# Barclays Bank PLC
Annual Report

31 December 2025

## Contents

**Strategic Report**

- Performance review 1
- Performance measures 7
- Managing risk 10
- Customer and clients 13
- Colleagues 15
- Society 17
- Section 172(1) statement 18

**Governance**

- Governance contents 20
- Corporate governance statement 21
- Directors’ report 35
- Schedule to the Directors' report: Sustainability statement 40
- Other governance 115

**Risk review**

- Risk review contents 118
- Risk management 120
- Material existing and emerging risks 123
- Principal risk management 144
- Risk performance 157
- Supervision and regulation 245

**Financial statements**

- Financial statements contents 262
- Independent Auditor's Report 263
- Consolidated financial statements 284
- Financial statements of Barclays Bank PLC 291
- Notes to the financial statements 295

EU Taxonomy tables 419

---

# Strategic report
## Performance review

The Strategic Report was approved by the Board of Directors on 9 February 2026 and signed on their behalf by the Chairman.

## Performance Review

### Overview
Barclays Bank PLC (BBPLC or the Company) is a wholly-owned subsidiary of Barclays PLC. The consolidation of Barclays Bank PLC and its subsidiaries is referred to as the Barclays Bank Group. The term Barclays refers to either Barclays PLC (BPLC) or, depending on the context, the Barclays Group. The term Barclays Group refers to BPLC together with its subsidiaries.

Barclays Bank PLC is the non ring-fenced bank within the Barclays Group. The Barclays Bank Group contains the Barclays UK Corporate Bank (UKCB), Barclays Private Bank and Wealth Management (PBWM), Barclays Investment Bank (IB) and Barclays US Consumer Bank (USCB) businesses. Barclays Bank PLC offers customers and clients a range of products and services spanning consumer and wholesale banking and is supported by the Barclays Group-wide service company, Barclays Execution Services Limited (BX), which provides technology, operations and functional services to businesses across the Barclays Group.

Barclays Bank PLC is focused on delivering for customers and clients around the world. Our diversified business portfolio provides balance, resilience and exciting opportunities. Barclays Bank PLC has strong global market positions and continues to invest in people and technology with the aim of delivering sustainable returns.

### Our structure
Through our four divisions, UKCB, PBWM, IB and USCB in addition to Head Office, we are organised and operate in a simpler way, delivering greater accountability and transparency, supporting synergies and reflecting the way we serve our customers and clients.

```mermaid
graph TD
    A[Barclays Bank PLC]
    A --> B[Barclays UK Corporate Bank]
    A --> C[Barclays Private Bank and Wealth Management]
    A --> D[Barclays Investment Bank]
    A --> E[Barclays US Consumer Bank]
```

#### UK Corporate Bank △
The UK Corporate Bank offers a range of Corporate Lending and Transaction Banking services to clients with an annual revenue of more than £6.5m through to FTSE350 companies.

- **Corporate Lending:** Offers a range of term, revolving, and overdraft facilities to medium and large sized corporates across the UK, with financing solutions tailored to specific industries and sectors
- **Transaction Banking:** Provides cash management, trade and working capital solutions, risk management solutions and payment services internationally

#### Private Bank and Wealth Management △
Private Bank and Wealth Management comprises PBWM UK - serving clients across the full wealth continuum in the UK and Crown Dependencies - and PBWM International, serving high- and ultra-high-net-worth clients in selected international markets.

- UK Digital Investing is for UK self directed investors, with investment starting from just £1
- UK Affluent is for UK clients with £250k to £3m of investible assets$^{1}$
- Private Banking UK is a full-service proposition for clients with investible assets of £3m+
- Private Banking International is a full-service proposition for clients with investible assets of £5m+ internationally$^{2}$ with a focus on clients in the Europe, Middle East and Asia wealth corridors

**Note**
1 The lower end threshold is under review
2 For India, the Private Bank proposition is available for clients with wealth of £3m+.
△ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

### Investment Bank △
The Investment Bank provides corporate clients, money managers, financial institutions, governments and supranational organisations with advisory, finance and risk management services.

- **Global Markets** provides institutional investors, sovereigns and corporates with a full range of execution services, ideas and risk management solutions across asset classes (Equities, Credit, Rates, FX and Securitised Products). The Research team provides institutional investors with data-driven analysis, actionable insights and access to our analysts across global sectors, markets and economies
- **Investment Banking** works with companies, governments and financial institutions worldwide to provide expert advice, innovative solutions and access to capital. It includes International Corporate Banking, which provides financial institutions and large corporate clients with wholesale lending and treasury solutions - supported by deep industry knowledge and local, on-the-ground specialists

### US Consumer Bank △
The US Consumer Bank is a leading co-branded credit card issuer and financial services partner in the United States.

- Barclays US Consumer Bank has more than 25 million customers and partnerships with 20 of America’s leading brands across the airline, travel, retail and affinity sectors.
- We provide co-branded, small business and private label credit cards, personal loans, online savings accounts and certificates of deposits.

### Head Office
Head Office provides centralised services across the Barclays Bank Group.

### The world in which we operate
Barclays Bank PLC is driven by a common Purpose: working together for a better financial future. To do so, we must be strong as an institution, prepared for the future, and able to navigate different market conditions and evolving trends.

We regularly review our operating environment and adapt to emerging trends. We've identified three areas relevant to our industry that we need to be aware of in the execution of our strategy, and continue to make good progress in addressing them:

- The impact of technology on banking products and services
- The role of capital markets as the principal driver of global growth
- The transition towards a low-carbon economy

In the development of our strategy and the evolution of our operating model, we regularly review and reflect on the changing environment in which we operate. Our plan is designed to remain resilient amid ongoing volatility and uncertainty, while meeting the needs of our wider stakeholders - including customers, clients, regulators, and shareholders.

We actively navigate risk and uncertainty, and are vigilant to deliver for our stakeholders as the environment evolves.

### Focus areas

**UKCB**
a. Driving productivity and seamless digital delivery, simplifying and improving client experience
b. Growing broad-based income through deeper client relationships with products and solutions which address their needs
c. Growing share of lending and attracting new clients

**PBWM**
a. Leveraging our simplified business structure - aligned to market opportunity in the UK and internationally - and reinvesting cost efficiencies to strengthen the business and support growth
b. Supporting Private Bank clients with their lifestyle, liquidity and legacy, and helping retail investors gain access to transparent, fairly priced investment solutions
c. Continuing to grow assets under management to increase the relative contribution of non-interest income, to deliver high-quality recurring revenue

△ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

### IB
a. Driving higher RWA productivity across all Investment Bank businesses
b. Deepening client relationships while maintaining prudent risk management
c. In Global Markets, sustaining momentum in our businesses with Top 5 market share$^{1}$, growing our focus businesses and continuing to scale more stable financing income
d. In Investment Banking, building share and product penetration across Advisory, Capital Markets and Treasury Coverage, and delivering an expanded reach for our International Corporate Bank

### USCB
a. Scaling and diversifying by growing existing partnerships and winning new partners
b. Investing in digitisation and AI to deliver enhanced customer experiences and operational efficiencies
c. Improving net interest margin by optimising pricing and credit mix, while reducing funding costs
d. Selective risk transfer to optimise use of balance sheet

### Year in review
**UKCB**
Barclays UK Corporate Bank serves over 13,000 businesses across the UK, playing an important role in joining together the different aspects of the organisation to deliver for clients. In 2025, the UK Corporate Bank delivered robust income growth of 14% underpinned by a strong deposit franchise and growing debt balances. Profit before tax was £949m and we maintained a disciplined cost-to-income ratio, ensuring operational efficiency.

Throughout the year, we responded proactively to a competitive market and shifting base rates. By adapting to evolving client needs and maintaining our focus on providing lending to help our clients to invest, we positively repositioned ourselves among peers and grew lending market share by 1%$^2$.

In 2025, we attracted over c.580 new to bank clients who drove c.50% of the increase in lending compared to 2024. This focus enabled us to achieve total loan growth of £4.6bn for the year. Despite our growth in lending, our loan loss rate remains well within our stated risk appetite and guidance.

Our willingness to lend plays a crucial role in giving UK businesses the confidence to invest in their workforce and technology helping in turn to unlock economic growth.

We have made strides in enhancing client experience by advancing our digital capabilities and streamlining processes. Clients now have more opportunities to self-serve through digital channels, including our 'Client Chat' capability, which resolves a significant number of queries at first contact. In 2025, c.50% of client interactions were self-served, compared to c.40% in 2024. We have also reduced client onboarding times by around 50% since the start of 2024 and, in response to client feedback, we have improved the speed, ease, and flexibility of our borrowing solutions, with further enhancements planned for 2026.

To strengthen client relationships and support diversified income streams, we've invested significantly in modernising our technology.

Our focus on deepening relationships and our efforts to improve experience have been reflected in improved client satisfaction scores. Measured as an independent benchmarking score by Savanta, our overall client satisfaction score has increased. Satisfaction scores relating to our client-facing colleagues are also strong, placing us second among our peers$^3$.

In April 2025, we announced a long-term strategic partnership with Brookfield to grow and transform our payment acceptance business, which provides critical infrastructure to the UK economy, processing billions of pounds of payments annually for small businesses and corporate clients.

Our extensive client relationships and experience of UK payments will benefit from Brookfield's global private equity expertise in payments, technology, operational transformation and corporate carve-outs, to ensure that the payment acceptance business is strategically positioned for long-term growth. The partnership will drive business growth by broadening the range of services offered and enhancing the experience for both existing and prospective clients.

**Note**
1 Top 5 market share as defined in the 20 February 2024 Investor Update: 1H23 and FY19 Coalition Greenwich Global Competitor Analytics. Industry wallet is defined as the total revenue of the following banks: BofA, Barclays, BNP Paribas, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, J.P. Morgan, Morgan Stanley and UBS. Analysis is based on Barclays’ internal business structure and internal revenues. Market share for purpose of this analysis is calculated as Barclays’ internal revenues divided by the aggregate revenue of the banks identified above within the given product set.
2 Bank of England December 2025 market data.
3 SavantaMarket Vue Survey Q4 2025

---

### PBWM
PBWM's vision is to be the investment partner for our clients, their families and the next generation. In 2025, financial markets witnessed trade and geopolitical volatility, and strong tailwinds driven by artificial intelligence (AI) - investors looked to take advantage of volatility spikes while diversifying risk. For PBWM, this led to strong transactional activity supported by increased trading on our digital investing offering, continued inflows into multi-asset portfolios, and alternative strategies such as private markets and hedge funds.

Our ability to support clients in such environments sustained our strong business performance. Assets Under Management (AUM) grew by £5.2bn and PBWM overall achieved a profit before tax of £367m.

At the start of 2025, PBWM simplified its business model to operate through two core areas: PBWM UK and PBWM International. Throughout the year, there were a series of strategic hires to strengthen the business.

In our UK Digital Investing business, we further enhanced client journeys and investment capabilities on our Smart Investor platform$^1$. In UK Affluent, we launched a pilot of a new digitally enabled mass affluent proposition - focused initially on Barclays UK Premier clients with £250k-£1m in assets to invest. Our ambition is to provide a fair-priced, transparently constructed advice service addressing the needs of this segment.

In our UK Private Bank, we expanded our Private Markets proposition with the launch of a new multi-vintage private equity fund and made it easier for clients to use our securities backed lending capability. In addition, we continued to grow our assets under management in our flagship funds and discretionary managed portfolios, and maintained their strong underlying long-term investment performance.

Internationally, we have been focused on building our presence in the Middle East and Asia. In order to further support our international capabilities, we continue to progress the development of our new Singapore booking centre, which we intend to launch during 2026.

Underpinning all of our strategic ambitions is a continued focus on improving our risk and control resilience, including by increasing our automation levels.

### IB
Barclays has a top tier Investment Bank supporting corporate and institutional clients around the world. In 2025, we maintained our rank of sixth across the Investment Bank in both Global Markets$^2$ and Investment Banking$^3$. We are a leading non-US-domiciled bank that can consistently compete with its US peers in each of the major capital markets of the US, Europe and Asia. Through our global expertise, scale and reach, we support global clients and help them achieve their commercial goals.

The Investment Bank delivered a profit before tax of £4,629m and remained disciplined on costs with consistent operational progress, following seven quarters of positive jaws.

RWAs remained stable for the fourth consecutive year. We grew income and improved return on RWAs by focusing on more stable income streams and on disciplined client management, capital deployment, and technology enhancements to improve client experience, such as BARXBot, a client-facing GenAI chatbot that automates how colleagues in Global Markets handle Requests for Quotes (RFQs) for clients.

The Investment Bank helped clients navigate a complex, evolving landscape throughout 2025 - one shaped by policy change, geopolitical events and economic conditions - by delivering strategic solutions through our diversified portfolio of products and services.

In Global Markets, we remain focused on executing our key product priorities while delivering our full suite of products and services to our clients. We have made strong progress with improved performance in the three focus businesses in Markets, while sustaining momentum in financing.

Our Research team is central to our Investment Bank franchise and continues to rank highly among our institutional client base.

In Investment Banking, we delivered revenue growth of 3% year on year. We also made good progress in key focus areas, continuing to optimise our loan book which helped to drive improved return on RWAs. This year, we maintained our traditional strength in DCM and saw an increase in both ECM fee share and advisory fee share with financial sponsors$^4$.

International Corporate Bank (ICB) was up 10% YoY, reflecting the continued rollout of the Treasury Coverage model - which has doubled the number of focus client with this model since 2024. This has also helped to drive year on year growth in US deposits$^5$.

**Note:**
1 Smart Investor will be known as Barclays Direct Investing
2 Based on external reported revenues. Peer banks include BoA, BNP, CITI, DB, GS, JPM, MS and UBS
3 Dealogic for the period 1 January 2025 to 31 December 2025 (as at 6 January 2026)
4 Dealogic Banking Fee share as at 31 December 2025
5 Reflects month end deposits

---

### USCB
The US is the world’s largest credit card market, and growing. With a c.3% share$^1$ of the total market and partnerships with 20 major brands, we continue to see significant opportunities for growth. In 2025, we delivered profit before tax of £513m, up from £408m in 2024 and £167m in 2023.

We remain focused on building lasting partnerships with top US brands. In 2025, we launched a new co-branded card programme with iconic automaker General Motors (GM) and acquired $1.6bn in receivables, further diversifying our mix of card partners. We also extended our current partnership agreements with Wyndham Hotels & Resorts, Upromise and our cruise line partners: Carnival, Princess and Holland America.

We added three million new customers organically in 2025. Our average payment rate of 31% in the fourth quarter is higher than pre-pandemic levels, further demonstrating the resilience and quality of our book.

We grew our retail deposit balances by 20% year on year and increased the percentage of core deposit funding for USCB from 64% to 69%. This was driven by demand for the tiered savings product and a new suite of exclusive digital banking products offered through our co-branded banking partnership with AARP.

In 2025, we announced that we had entered into an agreement to acquire Best Egg$^2$, a leading US digital direct-to-consumer originator of personal loans.

In 2025, we improved digital onboarding, increased self-service options and developed flexible payment features for our customers. We also expanded our Rewards Hub, an intuitive, one-stop digital shop for cardmembers to more easily manage their benefits. Over the past year, unique visitors to the Rewards Hub increased by 15%, demonstrating stronger brand loyalty and digital connection.

Since 2023, our investments in digitisation have led to an increase in customers using e-statements, and resulted in higher digital engagement with 96.2% of customers who interact with us doing so through digital channels$^3$. The percentage of customers using the Barclays mobile app also increased 5.5 percentage points year on year$^4$. Leveraging digital platforms to drive greater efficiency has helped reduce full year 2025 USCB cost to income ratio.

### Head Office
From 2003 to late 2019, Clydesdale Financial Services Limited (CFSL), a wholly-owned subsidiary of the Group, provided motor finance to customers in the UK. In 2020, CFSL was transferred from Barclays Bank PLC to Barclays Principal Investments Ltd (BPIL), another subsidiary of Barclays PLC. Barclays Bank PLC has provided an intragroup indemnity to BPIL in respect of historic litigation and conduct matters relating to CFSL.

Following the publication of the UK Financial Conduct Authority’s (FCA) consultation paper CP25/27 on a proposed Motor Finance redress scheme on 7 October 2025, Barclays has recognised in CFSL a provision of £325m in respect of this matter as at 31 December 2025 (as at 31 December 2024: £90m). Barclays has engaged with the FCA as part of its consultation process and the FCA’s Policy Statement and final redress scheme rules are currently expected to be published in February or March 2026. The ultimate financial impact on Barclays could differ from the recognised provision, which represents Barclays’ best estimate of the cost of redress based on the information currently available to Barclays.

In Q125, Barclays Bank Ireland PLC announced the completion of the sale of its German consumer finance business to BAWAG P.S.K., a wholly owned subsidiary of BAWAG Group AG.

**Note**
1 Source: newyorkfed.org/microeconomics/hhdc
2 The acquisition is expected to close in Q2 2026, subject to regulatory approvals and other closing conditions.
3 Measured at exit at end December 2025. Includes primary consumer card customers. Monthly interactions exclude Interactive Voice Response (IVR).
4 Reflects rate movement from December 2024 to December 2025 for mobile app users divided by open customers.

---

### Looking ahead

**UKCB**
We will continue to deepen client relationships, accelerate digital transformation and improve operational efficiency. We are focused on enhancing our product mix, strengthening income quality and driving technology-led improvements in client experience.

Efforts will be shaped by the evolving market environment, with an emphasis on adapting to client needs, regulatory changes and competitive pressures. We will continue to simplify processes, invest in talent, and leverage data-driven insights to support growth and resilience.

**PBWM**
Within UK Digital Investing, we're committed to delivering an integrated digital SIPP (self-invested personal pension). Following the completion of our pilot, we're launching our new UK Mass Affluent proposition, starting with Barclays UK Premier clients. We will also focus on supporting retail investing through the launch of Targeted Support following FCA's Advice Guidance Boundary Review.

Within the Private Bank we will continue to enhance our client experience, focusing on our digital capabilities as well as further expanding our credit proposition. We're investing in productivity and generative AI (GenAI) capabilities that support our front-line colleagues so they can spend more time with clients. We plan to expand our international business with further investments in the Middle East and Asia markets, including the launch of our new Singapore booking centre.

**IB**
Our goal is to strengthen our position as a leading global investment bank by leveraging our advisory expertise, deep sector knowledge, and differentiated client offering.

The Investment Banking business is focused on building share in Advisory and Capital Markets through productivity improvement, Treasury Coverage evolution and the continued investment and growth of our International Corporate Bank. Global Markets continues its focus on strengthening its core capabilities while maintaining a strong baseline of stable revenues in the form of financing.

We aim to be prudent managers of the firm's capital, and to drive consistent returns through client discipline, focused execution, capital nimbleness and operational efficiency. We're also streamlining operations, reducing legacy systems, and leveraging AI to scale and innovate.

We continue to work collaboratively across the Investment Bank towards a core set of cross-business priorities to create outcomes that generate growth. We work as one division to deliver for our clients holistically, reviewing overall relationship economics and cross-sell opportunities that will help shift from optimising to more profitably deploying capital.

We aim to achieve this through low single-digit compound annual income growth combined with disciplined cost management, driving operating leverage.

**USCB**
We remain committed to executing our strategy and improving returns. We will scale the cards business through organic growth and new partnership acquisitions as appropriate and accelerate USCB's diversification through the Best Egg acquisition.

We are embracing the latest technologies, such as GenAI and agile scalable platforms, to drive greater efficiency and deliver better experiences for our customers.

We continue to enhance our digital capabilities and provide seamless, intuitive experiences across all channels. We will maintain our focus on customer feedback, continually optimise our processes, and invest in tools to reduce friction and drive loyalty and sustainable growth.

---

# Strategic report
## Performance measures

### Performance measurement

#### Financial performance measures
The performance of Barclays Bank PLC contributes to the Barclays Group, against which the delivery of strategy is measured.

### Income Statement

| Barclays Bank Group results | 2025 | 2024 | 2023 |
| :--- | :---: | :---: | :---: |
| For the year ended 31 December | £m | £m | £m |
| **Total income** | **20,927** | **19,037** | **18,268** |
| Operating expenses | (12,593) | (12,245) | (12,270) |
| UK Regulatory levies | (228) | (242) | (149) |
| Litigation and conduct | (284) | (186) | (44) |
| **Total operating expenses** | **(13,105)** | **(12,673)** | **(12,463)** |
| Other net expenses | (13) | 0 | (4) |
| **Profit before impairment** | **7,809** | **6,364** | **5,801** |
| Credit impairment charges | (1,866) | (1,617) | (1,578) |
| **Profit before tax** | **5,943** | **4,747** | **4,223** |
| Taxation | (1,285) | (999) | (662) |
| **Profit after tax** | **4,658** | **3,748** | **3,561** |
| Other equity instrument holders | (783) | (792) | (808) |
| **Attributable profit** | **3,875** | **2,956** | **2,753** |

#### Consolidated income statement commentary
The Barclays Bank Group’s profit before tax increased 25% to £5,943m mainly driven by strong growth in Global Markets within IB.

The Barclays Bank Group maintains a diverse income profile across businesses and geographies. The appreciation of average GBP against USD negatively impacted income and profits, and positively impacted credit impairment charges and total operating expenses.

Refer to Note 2 Segmental Reporting for the Barclays Bank Group results by reporting segments.

#### 2025 compared to 2024
- Total income increased 10% to £20,927m (FY24: £19,037m)
  - IB income increased 9% to £13,330m (FY24: £12,192m), primarily driven by strong growth in Global Markets across both FICC and Equities, reflecting continued support provided to clients, and was additionally supported by higher income in the International Corporate Bank. This was partially offset by a decrease in Banking fees and underwriting income primarily from a strong prior year comparator in Equity Capital Markets, which included fees booked on a large UK rights issue in Q224. The overall increase includes FX adversity
  - USCB income increased 11% to £3,708m (FY24: £3,351m), driven by organic business growth, the acquisition of the GM portfolio, increased purchase activity, and a c.£40m one-off benefit related to partner rewards in Q425. NII increased 6% to £2,849m, including business growth and repricing initiatives. Net fee, commission and other income increased 29% to £859m driven by purchases and fee growth
  - UKCB income increased 14% to £2,125m (FY24: £1,856m). NII increased 21% to £1,532m, driven by higher average deposit and lending balances, and higher structural hedge income. Net fee, commission, trading and other income was stable at £593m
  - PBWM income increased 6% to £1,418m (FY24: £1,341m), driven by growth in deposit, invested asset and loan balances from net new inflows and market movements
  - Head Office income increased 16% to £346m (FY24: £297m income), mainly driven by the non-recurrence of the prior year loss on sale of the performing Italian retail mortgage portfolio, partially offset by the impact of the disposal of the German consumer finance business in Q125 and a fair value write-down of a legacy portfolio

---

- Total operating expenses increased 3% to £13,105m (FY24: £12,673m), primarily reflecting investment spend, business growth and inflation, partially offset by efficiency savings and favourable FX movements. Litigation and conduct charges of £284m were mainly related to a charge for motor finance redress in Q325
- Credit impairment charges were £1,866m (FY24: £1,617m), primarily driven by the impact from the acquisition of GM portfolio, an IB single name charge and elevated US macroeconomic uncertainty. US cards 30 and 90 day arrears rates$^1$ were 3.0% (Q424: 3.0%) and 1.6% (Q424: 1.6%) respectively. The USCB total coverage ratio decreased to 11.1% (December 2024: 11.4%) due to the acquisition of the GM portfolio
- The effective tax rate (ETR) was 21.6% (FY24: 21%). The 2025 ETR includes tax relief on payments made under Additional Tier 1 (AT1) instruments and on holdings of inflation-linked government bonds.

**Notes**
1 Including a co-branded cards portfolio classified as assets held for sale

### Balance Sheet Information
The following assets and liabilities represent key balance sheet items for the Barclays Bank Group

| As at 31 December | 2025 £m | 2024 £m |
| :--- | :---: | :---: |
| **Assets** | | |
| Cash and balances at central banks | 208,544 | 180,365 |
| Loans and advances at amortised cost to banks | 9,036 | 8,780 |
| Loans and advances at amortised cost to customers | 141,750 | 136,047 |
| Debt securities at amortised cost | 55,153 | 50,227 |
| Trading portfolio assets | 189,743 | 166,244 |
| Financial assets at fair value through the income statement | 185,002 | 191,845 |
| Derivative financial instruments | 252,192 | 292,356 |
| **Liabilities** | | |
| Deposits at amortised cost from banks | 20,393 | 13,252 |
| Deposits at amortised cost from customers | 324,358 | 306,124 |
| Financial liabilities designated at fair value | 293,527 | 279,777 |
| Derivative financial instruments | 240,757 | 279,331 |

#### Balance Sheet commentary
- Cash and balances at central banks increased £28.2bn to £208.5bn primarily driven by a higher liquidity pool, funded by increased wholesale funding and deposit growth across businesses
- Loans and advances at amortised cost to banks and customers increased £6.0bn to £150.8bn reflecting the strategic focus to grow customer lending in UKCB
- Trading portfolio assets increased £23.5bn to £189.7bn driven by increased trading activity to facilitate client demand in Global Markets, partially offset by the strengthening of spot GBP against USD
- Financial assets at fair value through the income statement decreased £6.8bn to £185.0bn as underlying growth in financing balances were more than offset by increased netting opportunities and the strengthening of spot GBP against USD
- Derivative financial instrument assets and liabilities decreased £40.2bn to £252.2bn and £38.6bn to £240.8bn respectively primarily driven by a reduction in mark-to-market on FX derivatives and strengthening of spot GBP against USD, partially offset by an increase in equity derivatives
- Deposits at amortised cost increased £25.4bn to £344.8bn driven by growth in deposits across International Corporate Bank, treasury and UKCB, partially offset by the strengthening of spot GBP against USD
- Financial liabilities designated at fair value increased £13.8bn to £293.5bn due to increase in client activity and growth in financing balances partially offset by increased netting opportunities and the strengthening of spot GBP against USD

The financial information above is extracted from the financial statements. This information should be read together with the information included in the accompanying consolidated financial statements.

---

### Capital and Other Metrics$^1$
Barclays Bank PLC capital requirements are set by the Prudential Regulation Authority (PRA) at a solo-consolidated level. Barclays Bank PLC solo-consolidated comprises Barclays Bank PLC, the parent, plus certain additional subsidiaries, whose inclusion within the consolidation is subject to PRA approval.

Leverage minimum requirements are set at the sub-consolidated level for Barclays Bank PLC. The sub-consolidated group represents the Barclays Bank PLC Group on a regulatory scope of consolidation subject to PRA approval. As a result, the Barclays Bank PLC leverage disclosures below are presented at Barclays Bank PLC sub-consolidated level. For further information, refer to Treasury and Capital Risk on page 231.

For the purpose of liquidity management, Barclays Bank PLC and its subsidiary Barclays Capital Securities Limited, a UK broker dealer entity, are monitored on a combined basis by the PRA under a Domestic Liquidity Sub-Group (Barclays Bank PLC DoLSub) arrangement.

| | 2025 | 2024 |
| :--- | :---: | :---: |
| Common equity tier 1 (CET1) ratio | 12.7% | 12.1% |
| Total risk weighted assets (RWAs) | £222.2bn | £223.6bn |
| UK leverage ratio (sub-consolidated) | 5.8% | 5.8% |
| Liquidity coverage ratio$^{2,3}$ | 149.7% | 147.9% |
| Net stable funding ratio$^4$ | 113.3% | 112.0% |

**Notes**
1 2024 comparatives for Capital, RWAs and Leverage are calculated applying the transitional arrangements in accordance with the CRR. This included IFRS 9 transitional arrangements and the grandfathering of certain capital instruments. Effective from 1 January 2025, these IFRS 9 transitional arrangements no longer applied. Effective from 29 June 2025, the grandfathered instruments no longer qualified as Tier 2 Capital.
2 Represents the average of the last 12 spot month end ratios. From June 2025, Barclays implemented a new methodology for calculating net stress outflows related to secured financing transactions in the liquidity coverage ratio.
3 Prior period comparators have been re-presented to reflect a change to the calculation of outflows from certain secured financing transactions that was adopted from Q1 2025.
4 Represents the average of the last four spot quarter end positions

As at 31 December 2025, Barclays Bank PLC’s solo-consolidated CET1 ratio was 12.7%, which exceeded the CET1 minimum regulatory capital requirement of 10.4%.

As a CRR firm, Barclays Bank PLC is required to disclose Return on Assets on a solo-consolidated basis of 0.4% (2024: 0.4%). The Barclays Bank PLC Group Return on Asset is 0.4% (2024: 0.3%).

### Non-financial performance measures
Barclays Bank PLC is part of the Barclays Group which uses a variety of quantitative and qualitative measures to track and assess holistic strategic delivery.

Barclays Bank PLC has addressed the Non-Financial Reporting requirements contained in sections 414CA and 414CB of the Companies Act 2006 through the disclosure contained in the Barclays PLC Annual Report 2025 on pages 44 to 47.

---

# Strategic report
## Managing risk

The Barclays Bank Group is exposed to internal and external risks as part of its ongoing activities. These risks are managed as part of our business model.

### Enterprise Risk Management Framework
At Barclays Bank Group, risks are identified and overseen in accordance with the Enterprise Risk Management Framework (ERMF), which supports the business in its aim to embed effective risk management and a strong risk management culture.

