Student Finance Overview

The bank does not have an ethical policy that applies to all its transactions. However, it has a number of statements and policies on ethical criteria that affect some of its activities.

1) The bank states that it does not engage in business operations in, or with the governments in, Sudan and Burma/Myanmar and that it considers other contentious borrowing requests on a case-by-case basis.

2) The bank has a statement on Environmental and Social Risk Assessment in Lending. This outlines its ESIA (Environmental and Social Impact Assessment Policy) which covers its business worldwide and applies in the following circumstances:

• Where there is a legal requirement for the project developer to conduct an environmental and social impact assessment and/or
• Where Equator Principles apply in project finance transactions.
• Where there is a known application of funds to a potentially sensitive project.

There is no minimum financial threshold for the application of the ESIA policy. The bank requires an ESIA to be undertaken for all transactions that fall within the scope of the ESIA Policy.

Minimum requirements for the scope of an ESIA are reported as including (amongst others): ecological resources, marine issues, human and economic development and quality of life values. The bank states that if it feels that after conducting an assessment 'the required action may prove too challenging to implement, or the client is unwilling to proceed, it will decline to participate in the project. However, as a general rule, it prefers to collaborate to improve project standards rather than simply step aside to allow a potentially less environmentally or socially inclined financial institution to support the transaction'.

In addition to this, it states that all clients operating in environmental sensitive sectors and which are subject to sanction by the bank's Group Credit Committee are referred to the Environmental and Social Risk Policy team for assessment (every two years as a minimum), in order to ensure lending transactions are included in the risk assessment process.

3) Regarding the defence industry, the bank states that 'we provide financial services to the defence sector within a specific policy framework. Each proposal is assessed on a case-by-case basis and legal compliance alone does not automatically guarantee our support. The status of the exporter and the importing/exporting country, the nature of the equipment, its likely use and the potential for it to be on-sold are all considered as part of the assessment process'.

4) The bank reports that it has a Nuclear Policy which outlines the risks involved in this sector and sets the minimum criteria expected if Barclays is to provide finance.

5) The bank has policy positions and statements of intent on various other areas.

These include animal testing, bribery and corruption, corporate conduct and ethics, the defence industry, environmental and social risk, environmental policy, human rights, sanctions and supply chain, amongst others.

For example, the animal testing statement states "when providing financial services to the pharmaceutical sector we have a strict policy that we will not enter into business transactions with any companies that do not comply fully with all relevant government regulations and the terms of their licences."

Application

• Has a Risk function team which includes a Environmental Risk Management team.
• The bank ensures the application of these policies through its Environmental and Social Risk Policy team. 
• The Reputation Council is involved in cases where the sensitivities are likely to remain significant. The bank's Reputation Council is a senior management committee reporting to the Group Executive Committee.

The bank reports that in 2011, a total of 219 transactions in Barclays operations around the world were referred to the Environmental Risk Management team. However, Barclays does not report whether some, or any, of these transactions were declined due to environmental or social risks.

1. The Barclays Group has a statement on human rights. This covers the following situations:           

• When assessing customers’ financial propositions generally, relationship managers should consider any relevant, material human rights aspects. In particular, it is important that all substantial loans to finance public or private sector projects, corporations or governments are reviewed for potential human rights impacts as part of the assessment/sanctioning process.
• Provision of project finance must be consistent with Barclays' own Environmental & Social Impact Assessment Policy (ESIA) policy and with the Equator Principles, which include specified human rights/social risk management criteria.
• New financial products and services that are developed should be consistent with Barclays human rights aspirations. Any risks or opportunities in this area should be evaluated.
• Where involvement may associate Barclays with actual or perceived violations of human rights, the issue is to be referred to the Group Brand and Reputation Committee.       

Barclays' policy positions, including the statement on human rights, can be found here.

Barclays does not report the percentage and total number of transactions that have undergone human rights screening.

No commitment to become fully carbon neutral was found.

Company has achieved 4% reduction in carbon emissions in 2011.