strategy and oversee its implementation. ### Governance structure Barclays' governance structure consists of the Board, Board Committees, Executive and Management Committees across both business and legal entity lines. ###### Board oversight of climate-related risks and opportunities Barclays PLC Board The Barclays PLC Board sets the strategic direction and risk appetite of the Group and is the ultimate decision making body for matters of Group-wide strategic, financial, regulatory or reputational significance. The Board is also responsible for the oversight of social and environmental matters, including climate-related risks and opportunities. During 2021, the Board received regular updates on Public Policy and Corporate Responsibility matters (together with Group Reputation Risk Reports) from the Group Head of Public Policy & Corporate Responsibility (PPCR). These updates covered matters such as key government and regulatory policy, regulatory engagement and ESG matters including climate. Four climate-specific updates were provided to the Board by the Group Head of PPCR and Group Head of Sustainability, covering areas such as progress on our climate strategy, policy updates, industry trends, stakeholder engagement and target-setting. In addition to these Board briefings, the Group Head of PPCR regularly engaged with the Barclays Group Chief Executive, Chairman and Non-Executive Directors on a range of matters relating to the Group's climate strategy. Barclays PLC Board Responsible for the overall leadership of the Group (with direct oversight of matters relating to reputation, environment and culture). ###### Board Management Legal Entity / Other Board Audit Committee Assesses the integrity of the Group's financial statements and evaluates the effectiveness of the Group's internal controls. Board Risk Committee Reviews and monitors the Group's approach to managing the financial and operational risks including those associated with climate change. Group Risk Committee Chaired by the Group CRO monitors Principal Risks and key topics of a material nature to Barclays, such as climate change. The most senior executive body responsible for review and challenge of risk practices and risk profile, for climate risk and other principal risk types. Climate Risk Committee Sub-committee of Group Risk Committee. Supports the oversight of Barclays Group climate risk profile. Climate Transaction Review Committee Co-chaired by Group Head of PPCR considers the reputation risks associated with certain transactions and clients with reference to our stated position on climate. Group ExCo Responsible for the implementation of the Group's Climate Strategy across the Group. Operational Sustainability Steering Committee Responsible for the development and implementation of Barclays' operational sustainability strategy. Business/Legal Entity Committees & Forums Business-specific forums which consider individual aspects relating to climate. Formal escalation paths and criteria exist which support the Committees/Forums in discharging their responsibilities and are aligned to the Group's Operation of Committees Policy. For further detail on our corporate governance please refer to pages 117-199 in the Annual Report. Oversight and management of climate-related risks and opportunities occur at a number of levels in the organisation and across business lines and legal entities. The Chart above shows the key Climate Committees/Forums and members of senior management with responsibility for climate-related issues. These structures ultimately report up to the Board or, where within their remit, the Board Audit Committee or the Board Risk Committee.

### Governance
This statement will be reviewed annually by the Barclays Group Sustainability Committee. Any revisions are approved by the Head of Public Policy & Corporate Responsibility and any material changes of strategy or policy are referred to the Board Sustainability Committee. This statement is also noted by the Group Executive Committee.

### Referral and escalation procedure
Where Groups are assessed as higher risk following either an enhanced due diligence review or following a CTRF assessment they will be considered for escalation to the appropriate business review committee for consideration and a decision on whether to proceed if transaction related.

Should the issues be assessed as presenting material reputational risk they would be escalated to the Group Reputation Risk Committee, which comprises members of the Group Executive Committee.

### 1.7 Governance

This Framework has been reviewed by the Group Sustainability Committee, a management committee which is responsible for climate and sustainability matters and reports to the Group Executive Committee. The Framework has been approved for publication.

At the time of publication of this Framework:

- Responsibility for managing the Framework, including periodic reviews and adding eligible transition activities is the responsibility of, and as applicable, requires the approval of the Sustainability and ESG team;

- Updates to this Framework will require the review and approval of the Group Sustainability Committee;

- The Framework will be embedded into classification processes at a Business Unit level. All eligibility decisions for a transaction will also be subject to approval at the relevant sustainable finance governance forum depending on product group and business area. This will usually include representation from business lines, sustainable finance business heads as well as Sustainability and ESG team, Compliance and Legal teams. The relevant forum has decision making rights on the classification of assets, activities and transactions as 'transition' for the purposes of transition financing included in our Target.