The ERMF governs the way in which the Barclays Group identifies and manages its risks.

The management of risk is then embedded into each level of the business, with all colleagues being responsible for identifying and controlling risk.

Financial crime risk was elevated to a principal risk in the ERMF, effective from 1 January 2025. Previously, financial crime risk was managed as part of compliance risk. Recognising the increased external threat of financial crime, this change will enhance transparency and visibility of financial crime risk within the Barclays Bank Group and reinforce independent assessment, management and oversight of financial crime risk.

### Risk appetite
Risk appetite defines the level of risk we are prepared to accept across the different risk types, taking into consideration varying levels of financial and operational stress. Risk appetite is key to our decision-making processes, including ongoing business planning and setting of strategy, new product approvals and business change initiatives.

The Barclays Bank Group may choose to adopt a lower risk appetite than allocated to it by the Barclays Group but cannot approve a higher risk appetite limit than determined by the Barclays PLC Board without its approval.

### Three lines of defence
The first line of defence comprises the revenue-generating and client-facing areas, along with all associated support functions, including Finance, Treasury, Human Resources and Operations and Technology. The first line identifies the risks, sets the controls and escalates risk events to the second line of defence. Employees in the first line have primary responsibility for their risks and their activities are subject to oversight from the relevant parts of the second and third lines.

The second line of defence is made up of Risk and Compliance and oversees the first line by setting limits, rules and constraints on their operations, consistent with the risk appetite.

The third line of defence comprises Internal Audit, and provides independent assurance to the Barclays Bank PLC Board and the Barclays Bank PLC Executive Committee on the effectiveness of governance, risk management and control over current, systemic and evolving risks.

The Legal function provides support to all areas of the Barclays Bank Group and is not formally part of any of the three lines of defence. The Legal function is responsible for proactively identifying, communicating and providing legal advice on applicable laws, rules and regulations. Except in relation to the legal advice it provides or procures, it is subject to second line oversight with respect to its own operational and compliance risks, as well as with respect to the legal risk to which the Barclays Bank Group is exposed.

### Monitoring the risk profile
Together with a strong governance process, using business and Barclays Group level Risk Committees, as well as Board level forums, the Barclays Bank PLC Board receives regular information in respect of the risk profile of the Barclays Bank Group. Information received includes measures of risk profile against risk appetite as well as the identification of new and emerging risks, which are derived by mapping risk drivers, identified through horizon scanning, to risk themes, and similar analysis. For further details of monitoring risks please refer to page 122.

In 2025, Barclays conducted an internal macroeconomic stress test under a severe 'Global Fragmentation' scenario, reflecting heightened US protectionism, inflationary pressures, and climate-related shocks. The exercise evaluated resilience to a UK recession, US economic contraction, and climate risks, testing vulnerabilities such as credit impairments, net interest income margin compression, and trading losses. The assessment confirmed the Group's resilience across capital, liquidity, and profitability, ensuring continued viability under adverse conditions.

We believe that our structure and governance supports us in managing risk in the changing economic, political and market environments.

For further detailed analysis of our approach to risk management and risk performance see the full Risk review on pages 118 to 261.

---

The Enterprise Risk Management Framework defines ten Principal Risks$^1$

| Principal Risks | Risks are classified into Principal Risks, as below | How risks are managed |
| :--- | :--- | :--- |
| **Climate Risk** | The risk of financial losses arising from climate change through, physical risks and risks associated with transitioning to a lower carbon economy. | A risk management framework has been implemented for managing financial and operational risks from climate change across Barclays’ first and second line activities. Barclays has enhanced its capabilities for identifying, assessing and quantifying the impact of climate physical and transition risks in the financed portfolios. Climate-related scenario analysis forms a key part of Barclays’ approach to assessing and quantifying the impact of both physical and transition risks. In addition, climate-related risk management activities are performed which includes setting risk appetite, monitoring key risk drivers, applying limits and controls to to stay within appetite, and undertaking relevant reporting. |
| **Credit Risk** | The risk of loss to the Barclays Bank Group from the failure of clients, customers or counterparties (including sovereigns) to fully honour their obligations to the Barclays Bank Group, including the whole and timely payment of principal, interest, collateral and other receivables. | Credit risk teams identify, evaluate, sanction, limit and monitor various forms of credit exposure, individually and in aggregate. The first line deliver business plans and products within risk appetite and all limits set by the second line, by maintaining detailed financial forecasts, applying controls and managing risks to which they are exposed. |
| **Market Risk** | The risk of loss arising from potential adverse changes in the value of the Barclays Bank Group’s assets and liabilities from fluctuation in market variables including, but not limited to, interest rates, foreign exchange, equity prices, commodity prices, credit spreads, implied volatilities and asset correlations. | Market risk teams use a range of complementary approaches to identify and evaluate traded market risk exposures. These risks are measured, limited and monitored by market risk specialists. The first line conduct trading activities within the risk appetite and all mandate & scale limits set by the second line. |
| **Treasury and Capital Risk** | **Liquidity Risk:** The risk that the Barclays Bank Group is unable to meet its contractual or contingent obligations or that it does not have the appropriate amount, tenor and composition of funding and liquidity to support its assets. **Capital Risk:** The risk that the Barclays Bank Group has an insufficient level or composition of capital to support its normal business activities and to meet its regulatory capital requirements under normal operating environments and stressed conditions (both actual and as defined for internal planning or regulatory testing purposes). This also includes the risk from the Barclays Bank Group’s pension plans. **Interest Rate Risk in the banking book (IRRBB):** The risk that the Barclays Bank Group is exposed to capital or income volatility because of a mismatch between the interest rate exposures of its (non-traded) assets and liabilities. This also includes credit spread risk in the banking book, the risk that the Barclays Bank Group is exposed to capital or income volatility because of changes in credit spreads on its (non-traded) assets and liabilities. | Treasury and Capital risk is identified and managed by specialists in capital, liquidity and asset and liability management teams. A range of risk management approaches are used such as limits, plan monitoring and stress testing. The assessment of liquidity risk should be comprehensive in assessing all sources of liquidity risk, representing all of the assets and liabilities, on-balance sheet and off-balance sheet items including at the regional and legal entity levels. Capital risk is predominantly assessed and controlled on a forward-looking basis through the means of capital forecasts and capital plans. Key capital risks must be identified well in advance to allow for mitigating actions to be agreed and become effective. Pension risks are monitored regularly and reported to relevant stakeholders and committees to support discussions with the relevant pension fund’s actuaries and trustees. IRRBB assessment uses earnings and value type metrics and it takes into account the type of IRRBB, the accounting nature and direct impact to earnings or capital; and, the appropriate holding period of the risk. |

---

| | | |
| :--- | :--- | :--- |
| **Operational Risk** | The risk of loss to the Barclays Bank Group from inadequate or failed processes or systems, human factors or due to external events (for example fraud) where the root cause is not due to credit or market risks. | Operational risks are managed in accordance with the Operational Risk Framework, owned and overseen by the second line. The primary responsibility for the management of operational risk rests within the business and functional units where the risk arises. Management complete Risk and Control Self-Assessments to assess operational risks and the effectiveness of the controls within processes. Identified risks, events and issues are escalated to senior management and the Board to ensure timely notification and to agree the appropriate response. |
| **Model Risk** | The potential for adverse consequences from decisions based on incorrect or misused model outputs and reports. | Model risk is managed in accordance with the Model Risk Management Framework supported by the Model Risk Policy and associated Standards . Model risk management applies a set of controls to identify and mitigate model risk within the Bank’s approved risk appetite which are centred around independent model validation. Model risk appetite is managed by residual risk tolerances, where applicable, commensurate with the nature and type of models used. |
| **Compliance Risk** | The risk of poor outcomes for, or harm to, customers, clients and markets, arising from the delivery of the Barclays Bank Group’s products and services (also known as 'Conduct Risk') and the risk to Barclays, its clients, customers or markets from a failure to comply with the laws, rules and regulations applicable to the Barclays Bank Group (also known as Laws, Rules and Regulations Risk 'LRR Risk'). | The first line is accountable for the overall assessment and management of compliance risks in their business or function and are responsible for implementing the requirements outlined in the Compliance Risk Management Framework (CRMF). Compliance must oversee adherence to the CRMF and the management of compliance risk, and provide independent second line of defence oversight to all Barclays businesses, providing advice and challenge where appropriate. |
| **Financial Crime Risk** | The risk that the Barclays Bank Group and its associated persons (employees or third parties) commit or facilitate financial crime, and/or, the Barclays Bank Group’s products and services are used to facilitate financial crime. Financial crime undermines market integrity and may result in: harm to clients, customers, counterparties or employees; diminished confidence in financial products and services; damage to the Barclays Bank Group's reputation; regulatory breaches; and/or financial penalties. | The first line is accountable for the overall assessment and management of financial crime risks in their business or function and are responsible for implementing the requirements outlined in the Financial Crime Risk Management Framework (FCRMF). Financial Crime must oversee adherence to the FCRMF and the management of financial crime risk, and provide independent second line of defence oversight to all Barclays businesses, providing advice and challenge where appropriate. |
| **Reputation Risk** | The risk that an action, transaction, investment, event, decision, or business relationship will reduce trust in the Barclays Bank Group’s integrity and/or competence. | Reputation risk is managed in accordance with the Group-wide Reputation Risk Management Framework (RRMF) supported by Reputation Risk Policies and associated Standards. Each business assesses reputation risk using standardised tools and the governance is fulfilled through management committees and forums, with clear escalation and reporting lines to the Group Board. |
| **Legal Risk** | The risk of loss or imposition of penalties, damages or fines from the failure of the Barclays Bank Group to meet applicable laws, rules and regulations or contractual requirements or to assert or defend its intellectual property rights. | Legal risk is managed by the identification and management of legal risks by the Legal function and the escalation of legal risk as necessary. The Barclays Bank Group's businesses and functions have responsibility for engagement of the Legal function in situations that have the potential for legal risk. Legal risk is also mitigated by the requirements of the compliance risk management framework, including the responsibility of the legal professionals to proactively identify, communicate and provide legal advice on applicable laws, rules and regulations. |

**Note**
1 The ERMF defines ten Principal risks. For further information on how these Financial and Operational Principal Risks apply specifically to the Barclays Bank Group, please see page 120.

---

# Strategic report
## Customer and clients

The following sub-sections include a summary of the Barclays Bank PLC specific items from the Barclays PLC Annual Report 2025, references to 'our' and 'we' refer to Barclays Bank PLC as part of the wider Barclays Group. For full details, refer to the Customer and clients section of the Barclays PLC Annual Report 2025.

Providing an excellent customer and client experience is key to our strategy. We seek to understand our customers’ and clients’ expectations and aspirations, developing products and services to build their trust and support them to achieve their ambitions.

### Engaging with customers and clients
Barclays Bank PLC is committed to serving our customers' and clients' best interests - and improving their experience is a key priority for the bank as we strive to make Barclays Bank PLC better. We frequently engage with customer and clients in a variety of ways - including running regular surveys, analysing customer complaints, direct interaction and drawing on data from millions of individual transactions - building our understanding of their evolving needs and enabling us to adapt to our products and services accordingly.

### In UK Corporate Bank
In UK Corporate Bank we are committed to helping clients invest in their future. We measure client feedback across various channels - starting with colleagues, and ensuring feedback from every interaction and conversation with clients is heard, understood and acted upon. We also leverage independent research from external providers throughout the year to assess how well we're meeting client needs, and identify opportunities to continually improve.

Our UK Corporate Bank is focused on delivering against a multi-year plan to provide a more seamless experience for clients. We're doing this with enhanced digital and self-serve capabilities, ensuring client journeys are faster and easier to complete, and delighting them with best-in-class service.

While we recognise there is more to do, the progress we are making on the delivery of our multi-year plan is promising. Our clients continue to value both the expertise of our colleagues and the strength of our relationships with them - citing us as easy to do business with, easy to communicate with, and responsive.

### In Private Bank and Wealth Management
In PBWM, our priority is to put clients at the heart of everything we do. We are committed to offering products and services that not only meet, but consistently exceed client expectations. By drawing on the full expertise and resources of the Barclays Bank Group, we ensure our clients benefit from specialist knowledge and strong, trusted relationships with our colleagues.

To better understand and anticipate client needs, we use a variety of channels including direct feedback and satisfaction analysis - and we are expanding these insight capabilities in 2026. This feedback drives continuous improvements to our offering, resulting in meaningful enhancements to the client experience.

Digital capabilities continue to be a key focus, and we're introducing functionality to give Private Bank clients a comprehensive digital view of their full relationship with Barclays Bank PLC. We have also streamlined our onboarding process, making it faster and simpler for new clients to join us. For our digital investing platform, we've made it easier for clients to discover and purchase funds along with a simpler pricing structure.

### In Investment Bank
In the Investment Bank, by reflecting on engagement with and feedback from our clients, we continued to build the expertise, knowledge and capabilities they're looking for.

We continue to invest in technology to improve client experience. BARXBot, our newly launched AI-powered assistant, is integrated with internal and external applications. It displays real-time quotes and pricing in the bank's trading platform - ready for the team to review and send to clients.

We're maintaining client centricity through our newly launched Global Treasury Coverage model - creating stronger connectivity between our International Corporate Banking, Debt Capital Markets, Risk Solutions Group, Corporate FX, Sustainable Banking and Policy Advisory teams. Our Lead Treasury Bankers have driven co-ordination across our product and coverage teams to ensure seamless client coverage, and to deliver more creative and tailored solutions for our clients.

### In US Consumer Bank
In USCB, we are committed to actively engaging with our customers and ensuring their voices shape the customer experience. Our enhanced Voice of the Customer (VoC) platform systematically collects and analyses insights, while cross-functional data analysis and benchmarking help us deliver world-class experiences. Our contact centre uses AI to summarize customer conversations resulting in improved accuracy and reduced average call handle time.

---

In 2025, USCB embedded a customer-centric transformation strategy to make it simpler for customers to apply and use their card, manage their account, enjoy rewards and benefits, and get help when they need it. We mapped each customer journey end to end, identified pain points and prioritised improvements based on customer feedback and impact potential.

---

# Strategic report
## Colleagues

The following sub-sections include a summary of the Barclays Bank PLC specific items from the Barclays PLC 2025 Annual Report. For full details, refer to the Colleagues section of the Barclays PLC 2025 Annual Report. Figures mentioned are for the Barclays Group, other than where specifically mentioned.

At the heart of achieving our plan to make Barclays simpler, better and more balanced are our colleagues. We are united by a shared Purpose, Values and Mindset, delivering to a consistently excellent standard in all we do - and we are making Barclays Bank PLC a great place to work, where every colleague can reach their potential.

For more information on our commitment to our colleagues, see home.barclays/sustainability/esg-resource-hub/reporting and disclosures/

### Engaging with colleagues
Sharing our strategy with colleagues - and explaining how they can contribute towards its delivery - has been a key part of our 2025 engagement. Regular, two-way dialogue helps us understand what is working well across the organisation and where we can improve.

Engagement with colleagues is delivered through townhalls, skip-level meetings, site visits, leader-led events, focus groups and surveys. Through our bi-annual Your View survey, our people can share their feedback on working at Barclays. We are committed to a respectful and inclusive environment where everyone feels safe to speak up. Our processes for raising concerns and whistleblowing provide channels for anonymous colleague feedback.

Our longstanding partnership with Unite in the UK offers further insight into the views of our people. We continue to consult with Unite on major change programmes to minimise job losses and prioritise reskilling and redeployment.

### Embedding a consistently excellent standard
A consistently excellent standard is what we expect of ourselves - and what our customers, clients and all our stakeholders trust us to deliver. This continues to be an integral part of our culture and a key enabler of our three-year plan.

Our consistently excellent culture-change programme continued to embed these standards across the organisation. Throughout 2025, local initiatives across divisions and functions supported Group-wide efforts to simplify processes, strengthen risk and control, and drive efficiency.

A consistently excellent standard is now embedded in HR tools, processes and products from hiring and induction, to performance management, promotions and development programmes.

In 2025, workshops were delivered to our colleagues globally, creating strong understanding across the organisation of what it means to deliver to a consistently excellent standard. We also launched the Risk and Control Digital Credential (RCDC) – our first Group-wide, externally accredited online learning programme, certified by the Institute of Risk Management. The RCDC equips colleagues with the knowledge and skills to proactively manage risk and strengthen controls. This initiative marked a significant step in our ongoing commitment to strong risk management and delivering to a consistently excellent standard.

### Investing in our talent
Our talent ambition is to help our colleagues grow, develop and thrive at every level of our organisation, building a strong talent pipeline for the future. In 2025, we strengthened how we identify, assess and develop high-potential talent, introducing greater rigour and consistency, through implementing our Talent Management Standards including a consistent definition of potential, approach to talent reviews and calibration. We delivered accelerator programmes and sponsorship initiatives and continued our Evolution leadership development programme. We also offered senior leaders a suite of practical tools, targeted workshops, and resources to develop their skills.

In 2025, we continued hiring interns, graduates and apprentices, and continued building on our relationships with key partners to support inclusive access to all our opportunities. Barclays won the National Graduate Recruitment Award for Most Popular Graduate Recruiter in Banking, Insurance and Financial services and was ranked in the top 20 in The Times Top 100 Graduate Employers list – recognising our focus on our Early Careers population as a key talent pipeline for the future.

We simplified and personalised learning for colleagues and invested in technology to support our People Leaders' development. For example, by piloting virtual coaching for our People Leaders and newly promoted Managing Directors (MDs) and expanding the deployment of our 360-feedback tool.

In 2025 we focused on enhancing our alumni proposition – including by launching a differentiated experience for our Executive Alumni. Our Group CEO hosted our first-ever MD alumni networking event in London, attended by members of the Executive Committee and Board.

---

### Our inclusive culture
We are evolving our approach to Inclusion and Opportunity with a focus on empowering our colleagues and leaders and driving company success - cultivating high-performing teams and providing rich opportunities for colleagues to progress, while aspiring to hire from the broadest global talent pools. We are committed to creating a workplace where everyone feels valued and respected, within a culture of belonging and equal opportunity for all.

### Supporting our workforce
Helping our people perform at their best remains a priority. Barclays provides a range of support for colleagues through its policies covering annual leave, life events, health issues, family and caring and flexible working.

We support colleague wellbeing with data-driven campaigns that encourage healthy habits and a positive culture, supported by our mental health awareness eLearning and our 'Be Well' online wellbeing portal. We also continued to enhance our provision for colleagues in the UK with an updated Employee Assistance Programme providing additional mental health support to their family members.

### Rewarding our colleagues
We offer eligible colleagues the opportunity to acquire Barclays shares on beneficial terms. In recognition of colleagues' collective effort towards delivering our three-year plan and the effort that is still required, in February 2025 we granted colleagues a share award and in 2026 we will grant a similar colleague share award, for a second successive year.

In July 2025, all UK colleagues were given access to Barclays Premier Banking, which offers a suite of exclusive products, services, and benefits.

### Enhancements to policy provisions
In 2025, we focused on aligning to our global policies to better support our colleagues and People Leaders in managing their work life at Barclays.

In November, we announced that our paternity leave policy in the UK will increase from two weeks to 16 weeks, and that the non-primary caregiver leave policy in Asia Pacific will increase from six weeks to ten weeks. Effective from 1 January 2026, these updates aim to help new parents spend more time with their families and support colleagues in balancing work and personal life.

### Our people policies
Our people policies$^1$ help us recruit the best people, provide equal opportunities and create an inclusive culture - in line with our Purpose, Values and Mindset, and in support of our long-term success. They are reviewed and updated regularly to ensure they remain aligned with our broader people strategy.

As part of our Fair Pay Agenda, we are committed to paying our colleagues fairly and appropriately relative to their role, seniority, skills, experience and performance. We pay at least a living wage in all our locations and provide colleagues with resources to ensure everyone has equal opportunity to progress.

**Note**
1 Our policies reflect relevant employment law, including the provisions of the Universal Declaration of Human Rights and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work.

---

# Strategic report
## Society

The following sub-sections include a summary of the Barclays Bank PLC specific items from the Barclays PLC Annual Report 2025, references to 'our' and 'we' refer to Barclays Bank PLC as part of the wider Barclays Group. For full details, refer to the Society section of the Barclays PLC Annual Report 2025.

Our success is measured not only by our commercial performance, but also by our contribution to society and the way we work together for a better financial future for all our stakeholders. Our focus on society falls broadly into three categories: Climate, Communities and Suppliers.

### Climate
In 2025, Barclays published the Barclays Transition Update, reiterated the ambition to be a net zero bank by 2050 and outlined how Barclays will continue to deliver against the strategy. In recognition of the realities of the transition and to balance this climate ambition, shareholder expectations and deliver this strategy, Barclay outlined in the Barclays Transition Update how the approach has evolved to focus on: working with clients on the transition, financing clients’ transition and scaling climate tech, while integrating nature and social considerations. Barclays Bank Group will, alongside other Barclays Group companies, contribute to achieving the ambition to be a net zero bank by 2050.

We recognise we have an important role to play in the transition, we cannot tackle this challenge on our own and that Barclays' ability to implement its climate strategy and deliver against its targets depends heavily on its clients progress and a wide range of external factors. We will consider and adapt our approach as needed to reflect the evolving landscape.

Please see the Climate and Sustainability Report in the Barclays PLC Annual Report 2025 and the Schedule to the Directors' Report: Sustainability Statement on page 40.

### Communities
Barclays seeks to make a positive impact in the communities where we operate by striving to help people build the skills and confidence they need to progress and by supporting businesses to grow.

Based on data and insight from our community partners, and aligned to business priorities, we evolve our programmes to help ensure they deliver meaningful and measurable benefit.

#### Skills and employability
A skilled workforce is essential for business growth and community prosperity – and supports a vibrant economy. Since 2023, our programmes have reached more than 8.16m people globally, helping them develop skills, confidence and connections.

#### Sustainable growth
Barclays understands that communities around the world rely on businesses to drive innovation and sustainable growth. Leveraging our resources, networks, and expertise, we offer comprehensive support to help businesses grow – from idea to IPO – through the programmes, dedicated workspaces and investment opportunities we provide. Since 2023, our initiatives have assisted over 14,000 businesses.

#### Charitable giving and community investment
We encourage our colleagues to support the causes they care about. In 2025, more than 4,900 employees around the world used matched funding from Barclays to amplify their fundraising and personal donations to their chosen charities – contributing a total of £9.4m (including matched donations) to 1,980 organisations. Through our UK Payroll Giving programme, 8,200 colleagues gave £1.2m in total, with matching support.

We also invest directly in our communities by providing funding and sharing our skills with trusted charities, non-governmental organisations and social enterprises. In 2025, our total investment – including charitable donations, management costs and the value of colleagues’ time – reached £49.1m.

### Suppliers
Barclays engages with Third-Party Service Providers (TPSPs), seeking to integrate sustainability considerations across our supply chain.

For full details on Climate, Communities and Suppliers, refer to the Society section of the Barclays PLC Annual Report 2025.

---

# Strategic report
## Section 172(1) statement

### How the Board has regard to the interests of stakeholders
In accordance with the Companies Act 2006 (the Act), this statement sets out how the Directors have had regard to the matters set out in Section 172(1) of the Act when performing their duty to promote the success of the Company for the benefit of its shareholders as a whole and to have regard to:

a. the likely consequences of any decision in the long term;
b. the interests of employees;
c. the need to foster business relationships with suppliers, customers and others;
d. the impact of operations on the community and the environment;
e. the desirability of maintaining a reputation for high standards of business conduct; and
f. the need to act fairly as between shareholders.

### Overview
Throughout the year, the Board and individual Directors engage directly and indirectly with a range of stakeholders to ensure they have a deep understanding of the impact of the Barclays Bank Group’s operations on key stakeholders, as well as their interests and views. This includes meeting with customers and clients, colleagues, investors, key regulators, non-governmental organisations (NGOs) and other stakeholders. This engagement, both directly and through reporting by executive management, to whom the day-to-day operations of the business are delegated, supports the Directors in complying with their legal duty under Section 172(1).

For more information on the Company’s key stakeholder groups and how we listen and respond to them, please refer to the “Customer and Clients”, “Colleagues” and “Society” sections of the Strategic Report. Further relevant information regarding the Barclays Group’s key stakeholder groups and how we listen and respond to them can be found in the “Our Stakeholders” section of the Barclays PLC Annual Report 2025.

You can find out more about how the Directors have had regard to the matters set out in Section 172(1) when discharging their duty, and the effect of those considerations in reaching certain decisions below and in the “What the Board did in 2025” section of the Governance Report.

During 2025 the Board considered (i) the evolution of the technology strategy and digital transformation plans in order to both protect the bank and its clients and customers and to support the aim to deliver a best in class client and customer experience; (ii) how to ensure continued operational and cyber resilience and meet regulatory expectations; and (iii) delivery and continued evolution of the Barclay Bank Group's strategy.

### Board oversight of technology, digital and cyber and operational resilience

#### Driving the technology strategy and digital transformation
Digital transformation and innovation is an imperative for financial services businesses in keeping pace with rapidly changing customer expectations and shareholder demands, in a highly regulated, competitive and complex environment where customer experience is key and the use and protection of customer data is paramount. Reflective of this, throughout 2025, the Board remained focused on the continued development of the Barclays Bank Group's technology strategy and ambitions. This included monitoring and overseeing the ambition and progress of technology initiatives by way of regular updates from the Group Chief Executive, the Group Co-Chief Operating Officers, business and function heads and the Group Transformation Office with spotlights on automating customer journeys and improving operating effectiveness.

Understanding how technology can help the Barclays Bank Group's customers and clients by making things simpler and safer, and building and maintaining trust and confidence has also been an area of ongoing interest for the Board. The Board supported the steps taken as part of the Barclays Group’s ‘Simpler, Better and More balanced’ strategy focused on customer service transformation, including evaluation of performance against the aligned Key Performance Indicators (KPIs) (Net Promoter Score, Complaints, Digital engagement). During 2025, Board members met with a number of clients to hear their perspectives on how the Barclays Bank Group is performing and where further enhancements can be made to client service and technology capabilities.

The Board regularly reviewed customer data metrics, including complaints and other non-financial KPIs to champion best in class customer service and continued good customer outcomes. In May, the Board approved retention of the role of the Consumer Duty Board Champion for a further year to support continued oversight of the ongoing embedment of the Consumer Duty across the Barclays Bank Group. The Board approved a regulatory Consumer Duty report in July, which indicated that Barclays Bank Group is continuing to deliver good outcomes for its customers, consistent with the Consumer Duty.

In addition to ongoing oversight of the Barclays Bank Group's digital transformation, to further enhance its understanding of technology matters, in June the Board travelled to San Francisco to meet with leaders of world-leading technology-first organisations about how their businesses have been at the frontier of technological change, to hear about how they have successfully navigated digital transformations, piloted emerging technologies, and generated a culture of rapid iteration,

---

while also keeping customers safe. This provided the Board with an opportunity to reflect on how these lessons could be applied to the Barclays Bank Group, including the role of the Board in overseeing and navigating the change ahead.

The Board considered how the Barclays Bank Group is fostering the development of the capabilities and talent that are essential for supporting the Barclays Bank Group’s digital agenda. Driving digital transformation is key both to the delivery of the products and services customers expect from us and to supporting the work of the Barclays Bank Group's colleagues. In April, the Chairman and the Chair of the Board Audit Committee visited India to meet with colleagues working on automation (including the use of AI responsibly) and digitisation of customer journeys to see end-to-end how processes are designed with a customer mindset. Reflective of this, the Board has also regularly considered key non-financial KPIs to assess whether the Barclays Bank Group is creating the right operating environment to make it simpler and more straightforward for colleagues to get things done.

#### Focus on operational and cyber resilience
The Board’s focus on technology transformation included oversight of operational and cyber resilience matters and technology infrastructure. This involved an evaluation of the wide range of risks associated with the scale of change required in response to an ever-evolving cyber-threat landscape. The Board provided oversight and challenge of the completeness and effectiveness of the programme of work to enhance cybersecurity capabilities and drive long-term resilience and, through the work of the Board Risk Committee, explored the AI threat landscape. The Board has continued to critically assess the risks associated with technology and digital transformation, including cybersecurity, operational resilience and data privacy, factoring ethical and reputational considerations in conjunction with regulatory expectations, and ensuring the Barclays Bank Group has the necessary capabilities to support a digitally driven agenda.

Following the 31 January 2025 IT incident that impacted Barclays' business in the UK, the Board and Board Risk Committee maintained close oversight of the incident review. The Board was kept informed of the approach to customer support and remediation and discussed with management the lessons that could be learned from the incident to improve the overall operational resilience of the Barclays Bank Group.

Considering the broader threat landscape, the Board monitored high-profile cybersecurity breaches in 2025 across banks, payment systems, retail and government institutions, using these as opportunities to further assess the resilience of Barclays Bank Group's systems and potential responses.

#### Oversight of delivery and continued evolution of the Barclays Bank Group's strategy
The Barclays PLC Annual Report 2024 set out the Barclays Group’s three-year plan to create a ‘Simpler, Better and More balanced' bank to improve operational and financial performance, and total shareholder returns.

During 2025 the Board has overseen and evaluated the Barclays Bank Group’s delivery of the strategy with regular updates from each business head covering matters including financial performance, customer and client service experience, strategic technology investment, and talent development. In approving the BBPLC medium term plan, the Board balanced the need for financial strength, consistent performance, prudent risk management and ongoing investment in support of the pursuit of operational excellence.

Building on our progress to date, the Board has considered with management how the Barclays Bank Group’s strategy will continue to evolve to enable it to deliver more for our customers, clients and shareholders, to continue to invest further to improve customers' experience and deepen relationships, while harnessing new technology, including AI, to improve efficiency and build segment-leading businesses and drive further growth. This was reflected in the Board overseeing and ultimately endorsing new targets to 2028.

Nigel Higgins
Chairman – Barclays Bank PLC
9 February 2026

---

# Governance
## Contents

Our corporate governance processes and the role they play in supporting the delivery of our strategy

| Governance | Page |
| :--- | :--- |
| • Corporate governance statement | 21 |
| • Directors’ report | 35 |
| Schedule to the Directors' report: Sustainability statement | 40 |
| • Other governance | 115 |

---

# Governance
## Corporate governance statement

### The Board$^△$
Details of the Directors who served during the financial year ended 31 December 2025 are set out in the table below, together with the composition of each of the Board’s Committees.

We welcomed Mary Mack to the Board as a Non-Executive Director with effect from 1 June 2025. Diane Schueneman stepped down from the Board with effect from 31 January 2025 and Mary Francis is to retire from the Board with effect from 6 May 2026. The Board is grateful to both Diane and Mary for their invaluable contribution to the Board during their respective tenures.

| | Board | Nominations Committee | Audit Committee | Risk Committee | Remuneration Committee | Sustainability Committee |
| :--- | :---: | :---: | :---: | :---: | :---: | :---: |
| **Nigel Higgins**$^1$ Chairman of the Board | C | C | | | M | C |
| **Robert Berry** Independent Non-Executive Director | M | | M | C | | M |
| **Anna Cross** Executive Director | M | | | | | |
| **Dawn Fitzpatrick** Independent Non-Executive Director | M | | | M | M | M |
| **Mary Francis**$^4$ Independent Non-Executive Director | M | | | | C | M |
| **Mary Mack**$^2$ Independent Non-Executive Director | M | | | | | |
| **Marc Moses** Independent Non-Executive Director | M | | M | M | | |
| **Brian Shea** Independent Non-Executive Director | M | | | | | |
| **C.S. Venkatakrishnan** Executive Director | M | | | | | M |
| **Julia Wilson** Independent Non-Executive Director | M | M | C | M | M | M |
| **Former Directors** | | | | | | |
| **Diane Schueneman**$^3$ Independent Non-Executive Director | M | M | M | | | |

C Chair of Board or Board Committee.
M Member of Board or Board Committee.

1 Nigel Higgins was appointed as a member of the Board Remuneration Committee with effect from 31 January 2025.
2 Mary Mack was appointed to the Board with effect from 1 June 2025.
3 Diane Schueneman stepped down from the Board and as a member of the Board Nominations and Audit Committees with effect from 31 January 2025.
4 Mary Francis is to step down from the Board, as Chair of the Board Remuneration Committee and as a member of the Board Remuneration and Sustainability Committees with effect from 6 May 2026.

### Attendance
Directors are expected to attend every Board meeting. During 2025, there were three ad hoc Board meetings held in addition to seven scheduled meetings.$^△$ Attendance at meetings in 2025 is set out in the table below. Owing to other commitments, some Directors were unable to attend certain ad hoc Board meetings, however they received papers in advance and had the opportunity to share their views with the Chair ahead of the meetings.

| Director | Meetings attended / eligible to attend | Ad hoc meetings attended / eligible to attend | Effective date |
| :--- | :---: | :---: | :--- |
| **Nigel Higgins** | 7/7 | 3/3 | Appointed 1 March 2019 |
| **Robert Berry** | 7/7 | 3/3 | Appointed 8 February 2022 |
| **Anna Cross** | 7/7 | 3/3 | Appointed 23 April 2022 |
| **Dawn Fitzpatrick** | 7/7 | 2/3 | Appointed 25 September 2019 |
| **Mary Francis** | 7/7 | 3/3 | Appointed 25 September 2019 |
| **Mary Mack** | 5/5 | 1/1 | Appointed 1 June 2025 |
| **Marc Moses** | 7/7 | 2/3 | Appointed 23 January 2023 |
| **Brian Shea** | 7/7 | 3/3 | Appointed 19 July 2024 |
| **C.S. Venkatakrishnan** | 7/7 | 3/3 | Appointed 1 November 2021 |
| **Julia Wilson** | 7/7 | 3/3 | Appointed 1 April 2023 |
| **Former Directors** | | | |
| **Diane Schueneman** | 0/0 | 0/1 | Stepped down 31 January 2025 |

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

### Overview of governance framework
Membership of the BPLC and BBPLC Boards is partially consolidated to drive efficiency and co-ordination, whilst also reducing complexity and unnecessary duplication. Consequently, the BBPLC Board is composed of a subset of the BPLC Board, with all members of the BPLC Board (except for the Senior Independent Director, the Chair of Barclays Bank UK PLC (BBUKPLC) and at least one other Non-Executive Director) also serving on the BBPLC Board. This structure facilitates oversight of the activities of BBPLC, in addition to which Board members have direct accountability to BPLC’s shareholders through their separate responsibilities as members of the BPLC Board.

The Board is committed to high standards of corporate governance and, in accordance with the Companies (Miscellaneous Reporting) Regulations 2018 (the 2018 Regulations), has adopted its own corporate governance arrangements, which it considers are appropriate to apply and are designed to facilitate effective decision-making to promote BBPLC’s long-term success.

The Board has chosen not to adopt and report against the UK Corporate Governance Code (Code), which is intended for companies with listed equity securities. Furthermore, whilst fully supportive of the Wates Corporate Governance Principles for Large Private Companies (in particular the focus on purpose, culture and colleague and stakeholder engagement), the Board considers that the Wates Principles are less appropriate for a wholly-owned subsidiary of a listed company, which is also a complex financial institution subject to a comprehensive regulatory regime. This is consistent with the approach of other significant subsidiaries within the Barclays Group which are subject to the 2018 Regulations.

Our governance framework is designed to:
- ensure we have an effective and entrepreneurial Board which makes decisions and provides oversight to promote BBPLC's success, creating long-term sustainable value for its shareholder and the ultimate shareholders of BPLC, having regard to the interests of all our other stakeholders
- ensure that our decision-making is aligned to our Purpose, Values and Mindset
- be effective in providing constructive challenge, advice and support to management
- provide checks and balances and drive informed, collaborative and accountable decision-making.

Set out below are the principles which underpin our corporate governance arrangements and how these principles have been applied during 2025. Certain additional information, signposted throughout this section, is also available in the Strategic report.

The Barclays Group-wide governance framework, which is set by BPLC, is designed to enable the effective management of the Barclays Group. This includes the setting of Barclays Group policies and approach in relation to matters such as Barclays’ Purpose, Values and Mindset, Barclays' Remuneration Policy and Barclays' Charter of Expectations. Where appropriate, this corporate governance statement makes reference to those Barclays Group-wide policies, which are relevant to the way in which the Company is governed.

The Company’s corporate governance principles and how the Company has applied them during 2025 and to the date of this report

### Principle One: Board leadership and company purpose
A successful company is led by an effective and entrepreneurial board, whose role is to establish the company’s purpose, values and strategy, satisfying itself that these and its culture are aligned, and make decisions to promote its success for the long-term benefit of its shareholder, having regard to the interests of other relevant stakeholders and factors.

- Through the leadership of the Board, a clear vision of Barclays' Purpose, Values and Mindset is articulated, underpinning and defining BBPLC's strategy and culture, with a drive to embed this at every level of the organisation.
- Given its fundamental importance, the Board regularly considered strategy matters throughout the year, including delivery against the Barclays Bank Group's elements of Barclays' three-year strategy and consideration of the new financial and operational targets through to 2028 to be announced on 10 February 2026. Further detail on the Company’s strategy can be found from page 1 of the Strategic report and details of the Barclays Group strategy can be found within the Strategic report of the Barclays PLC Annual Report 2025.
- The Board supports The Barclays Way, which provides the path for achieving a dynamic and positive culture. The Board believes that a positive culture, supported by effective leadership and a consistent ‘tone from the top’, is crucial to our success.

### What the Board did in 2025
The key areas of focus for the Board in 2025 are set out below.

#### Strategy and operational matters
- Considered strategy matters regularly throughout the year. In addition, regular reviews of the Private Bank and Wealth Management (PBWM), Global Markets, Investment Banking, US Consumer Bank (USCB) and UK Corporate Bank (UKCB) businesses enabled the Board to consider the key risks and opportunities for each of the businesses and monitor their progress against the targets set out in the Barclays Group's three-year plan.
- In Q3 2025, approved the acquisition of Best Egg, Inc. by Barclays Bank Delaware.

---

- Received focused updates on matters of Barclays Group-wide relevance, including financial crime risk, cybersecurity$^△$ operational resilience and transformation initiatives to support the delivery of the strategy. Our Section 172(1) statement from page 18 discusses the Board's consideration of stakeholder interests as part of its oversight of technology strategy.
- Reviewed and approved the BBPLC 2025 Medium Term Plan (MTP).
- Considered updates on climate and sustainability strategy through reports from the Board Sustainability Committee. A key focus during the year was the Barclays Transition Update and the Board confirmed its support for the parts of the Transition Update that relate to BBPLC's businesses. Other matters reported by the Board Sustainability Committee included updates on the Barclays Group's approach to nature and identifying and managing human rights risk. The Board also received an update on the Barclays Group's sustainable finance strategy which covered the Barclays Bank Group's businesses.$^△$
- In early 2025, approved the 2024 Barclays Group Modern Slavery Statement, which covered BBPLC.$^△$
- Considered culture and colleague engagement through regular updates on the Barclays Group-wide 'consistently excellent' (CE) cultural change programme and progress on embedment through reporting on CE metrics and Your View colleague survey results. Board members also engaged directly with colleagues during the year, including through town halls. Refer to the Colleagues section from page 15 of the Strategic report for more information on colleague matters.
- Reviewed progress on the Barclays Group-wide talent excellence programme aimed at enhancing practices to identify, assess and develop high potential talent across the organisation. This included consideration of the success measures and proposed outcomes for the programme.
- Confirmed that BBPLC's method of workforce engagement has been effective in 2025.$^△$
- Received updates on Barclays' inclusion and opportunity strategy which seeks to create a workplace where everyone feels valued and respected, within a culture of belonging and equal opportunity, insofar as it relates to the Barclays Bank Group.$^△$

### Finance
- Received regular updates from the Barclays Group Finance Director which included reporting on the financial performance of the Barclays Bank Group and its businesses.
- Reviewed and approved BBPLC’s financial results prior to publication.
- Reviewed and approved the payment by BBPLC in February 2025 of an interim dividend in respect of the year ended 31 December 2024 to its ordinary shareholder, and approved the payment in July 2025 of an interim dividend in respect of the first half of the year ending 31 December 2025. Details of dividends paid by BBPLC in 2025 are set out in Note 10 of the financial statements.
- Recommended to its shareholder for approval the reappointment of KPMG as BBPLC statutory auditor at its 2025 AGM.
- Confirmed the re-appointment of KPMG as the BBPLC statutory auditor with effect from the 2027 financial year following the conclusion of a formal audit tender process. Refer to page 37 for detail of the audit tender process.

### Governance, risk and regulatory matters
- Received regular updates on risk issues and emerging risks in the context of the macroeconomic, regulatory and geopolitical environment.
- Received regular updates on financial crime risk.
- Approved the BBPLC Risk Appetite Statement.
- Adopted the Barclays Group Enterprise Risk Management Framework (ERMF).
- Considered and approved the BBPLC elements of the Barclays Group Recovery Plan.
- Considered the Barclays Group's annual operational resilience self-assessment in respect of Important Business Services (IBS) and subsequent changes to the impact tolerance thresholds for certain IBS, insofar as they related to BBPLC.
- Received a Consumer Duty Dashboard for BBPLC and subsequently approved the BBPLC Consumer Duty Annual Board Report.
- Upon the recommendation of the Board Nominations Committee, considered succession planning for, and approved changes to, Board and Board Committee membership.
- Received and considered feedback from the Barclays Group’s key regulators insofar as it related to BBPLC.
- Received regular reports from the Chair of each Board Committee.

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

### Principle Two: Division of responsibilities
An effective board requires a clear division of responsibilities with the Chair leading the board and being responsible for its overall effectiveness, and the executive leadership of the company’s business being delegated to the Chief Executive. The board should consist of an appropriate combination of Executive and independent Non-Executive Directors, each with a clear understanding of their accountability and responsibilities. The board’s policies and procedures should support effective decision-making and independent challenge.

- A clear division of responsibilities has been established between the Executive and Non-Executive Directors. Page 21 sets out the details of the Board members, the majority of whom are independent Non-Executive Directors.
- Policies and protocols are in place to support effective decision-making and independent challenge, including the Barclays' Charter of Expectations which sets out the individual role profiles and required behaviours and competencies of the Chair, Non-Executive Directors, Executive Directors and Committee Chairs. In accordance with the Charter of Expectations, the Non-Executive Directors are responsible for providing effective oversight, strategic guidance and constructive challenge while holding the Executive Directors to account against agreed performance objectives. The Chairman meets privately with the Non-Executive Directors where appropriate.
- The Board's responsibilities are executed in part through the Board Committees, each of which has its own Terms of Reference which set out its remit and decision-making powers. The Chairs of each of the Board Committees provide a report on the work of the Committee at every scheduled Board meeting. Details of the principal Board Committees and their core responsibilities and activities in 2025 are set out later in this report.
- Appropriate information and support is provided to the Board, to enable it to undertake its work with due care and discharge its responsibilities.
- The Barclays Group Corporate Governance Operating Manual sets out guidelines as to how the Barclays Group's significant subsidiaries (and their respective Boards and Board Committees) should interact with each other, while providing guidance and clarity for management and Directors as to how these relationships and processes should work in practice. It is a dynamic document that evolves with the changing nature of the Barclays Group.

### The Board
Executive and Non-Executive Directors share the same duties and are subject to the same constraints. However, a clear division of responsibilities has been established. The Chairman is responsible for leading the Board and its overall effectiveness in directing the Company, demonstrating objective judgement and supporting a culture of inclusion and diversity of thought, and facilitating and encouraging constructive challenge and debate between all Directors, and which challenges executives where appropriate. The Chairman facilitates constructive Board relations and the effective contribution of all Non-Executive Directors, and ensures Directors receive information in an accurate, timely and clear form that is relevant to the discharge of their obligations. It is the Board’s responsibility to ensure that management delivers on short-term objectives, whilst promoting the long-term success of the Company and the Barclays Bank Group.

The BBPLC Matters Reserved to the Board ensures that appropriate coordination with the governance of the partially consolidated BPLC and BBPLC Boards is in place. The Matters Reserved to the Board specifies those decisions reserved solely to the decision-making power of the Board. Those matters include material decisions relating to strategy, risk appetite, medium term plans, capital and liquidity plans, risk management and controls frameworks, approval of financial statements, approval of large transactions and the approval of share allotments, dividends, share buy-backs and reputation risk with strategic implications relating to the Barclays Bank Group. The Board has delegated the responsibility for making and implementing operational decisions and running the Company’s business on a day-to-day basis to the Chief Executive Officer, supported by the BBPLC Executive Committee.

The current Board comprises a Chairman, who was independent on appointment, two Executive Directors and seven independent Non-Executive Directors. The Board comprises a majority of independent Non-Executive Directors, bringing significant expertise and independent challenge. The independence of the Non-Executive Directors is considered by the Board Nominations Committee annually. The percentage of independent Non-Executive Directors, including the Chairman, on the Board is 80%.$^△$ In respect of its Committees, except for the Board Sustainability Committee whose membership comprises 83% independent Non-Executive Directors,$^△$ the percentage of independent Non-Executive Directors on each of the Board Nominations Committee, Board Audit Committee, Board Risk Committee and Board Remuneration Committee is 100%.$^△$

There is no workforce representative on the Board or its Committees.$^△$

### Non-Executive Directors' time commitment and conflicts of interest
Non-Executive Directors, including the Chairman, are informed of the minimum time commitment prior to their appointment and they are required to devote sufficient time to the Company to discharge their responsibilities effectively.

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

The time commitments of Directors are considered prior to appointment and are monitored by the Board Nominations Committee. All Directors must seek approval (providing an indication of expected time commitment) before accepting any significant new commitments outside of Barclays. The Board is satisfied that there are no Directors whose time commitment is considered to be a matter for concern. A record of each Director's external time commitments is maintained by the Company.

In accordance with the Act and the Company's Articles of Association (Articles), the Board has authority to authorise conflicts of interest, and this ensures that the influence of third parties does not compromise or override the independent judgement of the Board. A conflicts register is maintained by the Company, which is a record of actual and potential conflicts, together with any Board authorisation of the conflict.

### Executive Committee
During 2025, the BBPLC Executive Committee membership included the Chief Executive Officer, the President of BBPLC and Head of Investment Bank Management, the heads of the four operating divisions within the Barclays Bank Group: UKCB, PBWM, the Investment Bank (IB) and USCB, the BBPLC Chief Financial Officer, BBPLC Chief Risk Officer, and other BBPLC functional partners.

We welcomed the following new members of the BBPLC Executive Committee in 2025:
- Olivier Vigneron, Chief Risk Officer
- Georges Lauchard, Chief Operating Officer
- Kate Vetch, Chief Compliance Officer

Anna Cross joined the BBPLC Executive Committee in 2025 as Interim BBPLC Chief Financial Officer, following the resignation of Aunoy Banerjee as BBPLC Chief Financial Officer, who stepped down on 23 October 2025.

The BBPLC Executive Committee meets quarterly and is chaired by the President of BBPLC and Head of Investment Bank Management. In addition to the day-to-day management of the Company, the Executive Committee supports the Chief Executive Officer in ensuring that the Barclays values, strategy and culture align, are implemented and are communicated consistently to colleagues.

### Principle Three: Composition, succession and evaluation
A board with the right balance of skills, experience, independence and knowledge is critical to the sustainable delivery of value to the company’s shareholder and broader stakeholders. The size of the board should be guided by the scale and complexity of the company and appointments should be based on merit against objective criteria, and having regard to the Board's Inclusion and Opportunity Policy, and subject to a formal, rigorous and transparent procedure, which is underpinned by an effective succession plan for the board and senior management. A successful board is a cohesive board that provides informed and constructive challenge to the management team and measures its effectiveness.

- The membership of the Board is drawn exclusively from the BPLC Board. The size and composition of the Board is considered appropriate for the Barclays Bank Group. There is a good balance between Executive and independent Non-Executive Directors, with the Non-Executive Directors able to provide essential independent challenge. Board members have a strong combination of technical, financial (including significant financial services experience) and commercial skills along with broader experience in culture and colleague engagement. Further detail on industry and leadership experience and international experience, on the basis of Board composition as at 31 December 2025, is set out in the tables below.$^△$
- All appointments to the Board are based on merit against objective criteria, and having regard to the Board Inclusion and Opportunity Policy. Board appointments are made following a formal, rigorous and transparent process, facilitated by the Board Nominations Committee, with the aid of external search consultancy firms. The Board Nominations Committee oversees succession to both Board and senior management positions.
- The Company continues to strive to build an inclusive workplace, making the most of the different backgrounds, perspectives, and experiences of our colleagues to better serve the Barclays Bank Group's customers and clients. You can read more about Barclays' approach to inclusion within the Colleagues section of the Barclays PLC Annual Report 2025 and in the Inclusion and Opportunity section below.
- There is regular review of the leadership and succession needs of the business to maintain depth and diversity of thought in the talent and succession pipeline at the Board, executive and key management level. This remains a key focus to maintain the quality of leadership that is in place to lead the business in the delivery of the Barclays Bank Group's strategy.
- Ongoing training and professional development is key in providing Board members with a deeper and more granular understanding of the business, contributing to informed and sound decision-making. Further information on training and induction for Directors in 2025 can be found in the Training and induction section later in this report.
- Effectiveness is supported through annual reviews of the Board, Board Committees and individual Directors. In 2025, the Board, Board Committee and individual Director effectiveness reviews were conducted internally.

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

- Feedback from the 2025 Board effectiveness review indicated that the Board continues to operate effectively, with a collegiate and respectful culture. The review noted that meetings are well-chaired and that the Board provides an appropriate balance of support and constructive challenge. The interaction between the Board and the Board Committees was commented on favourably, providing appropriate visibility of key matters and emerging themes. Feedback indicates that concurrent meetings of the BPLC and BBPLC Boards remain effective and continue to work well in practice.

| Industry and leadership experience$^1$ (number of Directors)$^△$ | International experience$^2$ (number of Directors)$^△$ |
| :--- | :--- |
| Financial services 10 | UK 10 |
| Political/Regulatory Experience 10 | US 5 |
| Current/recent Chair/CEO 8 | Rest of the World 5 |
| Accountancy/Auditing 4 | |
| Operations/Technology 2 | |

1 Individual Directors may fall into one or more categories.
2 International experience is based on the location of the headquarters/registered office of a company. Individual Directors may fall into one or more categories.

### Board Nominations Committee
The Board Nominations Committee is comprised solely of independent Non-Executive Directors. The Board Nominations Committee is chaired by Nigel Higgins, as Chair of the BBPLC Board. Julia Wilson is the other member of the Committee. Diane Schueneman stepped down with effect from 31 January 2025.

The Board Nominations Committee held two scheduled and no ad hoc meetings in 2025.$^△$ Board Nominations Committee meetings were attended during the year by the Chief Executive Officer and the Barclays Group Human Resources Director.

Attendance at Board Nominations Committee meetings during 2025 was as follows:

| Member | Meetings attended / eligible to attend | Effective date |
| :--- | :---: | :--- |
| **Nigel Higgins (Chair)** | 2/2 | Appointed 1 March 2019 |
| **Julia Wilson** | 2/2 | Appointed 1 April 2023 |

The principal role and responsibilities of the Board Nominations Committee, pursuant to its Terms of Reference, are:
- considering appointments to the Board, its Committees and boards of BBPLC's significant subsidiaries
- considering the composition of the Board and its Committees
- considering succession planning and talent management
- evaluating Board effectiveness
- assessing the length of Directors’ tenure
- considering Board induction and training
- considering governance matters.

During 2025, the principal activities of the Board Nominations Committee included:
- Reviewing and approving Board and Board Committee size, composition and succession planning, taking into account tenure, time commitment, skills, knowledge, experience and independence of the Directors, and identifying any desirable skills to aid the Company in operating and competing effectively (and leading the search and recruitment process).
- Receiving updates on the Company’s executive governance framework, executive talent and succession management, including Executive Committee succession planning and reviewing and approving proposed changes to Executive Committee composition.
- Continuing to support, alongside the Board, the Barclays Group’s inclusion and opportunity strategy.$^△$ You can read more about Barclays' approach to inclusion within the Colleagues section of the Barclays PLC Annual Report 2025.
- Recommending to the Board for adoption an updated version of the Board Inclusion and Opportunity Policy in February 2026, to ensure the policy continues to reflect the Group's inclusion and opportunity strategy. The Policy confirms that the Board aims to meet the recommendations of the FTSE Women Leaders Review regarding gender balance on boards and the Parker Review on ethnic representation on boards, details of which are set out below and further detailed in the Inclusion and opportunity section:

| | |
| :--- | :--- |
| **FTSE Women Leaders review gender balance ambition** | That: (i) the proportion of women on the Board is at least 40%; and (ii) at least one of the following senior Board positions is held by a woman: Chair, Chief Executive, Senior Independent Director or Chief Financial Officer. |
| **Parker review ethnic representation ambition** | That at least one Board member is from an ethnic minority background excluding white ethnic groups. |

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

- Receiving updates on succession planning for the Company's main subsidiary company boards.
- Considering an interim review of the 2024 Board effectiveness recommendations, and approving that an internally conducted Board, Board Committee and individual Director effectiveness review be undertaken in respect of 2025.

The Board Nominations Committee effectiveness review was internally conducted for 2025, with the results confirming that the Committee is operating effectively.

### Appointment and retirement of Directors
The appointment and retirement of Directors is governed by the Articles, the Act and related legislation.

The Articles may be amended only by a special resolution of the shareholders. The Board has the power to appoint additional Directors or to fill a casual vacancy amongst the Directors and any Director so appointed holds office only until the next AGM where they may offer themselves for re-election.

The Board Nominations Committee regularly reviews the composition of the Board, Board Committees and Executive Committee and the core skills, experience, knowledge and diversity of thought required. For the Board, it is standard practice to appoint any new Non-Executive Director or Chair for an initial three-year term, which may be extended for up to a further three-year term. As such, Non-Executive Directors typically serve up to a minimum of six years, although this period may be extended where considered appropriate by the Board Nominations Committee.

### Inclusion and opportunity
On the recommendation of the Committee, the Board adopted an updated version of the Board Inclusion and Opportunity Policy in February 2026, as described above. The policy confirms the Board's support for the Barclays Group's culture in which Barclays is committed to continuing to build an inclusive workplace.

As at the date of this report:
- BBPLC Board gender diversity stands at 50% female,$^△$ meeting the FTSE Women Leaders Review recommendation of 40% gender diversity, and the role of Chief Financial Officer is held by a woman.
- 20% of the Board (two Directors) are from a minority ethnic background (excluding minority white ethnic groups)$^△$ meeting the Parker review recommendation of having at least one Board member who is from an ethnic minority background (excluding white ethnic groups).

You can read more about Barclays' approach to inclusion within the Colleagues section and Board Nominations Committee report of the Barclays PLC Annual Report 2025.

### Training and induction
The Committee, together with the Group Company Secretary, supports the Group Chairman in facilitating continuous training and development for Directors. Directors are encouraged to participate in regular training and development sessions integrated within the Board and Board Committee schedules, and may additionally request tailored training as required. In 2025, Directors enhanced their business knowledge through Board deep dives into the Company's operating divisions and key Group functions, including Legal, Risk, Compliance, and Internal Audit. The Board also received regular updates on corporate governance matters and certain Barclays’ Compliance Risk policies, including financial crime,$^△$ as well as an annual briefing on the Senior Managers Regime.

A tailored induction programme is delivered for all new Directors appointed to the Board. This provides them with an understanding of the Barclays Bank Group, its purpose, strategy, business areas and key issues it currently faces. When a Director joins a Board Committee, the schedule also includes an induction to the operation of that Board Committee.

### Principle Four: Audit, risk and internal control
A board should establish formal and transparent policies and procedures to (i) identify the nature and extent of principal risks the company is willing to take in order to achieve its long-term strategic objectives; (ii) manage such risks effectively; (iii) oversee the internal control framework; (iv) promote the independence and effectiveness of internal and external audit functions; and (v) satisfy itself on the integrity of financial reporting.

- The Company is committed to operating within a strong system of internal controls that enables business to be transacted and risks taken without exposure to unacceptable potential losses or reputational damage. The principal risks facing the Barclays Bank Group have been identified and robust processes are in place to evaluate and manage such risks including regular reporting to, and oversight by, the Board Risk Committee and the Board. A key component of the risk management framework is the ERMF, which supports the business in its aim to embed effective risk management and a strong risk management culture. The ERMF is designed to identify and set minimum requirements, in respect of the main risks, to achieve the Company’s strategic objectives and to provide reasonable assurance that internal controls are effective. Further detail on the principal risks and management of them can be found in the Strategic report.

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

- The Board approves the Barclays Bank Group's risk appetite (the amount of risk the Barclays Bank Group is prepared to take to earn an appropriate return while meeting minimum internal and regulatory capital requirements in a severe but plausible stress environment), including testing whether the Barclays Bank Group’s financial position and risk profile provide sufficient resilience to withstand the impact of severe but plausible economic scenarios within the parameters set by the BPLC Board Risk Committee.
- The effectiveness of risk management and internal controls is reviewed regularly by the Board Risk Committee (responsible for overseeing the ERMF and current and potential future risk exposures) and the Board Audit Committee (responsible for evaluating the effectiveness of internal controls).
- The Board Audit Committee also has oversight of the financial reporting processes and the work of the external and internal auditors (including independence and effectiveness).

### Board Audit Committee
The Board Audit Committee is comprised solely of independent Non-Executive Directors, with membership of the Board Audit Committee aligned with the BPLC Board Audit Committee and designed to provide the breadth of financial expertise and commercial acumen it needs to fulfil its responsibilities. Its members as a whole have recent and relevant experience of the banking and financial services sector, in addition to general management and commercial experience, and are financially literate. The Board Audit Committee is chaired by Julia Wilson, who has significant corporate finance, tax and accounting experience. Robert Berry and Marc Moses are the other members of the Committee. Diane Schueneman stepped down from the Board Audit Committee with effect from 31 January 2025.

The Board Audit Committee held 13 scheduled meetings and three ad hoc meetings in 2025.$^△$ Board Audit Committee meetings were attended by representatives from the Barclays Group and BBPLC management in respect of matters relevant to their business or function area, including (as appropriate) the Chief Executive Officer, Barclays Group Finance Director, the Group Controller, the BBPLC Chief Financial Officer, the Barclays Group and BBPLC Chief Internal Auditor, the Barclays Group Chief Compliance Officer, the Barclays Group Chief Operating Officer, the Head of Group Control, and Barclays Group General Counsel. The Company’s statutory auditor, KPMG, also attended Committee meetings.