Whilst our governance bodies and processes may change going forward, Barclays will at all times maintain robust governance in relation to this Framework and the approvals required under it.

- A process was established in Q3 2023 for the BISL Board to have visibility of climate-related activities. We will seek to enhance this process and further improve visibility of climate-related risks and opportunities at BISL Board level. [...] Established following the creation of the combined PBWM business, the PBWM Responsible Investing and Sustainability Governance (RISG) Forum will allow enhanced BISL management oversight of climate‑related risks and opportunities. [...] The BISL Executive Committee oversees two subcommittees – the BISL Investment Committee and BISL Product Committee. During 2023, the BISL Investment Committee was chaired by the Head of UK Multi‑Asset Wealth and delegated its role of reviewing, overseeing and approving responsible investment activities to the Responsible Investing (RI) Forum – please see the management oversight section on the following page. [...] The RI Forum facilitated discussions and decision-making in areas such as, but not limited to, stewardship and regulatory reporting responsibilities for ESG, including TCFD, during the reporting period. The Head of Responsible Investing was the Chair of the RI Forum. Members included Risk Analytics, Behavioural Finance, Fund Managers, Portfolio Construction, Performance Analytics, Group Sustainability, Compliance, Legal, Business Operational Control and Product Specialists. Meetings were held quarterly. [...] Initial discussions took place regarding the approach towards addressing the requirements of the TCFD at the RI Forum in Q3 2023. [...] The remit and membership of the RI Forum reflect activities for the reporting period of this report. Following the revised PBWM structure, the RI Forum has been replaced by the PBWM RISG Forum with revised terms of reference. The PBWM RISG Forum reports to the BISL Investment Committee in the revised structure and climate-related discussions will now continue at the PBWM RISG Forum. We will seek to enhance BISL management's visibility of climaterelated risks and opportunities at this forum.

Responsible corporate citizenship requires active engagement in legislative processes and policy discussions. Our engagement with policymakers and public policy advocacy is led by Barclays' Strategic Policy Group, and is guided by both 'The Barclays Way', our Code of Conduct, and the following procedural rules and controls. In our discussions, we have a responsibility to make contributions that are accurate, honest and evidence-based. Barclays' advocacy and engagement activities, including direct and indirect advocacy, must also be undertaken in line with our internal controls, including Barclays' Code of Conduct (The Barclays Way) which requires that "where we engage with governments and regulators on issues relevant to our business, we are honest and transparent in our communication with them." The Barclays Way also provides detailed guidance on speaking up and raising concerns, directing employees to speak up if they see "behaviours and practices that are not in line with our Barclays Values"; making clear that speaking up, whether formally or informally, will not come at a consequence to them. We also believe that Barclays should only engage on issues where we have a legitimate interest (for example, where there is a consequence for our business, our customers and clients, or our colleagues). Barclays' Group Head of Strategic Policy is responsible for the coordination and oversight of public policy advocacy. [...] Responsibility for the coordination and oversight of public policy advocacy rests with the Group Head of Strategic Policy, working in partnership with the regional heads of the Strategic Policy Group. [...] **Accountability and oversight:** The Group Head of Strategic Policy agrees the objectives and strategy, and provides direction and guidance to management. This is reviewed regularly by the Group Executive Committee and Board. **Consistency:** The Strategic Policy Group 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 in partnership with Barclays.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]As a major economic contributor – whether via the customers and clients we serve, the colleagues we employ, or the tax we pay – we believe it is important to contribute towards relevant public policy debates. To this end, we engage constructively with policymakers in jurisdictions where the firm operates, including with governments, legislatures, trade associations, consumer groups and other organisations like think tanks and NGOs.

Responsibility for the coordination and oversight of public policy advocacy lies with the Group Head of Public Policy and Corporate Responsibility (PPCR), working in partnership with the regional heads of Government Relations and Regulatory Relations and Policy via an internal Group Public and Regulatory Policy Steering Group.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Responsibility for the co-ordination and oversight of public policy advocacy lies with the Group Head of Strategic Policy.