Attendance at Board Audit Committee meetings during 2025 was as follows:

| Member | Meetings attended / eligible to attend | Ad hoc meetings attended / eligible to attend | Effective date |
| :--- | :---: | :---: | :--- |
| **Julia Wilson (Chair)** | 13/13 | 3/3 | Appointed 1 April 2023 |
| **Robert Berry** | 13/13 | 3/3 | Appointed 1 March 2022 |
| **Marc Moses** | 13/13 | 3/3 | Appointed 23 January 2023 |
| **Diane Schueneman** | 2/2 | N/A | Stepped down 31 January 2025 |

Additionally, as part of the Company’s commitment to effective oversight and allocation of responsibilities between the BPLC Board Audit Committee, BBPLC Board Audit Committee and the BBUKPLC Board Audit Committee, Julia Wilson held regular meetings during 2025 with the BBUKPLC Board Audit Committee Chair to share relevant information and to ensure embedment of information flows and governance practice. In addition, discussions were held with the board audit committee chairs of the Company’s other major subsidiaries, Barclays Bank Ireland PLC (Barclays Europe) and Barclays US LLC (IHC).

The principal role and responsibilities of the Board Audit Committee, pursuant to its Terms of Reference, are to review and monitor:
- the integrity of the Barclays Bank Group’s financial statements
- the effectiveness of the Barclays Bank Group’s internal controls
- the independence and effectiveness of the internal and external audit processes
- the relationship with the Barclays Bank Group’s statutory auditor
- the effectiveness of the Barclays Bank Group’s whistleblowing procedures.$^△$

During 2025, the principal activities of the Board Audit Committee included:
- Financial reporting: assessing the appropriateness of BBPLC's financial disclosures, including considering feedback from KPMG and management's review of controls relating to financial reporting. The Committee reviewed and recommended to the BBPLC Board for approval the BBPLC Annual Report 2024 and the BBPLC Results Announcement for the period ended 30 June 2025. The Committee recommended to the Board that the financial statements should be prepared on a going concern basis. The Committee also received an update on the reporting requirements under Corporate Sustainability Reporting Directive (CSRD) for BBPLC and approach to the 2025 double materiality assessment.
- Impairment: assessing management's approach to impairment coverage levels, including the impact of delinquency levels in certain areas of the portfolio, the use of post-model adjustments and in respect of material exposures across the Barclays Bank Group.
- Conduct provisions: analysing management's judgements and estimates made with regard to the Barclays Bank Group’s material conduct provisions.

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

- Legal, competition and regulatory provisions: evaluating advice on the status of current legal, competition and regulatory matters and considering management’s judgements on the level of provisions, including challenging management on the timeliness of raising provisions as well as understanding areas of KPMG challenge. The Committee reviewed and challenged management's approach to the provision raised for motor finance. Seeking KPMG's views on the reasonableness of management's position, the Committee focused in particular on the methodology to determine the level of provision for motor finance claims and the reasonableness of assumptions made by management in developing the proposed methodology.
- Valuations: monitoring the valuation methods applied by management to significant valuation items and areas of judgement in relation to matters impacting the Barclays Bank Group.
- Tax: considering tax matters relating to the Barclays Bank Group, including the tax strategy, compliance with the Group's Tax Principles and judgements related to tax risk and the recognition and measurement of deferred tax assets. The Committee monitored interactions with tax authorities, development in tax litigation matters and material tax risks (including the adequacy of tax provisions and KPMG's views). The Committee also monitored the potential impact of US legislative changes in relation to tax on the Barclays Bank Group.
- Internal controls and business control environment: monitoring and evaluating the status of the more significant control matters and remediation programmes across the Barclays Bank Group. The Committee also discussed reports from the heads of UKCB, PBWM, IB and USCB on their control environment, together with views from the second and third lines of defence.
- Internal audit: receiving reports from Barclays Internal Audit (BIA) in relation to specific audits, key areas of focus and emerging themes with respect to businesses in the Barclays Bank Group; considering remediation plans arising from adverse audit reports and monitoring related remediation programmes; discussing BIA's assessment of the control environment in the Barclays Bank Group and key themes in Barclays Bank Group entities; and approving the annual BIA audit plan for the Barclays Bank Group. Committee members, along with the Barclays Europe and IHC board audit committee chairs, attended a 'BIA Teach In' which covered matters relating to People, BIA Strategy and Audit Methodology.
- External audit: reviewing and approving the annual external audit plan for the Barclays Bank Group (including the key areas of focus) and assessing the progress of the 2025 audit. The Committee also considered KPMG audit quality and discussed KPMG’s feedback and challenge of management on areas such as critical accounting estimates and judgements and internal controls. The Committee received an update on lessons learned following the first year of implementation of CSRD disclosures by BBPLC and Barclays Europe and the assurance conducted by KPMG. The Committee recommended to the Board for approval by shareholders of BBPLC at its 2025 AGM the reappointment of KPMG as the BBPLC external auditor. In addition, following the conclusion of a formal audit tender process the Committee recommended to the Board the re-appointment of KPMG as BBPLC's statutory auditor with effect from the 2027 financial year. Refer to page 37 for further details about the audit tender process.
- Speaking up: reviewing management's reports on whistleblowing matters, monitoring key whistleblowing metrics and considering potential whistleblowing trends.$^△$

The Board Audit Committee effectiveness review was internally conducted for 2025, with the results confirming that the Committee is operating effectively.

### Board Risk Committee
The Board Risk Committee is comprised solely of independent Non-Executive Directors with membership of the Committee broadly aligned with the BPLC Board Risk Committee. The Board Risk Committee is chaired by Robert Berry. Dawn Fitzpatrick, Marc Moses and Julia Wilson are the other members of the Committee.

Board Risk Committee meetings are attended by management as appropriate, including the Chief Executive Officer, Barclays Group Finance Director, Barclays Group Chief Risk Officer, BBPLC Chief Risk Officer, Barclays Group Chief Compliance Officer, BBPLC Chief Compliance Officer, Barclays Group Treasurer, Barclays Group Chief Internal Auditor, Barclays Group General Counsel and BBPLC General Counsel. The Company’s statutory auditor, KPMG, also attended meetings.

The Board Risk Committee held 10 scheduled meetings and three ad hoc meetings in 2025.$^△$ Owing to other commitments or religious observance, some Directors were unable to attend certain meetings, however they received papers in advance and had the opportunity to share their views with the Chair ahead of the meetings.

Attendance at Board Risk Committee meetings during 2025 was as follows:

| Member | Meetings attended / eligible to attend | Ad hoc meetings attended / eligible to attend | Effective date |
| :--- | :---: | :---: | :--- |
| **Robert Berry (Chair)** | 10/10 | 3/3 | Appointed 1 March 2022 |
| **Dawn Fitzpatrick** | 10/10 | 3/3 | Appointed 1 January 2020 |
| **Marc Moses** | 8/10 | 3/3 | Appointed 23 January 2023 |
| **Julia Wilson** | 10/10 | 2/3 | Appointed 1 April 2023 |

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

The principal role and responsibilities of the Board Risk Committee, pursuant to its Terms of Reference, are to:
- review, on behalf of the Board, the management of the principal risks as set out in the ERMF (with the exception of any matter with reputation risk which may have strategic implications relating to the Barclays Bank Group, which is a matter reserved to the Board)
- consider and recommend to the Board, within the risk parameters set by the BPLC Board Risk Committee, the Company’s risk appetite and tolerance for those principal risks
- review, on behalf of the Board, the Barclays Bank Group’s risk profile for those principal risks
- commission, receive and consider reports on key risk issues and emerging risks.

The Board Risk Committee continually considers the impact of issues on the Barclays Bank Group and the risk environment in which it operates. It reviews steps taken by the business to manage exposures in this context.

During 2025, the key activities of the Board Risk Committee included:
- Recommending to the Board the adoption of the ERMF following the approval of the ERMF by the BPLC Board.
- Further to reports presented by management on guidance and feedback received from key Barclays Group regulators, the Committee considered management's response to the matters raised by regulators, including updates on key remediation programmes, insofar as these related to the Barclays Bank Group.
- Receiving an update from the Barclays Group Chief Risk Officer and Chief Compliance Officer on their observations on the Barclays Group's risk and compliance culture, which included reflecting on the Committee's role to support the embedment of the desired culture.
- Advising the Board on the risk appetite and tolerance for the Barclays Bank Group in respect of the principal risks in the ERMF when determining strategy, including recommending the BBPLC Risk Appetite Statement to the Board for approval. The Committee adopted the aggregate stress loss limit allocation and stress loss limits for BBPLC.
- Considering and approving the 2025 internal stress test (IST) scenario theme and severity and 2025 IST results, and recommending that the Board approve the MTP on the basis that risk appetite was met under the IST. The Committee also approved the results of the 2025 internal reverse stress test.
- Considering updates on the results of Barclays US LLC's 2025 supervisory stress test conducted by the Federal Reserve Board.
- The Barclays Group Chief Risk Officer reported regularly on the Barclays Group's risk profile which included assessments of macroeconomic developments and geopolitical risks, in addition to reporting on key risks and portfolio metrics which included consideration of matters relevant to the Barclays Bank Group.
- Receiving briefings on key risk themes in the context of the evolving risk environment in which the Barclays Bank Group operates.
- Receiving focused business risk updates on Investment Banking, Global Markets, USCB, PBWM and UKCB, which included assessments of principal risks.
- An ongoing focus on credit risk, including reporting on management actions being taken to mitigate risk in key portfolios.
- Monitoring the capital, liquidity and financial resources of BBPLC to ensure it meets its regulatory requirements and obligations.
- Following preliminary assessments of the BBPLC Internal Capital Adequacy Assessment Process (ICAAP) and Internal Liquidity Adequacy Assessment Process (ILAAP) submissions in early 2025, subsequently approving the BBPLC ICAAP and ILAAP prior to their submission to the Prudential Regulation Authority (PRA).
- Recommending to the Board for approval the BBPLC elements of the Barclays Group Recovery Plan.
- Reviewing and considering the operational risks for Barclays Bank Group business as part of Barclays Group-wide reporting which included updates on key metrics and key operational risks, including those relating to transactions operations and the risks associated with new business activities.
- The Committee maintained oversight of cybersecurity risk through updates on the Barclays Group-wide programme of work to enhance Barclays' cybersecurity capabilities insofar as matters related to the Barclays Bank Group.$^△$
- Receiving regular reports on climate risk which covered matters including external regulatory trends, the global policy environment, progress against financed emissions reduction targets and actions to address increasing physical risks which considered matters relevant to the Barclays Bank Group's businesses.$^△$
- Overseeing the management of compliance risk within BBPLC, including through regular reports from the Barclays Group Chief Compliance Officer on the Barclays Group's compliance risk profile which included consideration of matters relevant to BBPLC. The Committee also received quarterly BBPLC compliance risk dashboards.
- Monitoring financial crime risk in the Barclays Bank Group through quarterly updates on the Barclays Group-wide programme to enhance financial crime capabilities, Compliance opinions on the Barclays Group financial crime risk profile and BBPLC financial crime risk dashboards.$^△$
- Considering the key conclusions from the due diligence conducted on the acquisition of Best Egg, Inc.
- Considering the methodology for setting the ex-ante adjustments to the 2025 incentives pool.

The Board Risk Committee effectiveness review was internally conducted for 2025, with the results confirming that the Committee is operating effectively.

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

### Audit, risk and internal control
The Board, together with the Board Audit Committee, is responsible for ensuring the independence and effectiveness of the internal and external audit functions. For this reason, the Board Audit Committee held regular private sessions with each of the BBPLC Chief Internal Auditor and the lead audit engagement partner of the statutory auditor without management present.

The Board is also responsible for ensuring that management maintains an effective system of risk management and internal control and assessing its effectiveness. Such a system is designed to identify, evaluate and manage, rather than eliminate, the risk of failure to achieve business objectives and can only provide reasonable, and not absolute, assurance against material misstatement or loss.

The Board Audit Committee oversees the control environment (and remediation of related issues) and also reviews annually the risk management and internal control system. Key controls are assessed on a regular basis for both design and operating effectiveness. Issues arising out of these assessments, where appropriate, are reported to the Board Audit Committee.

### Controls over financial reporting
A framework of disclosure controls and procedures is in place to support the approval of the financial statements of the Barclays Bank Group.

Specific governance committees are responsible for examining the financial reports and disclosures to help ensure that they have been subject to adequate verification and comply with applicable standards and legislation.

Where appropriate, these committees report their conclusions to the Board Audit Committee, which debates such conclusions and provides further challenge. Finally, the Board scrutinises and approves results announcements and the Annual Report to ensure that appropriate disclosures have been made. This governance process is designed to ensure that both management and the Board are given sufficient opportunity to debate and challenge the financial statements of the Barclays Bank Group and other significant disclosures before they are made public.

### Management's report on internal control over financial reporting
Management is responsible for establishing and maintaining adequate internal controls over financial reporting under the supervision of the principal executive and financial officers, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements, in accordance with (a) UK-adopted international accounting standards; (b) International Financial Reporting Standards (IFRS) as issued by the International Accounting Standards Board (IASB), including interpretations issued by the IFRS Interpretations Committee; and (c) IFRS adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union.

Internal control over financial reporting includes policies and procedures that pertain to the maintenance of records that, in reasonable detail:
- accurately and fairly reflect transactions and dispositions of assets
- provide reasonable assurances that transactions are recorded as necessary to permit preparation of financial statements in accordance with UK-adopted international accounting standards and IFRS and that receipts and expenditures are being made only in accordance with authorisations of management and the respective Directors
- provide reasonable assurance regarding prevention or timely detection of unauthorised acquisition, use or disposition of assets that could have a material effect on the financial statements.

Internal control systems, no matter how well designed, have inherent limitations and may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that internal control over financial reporting may become inadequate because of changes in conditions or that the degree of compliance with the policies or procedures may deteriorate.

Management has assessed internal control over financial reporting as at 31 December 2025. In making its assessment, management utilised the criteria set out in the 2013 COSO framework. Management has concluded that, based on its assessment, internal control over financial reporting was effective as at 31 December 2025.

The system of internal financial and operational controls is also subject to regulatory oversight in the UK and overseas. Further information on supervision by financial services regulators is provided under Supervision and Regulation in the Risk review section on pages 245 to 261.

### Changes in internal control over financial reporting
There have been no changes that occurred during the period covered by this report, which have materially affected or are reasonably likely to materially affect the Barclays Bank Group’s internal control over financial reporting.

---

### Principle Five: Remuneration
The remuneration policies and practices should support strategy and promote long-term sustainable success and be developed in accordance with formal and transparent procedures, ensuring no Director is involved in deciding their own remuneration outcome. Executive remuneration should be aligned to the company’s purpose and values and the successful delivery of the strategy with outcomes taking account of company and individual performance, and wider circumstances such as pay across the company’s workforce and Barclays' Fair Pay Agenda.

- The Barclays Group Remuneration Policy is set by the BPLC Board Remuneration Committee and reviewed and adopted by the BBPLC Board Remuneration Committee. The policy is designed to promote the long-term success of the Company and ensure that remuneration is aligned to the Barclays Bank Group's strategy and risk management approach.
- Remuneration for executives and senior management is considered in the context of the wider workforce remuneration and alignment of incentives and rewards with performance and culture. Their remuneration is reviewed annually by the BBPLC Board Remuneration Committee and the BPLC Board Remuneration Committee, as appropriate. No individual is involved in deciding their own remuneration.
- Barclays Bank Group is committed to paying people fairly, with regards to their specific role, seniority, responsibilities, skills and experience and other factors that properly affect pay, in a way that balances the needs of the Barclays Bank Group's stakeholders. You can find more information on the Barclays Fair Pay Agenda which underpins all remuneration decisions in the Remuneration report section of the Barclays PLC Annual Report 2025. The Barclays Bank Group also remains focused on strengthening our inclusive culture with a focus on empowering our colleagues and leaders, engaging our communities and driving company success. You can find more information on our approach to Inclusion & Opportunity in the Barclays PLC Annual Report 2025. Our UK gender and ethnicity pay gaps are published in the Barclays UK Pay Gaps 2025 disclosure.

### Board Remuneration Committee
The Board Remuneration Committee is comprised solely of independent Non-Executive Directors. The Committee is chaired by Mary Francis. Dawn Fitzpatrick, Nigel Higgins and Julia Wilson are the other Committee members. As noted above, Mary Francis is to step down from the Board and her role as Board Remuneration Committee Chair with effect from 6 May 2026. Her successor as Chair of the Board Remuneration Committee will be announced in due course.

The Board Remuneration Committee held 5 scheduled and 1 ad hoc meetings in 2025.$^△$ Meetings were attended by the Group Chief Executive, Group Finance Director, Group Chief Risk Officer, Group Human Resources Director, and the Group Reward and Performance Director/Co-Heads of Reward and Performance as required. Attendance at Board Remuneration Committee meetings during 2025 was as follows:

| Member | Meetings attended / eligible to attend | Effective date |
| :--- | :---: | :--- |
| **Mary Francis** | 6/6 | Appointed 25 September 2019 |
| **Dawn Fitzpatrick** | 6/6 | Appointed 1 July 2021 |
| **Nigel Higgins** | 5/5 | Appointed 31 January 2025 |
| **Julia Wilson** | 6/6 | Appointed 1 July 2023 |

The principal role and responsibilities of the Committee, pursuant to its Terms of Reference, are to:
- set the overarching principles and parameters of remuneration policy for the Barclays Bank Group within the parameters set by the BPLC Board Remuneration Committee;
- consider and endorse the incentive pool for the Barclays Bank Group and the remuneration of key Barclays Bank Group executives and other specified individuals as determined by the Board Remuneration Committee from time to time; and
- exercise oversight over remuneration issues within the Barclays Bank Group.

During 2025, the principal activities of the Committee included:
- Reviewing the Barclays Group Reward Policy and confirming its continued adoption;
- Reviewing the Board Remuneration Committee's Control Framework, Terms of Reference, annual activity and effectiveness;
- Reviewing and adopting the methodology and framework for 2025 incentive funding, and reviewing and endorsing the resulting incentive pool, including considering financial performance and risk updates (and the appropriateness of risk adjustments to incentives);
- Considering the remuneration structures for Material Risk Takers (MRTs) in the context of the new PRA/ FCA UK bank pay regulations;
- Considering updates on the review of wider workforce remuneration, and UK gender and ethnicity pay gaps;$^△$
- Considering regular updates on stakeholders matters, regulatory and legal considerations and pay round considerations;
- Reviewing and approving, as appropriate, specific remuneration proposals for individuals within the Committee’s remit; and
- Considering and approving recommendations of the Remuneration Review Panel, which supports the Committee in overseeing the alignment of remuneration with the conduct expectations of Barclays, its regulators and its stakeholders.

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

The Board Remuneration Committee effectiveness review was internally conducted for 2025, with the results confirming that the Committee is operating effectively.

### Principle Six: Stakeholder relationships and engagement
Directors should foster effective stakeholder relationships aligned to the company’s purpose. The board should recognise the importance of listening to, and understanding, the views of its stakeholders, including the workforce, and specifically the impact of the company’s behaviour and business on customers and clients, colleagues, suppliers, communities and society more broadly; having regard to these views and impact when taking decisions.

- As described under Principle One, the Company has a defined Purpose and strategy; through this the Board has identified key stakeholders on whom the success of the Company depends.
- The Board and management engage throughout the year with the Company's stakeholders. The Board seeks to understand the views of key stakeholders and the impact of the Company’s behaviour and business on customers and clients, colleagues, suppliers, communities and society more broadly. Refer to pages 13 to 17 of the Strategic report for further information about our engagement with stakeholders. See also the Directors' report for information about how we engage with suppliers.
- The Company’s long-standing commitment to the importance and value of colleague engagement continues; the Company’s people are its most valuable asset. While there is no designated workforce engagement Director on the BBPLC Board, the Board receives feedback on culture and colleague engagement during the year through, for example, updates on colleague and workforce matters presented to Board meetings. Board members also have the opportunity to engage with colleagues during the year at colleague events. Further detail on the Company’s workforce commitment and engagement model can be found in the Colleagues section on page 15 of the Strategic report.
- The Board Sustainability Committee supports the Board's oversight of climate and sustainability matters, in accordance with its Terms of Reference.

### Board Sustainability Committee
The Board Sustainability Committee comprises a majority of independent Non-Executive Directors, with membership of the Committee broadly aligned with the BPLC Board Sustainability Committee. The Board Sustainability Committee is chaired by Nigel Higgins. Robert Berry, Dawn Fitzpatrick, Mary Francis, C.S. Venkatakrishnan and Julia Wilson are also members of the Committee. As noted above, Mary Francis is to step down from the Board and her role as a member of the Board Sustainability Committee with effect from 6 May 2026.

The Board Sustainability Committee held three scheduled meetings and one ad hoc meeting in 2025.$^△$ Owing to other commitments or illness, some Directors were unable to attend certain meetings, however they received papers in advance and had the opportunity to share their views with the Chair ahead of the meetings. Board Sustainability Committee meetings are attended by management including the Head of Public Policy and Corporate Responsibility, Group Head of Sustainable and Transition Finance, and the Head of Legal, Public Policy and Corporate Responsibility. Attendance at Board Sustainability Committee meetings during 2025 was as follows:

| Member | Scheduled meetings attended / eligible to attend | Ad hoc meetings attended / eligible to attend | Effective date |
| :--- | :---: | :---: | :--- |
| **Nigel Higgins (Chair)** | 3/3 | 1/1 | Appointed 23 March 2023 |
| **Robert Berry** | 2/3 | 1/1 | Appointed 23 March 2023 |
| **Dawn Fitzpatrick** | 1/3 | 1/1 | Appointed 23 March 2023 |
| **Mary Francis** | 3/3 | 1/1 | Appointed 23 March 2023 |
| **CS Venkatakrishnan** | 3/3 | 1/1 | Appointed 23 March 2023 |
| **Julia Wilson** | 3/3 | 1/1 | Appointed 1 April 2023 |

The principal role and responsibilities of the Board Sustainability Committee, pursuant to its Terms of Reference, are:$^△$
- supporting and advising the Board in its oversight of climate and sustainability matters relating to (i) the services and products provided to the Company's clients and customers, (ii) particular sectors, and (iii) its own corporate activities
- supporting the Board in monitoring the implementation of the Company’s climate and sustainability strategy and reviewing and making recommendations to the Board on the suitability of material changes to its strategy.
- reporting to the Board on the climate and sustainability matters for which it is responsible, escalating issues and making recommendations to the Board where appropriate.

During 2025, the principal activities of the Committee included:$^△$
- Detailed discussion and review of the Barclays Transition Update ahead of publication. The Committee considered the risks and opportunities presented by the transition.
- Discussions were informed by external perspectives, including external legal and policy experts, and underpinned by management's active engagement with external stakeholders. The Committee also received regular updates on external developments, market practice and regulatory changes.

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

- The Committee discussed the continuing work to advance Barclays position on nature and human rights, recognising the growing importance of these issues to stakeholders and to the long-term sustainability of the business.

The Board Sustainability Committee effectiveness review was internally conducted for 2025, with the results confirming that the Committee is operating effectively.

### Additional information relating to sustainability matters$^△$

#### Board and Board Committee oversight of sustainability matters
The Board sets the strategic direction for BBPLC. Further details on the role and responsibilities of the Board are set out in Principle One: Board Leadership and company purpose. Further to this, the Board and, as appropriate, its Committees oversee sustainability matters which may, where appropriate, include material impacts, risks and opportunities (IROs) as relevant.

The Matters Reserved to the Board sets out those matters reserved to the Board, which include material decisions relating to strategy, risk appetite, risk management and controls frameworks and the approval of large transactions among other matters. The Board considers a range of matters in its decision-making process, which may include, where appropriate, consideration of any material IROs, as relevant.

Each Committee has its own Terms of Reference setting out its principal role and responsibilities and incorporating oversight of our IROs where appropriate. In particular:
- Recognising the importance of climate and sustainability matters and the growing importance of other sustainability areas including nature, the Board Sustainability Committee supports and advises the Board in its oversight of climate and sustainability matters, including related risks and opportunities. The Chief Executive Officer is an Executive member of the Board Sustainability Committee and in that role brings invaluable climate and sustainability insights to the Committee’s discussions, including external perspectives from his outside engagements.
- The Board Risk Committee oversees risk appetite and the management of principal risks, including climate risk. In evaluating BBPLC’s risk profile, the Committee’s considerations include the risk of financial losses arising from climate change through physical risks and risks associated with transitioning to a lower carbon economy and progress against the Barclays Group’s financed emissions reduction targets (insofar as BBPLC contributes to these targets).
- The role of the Board Remuneration Committee includes exercising oversight over remuneration issues within the BBPLC Group, including the Fair Pay Agenda and gender and ethnicity pay gaps.

The Matters Reserved to the Board and Committee Terms of Reference are reviewed on a regular basis and updated as required, including if appropriate, to reflect changes in the nature of BBPLC's business and any relevant material IROs.

### Skills and expertise related to sustainability matters
Board members and members of relevant Board Committees (for example, the Board Sustainability Committee) are able to reflect on and deepen their skills and expertise on sustainability matters, including in relation to our IROs as relevant, through periodic briefings on key business developments and external developments provided by management. Further information regarding briefings related to our material sustainability matters (including where appropriate updates regarding their management) provided to the Board during 2025 can be found in Principle One: Board leadership and company purpose (see the 'What the Board did in 2025' section). Information regarding the key sustainability-related activities of relevant Committees in 2025 can be found in Principle Three: Composition, succession and evaluation, Principle Four: Audit, risk and internal control, Principle Five: Remuneration and Principle Six: Stakeholder relationships and engagement.

Where the Board or a Board Committee identifies that additional expertise and insight would be helpful to support informed decision-making, they are able to call on internal subject matter experts to provide additional briefings and training on particular material sustainability matters. Where appropriate, training may be requested from relevant external experts.

$^△$ Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000

---

# Governance report
## Directors’ report

The Directors present their report together with the audited accounts for the Company for the year ended 31 December 2025.

Section 414A of the Act requires the Directors to present a Strategic report in the Annual Report. The report can be found on pages 1 to 19.

BBPLC has addressed the Non-Financial Reporting requirements contained in sections 414CA and 414CB of the Act through the disclosure contained in the Barclays PLC Annual Report 2025 on pages 44 to 51. In addition, the Company has chosen, in accordance with section 414C(11) of the Act, and as noted in this Directors’ report, to include certain matters in its Strategic report that would otherwise be disclosed in this Directors’ report:
- An indication of likely future developments may be found in the Strategic report.
- The particulars of important events affecting the Company since the financial year end can be found in the Strategic report and Note 24 (Legal, competition and regulatory matters) to the financial statements.

Other information that is relevant to the Directors’ report, and which is incorporated by reference into this report, can be located at:

| | Pages |
| :--- | :--- |
| Performance measures | 7 to 9 |
| Corporate governance statement | 21 to 34 |
| Sustainability statement | 40 to 114 |
| Risk management | 120 to 143 |
| Principal risks | 10 to 12, 120, 144 to 156 |

Disclosures required pursuant to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 as updated by the 2018 Regulations can be found on the following pages:

| | Pages |
| :--- | :--- |
| Engagement with employees (Sch.7 Para 11 and 11A Regs 2008/2018 and Section 172(1) Statement) | 15 |
| Financial Instruments (Sch.7 Para 6 Regs 2008) | 319 |
| Hedge accounting policy (Sch.7 Para 6 Regs 2008) | 323 |

### Profits and dividends
The results of the Barclays Bank Group show statutory profit after tax of £4,658m (2024: £3,748m). The Barclays Bank Group had net assets of £62,313m as at 31 December 2025 (2024: £59,220m).

The Company declared a £1,175m dividend to its parent, Barclays PLC, in respect of 2025, which is expected to be paid on or around 10 February 2026.

Dividends paid on preference shares for the year ended 31 December 2025 amounted to £32m (2024: £41m).

Further details on dividends on ordinary shares and preference shares paid in 2025 are set out in Note 10 to the financial statements.

### Share capital
There was no increase in ordinary share capital during the year. BPLC owns 100% of the issued ordinary shares. There are no restrictions on the transfer of ordinary shares or agreements between holders of ordinary shares known to the Company which may result in restrictions on the transfer of securities or voting rights. Further information on the Company’s share capital, including preference shares, can be found in Note 26 of the financial statements.

### Shareholder rights in relation to shareholder meetings
The Company is required to hold an annual general meeting each year in addition to such other general meetings as the directors think fit. 21 clear days' notice must be given for an annual general meeting and 14 clear days' notice must be given for any other general meeting. The Company is also required to hold a general meeting if so requested by a shareholder or shareholders representing at least 5% of such of the paid-up capital of the Company as carries the right of voting at general meetings of the Company. Such a meeting must be called within 21 days of the Company being required to hold such a meeting and must be held not more than 28 days after the notice convening such a meeting.

Notice of a general meeting must be in writing and must specify the place, the day and time of meeting, and the general nature of the business to be transacted. If a special resolution is proposed, the notice must also specify the intention to propose the resolution as such.

Subject as noted below, all shareholders are entitled to attend and vote at general meetings.

---

The quorum for a general meeting is two qualifying persons present and entitled to vote. Voting is done on a show of hands unless a poll is properly demanded by the chair of the meeting or any shareholder entitled to vote on the resolution. Shareholders may vote at a general meeting in person or by proxy or, in the case of a corporation, by a duly appointed corporate representative. At a general meeting, shareholders vote on matters which are required to be approved by shareholders, by ordinary resolution or special resolution, as a matter of law or in accordance with the articles of association. An ordinary resolution is passed, on a show of hands, by a simple majority of votes cast or, on a poll, by shareholders representing a simple majority of total voting rights of the voting shareholders. A special resolution is passed, on a show of hands, by a majority of not less than 75% of the votes cast or, on a poll, by shareholders representing not less than 75% of the total voting rights of the voting shareholders.

Holders of preference shares have no right to receive notice of, attend or vote at, any general meetings of the Company.

### Powers of Directors to issue and allot or buy back the Company’s shares
The powers of the Directors are determined by the Act and the Articles. No shares were issued or bought back in 2025 except as set out in 'Repurchase of shares' below. The Directors are authorised to issue and allot shares and to buy back shares subject to annual shareholder approval at the AGM. Such authorities were granted by shareholders at the 2025 AGM. It will be proposed at the 2026 AGM that the Directors be granted new authorities to allot and buy back shares.

### Repurchase of shares
The Company did not repurchase any of its ordinary shares in 2025. 31,856 Euro non-cumulative callable preference shares of €100 each were redeemed and cancelled by the Company on 16 June 2025.

### Directors
The list of current Directors of the Company can be found in the Corporate Governance Statement on page 21. Changes to Directors during 2025 and up to the date of this report are set out below. As noted elsewhere in this report, Mary Francis will step down from the Board with effect from 6 May 2026.

| Name | Role | Effective date |
| :--- | :--- | :--- |
| **Diane Schueneman** | Non-Executive Director | Stepped down 31 January 2025 |
| **Mary Mack** | Non-Executive Director | Appointed 1 June 2025 |

### Directors’ indemnities
Qualifying third party indemnity provisions (as defined by section 234 of the Act) were in force during the course of the financial year ended 31 December 2025 for the benefit of the then Directors of the Company and the then directors of certain of the Company's subsidiaries and, at the date of this report, are in force for the benefit of the Directors of the Company and the directors of certain of the Company's subsidiaries in relation to certain losses and liabilities which they may incur (or have incurred) in connection with their duties, powers or office. The Barclays Group also maintains Directors’ & Officers’ Liability Insurance which gives appropriate cover for legal action brought against its Directors.

Qualifying pension scheme indemnity provisions (as defined by section 235 of the Act) were in force during the course of the financial year ended 31 December 2025 for the benefit of the then directors and, at the date of this report are in force for the benefit of directors of Barclays Pension Funds Trustees Limited as trustee of the Barclays Bank UK Retirement Fund, and Barclays Executive Schemes Trustees Limited as Trustee of Barclays Capital International Pension Scheme (No.1) and Barclays PLC Funded Unapproved Retirement Benefits Scheme. The directors of the trustees are indemnified against liability incurred in connection with the trustee’s activities in relation to the aforementioned schemes.

### Political donations
The Barclays Bank Group did not give any money for political purposes in the UK or outside the UK, nor did it make any political donations to political parties or other political organisations or to any independent election candidates, or incur any political expenditure during the year. Details of any political contributions made by the wider Barclays Group can be found in the Barclays PLC Annual Report 2025.

### Support for candidates and colleagues with disabilities and long-term conditions
Barclays' commitment to inclusion includes ensuring that candidates with disabilities and long-term health conditions receive support and adjustments in the application process and beyond. Barclays welcomes applications from all candidates and is committed to ensuring reasonable adjustments (accommodations) are put in place to ensure a fair and inclusive candidate experience. Barclays is committed to providing all colleagues with the support and tools they need to have a productive and fulfilling career. We can consider making adjustments to remove or reduce barriers colleagues might face if they have a disability, health concern or mental health condition. We also ensure opportunities for training, career development and promotion are available to all.

---

### Engagement with customers, suppliers and others in a business relationship with the Company
The Barclays Group asks its TPSPs to (i) make responsible decisions that, where relevant, take our stakeholders' needs into account in both the short and long term and (ii) to comply with all applicable laws, rules and regulations within the geographies in which they operate.

The Barclays Group’s standard approach$^1$ to TPSP onboarding and contract renewal begins by assessing the inherent risk associated with the goods and/or services being provided in-line with Barclays’ TPSP risk assessment process. TPSPs that are assessed as being above a low risk of exposure from a business risk perspective are subject to the Barclays Group’s Supplier Control Obligations (SCOs). Prior to contractual agreement and service go-live, these TPSPs are required to confirm adherence to the SCOs (subject to negotiation) and the TPSP CoC.

TPSPs to whom the SCOs apply will be actively managed and subject to controls assurance on an annual basis to assess whether the control requirements and expectations outlined within the TPSP CoC are being met. Where TPSPs are unable to meet our expectations defined within the SCOs and the TPSP CoC, the issue will be managed, as appropriate, in-line with the Barclays Group’s Issue Management Standard. The TPSP CoC and SCOs are published on the Barclays Group public website for all new and existing TPSPs to view and are refreshed at least annually to help ensure the Barclays Group expectations continue to be met.

For more information on our engagement with customers and clients, please refer to the “Customers and clients” section of the Strategic Report, page 33 of the Governance Report, and the “Customers and clients” section of the Barclays PLC Annual Report 2025.

**Note**
1 Where financial institutions and market counterparties provide services to the Barclays Group, the nature of the services leveraged, may require an alternate onboarding approach and as such some control expectations may not be applicable. This is assessed at the point of onboarding.

### Branches and Country-by-Country reporting
The Barclays Bank Group operates through branches, offices and subsidiaries in the UK and overseas. Those branches are in a number of different jurisdictions including in Hong Kong, Singapore and New York. The Company is exempt from publishing information required by the Capital Requirements (Country-by-Country Reporting) Regulations 2013 as this information is published by its parent, BPLC. This information is available on the Barclays website: home.barclays/annualreport.

### Research and development
In the ordinary course of business, the Barclays Bank Group develops new products and services in each of its business divisions.

### Key intangible resources
Our key intangible resources are those resources without physical substance on which our business model fundamentally depends. We deploy them to serve the financial needs of our diversified customer base, delivering value through synergies, providing clear outcomes for our stakeholders. They include our:
- People, purpose, values and mindset - Our people are our organisation. We deliver success through a purpose-driven and inclusive culture;
- Brand - Our brand equity instils trust, lowers the cost of acquiring customers and clients and helps retain them for longer; and
- Technology and infrastructure - Our deep technology and infrastructure capabilities drive customer experiences and support strong resiliency.

### Change of control
There are no significant agreements to which the Company is a party that take effect, alter or terminate on a change of control of the Company following a takeover bid.

There are no agreements between the Company and its Directors or employees providing for compensation for loss of office or employment that occurs because of a takeover bid.

### Statutory auditor
The BPLC Board Audit Committee reviews the appointment of the Barclays Group statutory auditor, as well as their relationship with the Barclays Group, including monitoring the Barclays Group’s use of the statutory auditors for non-audit services and the balance of audit and non-audit fees paid to them. The BBPLC Board Audit Committee also monitors the use of the statutory auditor for non-audit services within the Barclays Bank Group.

In our 2024 Annual Report, we disclosed Barclays PLC's intention to conduct a formal audit tender process for the role of the Barclays Group statutory auditor (including BBPLC). The audit tender process was conducted in early 2025 and overseen by the BPLC Board Audit Committee (with support from the BBPLC Board Audit Committee). Following conclusion of the audit

---

tender process in May 2025, upon recommendation from the BBPLC Board Audit Committee, the BBPLC Board confirmed the re-appointment of KPMG as BBPLC's statutory auditor with effect from the financial year ending 31 December 2027.

For further information about the audit tender process, please refer to the report of the Board Audit Committee in the Barclays PLC Annual Report 2025.

### Non-audit services
In order to safeguard the statutory auditor’s independence and objectivity, the Barclays Group has in place a policy on the Provision of Services by the Barclays Group Statutory Auditor (the Policy) setting out the circumstances in which the statutory auditor may be engaged to provide services other than those covered by the Barclays Group audit. The Policy applies to all Barclays subsidiaries and other material entities over which Barclays has significant influence. The core principle of the Policy is that non-audit services (other than those legally required to be carried out by the Barclays Group’s auditor) should be performed by the statutory auditor only in certain controlled circumstances. The Policy sets out those types of services that are permitted.

Under the Policy, except for specific categories of ‘permitted’ services that require explicit Board Audit Committee approval, the BPLC Board Audit Committee has pre-approved all permitted services for which fees are less than £100,000 and certain other annual recurring non-audit services. All requests to engage the statutory auditor are assessed by independent management before work can commence. Requests for permitted service types in respect of which the fees are expected to meet or exceed the above threshold, but expected to be less than £250,000, must be approved by the Chair of the BPLC Board Audit Committee before work is permitted to begin. Services where the fees are expected to be £250,000 or higher must be approved by the BPLC Board Audit Committee as a whole. All expenses and disbursements must be included in the fees calculation. More information on the Policy can be found in the Barclays PLC Annual Report 2025.

The fees payable to KPMG for the year ended 31 December 2025 amounted to £57m (2024: £57m), of which £16m (2024: £15m) was payable in respect of non-audit services. A breakdown of the fees payable to the auditor for statutory audit and non-audit work can be found in Note 38 to the financial statements.

### Disclosure of information to the Auditor
Each Director confirms that, so far as they are aware, there is no relevant audit information of which the Company’s auditor is unaware and that each of the Directors has taken all the steps that they ought to have taken as a Director to make themself aware of any relevant audit information and to establish that the Company's auditor is aware of that information. This confirmation is given pursuant to section 418 of the Act and should be interpreted in accordance with and subject to those provisions.

### Directors’ responsibilities
The following statements, which should be read in conjunction with the auditor’s report set out on pages 263 to 283, are made with a view to distinguishing for shareholders the respective responsibilities of the Directors and of the auditor in relation to the accounts.

### Going concern
In preparing each of the Barclays Bank Group and Company financial statements, the Directors are required to:
- assess the Barclays Bank Group's and Company’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern; and
- use the going concern basis of accounting unless they either intend to liquidate the Barclays Bank Group and the Company or to cease operations, or have no realistic alternative but to do so.

The Barclays Bank Group’s business activities, financial position, capital, factors likely to affect its future development and performance, and its objectives and policies in managing the financial risks to which it is exposed are discussed in the Strategic report and Risk review sections of this report.

The Directors have evaluated these risks in the preparation of the financial statements and consider it appropriate to prepare the financial statements on a going concern basis.

### Preparation of accounts
The Directors are required by the Act to prepare the Company and the Barclays Bank Group accounts for each financial year and, with regard to Barclays Bank Group accounts, in accordance with UK-adopted international accounting standards. The Directors have prepared these accounts in accordance with (a) UK-adopted international accounting standards; (b) IFRS as issued by the IASB, including interpretations issued by the IFRS Interpretations Committee; and (c) IFRS adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union. Pursuant to the Act, the Directors must not approve the accounts unless they are satisfied that they give a true and fair view of the state of affairs of the Barclays Bank Group and the Company and of their profit or loss for that period.

---

The Directors consider that, in preparing the financial statements, the Barclays Bank Group and the Company have used appropriate accounting policies, supported by reasonable judgements and estimates, and that all accounting standards which they consider to be applicable have been followed.

The Directors are satisfied that the Annual Report and Financial Statements, taken as a whole, are fair, balanced and understandable, and provide the information necessary for shareholders to assess the Company’s position and performance, business model and strategy.

Directors are responsible for such internal controls as they determine are necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

### Directors’ responsibility statement
The Directors have responsibility for ensuring that the Company and the Barclays Bank Group keep accounting records which disclose, with reasonable accuracy, the financial position of the Company and the Barclays Bank Group, and which enable them to ensure that the accounts comply with the Act.

The Directors are also responsible for preparing a Strategic report, Directors’ report and Corporate Governance Statement in accordance with applicable law and regulations.

The Directors are responsible for the maintenance and integrity of the Annual Report and Financial Statements as they appear on the Barclays website. Legislation in the UK governing the preparation and dissemination of financial statements may differ from legislation in other jurisdictions.

The Directors have a general responsibility for taking such steps as are reasonably open to them to safeguard the assets of the Company and to prevent and detect fraud and other irregularities.

The Directors are responsible for preparing the financial statements in accordance with Commission Delegated Regulation (EU) 2019/815 with regard to regulatory technical standards on the specification of a single electronic reporting format.

The current Directors, whose names and functions are set out on page 21, confirm to the best of their knowledge that:
(a) the financial statements, prepared in accordance with (a) UK-adopted international accounting standards; (b) IFRS as issued by the IASB, including interpretations issued by the IFRS Interpretations Committee; and (c) IFRS adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union, give a true and fair view of the assets, liabilities, financial position and profit or loss of the Company and the undertakings included in the consolidation taken as a whole; and
(b) the management report, which is represented by the Strategic report and Directors' report: (i) includes a fair review of the development and performance of the business and the position of the Company and the undertakings included in the consolidation taken as a whole, together with a description of the principal risks and uncertainties that they face; and (ii) the Sustainability Statement referenced therein, which is set out on pages 40 to 114, has been prepared in accordance with the European Sustainability Reporting Standards and the specifications adopted pursuant to Article 8(4) of Regulation (EU) 2020/852.

### Sustainability Statement
The content of the Sustainability Statement, required to be included in the Management Report further to the Transparency (Directive 2004/109/EC) Regulations 2007 (as amended), is set out in the Schedule to the Directors' Report on pages 40 to 114.

By order of the Board

Hannah Ellwood
Company Secretary
9 February 2026
Barclays Bank PLC
Registered in England. Company No. 1026167
Registered office, 1 Churchill Place, London E14 5HP

---

# Schedule to the Directors' report: Sustainability statement
## Contents

| | Page |
| :--- | :--- |
| **General information** | |
| Basis of preparation for sustainability reporting | 41 |
| **Sustainability governance** | |
| • Board and Board Committee oversight of sustainability matters | 42 |
| • Management's role in governance | 42 |
| • Sustainability-related performance in incentive schemes | 43 |
| • Sustainability due diligence | 44 |
| • Risk management and internal control over sustainability reporting | 45 |
| Strategy, business model and value chain | 46 |
| Interests and views of stakeholders | 48 |
| **Double materiality assessment** | |
| • Assessment process | 49 |
| • Material impacts, risks and opportunities, and their Interaction with strategy and business model | 52 |
| **Environmental information** | |
| Climate change | 55 |
| Biodiversity and ecosystems | 68 |
| EU Taxonomy | 70 |
| Sustainable and transition products and services (entity specific) | 71 |
| **Social information** | |
| Own workforce | 73 |
| Workers in the value chain | 89 |
| Affected communities | 90 |
| Consumers and end users | 92 |
| **Governance information** | |
| Data privacy (entity specific) | 94 |
| Anti-Money Laundering and Sanctions (entity specific) | 96 |
| EU Taxonomy (qualitative information) | 99 |
| Important information/ Disclaimers | 106 |
| **Further information** | |
| Disclosure requirements (including those incorporated by cross reference) | 107 |
| Key definitions as captured in the Barclays Climate Change Statement | 108 |
| Independent Practitioner’s Limited Assurance Report to the Directors of Barclays Bank PLC | 111 |
| Schedule A: Datapoints in cross-cutting and topical standards that derive from other EU legislation | 412 |
| Schedule B: EU Taxonomy (quantitative information) | 419 |

---

# Schedule to the Directors' report: Sustainability statement
## General Information

### Basis of preparation for sustainability reporting
This ‘Sustainability Statement’ has been prepared in accordance with the requirements set out in the Corporate Sustainability Reporting Directive (CSRD); the European Sustainability Reporting Standards (ESRS); the Transparency (Directive 2004/109/EC) Regulations 2007, as amended; and the requirements of the EU Taxonomy Regulation, as amended by Commission Delegated Regulation (EU) 2026/73. The content of this Sustainability Statement is subject to limited assurance, and findings of this exercise are outlined within the assurance provider's conclusion, set out on page 111.

The threshold for information material for inclusion within this Sustainability Statement is based on the requirements outlined in paragraph 31 of ESRS 1. The sustainability matters disclosed are aligned to the results of the double materiality assessment (DMA), set out on page 49, and the information provided to meet our related disclosure requirements, including any metrics, has been based on the significance of the information in relation to the matter and identified impact, risk or opportunity, or the capacity of such information to meet the users’ decision-making needs.

### Level of consolidation
This Sustainability Statement has been prepared on a consolidated basis for Barclays Bank Group, consistent with the financial statements. For further information on the financial consolidation, see the notes to the financial statements set out on pages 295 to 409.

### Coverage of value chain
An important cornerstone of the ESRS disclosure requirements is the DMA. The DMA was first performed in 2024 to determine our material sustainability matters. Barclays Bank Group refreshed its DMA in 2025 for this reporting period.

The DMA covered direct and indirect business relationships in the value chain. For details relating to our value chain, see page 46. The DMA process and reporting criteria are described further on page 49. The outcome of the DMA serves as the starting point for our disclosures on our material impacts, risks and opportunities (IROs), which are included in the Environmental, Social and Governance sections below.

### Omission of information
We have not used the option in the ESRS to omit any specific pieces of information corresponding to intellectual property, know-how, or the results of innovation.

### Disclosures in relation to specific circumstances that may have an effect on the preparation of the sustainability statement

#### i) Sources of estimation and outcome uncertainty
Financed emissions calculations rely on externally sourced data mapped to internal customer and client identifiers. The externally sourced data has various limitations for each sector, including lack of coverage, low resolution, consistency and transparency of company-reported data, as well as the time lag for external sources to report estimates or actuals.

For further details on the data sources and estimations in financed emissions metrics, including a summary of the basis of preparation and level of accuracy, see page 67.

#### ii) Changes in preparation or presentation of sustainability information
For the 2025 disclosure, we have made the following changes to our disclosed metrics:
- Inclusion Index has replaced other previously disclosed diversity related metrics, see further details on page 81,
- Updated the EU Taxonomy tables reporting to align the requirements of the EU Taxonomy Regulation, as amended by Commission Delegated Regulation (EU) 2026/73. See further details on pages 99 and 419.

#### iii) Incorporation by reference
The following disclosures, required by the ESRS, are included in other relevant sections of the Annual Report and incorporated by reference into this Sustainability Statement:
- Certain disclosure requirements are closely linked to requirements that Barclays Bank Group is already subject to, such as the requirement in the Companies Act 2006 to describe its governance structure; and
- Information regarding Barclays Bank Group's products and services and significant markets and clients served are outlined in the Investment Bank, UK Corporate Bank, US Consumer Bank and Barclays Private Bank and Wealth Management content within our Strategic Report.

The table on page 107 identifies all these disclosure requirements.

---

#### iv) Use of phase-in provisions
We have applied phase-in reliefs set out in the Commission Delegated Regulation (EU) 2025/1416 (Quick Fix Regulation) adopted on 11 July 2025, including in relation to:
- All disclosure requirements (E4, S2, S3 and S4 impacts);
- Own workforce metrics (S1-7 to S1-15); and
- Quantitative disclosures on anticipated financial effects (ESRS 2 SBM 3).

### Sustainability Governance

#### Board and Board Committee oversight of sustainability matters
Specific information relating to our Board and its Committees can be found in the Corporate governance statement from page 21. In particular:
- Information on the composition and diversity of our Board and its Committees is set out on page 21 (the table in ‘The Board’ section), page 24 (Principle Two: Division of responsibilities, ‘The Board’ section), page 26 (Principle Three: Composition, succession and evaluation, the tables setting out industry and leadership experience and international experience) and page 27 (Principle Three: Composition, succession and evaluation, the ‘Inclusion and opportunity’ section);
- Information on the roles and responsibilities of our Board and its Committees in relation to sustainability matters and how these are reflected in governance documentation is set out on page 34 (Additional information relating to sustainability matters, the ‘Board and Board Committee oversight of sustainability matters’ section);
- Information relating to the skills and expertise of Board and Committee members in relation to sustainability matters is set out on page 34 (Additional information relating to sustainability matters, the ‘Skills and expertise related to sustainability matters’ section);
- For further information on how the Board and its Committees are informed about our material impacts, risks and opportunities, see page 34 (Additional information relating to sustainability matters, the ‘Skills and expertise related to sustainability matters’ section);
- For further information on how the Board and its Committees consider our material impacts, risks and opportunities when overseeing our strategy, risk management and any decisions on major transactions, see page 34 (Additional information relating to sustainability matters, the ‘Board and Board Committee oversight of sustainability matters’ section); and
- Information about the material risks, impacts and opportunities considered by the Board and its Committees during 2025 is set out on page 34 (Additional information relating to sustainability matters section).

In relation to our material impacts, risks and opportunities, the Barclays Bank Group has set a target in relation to the completion of mandatory training by colleagues (please see page 81 for further details). Given the nature of the target, it is set and overseen by management. Any material issues relating to performance against this target may be escalated to the Board Audit Committee, as appropriate, as part of reporting provided by management on the control environment in relation to monitored risks, which includes people risk.

#### Management’s role in the governance processes
Oversight and management of Barclays' climate and sustainability strategy, of which Barclays Bank Group is a key contributor, continues to be embedded in business-as-usual management structures, including executive committees. These committees are mandated and form part of Barclays’ formal governance architecture. Each committee is itself governed by Terms of Reference that lay out the duties, decision-making authority and escalation route of any material issues. The executive management committees receive periodic briefings on matters including climate change and consider both risks and opportunities. Climate and sustainability-related risks are assessed and escalated where relevant through the various risk forums.

The GSC is a sub-committee of Group ExCo and is chaired by the Group Head of PPCR. GSC members include senior sustainability representatives from across the businesses, including the Group Head of Sustainable and Transition Finance, as well as members representing key functions across the Group.

The GSC is responsible for approving and recommending sustainability matters on behalf of Group ExCo to the Board Sustainability Committee as appropriate. The GSC is also responsible for determining, agreeing or recommending sustainability position statements, frameworks, targets, relevant disclosures and advocacy areas necessary to support strategy delivery and agreeing the strategic change priorities to support overall sustainability strategy.

---

The Group Risk Committee (GRC) is the designated forum to review risk profile, risk practices and recommend, where necessary, updates to the Board Risk Committee. In relation to climate, the GRC reviews and recommends proposed risk appetite and relevant limits to the BRC. To support the oversight of Barclays' climate risk profile, the Climate Risk Committee ('CRC') was established as a sub-committee of GRC. The CRC is responsible for reviewing and approved a range of updates including the climate risk exposures, risk appetite, limits and plans for embedding climate risk into business activities. Additionally, climate-related risk metrics, risk trends, climate scenario analysis and stress test exercises, and progress against Barclays Group targets are reviewed and discussed at the CRC.

The Disclosure Committee (DisCom), which is chaired by the Group Finance Director, has been set up as a sub-committee of the Group ExCo. DisCom is convened to review and monitor the integrity of the Group’s financial and narrative statements and other information provided to stakeholders, whether by means of announcement or otherwise. In addition to reporting to the Group ExCo, DisCom also reports to the Board Audit Committee (BAC). DisCom is convened to undertake a number of specific duties, including:
- financial reporting: to review and monitor the integrity of the Group’s financial statements, interim management statements, preliminary announcements (if prepared), and any other formal announcements relating to the Group’s financial performance.
- narrative reporting: to review and monitor the integrity of the Group’s narrative statements, including but not limited to the BPLC, BBPLC and BBUKPLC Annual Reports, the BPLC Country Snapshot and the BPLC Modern Slavery Statement.

The Group Reputation Risk Committee (GRRC) is a sub-committee of the Group ExCo which reviews and challenges, and directs as appropriate, the management and mitigation of Reputation Risk matters in Barclays Group as they are brought to the attention of the GRRC via relevant Reputation Risk assessment and escalation processes. This includes Reputation Risk associated with sustainability related matters. The GRRC is co-chaired by the Head of Public Policy and Corporate Responsibility and Group Chief Compliance Officer, and members include the Group Chief Risk Officer and Group General Counsel.

#### BBPLC Business-Level Committees
Business-level committees are convened for senior management to review transactions with potential material Reputation Risk to Barclays. These may include transactions involving climate and sustainability-related risks. Where particularly heightened risks are identified, these transactions may be escalated to the Group Reputation Risk Committee. Matters reviewed by these committees include transactions, relationships, agreements, strategies and other business activities.

#### ERMF Oversight
The ERMF governs the way in which the Barclays Bank Group identifies and manages its risks. It outlines the highest level arrangements for risk management by setting out standards, objectives and key responsibilities of different groups of employees of the Barclays Bank Group. The ERMF is complemented by frameworks, policies and standards which are mainly aligned to individual principal risks:
- frameworks cover high-level principles guiding the management of principal risks, and set out details of which policies are needed, and high-level governance arrangements;
- policies set out the control objectives and high-level requirements to address the key principles articulated in their associated frameworks. Policies state ‘what’ those within scope are required to do; and
- standards set out details of the control requirements to ensure the control objectives set by the policies are met.

In relation to the management of material impacts and opportunities, our standard business controls and operating procedures apply.

The target set out on page 81, which relates to our material IRO (S1 - Equal Opportunities for all), is set centrally by management and overseen by management in each key business area through relevant reporting.

### Sustainability-Related Performance in Incentive Schemes
Barclays’ Reward Policy, and the remuneration philosophy within, applies to all colleagues globally. It is set by the BPLC Board Remuneration Committee and adopted by the BBPLC Board Remuneration Committee and is designed to promote the long-term success of Barclays and ensure that remuneration is aligned to the Barclays strategy and risk management approach. The remuneration philosophy includes our objectives to:
- Reward sustainable performance. Sustainable performance means making a positive and enduring difference to investors, customers and communities, delivering good customer outcomes, taking pride in leaving things better than we found them, and playing a valuable role in society.

---

- Support Barclays’ Values and culture, meaning that results must be achieved in a manner consistent with our Values, and emphasising that our Values, culture and Mindset should drive the way that business is conducted.
- Align pay with risk appetite, risk exposure and conduct expectations, including sustainability-related risks. Barclays’ remuneration approach is designed to reward colleagues for achieving results in line with the Barclays' risk appetite and conduct expectations.

Incentives are delivered in the form of annual bonus awards for all employees (subject to eligibility criteria) and Long Term Incentive Plan (LTIP) awards for the Executive Directors of BB PLC. Non-Executive Directors of BB PLC are not eligible for annual bonus awards or other incentives.

Annual bonuses incentivise and reward the achievement of the Barclays Group, business and individual objectives, and reward colleagues for demonstrating behaviours in line with Barclays’ Values and Mindset. Climate and sustainability-related performance is factored into annual bonus outcomes in two ways – via its impact on incentive pools and through individual performance assessments.

In determining the Group and BB PLC incentive pools, Barclays’ performance against non-financial measures, including climate and sustainability-related measures, is considered, impacting annual bonus awards of all employees. Since the assessment is holistic, there is no predetermined weighting for sustainability-related measures. For 2025, climate and sustainability-related measures considered as part of this assessment included:
- climate-related measures focused on progress towards Barclays’ Sustainable and Transition Financing target, reductions in its financed emissions and progress against targets relating to achieving net zero operations;
- consideration of how Barclays is investing in communities through programmes such as LifeSkills (including number of people upskilled and placed into work);
- colleague-related measures including engagement, culture and inclusion.

The incentive pools are also adjusted to take account of risks, both crystalised and potential future risks, and consideration is given to vulnerabilities across all of Barclays’ principal risks, which include climate risk.

Performance for all colleagues is assessed against individual performance objectives aligned to the consistently excellent standard. Where relevant, these objectives include sustainability-related considerations, which are tailored to the individual’s role. Individual bonus outcomes are determined based on Barclays Group, business and individual performance, and are discretionary, so there is no predetermined weighting for sustainability-related measures (except for the Executive Directors of BB PLC as described below). For employees earning higher bonuses and other employees identified as ‘Material Risk Takers’, a significant portion of their annual bonus is deferred.

The Group Executive Committee members responsible for Barclays’ five business divisions, including those who are also BBPLC Executive Committee members, have specific climate and sustainability-related objectives relevant to the businesses they manage included in their performance objectives and assessment. Their remuneration approach is aligned with the approach for all other colleagues and is reviewed annually by the BBPLC Board Remuneration Committee and, where appropriate, the BPLC Board Remuneration Committee. No individual is involved in deciding their own remuneration.

For the Executive Directors of BBPLC, who are also Executive Directors of BPLC, incentive outcomes are more structured than for other employees. The BPLC Board Remuneration Committee sets financial and non-financial measures aligned with the Barclays strategic priorities at the start of the performance period for each award. At the end of the performance period, performance against the measures is assessed and a detailed retrospective narrative is provided in the Annual Report. The measures include:
- In the 2025 annual bonus, 10% is based on a combination of measures relating to customers, clients and colleagues, which include engagement, culture and inclusion. A further 5% is based on an assessment of performance against risk awareness and operational excellence measures. The same will apply for the 2026 annual bonus.
- In the 2025-2027 LTIP, and the 2026-2028 LTIP, climate and sustainability-related measures are included as part of a broader category of measures relating to sustainability, customers and clients, weighted at 25%. The sustainability-related measures will likely include financing clients’ transition, reducing our financed emissions and achieving net zero operations, as well as supporting our communities.

### Sustainability due diligence
Sustainability due diligence is the process used to identify, prevent, mitigate and account for how the actual and potential negative impacts on the environment and people connected with a company's business are addressed. These include negative impacts connected with a company’s own operations and its upstream and downstream value chain, including through its products or services, as well as through its business relationships. Due diligence is an ongoing practice that

---

responds to and may trigger changes in our strategy, business model, activities, business relationships, operating, sourcing and selling contexts.

The table below outlines where information relating to sustainability due diligence can be found within the Sustainability Statement.

| Core elements of due diligence | Pages in the Sustainability Statement |
| :--- | :--- |
| Embedding due diligence in governance, strategy and business model | 42 |
| Engaging with affected stakeholders in all key steps of the due diligence | 48 |
| Identifying and assessing adverse impacts | 49 |
| Taking actions to address those adverse impacts | 63, 69, 89, 92, 93, 95, 97 |
| Tracking the effectiveness of efforts and communicating | 65, 72, 81, 87, 96 |

### Risk management and internal control over sustainability reporting
Barclays' approach to risk management and internal control over sustainability reporting is set out in the Operational Risk Framework (ORF), which defines what the organisation needs to do to manage operational risk effectively. Operational risk is managed under the Barclays’ ERMF. The ORF and associated policies and standards allow operational risks to be managed effectively and consistently, and in line with regulatory expectations.

The framework consists of integrated components that work together to effectively manage operational risk. The components involve the structure of risk identification and assessment, mitigation and management, and monitoring and reporting of risks, operated across the three Lines of Defence.

The risk identification and assessment for sustainability reporting, as set out in the ORF, is supported by various risk assessment tools. Risk and Control Self-Assessment (RCSA) is a Group-wide approach to identify and assess:
- the risks that are inherent in each process;
- the effectiveness of the controls in place to mitigate the risks;
- the level of residual risks after the application of the controls; and
- the actions required to reduce any residual risk that is outside the risk appetite/tolerance.

The RCSA process assesses the effectiveness of the control environment and helps management determine if the residual risk is within or outside the appetite/tolerance; and is a key factor in determining changes to the residual risk. For example, where the control environment improves, the level of residual risk is expected to fall, and vice versa.

The risk and control assessments, risk events, issues and key indicators, among others, inform management if a risk should be subjected to an enhanced oversight, review and challenge, and be prioritised for any risk mitigation/reduction plan.

The main risks associated with the sustainability reporting processes, defined by Barclays' financial reporting policies and standards, are grouped in risk themes (such as calculation error, reporting error and late reporting) which in turn consider risks relating to:
- completeness and integrity of data;
- accuracy of estimation results;
- timing and availability of information; and
- fairness, balance and understandability of disclosures.

Such policies and standards also describe the control objectives and control requirements to mitigate the associated risks. These are preventative and detective controls, such as data integrity checks, external disclosure checks, reconciliations, validations, analytical reviews, and management review/challenge, operated by the relevant functions over the sustainability reporting process.

To further mitigate the risks related to sustainability reporting, specific governance committees, such as the Disclosure Committee, are responsible for reviewing and monitoring the integrity of the BBPLC Annual Report, including the sustainability reporting.

These controls are established to manage and mitigate the risks within the risk appetite and tolerance. Risk mitigation is either through implementation of additional controls against the risk, or remediation of existing controls assessed as operating ineffectively, in order to strengthen the effectiveness of the control environment of the relevant functions to the sustainability reporting process.

---

Any findings of the risk assessment and internal controls associated with the sustainability reporting processes are assessed by the relevant function for severity (financial and non-financial impact) and probability of occurrence in accordance with the Risk and Issue Classification Matrix (RICM). RICM provides a consistent basis for classifying risks and issues and helps determine the escalation and reporting requirements, commensurate with the overall risk exposure.

Any issues, such as control gaps, are documented and recorded in the approved system of record, including remedial actions to address the findings, and are tracked and reviewed for completion and closure. Where applicable, a risk reduction plan is performed whenever the residual risk (after taking into consideration the effectiveness of controls) is outside of the risk appetite/tolerance. Such plan includes remedial activities to bring the residual risk within the acceptable level.

Any findings of risk assessment and internal controls associated with the sustainability reporting process are reviewed and reported by the relevant functions through risk and control committees on a regular and event-driven basis, such as the Risk Category and Control Forums. Where applicable, any material findings are escalated and reported to the Barclays Bank PLC Board Risk Committee (BRC). The BRC reviews the effectiveness of risk management and the Barclays Bank Group risk profile, including the material issues affecting each business portfolio and forward risk trends. The committee also commissions regular updates and in-depth analyses of significant risk topics, which are presented by business heads, the Group CRO or senior risk managers.

### Strategy, business model and value chain

#### Business model
Barclays Bank Group's business model is aligned with the business model of Barclays Group. Barclays deploys its tangible and intangible assets, including people, technology, infrastructure and brand, to serve the financial needs of its diversified customer base, create synergies across the organisation, generate a well-diversified income stream and provide positive outcomes for its stakeholders.

#### Significant products, services, significant markets and customer groups
Barclays Bank Group's products and services and significant markets and clients served, including the UK, US and Europe, are outlined in the Investment Bank, UK Corporate Bank, US Consumer Bank and Barclays Private Bank and Wealth Management content within our Strategic Report set out on page 1.

#### Headcount
Barclays Bank Group had a workforce of 23,088 employees globally at the end of FY25 (FY24: 23,788). For further details on the characteristics of our workforce, please refer to the S1 disclosure on page 73.

#### Main features of our upstream and downstream value chain

```mermaid
graph LR
    subgraph Upstream
    I[Investors]
    T[Third Party Service Providers]
    end
    subgraph "Barclays Bank plc Group"
    B1[Barclays Investment Bank]
    B2[Barclays UK Corporate Bank]
    B3[Barclays US Consumer Bank]
    B4[Barclays Private Bank and Wealth Management]
    end
    subgraph Downstream
    C[Clients and Customers]
    end
    I --> B1
    T --> B1
    I --> B2
    T --> B2
    I --> B3
    T --> B3
    I --> B4
    T --> B4
    B1 --> C
    B2 --> C
    B3 --> C
    B4 --> C
    Workers_in_Value_Chain[Workers in Value Chain]
    Affected_Communities[Affected Communities]
```

### Direct relationships in value chain

#### Upstream
- **Investors:** Barclays Bank Group is a wholly owned subsidiary of the Barclays Group, focused on creating long-term sustainable value for Barclays and ultimately its shareholders. Barclays Bank Group is also a frequent issuer in the debt capital markets and have wholesale and retail debt investors.
- **Third-Party Service Providers (TPSPs)$^1$:** A TPSP is any entity that has entered into an arrangement with Barclays' entities, including those in the Barclays Bank Group, to provide business functions, activities, goods and/or services. For example, through TPSPs, Barclays Bank Group obtains a wide range of goods and services including technology and facilities management, client-focused payment solutions, customer service, and clearing services, supporting colleagues through recruitment services, learning partnerships and other TPSPs that support multiple functions through data services.

---

#### Downstream
- **Clients and Customers:** Investment banking clients include corporates, money managers, financial institutions, governments and global organisations. Corporate clients are also served through the UK Corporate Bank. Private Bank and Wealth Management primarily cater to high net-worth individuals. US Consumer Bank caters to retail and non-retail clients through the provision of cards. Barclays Bank Group also partners with distributors to provide co-branded cards.

#### Indirect relationships in value chain
- **Affected communities:** Individuals or groups who may be affected by the actions, operations and/or value chains of those parties in Barclays Bank Group's upstream (TPSPs) or downstream (Clients and Customers) value chain.
- **Workers in our value chain:** Individuals who work in Barclays Bank Group's upstream or downstream value chains but may not have a direct contractual relationship with the Barclays Bank Group.

**Note:**
1 Third-Party Service Providers are equivalent to suppliers as defined in Annex II- Acronyms and Glossary of Terms in ESRS, published by Council of European Union

### Sustainability strategy and goals
Barclays Bank Group contributes to Barclays' sustainability strategy and goals. These are primarily focused on impacts, risks and opportunities arising from financing activities. Barclays Bank Group supports Barclays’ climate strategy, which focuses on working with clients on their transition, financing clients’ transition, and scaling climate technology, while integrating nature and social considerations. This is reflected in Barclays' target to facilitate $1trn of Sustainable and Transition Finance between 2023 and the end of 2030. The products and services offered as a part of this strategy are financing activities including debt and equity capital markets, corporate lending, trade finance and consumer lending. It applies to all Barclays businesses globally. These products and services help to generate positive social and environmental outcomes through financing of activities such as, but not limited to, energy efficiency, renewable energy, affordable housing, basic infrastructure and services.

Barclays Bank Group products and services that support the Barclays climate strategy are as follows:
- **UKCB:** Delivered through proactive engagement, thought leadership, and continuous development of new sustainable solutions, we work with clients to understand their transition ambitions and challenges to provide an enhanced offering.
- **PBWM:** Responsible investing and sustainable investing solutions focus on ESG integration and dedicated sustainable investment strategies, as appropriate per the relevant mandates.
- **IB:** Blending the existing expertise and relationships in our coverage groups with specialised teams focused on sustainable finance growth areas – providing enhanced and integrated solutions for our clients.

Barclays has set 2030 financed emissions reduction targets for eight high-emitting sectors set out on page 65. More generally, our broader sustainability goals include developing ways to effectively mitigate our material potential sustainability impacts and risks which could impact our customers and services, for example through the effective management of potential data privacy and cyber security impacts globally.

The Third Party Service Provider Code of Conduct (TPSP CoC) encourages our TPSPs to adopt our approach to doing business and details our expectations for matters including environmental management, human rights and also for living the Barclays Values. The TPSP CoC is published on the Barclays public website for all new and existing TPSPs to view and are refreshed at least annually.

Our sustainability goals in relation to other stakeholders (such as investors and regulators) are focused on maintaining and strengthening these relationships, and continuing to develop understanding of their individual sustainability related views, goals, expectations and challenges.

### Main challenges ahead relevant to sustainability reporting
We recognise that, as part of Barclays, we have an important role to play in the transition, we cannot tackle this challenge on our own and that Barclays' ability to implement its climate strategy and deliver against its targets depends heavily on client progress and a wide range of external factors. We will consider and adapt our approach as needed to reflect the evolving landscape.

The development of sustainability related metrics, targets and disclosures are also dependent on data availability. Barclays relies on disclosures made by its clients and customers, which at this time are complex and still evolving, to be reliable and consistent. Further information is set out in the Important Information section on page 106.

---

### Interests and views of stakeholders
The table below outlines how we engage with our six key stakeholder groups. The purpose of this engagement is to enable us to understand the interests and views of our key stakeholders, in relation to sustainability matters, and allow us to consider these views in our strategy and business model. The table outlines:
- the different types of engagement methods used to engage with our key stakeholders;
- the purpose of our engagement with our key stakeholders; and
- how the outcomes are used in our strategy and business model.

The Board is informed of our stakeholders’ views on sustainability-related impacts, where relevant, through updates from management and Board stakeholder engagement. This engagement is discussed in Principle Six: Stakeholder relationships and engagement set out on page 33 in our Corporate governance statement. You can read about how the Board engages with certain stakeholders in our Section 172(1) statement in the Strategic report on page 18.

Stakeholder engagement enables us to understand the priorities of our different stakeholder groups. The key topics our stakeholders raised and discussed, as part of stakeholder engagement, allow us to understand their interests and views on our strategy and business model pertaining to Environmental, Social and Governance matters. This understanding is used to support the due diligence process and was considered as part of the DMA, as outlined on page 49, and specifically:
- When assessing the appropriateness of the IROs that were taken forward for assessment under the DMA, and
- During the stakeholder questionnaire (as discussed in the 'Double Materiality Assessment' section), to inform and enhance our understanding of external stakeholders views.

| Stakeholder | How we engage | Engagement purpose | How the outcomes are taken into account |
| :--- | :--- | :--- | :--- |
| **Third-party service providers (TPSPs)** | • Direct engagement with TPSPs through our relationship managers and sustainability subject matters experts<br>• Communication of our TPSP Code of Conduct to ensure TPSPs are aware of and able to meet expectations on matters including environmental management and human rights | • Promote good practice on matters including environmental management and human rights | • Assess the TPSPs against environmental management and human rights matters |
| **Investors** | BBPLC is a wholly owned subsidiary of BPLC. BPLC is a publicly traded company with diverse group of investors. Investors in BPLC refer to the disclosures made at BBPLC level. Barclays Group engagement with investors includes:<br>• Regular quarterly meetings and updates on results and future guidance and expectations<br>• Frequent deep-dive and thought leadership conferences and group sessions Ad hoc engagement to address queries<br>• Annual AGM to engage with BPLC investors and shareholders<br>• Via an ESG resources hub to demonstrate non-financial performance, policies and statements, and applicable ESG ratings, as well as frameworks utilised by Barclays | • Provide a feedback mechanism for the Group, and indirectly to BBPLC and Barclays Europe to understand the needs of investors<br>• Educate and explain current performance and future expectations to best illustrate performance to investors<br>• Provide access to the subject matter experts within the Barclays Group as well as access to Senior Management and the Board | • Drives topics of prioritisation in a changing environment, guiding relevant and accurate reporting against market expectations<br>• Inform disclosure requirements of investors to aid investment decision, helping to develop sustainability-related policy and strategy, governing all activities of Barclays |
| **Government, Policy makers and Regulators** | • Ongoing supervisory relationships with our regulators<br>• Engagement with policymakers and governments directly and indirectly (including through trade associations) consistent with our business strategy<br>• Participating in key international and domestic policy forums<br>• Providing feedback and engaging with regulatory and government consultations, directly and indirectly through trade associations | • Enhance our understanding of regulatory expectations and requirements in relation to our business<br>• Identify and engage in the development of the key policy initiatives that could impact us and our clients, including in relation to sustainable finance and the energy transition | • Embed our understanding of regulatory expectations and requirements within our business<br>• Make informed and insightful contributions to the development of policy that could impact us and our clients<br>• Enhance existing relationships and build new relationships with a range of governments, policymakers, regulators and relevant trade associations |

---

| Stakeholder | How we engage | Engagement purpose | How the outcomes are taken into account |
| :--- | :--- | :--- | :--- |
| **Employees** | Our approach to workforce engagement delivers meaningful, regular two-way dialogue and recognises the importance of closing the feedback loop. We engage with colleagues in a wide variety of ways, including:<br>• Townhalls<br>• Skip-level meetings<br>• Site visits<br>• Leader-led engagement<br>• Focus groups<br>• Surveys<br>• Unions and Works Councils | Our engagement channels provide senior leaders with the opportunity to engage with colleagues in a variety of ways. We engage in regular, meaningful, two-way dialogue with our colleagues to understand what is working well across the organisation and where we can improve. | Our engagement mechanisms enable us to listen to our colleagues, monitor organisational culture, and supports Senior Leaders to take action. |
| **Customers and Clients** | • Regular client surveys<br>• Analysis of customer complaints<br>• Direct interaction | • Support our customers' and clients'<br>• Gather customer and client feedback, and engage on their own financial health, financial and non-financial strategy and plans<br>• Influence and develop products and services to meet their needs | • Build our understanding of customer and client evolving needs<br>• Adapt our products and services accordingly<br>• Continue to build the expertise, knowledge and capabilities customers and clients are looking for<br>• Identify and address the root causes of customer complaints<br>• Tailor financing and advise clients on future financing requirements, aiding their own sustainability and supporting the longevity of our relationship |
| **Affected Communities and Workers in the downstream value chain** | On an ad hoc basis, we have engaged credible proxies and representatives to gain insight into the perspectives of affected communities, this has taken the form of engagement with credible proxies, such as NGOs and civil society organizations. | • Develop our understanding of the actual and potential human rights risks relevant to our business from the perspective of affected stakeholders<br>• Enhance the robustness and legitimacy of the process for assessing salient human rights risks | • Inform the identification of a list of human rights impacts relevant to the then Corporate and Investment Bank<br>• Support the enhancement of the evolving framework of policies and processes that seek to embed our commitment across our business |

### Double materiality assessment
Double materiality has two dimensions, impact materiality and financial materiality. A sustainability matter is material from an impact perspective when it pertains to the undertaking’s material impacts on people or the environment over the short, medium or long-term. A sustainability matter is material from a financial perspective if it generates risks or opportunities that materially influence (or could reasonably be expected to materially influence) the undertaking’s financial position, financial performance, cash flows, access to finance or cost of capital over the short, medium or long term. The ESRS require undertakings to disclose specific information on environmental, social and governance matters when the undertaking has assessed the matter as material in its double materiality assessment.

#### Description of the process to identify and assess material impacts, risks and opportunities
During 2025, Barclays Bank Group updated its DMA using the steps outlined below. Subject matter experts (SMEs) supported the completion of the DMA. The SMEs were identified based on their role in or knowledge of the Barclays Bank Group and appropriate knowledge of the specific sustainability matters and related impacts, risks and opportunities.

The DMA was a continuous process with steps completed through the year and the prior period's results reviewed through ongoing assessment and used where deemed appropriate for the current reporting period.

#### Step 1: Understanding Barclays' products and services, value chain and stakeholders
We relied on last year’s process to identify activities, business relationships and geographies of Barclays Bank Group that could give rise to heightened risk of adverse impacts across our value chain. For more details on the outcomes of this, see Significant products, services, significant markets and customer groups and Value Chain sections on page 46 and Stakeholder engagements on page 48.

---

#### Step 2: Developing a preliminary list of potentially relevant sustainability matters
In 2024, we completed an exercise to identify a list of sustainability matters that were relevant and important to Barclays Bank Group, its stakeholders, the geographies and the sectors in which it operates. The following eight document types were manually reviewed, and relevant sustainability topics were extracted:
1. BBPLC and BPLC Company documents
2. ESG frameworks
3. ESG rating agency publications
4. Industry publications
5. Regulations
6. Investor reports
7. Peer sustainability disclosures
8. Media results relating to ESG topics

The sustainability matters identified were ranked based on the number of occurrences in the data sources and weighted, in order to prioritise the matters and arrive at a list of potentially material sustainability matters. This list formed our initial basis for assessing relevant impacts, risks and opportunities.

In the current reporting period, the list of sustainability matters was reviewed by SMEs to ensure it was up to date. In conducting their review, SMEs exercised professional judgement, taking into account:
- Market insights;
- Regulatory focus areas; and
- Emerging sustainability topics.

The list of sustainability matters was amended based on this review, to ensure sustainability matters assessed under the DMA remained appropriate.

#### Stakeholder questionnaire
In 2025, we used a questionnaire to ensure we were capturing our ongoing stakeholder engagement, including with external experts for a number of areas. The SMEs responsible for engaging with the stakeholder groups outlined on page 48 completed the questionnaire based on their interactions over the past 12 months. The objective was to document stakeholders' views and ensure all views relevant to potentially material sustainability matters and impacts, risks and opportunities are considered in the DMA and to inform our understanding of how stakeholder groups are impacted. The responses were collated and mapped to the list of sustainability matters. New sustainability matters were added, and relevant SMEs were informed of stakeholders' views.

#### Step 3: Identifying the impacts, risks and opportunities of each sustainability matter across the value chain
*Existing impact, risk and opportunity library*
Any new impacts, risks and opportunities identified by SMEs were added to the library for assessment. Items considered no longer appropriate were excluded from the 2025 assessment. This includes those that have been superseded by new impacts, risks, or opportunities, or those with a negligible materiality score in prior periods that is expected to remain unchanged. In addition, some existing IROs within the library, including those which formed part of our material IROs for the previous financial reporting period, were revised to reflect the findings from the review conducted for this reporting period. This has resulted in some changes to the presentation and description of some IROs reported this year, compared to the previous reporting period, see further detail on page 52.

*Drafting a new impact, risk and opportunity*
When a new impact, risk or opportunity is identified, SMEs draft concise descriptions of the impact, risk or opportunity to be assessed for materiality. The description clearly identifies the driver of the impact, risk or opportunity and assigns it the appropriate value chain location. Additionally, for impacts, SMEs state whether the impact is positive or negative and, for risks and opportunities, SMEs indicate whether they are connected to an impact or a dependency, and in the case of risks, identify the related principal risk, where relevant.

---

#### Step 4: Scoring materiality
*Existing impact, risk and opportunity*
For impacts, risks and opportunities previously assessed, SMEs reviewed the prior year’s scoring for appropriateness by considering the following:
- Changes in organisation or operational changes (i.e. changes in own operations, upstream or downstream value chains);
- Any mergers and acquisitions, change in strategy or entering new markets affecting Barclays Bank Group (i.e. entering/exiting new products or geographical markets);
- Significant changes in regulatory, geopolitical or social environments which may impact regulatory obligations (i.e. investigations, peer bank incidents/fines);
- Internal check-and-challenge review based on other assessments conducted by Barclay Bank Group; and
- Developments in sustainability across the market.

In instances where the assessment needed updating, the SME re-assessed the impact, risk or opportunity following the guidance outlined in Step 4.a or Step 4.b.

*New impact, risk and opportunity for 2025*
Each new impact, risk and opportunity is assessed by the most appropriate SME function, based on the SME relevant expertise. In cases where the impact, risk or opportunity is assigned to multiple functions, the average of their assessments was used to calculate a materiality score. Further detail on the scoring is outlined below.

#### Step 4.a: Impact materiality: Assessing the materiality of the impacts
All impacts are scored and prioritised by SMEs based on severity, reflecting their scale, scope, irremediability (for negative impacts) and likelihood (for potential impacts) as relevant for Barclays Bank Group. The SMEs rated each parameter on a scale of 0-5, with the severity ratings then averaged and multiplied by the likelihood to obtain a rating for each impact. SMEs also considered the specific time horizon within which the impact could occur and any outsized impact related to geography or business segment in their assessment.

#### Step 4.b: Financial materiality: Assessing the materiality of risks and opportunities
All risks and opportunities were scored and prioritised by SMEs based on their financial magnitude and likelihood as relevant for Barclays Bank Group. The initial assessment of magnitude and likelihood was qualitative and relied on their professional judgement. The qualitative assessment was then augmented with quantitative thresholds, where available, such as stress test outcomes. Professional judgement was applied in mapping the quantitative thresholds and definitions of Barclays risk register to the qualitative definitions of magnitude and likelihood. The SMEs rated each parameter on a scale of 0-5 with the magnitude ratings then multiplied by the likelihood to obtain a rating for each risk and opportunity. SMEs also considered the specific time horizon within which the risk or opportunity could occur in and any outsized risk or opportunity related to geography or business segment in their assessment.

#### Step 5: Validation of the completeness and materiality of IROs through internal governance forums
The 2025 SME assessment scores are reviewed and challenged through the internal calibration forums and internal working groups, consisting of SMEs involved in the DMA, to ensure appropriate comparability and agreement across the output of the assessment. Following this, SMEs confirmed their scores for this reporting period.

A threshold of materiality to identify the shortlist of material sustainability matters (including their specific impacts, risks and opportunities) was determined by the CSRD Steering Committee, which includes representatives from business, finance, risk, regulatory, group sustainability and legal functions. Impacts, risks, and opportunities that scored above the determined threshold, and their corresponding sustainability matters, were considered material for reporting purposes. Impacts, risks, and opportunities that scored close to the threshold or have moved across the threshold year-over-year, were subject to additional investigation by the Steering Committee, on a case-by-case basis.

The CSRD Steering Committee reserved the right to amend the initial materiality decision for each and its corresponding sustainability matter, based on their expert judgement and senior leadership insight.

The material sustainability matters and related IROs for 2025 were then presented to the BB PLC Audit Committee. For the full list of material sustainability matters see page 52.

We will continue to consider how we approach our double materiality assessment for future reporting periods, considering any changes made to the ESRS.

---

### Additional information on IRO identification for Environmental matters
As part of the DMA process, when assessing climate change, we considered Barclays Bank Groups’ direct operations and our value chain’s emission contribution and the impact of these emissions. Additionally, we completed analysis to identify and assess both physical and transition risks and opportunities including the use of scenario analysis to assess how our assets and business activities may be exposed to or impacted by climate risks. Further details, including scenarios overview, are set out on page 55 in the Climate Change disclosure.

Actual and potential impacts, risks and opportunities relating to pollution, water and marine resources, resource use and circular economy in Barclays' direct operations and its value chain were identified and assessed qualitatively based on expert judgement of Barclays subject matter experts according to the process and criteria above. This process will continue to be developed.

The DMA was primarily qualitative and relied on the professional judgement of the SMEs. Accordingly, we did factor BB PLC site-level operational activities to determine our actual and potential impacts, opportunities relating to pollution, water and marine resources, and resource use and circular economy.

We did not undertake any additional consultations with our stakeholders beyond the engagement outlined in the DMA.

### Additional information on IRO identification for Business conduct matters
Business conduct within our operations was assessed to identify material impacts, risks and opportunities in line with the DMA process. This included assessing our specific activities, sectors and locations, to identify any specific matter that may be relevant to us.

### Embedding sustainability in risk management:
We recognise sustainability related risks (including environmental, social and governance) as drivers of other existing financial risks (credit risk, market risk, treasury and capital risk) and non-financial risks (including operational risk and reputation risk). As such, these risk drivers are not treated as a standalone risk type. These risks are continuously identified, assessed, and monitored through our risk management processes as they develop over time. We prioritise sustainability related risks based on internal assessment outcomes, regulatory requirements, and investor and stakeholder sentiments.

The process for evaluating financial materiality of risks through the existing risk management processes is outlined below. The risk register contains all material risks that may impact forward-looking business plans across key legal entities and business units. Quantitative (typically based on stress testing) or qualitative assessments are performed to quantify the impact of material risks on capital or liquidity positions of legal entities/business units. Following this assessment, each material key risk driver is mapped to the risk ratings (which are derived based on the magnitude of impact and materiality thresholds). Barclays Bank Group's risk register is refreshed on at least an annual basis and is subsequently used to support strategic planning, scenario design, sensitivity analysis and capital adequacy assessments

While the existing risk management processes inform the DMA, the DMA process itself is not currently integrated into our overall risk management processes or used to evaluate our overall risk profile and processes. While the outputs from Risk register feed into the DMA process, they may differ from the materiality ratings determined through the DMA process. There needs to be further deliberation on how the concepts of magnitude and likelihood as required by DMA for ESRS disclosures can be better aligned with existing risk processes.

### Embedding sustainability in opportunity management:
On an annual basis, a strategic review of sustainable finance opportunities is undertaken by the business along with relevant stakeholders. The opportunities prioritised are then captured into Barclays' annual planning cycle. Barclays’ 2025 financial planning process included a review of its strategy, its implementation, and tracking of progress against climate-related targets – as well as capturing a view of climate-related opportunities. During 2025, Barclays Bank Group continued to enhance its monthly reporting framework to cover a view of the balance sheet from Sustainable and Transition Finance. This supports Barclays' ability to review its sustainable and transition finance portfolio at greater granularity and improve relevant business engagement through the financial planning process.

The DMA process is not currently integrated into our overall opportunity management processes or used to evaluate our overall pipeline of opportunities.

### Material Impacts, Risks and Opportunities and their Interaction with Strategy and Business Model
We have identified one new sustainability matter compared to our previous reporting period: a new potential negative impact relating to Anti-Money Laundering (AML) and Sanctions. Alongside making a number of editorial or presentational changes across the descriptions for our IROs (such as streamlining the language or aggregating our potential negative impacts in relation to S3 from five to three key themes), we have also updated a number of these descriptions from last year as a result of our DMA process, as follows:

---

- E4 (Biodiversity and ecosystems) – Updated our negative impact disclosure as we continue to build our understanding of drivers of biodiversity loss and related negative impacts in our downstream value chain, with pollution no longer identified as a primary driver that is materially relevant to our clients’ impacts.
- S1 (Own workforce) – Updated our positive impact disclosures to reflect our evolving approach to inclusion and opportunity and equal opportunities for all to progress, while aspiring to hire from the broadest global talent pools, within a culture of belonging and equal opportunity for all. We have presented policies in such a way as to reinforce our wider focus on creating a workforce culture where colleagues feel safe to speak up. See Strategy Update in 2025 section on page 76 for further details.

The table below shows the material sustainability matters for Barclays Bank Group and their mapping to the associated ESRS standard or, in the case of our entity-specific sustainability matters, the most appropriate ESRS standard.

| ESRS | Page | IRO | Type | Value Chain | Time Horizon |
| :--- | :---: | :--- | :--- | :---: | :---: |
| | | | | Upstream | Own Operations | Downstream | Short >= 1year) | Medium (1-5 years) | Long (>5 years) |
| E1 | 55 | Climate Change Mitigation | Negative Impact | | | * | * | * | * | * |
| E1 | 55 | Climate Change - Transition | Risk | | | * | | * | * |
| E4 | 68 | Drivers of Biodiversity$^1$ | Negative Impact | | | * | * | * | * |
| Entity Specific | 71 | Sustainable and Transition Products and Services$^2$ | Positive Impact | | | * | * | * | * |
| Entity Specific | 71 | Sustainable and Transition Products and Services$^2$ | Opportunities | | | * | * | * | * |
| S1 | 76 | Equal Opportunities for All | Positive Impact | * | | * | * | * |
| S1 | 84 | Working Conditions | Positive Impact | * | | * | * | * |
| S2 | 89 | Labour Rights (including Modern Slavery) | Negative Impact | | | * | * | * | * |
| S3 | 90 | Communities' economic, social and cultural rights | Negative Impact | | | * | * | * | * |
| S3 | 90 | Communities' civil and political rights$^1$ | Negative Impact | | | * | * | * | * |
| S3 | 90 | Indigenous Peoples rights$^1$ | Negative Impact | | | * | * | * | * |
| S4 | 92 | Cybersecurity$^1$ | Negative Impact | | | * | * | * | * |
| Entity Specific | 94 | Data Privacy - Accurate records$^2$ | Negative Impact | * | | * | * | * |
| Entity Specific | 94 | Data Privacy - Right to privacy of consumers and end-users$^2$ | Negative Impact | | * | * | * | * |
| Entity Specific | 96 | Anti-Money Laundering and Sanctions$^2$ | Negative Impact | * | | * | * | * |

**Notes:**
1 Denotes sustainability matter disclosed under ESRS 2 BP-2 paragraph 17 to comply with the phased-in reliefs set out in ESRS 1, Appendix C and allowed by the Quick Fix Regulation.
2 Denotes entity specific sustainability matter disclosed under ESRS 1, Appendix A, AR 1-5 and ESRS 2 sections 4.2-5 (MDRs).

Information about the current effects of these material IROs on our business model, value chain, strategy and decision making, and how we manage and respond to these effects are reflected, in particular, in the key actions we have taken over the year and the actions which we have planned, is outlined in the topical disclosures below relating to each of these IROs. When determining what information to include we consider the significance of the information in relation to the matter or the decision usefulness of the information, aligning to the ESRS 1 section 3.2 requirements.

---

Anticipated effects of these material IROs on our business model, value chain and strategy are also reflected in the key actions we plan to take. Further information regarding both our strategy and actions can be found in the topical disclosures below relating to each of these IROs.

We will continue to reflect on how we can appropriately monitor and respond to the anticipated effects of our material IROs on our business model, value chain and strategy and decision making.

### List of datapoints in cross-cutting and topical standards that derive from other EU legislation
We are required to disclose a list of datapoints in cross-cutting and topical standards that derive from other EU legislation. These disclosures are incorporated by reference into this section of the Sustainability Statement and can be found in Schedule A to the Sustainability Statement on page 412.

### Resilience of strategy and business model
Barclays Bank Group assesses the resilience of its strategy and business model regarding the capacity to identify material impacts, address related risks and take advantage of resulting material opportunities. This is the responsibility of the relevant committees and senior management, who are responsible for ensuring the risk and opportunities are considered in both the strategy and the business model. At this point in time, there are no material amendments to our strategy or business model required. Further specific details can be found in the Climate Change and Sustainable and Transition Products and Services sections on pages 55 and 71 respectively.

---

# Schedule to the Directors' report: Sustainability statement
## Environmental Information

### Contents
Barclays Bank Group identified material IROs in the following environmental topical standards:

| ESRS Standard | Section | Page |
| :--- | :--- | :--- |
| E1 | Climate Change | 55 |
| E4 | Biodiversity and Ecosystems | 68 |

## E1: Climate Change

### Climate change related impacts, risks and opportunities
The DMA process identified the following material IROs for climate change as outlined in the table below:

| Material Impacts and Risks | | Value Chain | Time Horizon |
| :--- | :--- | :--- | :--- |
| Description | Type | Upstream | Own Operations | Downstream | Short (0-1 year) | Medium (1-5 years) | Long (>5 years) |
| **Climate Change Mitigation** | | | | | | | | |
| Barclays Bank Group is connected to environmental impacts in relation to continuing financing to clients operating in high-emitting sectors$^1$. | Negative Impact | | | * | * | * | * |
| **Climate Change - Transition** | | | | | | | | |
| Barclays Bank Group may face material financial risk arising from transition-related impacts on its investments and financing activities. The transition risks caused by extensive policy, legal, technology and market changes may result in significant adverse impacts to wholesale credit corporates, especially within high-emitting industries which may not be well-prepared to transition. | Risk | | | * | | * | * |

**Note:**
1 For more detail on high-emitting sectors, please refer to the Metrics section on page 66.

### Strategy
Barclays recognises that climate change has widespread impacts on the group and its legal entities, its clients and the broader economy. Barclays integrates climate risk considerations into its strategy, scenario analysis, policies and actions, risk management frameworks, and performance metrics and targets to ensure a resilient and sustainable response to climate change. Barclays ambition to be a net zero bank by 2050, approved by shareholders in 2020, was driven by a recognition of the risks and opportunities associated with climate change. Since then, Barclays has continued to deliver against its strategy whilst at the same time, evolving its approach in recognition of the realities of the transition. The Barclays Transition Update (BTU): Clients, Capital and Innovation, published in July 2025, sets out how the Group plans to continue delivering on its net zero ambition.

### Transition plan for climate change
Barclays Bank Group does not have its own transition plan for climate change mitigation, nor does it plan to adopt its own transition plan. However, Barclays Bank Group forms part of Barclays and, as such, alongside other Barclays Group companies, will contribute to achieving Barclays ambition to be a net zero bank by 2050. The actions taken by Barclays Bank Group are grouped under decarbonisation levers and captured in the E1-3 (MDR-A) disclosure on page 63.

The BTU outlines the role that Barclays can play in supporting its clients as they navigate the opportunities and challenges from transitioning to a low-carbon economy and how overall it is managing the risks presented by the transition. The update is structured around three themes that Barclays as a whole is focusing on: working with clients on their transition, financing clients’ transition and scaling climate technology. The update is published on the Barclays website.

### Climate related risks and scenario analysis
Barclays Bank Group is exposed to climate-related risks indirectly through its downstream financing and investment activities. The feedback effects of climate risk drivers through macro and micro transmission channels when materialised are likely to be observed in Barclays Banks Group's portfolios in its traditional risk categories such as credit risk, market risk, treasury and capital risk, and operational risk. Climate risk is recognised as a driver of other existing financial risks (credit risk, market risk, treasury and capital risk) and non-financial risks (including operational risk and reputation risk).

---

Climate risk is designated as a principal risk under Barclays' Enterprise Risk Management Framework (ERMF), with the purpose of capturing the impact of climate change on the Barclays Bank Group's financial and operational risk categories. For climate risk as a principal risk, Barclays has developed and implemented a dedicated risk framework, the Climate Risk Framework, which integrates within the broader ERMF aiming to guide effective management of climate risk and support the delivery of the Barclays' Climate Strategy. This framework is applicable to all legal entities in the Barclay's Group (including Barclays Bank Group) and business lines. Climate change can also drive non-financial risk categories such as reputational risks mainly in connection with the negative impacts on climate, which continue to be managed under their respective frameworks. Barclays Bank Group continuously updates and refines its risk management practices and internal frameworks.

### Identifying and assessing climate risk in downstream financing and investment activities
The Climate Risk Framework supports in establishing a systematic and enterprise-wide approach to managing financial and operational risks from climate change. The approach to identifying, measuring and managing climate-related risks is consistent with other key risks, focusing on those climate risk drivers that are relevant and could amplify financial and operational risk types. The potential impacts of transition risk drivers will vary across Barclays Bank Group's portfolios depending on composition, industry, geographic location, business operations and other contextual factors. Transition risk is defined by Barclays as the risk of financial losses caused by the changes driven by the economy shifting to a lower carbon basis, including for example changes in policy, technology and consumer and investor sentiment. Transition risks could occur in all timeframes. There remains significant uncertainty around the speed and scale of the transition. Assessments across short (0-1 yr), medium (1-5 yrs) and long-term (>5yrs) timeframes are conducted to understand and quantify the impact of climate transition risks on its financed portfolios and risk types. The approach is customised to reflect portfolio characteristics, size and exposure to specific climate risk drivers (including transition risk drivers) within various portfolios. Barclays has leveraged and enhanced its risk taxonomy and existing risk identification processes, such as horizon scanning, sector and geographical assessments to connect and understand the impact of various transition risk drivers on its existing risk categories. Please refer to the Climate Risk Management section (page 144) for further details.

Barclays Bank Group uses its risk register process to assess the potential effects of climate risk drivers on its existing financial and operational risk categories and portfolios across various time horizons. The materiality of financial impact from climate risks is derived either quantitatively (typically based on stress testing) or through qualitative estimations. The outcome of this process feeds into the CSRD double materiality assessment to identify and flag material sustainability topics for the firm.

### Climate Scenario Analysis
Climate Scenario Analysis forms a key part of the Barclays Bank Group's approach to assessing and quantifying the impact of both physical and transition risks in our portfolios. Through climate scenario analysis, the climate-related risks and uncertainties can be translated into financial impacts to Barclays, allowing Barclays (including Barclays Bank Group) to identify risks and better understand the resilience of its business strategy and the impact on the Bank's business.

Barclays uses climate scenario analysis primarily for (1) understanding Barclays’ resilience to climate scenarios, (2) as a consideration within its financial planning process, (3) as a consideration within its assessment of Expected Credit Losses reported under IFRS 9. Barclays continues to build its use of scenario analysis to explore and further understand the evolving landscape – identifying areas of risks and opportunities – to challenge existing assumptions of future climate pathways and measure the risks that climate change poses to us.

Two stress tests incorporating climate risk were conducted during 2025, each with its own scenario aligned to a less than 2°C pathway. Whilst we only assessed transition risk to be material, the scenarios explored Barclays’ financial resilience to both transition and physical risks. Firstly, the 2025 annual Internal Stress Test (IST25) featured a scenario with climate risk drivers over a five-year period. Secondly, a climate-based Reverse Stress Test (RST) was run with a shorter-term focus, designed to test resilience to extreme, near-term climate events.

Based on the results of the scenario analyses performed to date, our view is that Barclays Bank Groups' strategy remains resilient to climate scenarios. Given the evolving climate landscape, we seek to further enhance our capabilities and modelling to refine our understanding of Barclays Bank Groups' resilience to various climate scenarios, particularly given high uncertainty in this area.

The IST25 was conducted as a Group-wide exercise across all portfolios, with the scenario specifically designed to evaluate Barclays Bank Groups’ ability to withstand both climate-related and traditional macroeconomic risks. This year’s scenario placed greater emphasis on physical climate risks than in previous years. Variable paths were benchmarked against NGFS (Network for Greening the Financial System) short-term scenarios wherever narratives aligned, ensuring stronger consistency with industry-standard methodologies.

#### Scenario analysis - scope and process
The IST25 climate scenario consists of three chronological stages. These stages include initial policy announcements that trigger immediate asset repricing, while more stringent policy requirements unfold over a longer time horizon - dampening recovery in years 3 to 5. Against this backdrop, the scenario stages also incorporate physical risk considerations: In the first

---

two years, severe ‘stormy and wet’ weather occurs, characterised through floods and hurricanes. This is followed by three years of ‘hot and dry’ weather, resulting in water stress and wildfires. The insurance market tightens in the face of increased claims, with restricted risk appetite in high-risk zones and to key perils. Events create greater societal awareness of physical risks and their damages, shifting preferences towards lower risk assets.

The scenario's three stages include the following key events over five years, which is aligned to our short and medium-term horizons for climate risk generally:

**Stage 1:**
- Consumer preferences shift toward greener products and practices, particularly in the UK and EU, while consumption is cut to cope with the recessionary environment. Behavioural shifts are pronounced at sector level as consumers turn away from firms who finance carbon-heavy industries.
- Investors reassess their participation with certain firms. Those with heavy exposure to brown income and/or assets, combined with poor transition plans, are negatively impacted in equity markets – with capital reallocated to greener firms.

**Stage 2:**
- Regional climate policy divergence grows as UK, EU and China forge ahead as leaders on the transition, with India pivoting because of increased energy security concerns, and the US continuing to focus on domestic fossil fuel energy production, putting downward pressure on oil and gas prices. Low carbon investments surge due to accelerated investment in the Power grid and Electric Vehicles (EV) infrastructure, supported by declining costs and efficiency increases.
- In 2028, the UK and EU accelerate or announce additional climate policies. Governments rapidly scale up investment in EV charging infrastructure to speed up the automotive sector’s transition. Existing emissions trading schemes are strengthened to align with a 1.5°C pathway, triggering a significant carbon price shock in 2028. This slows economic recovery and leads to heightened inflation as production costs rise due to increased energy costs, although some of these impacts are partially offset by substantial public and private investment aimed at enabling a faster transition. Carbon Border Adjustment Mechanisms (CBAMs) are introduced, causing supply-side shocks and increased trade frictions. Proposals to tighten EPC minimum standards are accelerated, bringing forward compliance deadlines for Buy-to-Let, Social Housing, and UK Commercial Real Estate properties to achieve EPC rating C or above.
- In the US, no additional climate policy is assumed at this stage. Nevertheless, some indirect effects are felt from the transition in Europe, primarily through reduced demand for carbon-intensive US exports as CBAMs decrease their competitiveness, and global fossil fuel price shocks.

**Stage 3:**
- By 2029, carbon price growth in the UK and EU slows but remains high. Technological progress, coupled with global capital shifting towards low-carbon solutions, drives the creation of new green jobs.
- In 2029, the US makes a rapid pivot back to transition policy, aiming to catch up domestically in low-carbon technologies. Policies similar to those introduced in Stage 2 in Europe are implemented, with similar inflationary impacts.

The scenario will have significant impacts on Barclays, including:
1. Amplified market shocks: additional to existing macroeconomic shocks, there will be further equity and credit shocks for brown industries and financiers, as a result of immediate repricing.
2. Amplified credit deterioration: additional credit risk on brown industries as a result of lower earnings expectations and refinancing risks.
3. Increase in frequency of physical risk events: throughout the time horizon, there is an increase in the occurrence of physical hazards such as flood, hurricanes and droughts.

### Results and insights
Results of the exercise indicate that losses are again highest within the Investment Bank, primarily driven by exposures to carbon-intensive sectors that are most vulnerable to the combined effects of transition and physical climate risks. In particular, the scenario featured a sharp rise in carbon prices in the EU and UK, with the EU Emissions Trading System (ETS) price rising to $309/tCO2e. This was driven by a decline in global oil and gas demand, accelerated transition policies and the increasing cost burden from carbon pricing, all of which placed pressure on profitability in these industries.

---

The impacts of the IST25 scenario remain manageable within the Bank’s established risk profile. The IST25 results are fully integrated into the Group’s Internal Capital Adequacy Assessment Process (ICAAP), informing the setting of risk appetite and supporting the Board’s approval of the medium-term capital plan. The scenario confirms that the Group’s capital and liquidity positions remain robust, with headroom above regulatory and internal thresholds. Management actions, both business-as-usual and strategic, provide additional capacity to absorb stress impacts if required.

### Challenges and limitations
Barclays is continuing to better its understanding of the interlinking relationships between climate, particularly transition risk, and macro variables. A lack of adequate historical data is a key limitation to progress modelling capabilities. Inherent challenges exist in climate modelling due to limitations in data quality and availability, given the short history of climate assessments within the financial services industry.

There exist inherent uncertainties with scenario design largely attributed to limited history of the interactions between climate risks and the economy. There is a level of uncertainty with climate stress-testing projections in (i) how the scenario will manifest; (ii) how customers and clients will react; and (iii) the final loss quantification. Over longer time horizons, it becomes increasingly difficult to capture the range of second-order effects as physical and transition risks evolve, assess the rate in which risks manifest or subside, or identify inflection points. During 2025, Barclays conducted an exploratory exercise to extend climate scenario analysis from a 5-year period to a 10-year period. We continue to reflect on the outcomes of this exercise to deepen our understanding and support the further development of long-term assessment capabilities.

It is recognised, however, that further advances in modelling capability and data availability are required to fully capture the potential extent of climate-related losses. Given the evolving climate landscape, we seek to further enhance our capabilities and modelling to refine our understanding of the Barclays Bank Group's resilience to various climate scenarios, particularly given high uncertainty in this area.

### Policies

#### Policies relating to Climate Change Mitigation Impacts

##### Climate Change Statement
Barclays Bank Group applies the Barclays position statement titled ‘Climate Change Statement’ to manage our downstream negative impact in certain high-emitting sectors. The statement addresses climate change mitigation and relates to the negative downstream impact that Barclays Bank Group can have by continuing to finance activities and/or companies active in high-emitting sectors which significantly contribute to global emissions. The statement does not address climate change adaptation, energy efficiency or renewable energy deployment. With regard to climate change adaptation, energy efficiency and renewable energy deployment, we address this by including the financing of the above activities as eligible under our Sustainable and Transition Finance Frameworks, to be counted towards Barclays Group target to facilitate $1 of trillion Sustainable and Transition Finance between 2023 and the end of 2030.

The Climate Change Statement sets out Barclays' position and approach to certain high-emitting sectors. The statement has been developed in addition to Barclays sector-specific emission reduction targets consistent with the Barclays Purpose. The statement considers risk and market factors for energy and power sectors.

The key contents of the Climate Change Statement are:
- Conditions or restrictions on the financing of certain activities, such as project finance for expansion projects in upstream oil and gas, or financing provided to certain clients or groups active in sectors including but not limited to upstream oil and gas, thermal coal mining and thermal coal power.
- The applicability of stated financing restrictions and the governance approach of the statement.
- A brief overview of the following:
  - The Client Transition Framework (CTF) evaluates our in-scope clients’ progress towards business models aligned to a low-carbon economy.
  - The Client Transition Review Forum (CTRF) which carries out targeted reviews of groups (any entity, the relevant parent company and its consolidated subsidiaries, as a whole) subject to a CTF assessment. These reviews are informed by the CTF assessment and take into account consideration of relevant risks and other business factors.
  - The approach to Sustainability Enhanced Due Diligence (SEDD) which evaluates groups that are in scope of the statement, their performance on a range of environmental and social issues in addition to adherence to restrictions detailed in our external position statements (taking into account regional and jurisdictional considerations).

---

Clients in-scope of our Climate Change Statement are subject to SEDD and assessed against the Equator Principles (if a project finance or credit transaction is deemed to be in scope) including, where appropriate, any relevant International Finance Corporation (IFC) performance standards. The Performance Standards are directed towards clients, providing guidance on how to identify risks and impacts, and are designed to help avoid, mitigate and manage risks and impacts as a way of doing business in a sustainable way, including stakeholder engagement and disclosure obligations of the client in relation to project-level activities.

Additional SEDD questions will vary by sector, for instance, for Biomass, this process will also consider the sustainable sourcing of feedstock. External technical input may be obtained to assist the business in reviewing and assessing whether certain Group activities meet our internal SEDD criteria, or where there is uncertainty as to whether a certain activity is within scope of our SEDD criteria.

The Climate Change Statement is periodically reviewed and updates considered in light of the rapidly changing external environment. The statement is informed by engagement with Barclays stakeholders, including shareholders, clients, subject specialists and civil society. Barclays also use these engagements to share the statement with affected stakeholders and clients. Any review of this Statement will be undertaken by the Barclays Group Sustainability Committee with escalation to the Barclays Board Sustainability Committee or the Barclays Board (as appropriate).

Group-wide frameworks, policies and standards will be adopted throughout Barclays and applied unless local laws or regulations require otherwise. As such, the BB PLC CEO is the most senior individual in the organisation that is accountable for the implementation of the statement.

The scope of the statement is outlined in the table below and covers our approach to financing sectors such as Upstream Oil and Gas, Unconventional Oil and Gas, Thermal Coal Mining, Thermal Coal Power, Mountain Top Removal Coal Mining and SEDD requirements for Biomass.

Words in italics as captured in the table below are defined in the Key Definitions table in the 'Further Information' section starting from 107. These definitions clarify the intended scope of this statement. The Climate Change Statement is available to stakeholders on the Barclays website.

---

| Sector | Project Level | Entity Level |
| :--- | :--- | :--- |
| Upstream Oil and Gas | • We will not provide *project finance* for *expansion* projects or infrastructure projects primarily to be used for such *expansion* projects<br>• We will not provide other *direct financing* to *Energy Groups* for *expansion* projects or infrastructure projects primarily to be used for such *expansion* projects | • We will not provide *financing* to new clients that are *Energy Groups* where more than 10% of their total planned oil & gas capital expenditure is in *expansion*<br>• We will only provide new *financing* or renewal of existing *financing* for *Non-diversified Groups* where more than 10% of their total planned oil & gas capital expenditure is in *long-lead expansion*, by exception<br>• We expect all *Energy Groups* to be producing relevant information in relation to their transition plans or decarbonisation strategies<br>• We expect *Energy Groups* to demonstrate that they are committed to reducing their own emissions by having:<br> ◦ net zero-aligned near-term Scope 1 and 2 emissions reduction targets (absolute or intensity-based); and<br> ◦ targets to reduce methane emissions by 2030, aligned with OGCI, OGMP2.0, or similar industry guidance; and<br> ◦ a commitment to end all routine / non-essential venting and flaring by 2030.<br><br>**Client Transition Framework (CTF)**<br>We assess the information available on *Energy Groups’* plans for alignment with our 2030 financed emissions reduction targets through the *Client Transition Framework (CTF)* against several factors including, but not limited to, the following:<br>• Scope 1 and 2 emissions reduction targets, including methane.<br>• Scope 3 absolute emissions reduction targets/ commitments.<br>• Plans to expand production.<br>• Low carbon business model activities and plans.<br><br>**Client Transition Review Forum (CTRF)**<br>We have established a *Client Transition Review Forum (CTRF)* to carry out targeted reviews of *Groups* subject to a *CTF* assessment. *Energy Groups* meeting any of the following will be subject to mandatory annual review by the CTRF to determine whether continued *financing* support is appropriate in the context of their investment plans and overall decarbonisation or transition plans:<br>• *Energy Groups* where more than 10% of their total planned upstream oil & gas capital expenditure is in *expansion*.<br>• *Non-diversified Groups*<br> ◦ We recognise that *Non-diversified Groups* may present greater transition risk than diversified *Energy Groups*, in particular those engaged in *long-lead expansion*.<br> ◦ We have very limited appetite for *Non-diversified Groups* where they are engaged in *long-lead expansion*.<br>• *Energy Groups* with the lowest *CTF* assessment scores.<br><br>Notwithstanding the outcomes of the CTRF reviews, *financing* decisions are transaction specific and will continue to be subject to consideration by relevant committees, if appropriate, to consider issues such as credit risk, reputational risk and capital impact.<br><br>See “Applicability of Financing Restrictions” below for further detail on how restrictions will be applied. |

---

| Sector | Project Level | Entity Level |
| :--- | :--- | :--- |
| Unconventional Oil and Gas | **Amazon Biome/Ultra-Deep Water/Extra Heavy Oil**<br>• We will not provide *direct financing* to *Energy Groups* for any oil and gas projects in the *Amazon Biome*, or any oil and gas projects involving *Ultra-Deep Water* and/or *Extra Heavy Oil*, or infrastructure projects primarily to be used for such oil and gas projects<br><br>**Arctic Circle**<br>• We will not *directly finance* oil and gas projects in the *Arctic Circle*<br><br>**Hydraulic Fracturing (Fracking)**<br>• We will not *directly finance* projects involving *Hydraulic Fracturing (Fracking)* in the UK and Europe<br><br>**Oil Sands**<br>• We will not provide *direct financing* wholly or primarily to be used for the construction of new: (i) *Oil Sands* exploration, production and/or *Oil Sands* processing assets; or (ii) *Oil Sands* pipelines | **Amazon Biome**<br>• We will not provide *financing* to *Clients* *engaged in* exploration, appraisal, development, and production of oil and gas in the *Amazon Biome*<br><br>**Arctic Circle**<br>• We will not provide *financing* to *Clients* *materially engaged in* oil and gas exploration and production or pipeline transportation operations in the *Arctic Circle*<br>• We will not provide *financing* to *Clients* with ancillary oil and gas businesses in the *Arctic Circle* where proceeds are known to be for supporting new oil and gas exploration, production or new pipeline transportation projects in the *Arctic Circle*<br><br>**Hydraulic Fracturing (Fracking)**<br>• We will not provide *financing* to *Clients* *materially engaged in* *Fracking* activities in the UK and Europe<br><br>**Oil Sands**<br>• We will not provide *financing* to *Oil Sands* exploration and production companies<br>• We will not provide general corporate purposes *financing* that is specified as being wholly or primarily for the construction of new: (i) *Oil Sands* exploration, production and/or *Oil Sands* processing assets; or (ii) *Oil Sands* pipelines<br><br>**Unconventional Oil and Gas**<br>• We will not provide *financing* to *Energy Groups* whose aggregate share of production in *Oil Sands*, *Extra Heavy Oil*, *Hydraulic Fracturing* in the UK/EU, and *Arctic Circle* oil and gas exceeds 20% of their total oil and gas production. |
| Thermal Coal Mining | • We will not provide *project finance* for greenfield development or *material expansion* of thermal coal mines anywhere in the world, including *captives*<br>• We will not provide *project finance* for development of infrastructure projects primarily to be used for *thermal coal* mines anywhere in the world | • We will not provide *financing* to new clients *engaged in* *thermal coal mining*<br>• We will not provide general corporate purpose *financing* that is specified as being for new or *material expansion* of *thermal coal mining*<br>• We will not provide *financing* to existing clients that generate more than 30% of revenues from *thermal coal mining*<br>• We will not provide general corporate purposes *financing* to clients with entities *engaged in* opening new *thermal coal mines* or *material expansion* of existing *thermal coal mines*, unless an undertaking is received from the borrower, or we are otherwise satisfied that the proceeds of such *financing* will not be made available to entities *engaged in* opening new *thermal coal mines* or *material expansion* of existing *thermal coal mines*<br><br>**By 1 January 2030:**<br>• For EU and OECD, we will phase out *financing* to all clients *engaged in* *thermal coal mining*<br>• For the rest of the world, we will no longer provide *financing* to *clients* that generate more than 10% of revenue from *thermal coal mining*<br><br>**By 1 January 2035:**<br>• We will phase out *financing* for all clients *engaged in* *thermal coal mining* |

---

| Sector | Project Level | Entity Level |
| :--- | :--- | :--- |
| Thermal Coal Power | • We will not provide *project finance* to enable the construction or *material expansion* of *thermal coal-fired power plants* anywhere in the world, including *captives* | • We will not provide general corporate purpose *financing* that is specified as being for new or *material expansion* of *thermal coal-fired power plants*<br>• We will not provide *financing* to clients that generate more than 30% of revenue from *thermal coal-fired power generation*<br>• We will not provide general corporate purposes *financing* to clients with entities *engaged in* developing new *thermal coal-fired power plants* or *material expansion* of existing *thermal coal-fired power plants*, unless an undertaking is received from the borrower, or we are otherwise satisfied that the proceeds of such *financing* will not be made available to entities *engaged in* developing new *thermal coal-fired power plants* or *material expansion* of existing *thermal coal-fired power plants*<br><br>**By 1 January 2030:**<br>• For EU and OECD, we will phase out *financing* to clients *engaged in* *thermal coal-fired power generation*<br>• For rest of the world, we will no longer provide *financing* to *clients* that generate more than 10% of revenue from *thermal coal-fired power generation*<br><br>**By 1 January 2035:**<br>• We will phase out *financing* for all clients *engaged in* *thermal coal-fired power generation*.<br><br>**Exceptions to the phase out date(s) for thermal coal-fired power generation apply if:**<br>• Remaining *thermal coal-fired power plants* are abated to reduce GHG emissions to near zero; or<br>• Remaining *thermal coal-fired power plants* solely utilised as backup to low carbon power supply; or<br>• Remaining *thermal coal-fired power plants* are required to remain open by operation of law, regulation or contract. |
| Mountain Top Removal (MTR) Coal | • We will not *directly finance* projects or developments using *MTR coal mining*. | |
| Biomass | | • We will conduct SEDD on *Groups* that have >500MW installed *Biomass* capacity AND/OR >50% of their total installed capacity as *Biomass*. |

### Exceptions to Barclays Climate Change Statement
- We will consider exceptions to our *thermal coal* mining policy on a case-by-case basis for any *transition finance* provided by Barclays to *clients* reducing their *thermal coal* portfolio including retrofitting of existing facilities.
- We will consider exceptions to our *thermal coal* power policy on a case-by-case basis for any *transition finance* to clients reducing their *thermal coal* portfolio including retrofitting of existing facilities or where we are providing *financing* for decommissioning plants for those unable to transition.

### Applicability of financing restrictions in Barclays Climate Change Statement
- Any existing commitments or *financing* entered into prior to any of the restrictions coming into effect under the Upstream Oil & Gas and Unconventional Oil & Gas sections of this statement may remain in place (but refinancings of any such commitments or *financing* shall be subject to the restrictions described above).
- In certain cases, we may enter into *Sustainable Finance* or *Transition Finance* transactions with an entity in a Group that would otherwise be restricted as a result of the application of the Upstream Oil & Gas section of this statement where Barclays is satisfied that any *Sustainable Finance* or *Transition Finance* transactions provided to it will not be used directly to support oil & gas activity.
- In cases where *clients* are identified as not meeting the non-mandatory expectations and Barclays has an active relationship with those *clients*, we encourage them to adhere to these expectations. Where *clients* are unable or unwilling to do so over time, we will review the relationship and may reduce our support.

---

### Policies relating to Climate Change Transition in downstream financing
Barclays Bank Group has adopted and implemented the Climate Risk Framework for Climate - Principal risk, focusing on managing impacts on financial and operational risk categories from climate change within the broader ERMF aiming to guide effective management of climate risk and support the delivery of its Climate Strategy. The Climate Risk Framework is underpinned by the Climate Risk Policy and Climate Risk Standard which collectively aim to embed climate-related considerations into Barclays’ risk management practices. The Group Head of Climate Risk is the owner of climate risk as a principal risk, accountable for the management and oversight of this framework and associated policies and standards.

The Climate Risk Policy and Climate Risk Standard set out the control objectives and minimum control requirements for managing climate risk across different stages of the risk management cycle (across risk identification and assessment, management and mitigation, monitoring and reporting). Further, these components guide Barclays Bank Group in managing transition risks in its financed portfolios, maintaining financial resilience and aligning with its broader climate strategy. These documents articulate the approach for risk appetite by specifying guiding principles, quantitative limits and escalation protocols to maintain exposures within acceptable boundaries. These documents also outline the roles and responsibilities across governance structures and the three lines of defence for managing and overseeing climate risk.

The key principle underpinning the Climate Risk Framework is that climate risk is considered as a driver of traditional risk categories (e.g. credit risk, market risk, operational risk etc), and as such the frameworks and standards of other principal risk categories have also been enhanced to support the integration and embedding of climate risk within existing risk practices. The oversight and management of climate-related risks occur at a number of levels including through various governance committees and forums across business lines and legal entities. The frameworks, policies and standards are reviewed annually and updated to reflect internal and external developments including changing regulatory expectations.

### Actions

#### Actions to manage Climate Change Mitigation Impacts
We have taken and will continue to take the following key actions, grouped under decarbonisation levers:

##### Measuring and monitoring emissions

###### Sustainability Enhanced Due Diligence (SEDD) to achieve Climate Change Statement objectives
We conduct SEDD on clients in-scope of our public position statements, via detailed Sustainability Enhanced Due Diligence (SEDD) questionnaires, which are used to evaluate their performance on a range of environmental and social issues in addition to adherence to restrictions detailed in our public position statements (application of the provisions is subject to compliance with applicable laws and regulations, which may change from time to time) and may be supplemented by a review of client policies/procedures, further client engagement and adverse media checks as appropriate. SEDD questionnaires generate an outcome based on alignment with position statements and identified environmental and social issues, which in turn determines whether further review by the Environmental and Social Risk Management (ESRM) team within Group Sustainability, client engagement may be required and the periodic review cycle (either annual or biennial). We follow a risk-based approach where certain clients would require further risk assessment prior to execution of transactions. The outcome of this action is the evaluation of a clients performance on a range of environmental and social issues and adherence to restrictions detailed in our external position statements, which in turn determines whether further review and client engagement may be required throughout the year and can be used to inform our financing decisions. SEDD for clients in scope of our external position statements is undertaken by Barclays client coverage teams, supported by control teams, as well as the Environmental and Social Risk Management (ESRM) Team, within the Group Sustainability function, who may advise on the application of the statements. Application of SEDD in relation to other identified impacts, risks and opportunities, is detailed in pages 69, 89 and 92.

Clients in-scope of our Climate Change Statement continue to be subject to SEDD.

###### Financed emissions tracking and benchmarking
Barclays measures certain financed emissions and tracks them at a portfolio level against the goals and timelines of the Paris Agreement – this methodology is called BlueTrack™. Currently, Barclays has set 2030 financed emissions reduction targets for Upstream Energy, Power, Steel, Cement, Automotive manufacturing, Aviation, UK Commercial Real Estate, UK Agriculture portfolios and a convergence point for UK Housing. The BlueTrack™ methodology was developed to measure and track Barclays progress against targets integrating 1.5°C aligned scenarios. The BlueTrackTM methodology uses an external climate scenario to construct a Paris-aligned portfolio benchmark that defines how a given financing portfolio will need to reduce emissions over time. These scenarios have been selected because they have been developed by reputable external providers, are aligned with the Paris Agreement goals and are sufficiently granular. The financed emissions for Barclays Bank Group are reported within the metrics section of this disclosure.

---

### Working with clients on their transition
We listen to our clients and build a nuanced understanding of the commercial realities shaping their transition pathways. This is informed by regular client dialogue led by our coverage teams and dedicated sustainable finance specialists, supported by specialised analytical tools such as our Client Transition Framework (CTF).

The CTF evaluates our in-scope clients’ progress towards business models aligned to a low-carbon economy, primarily focused on clients' public disclosures. It provides a detailed understanding of clients’ current and future transition activities. Clients who are assessed receive a CTF score of T1 (most developed) to T5. It helps us monitor and measure the decarbonisation progress of our in-scope clients, which in turn informs our engagement efforts. Engaging with our clients to assist with understanding their businesses, the challenges they face and the risks and opportunities they are seeking to address is critical to our ability to support them as they navigate the transition to a low-carbon economy.

In 2025, the CTF Methodology was extended to increase the scope of clients covered by assessments to include in-scope publicly listed corporate clients in all sectors across the Investment Bank and UK Corporate Bank, as well as in-scope clients within the UK Commercial Real Estate portfolio. This is in addition to continuing annual CTF assessments for in-scope clients in the previously assessed sectors (Upstream Energy, Power, Steel, Cement, Automotive manufacturing, & Aviation). The continued use of AI for data collection of clients’ public disclosures has enabled this expanded scope and has approximately quintupled the total limits covered by our assessments versus 2024. The aggregate 2025 CTF results reflects the impacts of the expanded scope, methodology updates, and lending activity.

In the sectors where we have set 2030 financed emissions reduction targets, these scores inform our engagement, origination decisions, and portfolio management, and help ensure that our approach is both commercially disciplined and forward-looking, enabling us to support clients credibly whilst managing transition-related exposures across the bank. We intend to implement this approach for UK Commercial Real Estate during 2026. For sectors where we have not set financed emissions reduction targets, we will continue to consider how we embed the outputs from these CTF assessments during 2026. In all cases, financing decisions continue to remain transaction-specific and subject to standard committee reviews including for credit risk, reputational risk, and capital impact.

The expected and achieved reduction in emissions from these above actions have not been calculated for Barclays Bank Group. Measuring the result of our actions on achieved and expected GHG reductions is both non-linear and complex, and therefore we have not isolated the specific impact of our actions. Further, with respect to expected GHG reductions, it is very difficult to accurately quantify the likely specific impact of our actions due to our dependence on our clients’ ability to commercially decarbonise their business models, which is influenced by a wide range of external factors, including market developments, technological progress and its financial viability, a stable and supportive policy environment, regulatory alignment, changes to societal behaviour, geopolitical developments and regional variations. Therefore, we do not report our achieved or expected GHG reductions specifically as a result of our actions.

### Sustainable and transition finance
We continue to expand the breadth of sustainable and transition finance banking products we offer to support the transition to a low-carbon economy, including those aimed at mitigating climate change. For details on this please refer to actions on page 71 of the Sustainable Products and Services section.

### Actions to manage Climate Change Transition risk in downstream financing activities
Barclays, including Barclays Bank Group has adopted an integrated approach to managing and mitigating climate risk in its downstream financing activities, combining continuous monitoring with both portfolio-level and bottom-up transaction-level assessments. These activities are tailored to the underlying portfolio’s composition and characteristics, ensuring that risk management efforts are focused on areas with material exposure to climate risks.

Barclays, including Barclays Bank Group's approach to setting risk appetite for climate risk is aligned with its ambition to be a net zero bank by 2050 and reducing financed emissions in line with its 2030 targets. Climate risk considerations have been included in the risk appetite qualitative statements and quantitative constraints. The risk appetite for climate risk is managed through various risk limits, triggers and indicators set across different Principal Risk types. Regular monitoring, reporting and governance provide oversight of climate risk profile and exposures and ensure they remain within the thresholds of risk appetite. When breaches occur, investigation is conducted to understand the rationale for the breach. Corrective actions, such as decreasing exposure or considerations for other risk mitigating measures are reviewed and discussed to address the breach. Client and portfolio-level assessments are performed to identify and assess portfolios that are more vulnerable to climate risks. These actions are completed on a continuous basis through the year. For further information on actions, refer to the Climate Risk Management section of the Risk Review on page 144.

At a transaction level, Barclays Bank Group integrates climate considerations into its credit decisioning and underwriting processes. Barclays Bank Group has implemented enhanced oversight and additional scrutiny for new deals originated in elevated sectors, particularly those with sector targets and subjected to external position statements. The scores from the Client Transition Framework (CTF) and emissions data from BlueTrack™ support identification of clients and portfolio segments with elevated transition risk. These insights further inform key risk management practices—including risk

---

monitoring, limit setting, concentration management, credit decisioning, across both portfolio level and transaction level. Please refer to the Climate Risk Management section for additional details (page 144).

Stress testing, ICAAP (Internal Capital Adequacy Assessment Process) and ILAAP (Internal Liquidity Adequacy Assessment Process) are essential tools used by Barclays Bank Group to manage and mitigate financial risks. These exercises help assess the Bank's resilience under adverse scenarios, ensuring it maintains sufficient capital and liquidity buffers to withstand shocks.

Barclays continues to enhance its risk management capabilities with increased knowledge and ability to identify, quantify and manage climate related risks, including transition risk, in line with external developments and regulatory expectations.

### Future Actions planned in relation to Climate Change Mitigation Impacts and Climate Change Transition risk
Barclays Bank Group will continue to contribute to Barclays efforts to manage portfolios, maintain balance between commercial objectives, prudent risk management practices and other non-financial objectives in support of Barclays ambition to be a net zero bank by 2050. Barclays periodically reviews its policies and the actions in relation to its objectives and targets and updates them in consideration of the rapidly changing environment and as informed by engagement with stakeholders, shareholders, clients, subject specialists and civil society groups. Barclays will continue to periodically review its risk appetite and risk management approach for climate risk to maintain alignment with their strategic objectives as well as regulatory developments on financial risks from climate change. As such, we will continue to support and contribute to these key Barclays actions, which we expect to contribute to the achievement of policy objectives and Barclays’ targets across Barclays on an ongoing basis.

### Targets

#### Considering Climate Change Mitigation Impacts and Climate Change Transition risk
Barclays Bank Group does not have any entity specific targets relating to the impact and risk referred to above because Barclays Group views sustainability as a global issue which is best tackled from a top down approach, with targets set at the Barclays Group level. Further, given the global footprint of many Barclays clients, who often engage with multiple Barclays entities, setting targets at the Barclays Group level ensures a more cohesive and aligned approach to achieve our sustainability objectives.

However, Barclays Bank Group as a part of the wider reporting group contributes towards achieving the 2030 financed emissions reduction targets set at the Barclays Group level to manage climate change impacts or transition risk. Therefore, we track the effectiveness of the policies and actions referred to above through monitoring of the progression against the targets set at Barclays level. Barclays has set 2030 emission reduction targets using BlueTrack™ for eight high-emitting sectors: Upstream Energy, Power, Cement, Steel, Automotive manufacturing, UK Commercial Real Estate, UK Agriculture and Aviation; and a convergence point for UK Housing. These 2030 financed emissions reduction targets established at the Barclays level for high-emitting sectors also include legal entities’ portfolios. Emission reduction targets and CTF scores help us engage with clients, inform decision making and risk management practices. In addition, in relation to tracking the effectiveness of our policies and actions in relation to transition risk, the approach and practices for managing climate risk are reviewed on a regular basis for alignment with regulatory developments and industry leading practices. Barclays has implemented controls to manage climate-related risks. A governance forum oversees these controls including climate related risk events, policy and issue management. Additionally, the assurance teams are responsible for performing climate risk specific reviews to ensure effectiveness of the Climate Risk Framework and risk practices.

The 2030 financed emissions reduction targets set at Barclays level are outlined in the below table.

---

### Financed emissions metrics - Barclays

| Sector | Sector boundaries | Emissions Scope | GHG included | Reference scenario | Target metric | Unit of measurement | Baseline year | Target vs baseline |
| :--- | :--- | :---: | :--- | :--- | :--- | :--- | :---: | :--- |
| Upstream Energy | Upstream Energy | 1,2 & 3 | Carbon dioxide and Methane | IEA SDS IEA NZE2050 | Absolute emissions | MtCO$_2$e | 2020 | -15% by end of 2025 -40% by end of 2030 |
| Power | Power generators | 1 | Carbon dioxide | IEA SDS IEA NZE2050 | Physical Intensity | kgCO$_2$e/ MWh | 2020 | -30% by end of 2025 -50% to -69% by end of 2030 |
| Cement | Cement manufacturers | 1 & 2 | All GHGs | IEA NZE2050 | Physical Intensity | tCO$_2$e/t | 2021 | -20% to -26% by end of 2030 |
| Steel | Steel manufacturers | 1 & 2 | All GHGs | IEA NZE2050 | Physical Intensity | tCO$_2$e/t | 2021 | -20% to -40% by end of 2030 |
| Automotive manufacturing | Light Duty Vehicles manufacturers | 1,2 & 3 | All GHG for scope 1 and 2; Carbon dioxide for scope 3 | IEA NZE2050 | Physical Intensity | gCO$_2$e/ km | 2022 | -40% to -64% by end of 2030 |
| Aviation | Commercial Aviation (Air Travel) – Passenger (including belly cargo) and Dedicated cargo | 1 & 3 | Carbon dioxide for scope 1; All GHGs for scope 3 | MPP Prudent | Physical Intensity | gCO$_2$e/ RTK | 2023 | -11% to -16% by end of 2030 |
| UK Commercial Real Estate | UK Corporate Bank | 1 & 2 | CO$_2$, methane and nitrous oxide | CRREM II | Physical Intensity | kgCO$_2$e/ m$^2$ | 2023 | -51% by end of 2030 |
| UK Agriculture | UK Livestock & Dairy Farming | 1,2 & 3 | Carbon dioxide, methane and nitrous oxide | CCC BNZ | Absolute emissions | MtCO$_2$e | 2023 | -21% by end of 2030 |
| UK Housing$^1$ | UK buy-to-let and owner-occupied mortgages, Social Housing and Business Banking | 1 & 2 | Carbon dioxide, methane and nitrous oxide | CCC BNZ | Physical intensity | kgCO$_2$e/ m$^2$ | 2023 | Portfolio convergence point vs. baseline -40% by end of 2030 |

**Note**
1 Barclays has identified a 2030 emission intensity convergence point for UK Housing but has not set a formal target.

The key drivers behind changes to the portfolio metrics for 2025, as well as cumulatively against the relevant baseline, within the ‘Update on Progress Against Targets’ section of Barclays’ Annual Report.

### Metrics

#### Metrics relating to Climate Change Mitigation Impact and Climate Change Transition risk

##### Emissions
We have disclosed Scope 3 Category 15 emissions in line with the results of our DMA and obligations under the ESRS.

We have determined it appropriate to report absolute emissions only from activities where Barclays have set 2030 financed emissions reduction targets due to the below reasons:
1. Emissions from sectors where Barclays has set 2030 financed emissions reduction targets represent the only relevant data points in relation evaluating the performance and effectiveness of the E1 IROs.
2. Within financed emissions, the activities where Barclays has set targets are those that drive the group business strategy and client action.
3. Upstream Energy and Power measures are also embedded within the strategic non-financial measures for Executive Directors of BPLC. Further details on the performance assessment against these measures can be found in the Remuneration report section of the Barclays’ PLC Annual Report 2025.
4. Barclays has taken into account stakeholder engagement, including engagement with affected stakeholders in reaching the conclusions set out above as to material impact and related risk and the relevance and materiality of the information proposed to be disclosed.

The Scope 3 Category 15 emissions metrics, in the table below, have been calculated through our BlueTrack$^{\text{TM}}$ methodology, outlined in the Financed emissions tracking and benchmarking section above.

For other business activities where Barclays have not set targets, the Barclays Bank Group has not disclosed metrics.

---

Scope 3 categories 1-14 have been considered not significant for reporting. No baseline figures have been included because targets have not been set at the Barclays Bank Group’s level.

### Scope 3 financed emissions where Barclays has set targets

| Activities$^1$ | Sector boundaries | Unit of measurement | December 2025 | December 2024 |
| :--- | :--- | :--- | :---: | :---: |
| Upstream Energy | Upstream Energy (producers of coal, oil, gas and NGLs) | MtCO$_2$e | 43.7 | 41.1 |
| Power | Power generators | MtCO$_2$e | 13.6 | 14.0 |
| Cement | Cement manufacturers | MtCO$_2$e | 1.5 | 0.8 |
| Steel | Steel manufacturers | MtCO$_2$e | 0.8 | 0.9 |
| Automotive manufacturing | Light Duty Vehicles manufacturers | MtCO$_2$e | 3.6 | 3.8 |
| Aviation | Commercial Aviation (Air Travel) – Passenger (including belly cargo) and Dedicated cargo | MtCO$_2$e | 4.6 | 4.9 |
| UK Commercial Real Estate | UK Corporate Bank | MtCO$_2$e | 0.1 | 0.1 |
| UK Housing$^2$ | UK buy-to-let and owner-occupied mortgages, Social Housing and Business Banking | MtCO$_2$e | 0.2 | 0.1 |
| **Total** | | **MtCO$_2$e** | **68.1** | **65.7** |

**Notes**
1 Barclays Bank PLC does not have UK agriculture activities that contribute to the Barclays plc target.
2 Barclays has identified a 2030 emission intensity convergence point for UK Housing but has not set a formal target.

#### Our methodology and assumptions in calculating financed emissions
Financed emissions are calculated by applying an attribution factor to client emissions. Client emissions are calculated using a range of data quality options, ranging from reported emissions to sector-average emission factors. Based on the PCAF Standard, we use a range of external and internal data feeds to estimate client emissions. We rely on external vendors to source production activity and reported emissions data. In certain cases, the data, fall-back inputs or modelled outputs are overridden using expert judgement. To facilitate this, we run a series of validation tests on both emissions and financial data. For cases where there is a significant divergence identified with supporting evidence – for example where a company has divested a material asset which is not yet reflected in the underlying data – we apply an override to the data.

Within each sector, we have defined an appropriate value chain activity and emissions boundary on which our Group targets are defined. We identify in-scope clients based on the internal Barclays Industry Classification (BIC) codes.

| Approach for estimating emissions mapped to PCAF DQ scores | | |
| :--- | :--- | :---: | :---: |
| | | **PCAF Data Quality score$^1$** | |
| **Activity** | **Data Quality option employed** | **Scope 1,2** | **Scope 3** |
| Upstream Energy | Estimated based on production data | 3.1 | 3.1 |
| Power | Estimated based on average portfolio economic intensity if production data is not available | 3.1 | NA |
| Automotive manufacturing | | 2.2 | 3.2 |
| Aviation | Estimated based on production data | 3.0 | 3.0 |
| Cement | Reported emissions | 2.1 | NA |
| Steel | | 2.0 | NA |
| UK CRE | Estimated based on data available in EPC certificates | 4.0 | NA |
| UK Housing | Estimated based on average sub-portfolio economic intensity if EPC is not available | 4.3 | NA |

**Notes**
1 We have scored the quality of the data we have used to estimate our financed emissions using PCAF's Global GHG Accounting and Reporting Standard. In the Standard, data quality score DQ1 and 2 relates to high quality data from company disclosures, DQ3 to emissions estimated using physical activity data and DQ4 and DQ5 to deriving emissions estimated using revenue or asset-based emission factors.

Climate data, models and methodologies are evolving and are not yet at the same standard as more traditional financial metrics – nor are they yet subject to the same or equivalent disclosure standards, historical reference points, benchmarks or globally accepted accounting principles. Most of our data is collected from external sources, and the quality and methodologies relating to the underlying data can be hard to assess. External sources then require mapping to Barclays’ internal data. While we have set a framework that facilitates a robust matching process, it is likely residual issues will remain for reasons such as mergers and acquisitions within corporate sectors. There are also issues with time lags as most of our data is not available as at the reporting date. Further details on our BlueTrack$^{\text{TM}}$ methodology can be found within our

---

Financed Emissions Methodology paper (published in 2026) accessible at: https://home.barclays/sustainability/esg-resource-hub/reporting-and-disclosures/

### Internal Carbon Pricing
Barclays Bank does not apply an internal carbon pricing scheme, however financed emission and carbon intensity are considered as part of the decision making process in our financing portfolio.

## E4: Biodiversity and Ecosystems

The below table describes the impact for the material sustainability matter related to biodiversity and ecosystems, as identified during the DMA process:

| Material Impacts | | Value Chain | Time Horizon |
| :--- | :--- | :--- | :--- |
| Description | Type | Upstream | Own Operations | Downstream | Short (0-1 year) | Medium (1-5 years) | Long (>5 years) |
| **Drivers of Biodiversity Loss**<br>Barclays Bank Group is connected to environmental impacts through the provision of financial services to clients in sectors which materially contribute to certain drivers of biodiversity and ecosystems loss.<br>Our clients primarily contribute through:<br>• highly water intensive operations in water stressed areas; and<br>• converting or degrading land, including deforestation. | Negative Impact | | | * | * | * | * |

### Strategy
Barclays Bank Group is working to build an understanding of the ways our activities and those of our clients impact and depend on nature, including negative impacts on biodiversity and ecosystems. To better understand how these impacts may originate from our financing of different industry sectors, we continue to refer to Barclays' sector heatmap which analyses the potential materiality of nature impacts and dependencies associated with priority sectors identified in the Taskforce on Nature related Financial Disclosures (TNFD) Guidance for Financial Institutions, and which informs the selection of sectors for further analysis.

Building on our application of the TNFD’s Locate, Evaluate, Assess, Prepare (LEAP) approach to a sample of clients in Barclays Mining and European Power portfolios in 2024, this year we initiated an assessment of our Automotive manufacturing portfolio, including consideration of these clients' upstream and downstream impacts. This will help to further build our understanding and management of nature-related dependencies, impacts, risks and opportunities in our portfolio. We also contributed to Barclays' report 'Navigating Nature Risk: Applying the TNFD’s LEAP framework', which outlined the methodology, results and key insights from the assessment of a sample of Barclays Mining and European Power portfolios.

### Policies
We apply the following Barclays policy statements in relation to addressing the potential negative impacts on biodiversity and ecosystems in our downstream value chain relating to land use change:
- Forestry and Agricultural Commodities (FAC) Statement;
- Protected Areas Statement; and
- Climate Change Statement.

### FAC Statement
The FAC Statement addresses the potential deforestation (including through direct exploitation or degradation of forests), land conversion and human rights impacts associated with our financing of the forestry and agricultural commodities sectors. It covers the provision of financial services to Barclays clients involved in the production or primary processing of soy, beef, palm oil and timber in High Deforestation Risk Countries$^1$ and includes both mandatory requirements and non

---

mandatory expectations for in scope clients covering their policies, zero deforestation commitments, supply chain traceability, verification and reporting.

### Protected Areas Statement
The Protected Areas Statement aims to support the preservation of biodiversity and ecosystems in Protected Areas, through a combination of financing restrictions for certain projects and provisions relating to conducting Sustainability Enhanced Due Diligence (SEDD) on in scope clients. It covers clients developing new assets or expanding existing assets in a Protected Area and/or within its buffer zone(s). Specifically it restricts the provision of project financing to support the development or expansion of a material project located in a Protected Area and/or within its buffer zone(s), or where it becomes known that a client is developing or expanding assets relating to a material project in a UNESCO World Heritage Site or Ramsar Wetland and/or within its buffer zone(s).

### Climate Change Statement
Barclays Climate Change Statement, as outlined in detail on page 58, addresses the provision of certain financing for projects in sensitive biomes such as the Amazon and Arctic, which are known to be important areas for biodiversity preservation and which may be negatively impacted by the Energy sector.

The Climate Change Statement restricts:
- The provision of direct financing to Energy Groups$^1$ for any oil and gas projects in the Amazon Biome, and restrictions on the provision of financing to Clients engaged in exploration, appraisal, development and production of oil and gas in the Amazon Biome; and
- The provision of direct financing for oil and gas projects in the Arctic Circle, and restrictions on the provision of financing to Clients materially engaged in oil and gas exploration and production or pipeline transportation operations in the Arctic Circle.

We do not have policies in place that are primarily aimed at addressing the potential negative impacts of our financing from a water consumption perspective. Barclays is engaged in ongoing work to build a deeper understanding of these potential negative impacts in our downstream value chain through assessment of prioritised sectors, applying the TNFD's LEAP framework. These assessments can provide Barclays and Barclays Bank Group with a detailed understanding of how clients in selected sector portfolios may potentially negatively impact on biodiversity and ecosystems, including as a result of water consumption, and their findings may support the enhancement of the Barclays risk management approach and policy framework.

**Note:**
1 High Deforestation Risk Countries are defined in Barclays Forestry and Agricultural Commodities Statement as:
- For forestry and timber and palm oil companies: Angola, Argentina, Bolivia, Brazil, Cambodia, Cameroon, Colombia, Côte d’Ivoire, Democratic Republic of Congo, Ecuador, Ethiopia, Gabon, Ghana, Guatemala, Guinea, Honduras, India, Indonesia, Laos, Liberia, Madagascar, Malaysia, Mexico, Mozambique, Myanmar, Nicaragua, Nigeria, Panama, Papua New Guinea, Paraguay, Peru, Philippines, Suriname, Tanzania, Thailand, Uganda, Venezuela, Vietnam, Zambia.

### Actions
We have taken the following key actions this year in relation to addressing the negative impacts on biodiversity and ecosystems in our downstream value chain:
- Continued to conduct SEDD on clients in scope of the FAC Statement, Climate Change Statement and Protected Areas Statement, which has resulted in more informed decision making in relation to the financing provided.
- Engaged with a selection of Mining and European Power clients on nature impacts, risks and opportunities identified during our 2024 LEAP assessment of these portfolios. During these engagements we shared and tested our approach and results with these clients, engaging on identified areas of interest and related mitigation activities, as well as exploring their strategic and financing requirements.
- Initiated an additional TNFD LEAP assessment of our Automotive manufacturing portfolio, measuring selected material impacts for this sector such as water use, water pollution, and air pollution across the value chain. We plan to conduct client engagement with a selection of Automotive manufacturing clients once this exercise is completed in 2026.
- Extended nature-related criteria within our Client Transition Framework assessments to cover four sectors in total: Power, Mining, Automotive and Food, building on the pilot conducted for the Power sector last year. The evaluation provides a structured view of how clients are integrating nature considerations into their business models, and these insights will help inform client engagement planned for next year. Further information on our CTF is provided on page 64.

**Note:**
1 Energy Groups refers to Groups that have over 20% revenue from upstream oil and gas activities (i.e. exploration, development and production) and/or Groups that are considered to be super major or major integrated oil and gas companies.

---

### EU Taxonomy information (disclosures pursuant to Article 8 of the Taxonomy Regulation (EU/2020/852))
Further to Article 8 of the Taxonomy Regulation, we are required to disclose certain information regarding how and to what extent our activities are associated with environmentally sustainable economic activities, as defined in that regulation. These disclosures are incorporated by reference into this section of the Sustainability Statement and can be found as follows:

1. Qualitative information to support our explanations of Taxonomy key performance indicators (‘KPIs’), especially the Green Asset Ratio (‘GAR’)– see page 99 of the Sustainability Statement
2. A series of detailed prescribed templates disclosing quantitative information analysing our KPIs, including the assets included in the GAR and sectoral information– see the Schedule B to the Sustainability Statement on page 419

---

# Schedule to the Directors' report: Sustainability statement
## Entity Specific: Sustainable and Transition Products and Services

The table below describes the impact and opportunity in relation to the entity specific sustainability matter, Sustainable and Transition Products and Services, which we identified during our DMA process.

| Material Impacts and Opportunity | | Value Chain | Time Horizon |
| :--- | :--- | :--- | :--- |
| Description | Type | Upstream | Own Operations | Downstream | Short (0-1 year) | Medium (1-5 years) | Long (>5 years) |
| **Sustainable and Transition Products and Services**<br>Barclays Bank Group is connected to impacts on the environment and people by providing sustainable and transition finance to clients, which encompasses environmental, social, transition, nature and broader sustainability linked financing.<br>Barclays Bank Group has an opportunity by offering sustainable and transition products and services. Barclays Bank Group has a sustainable and transition finance strategy of offering and supporting sustainability related products and services to capitalize on the potential market. | Positive Impact<br>Opportunity | | | * | * | * | * | * |

### Strategy
Barclays Bank Group recognises the opportunities arising from the global transition to a low-carbon economy and the positive impact this can have on economies, our customers and clients. Barclays has developed reporting frameworks for the following types of finance.
- Sustainable Finance consists of finance for dedicated use of proceeds, financing for clients with an eligible business mix in relevant environmental and social categories, and sustainability-linked financing which refers to general purpose funding.
- Transition Finance consists of financing provided to clients for activities that support greenhouse gas emission reduction, directly or indirectly, towards a 1.5°C pathway

Barclays Bank Group uses the Sustainable Finance Framework ("SFF") and Transition Finance Framework ("TFF") to enable us to track our financing which contributes to our positive impacts as we capitalise on identified opportunities. The SFF and TFF were developed by Barclays and outline the approach to the classification of our finance as sustainable finance and transition finance respectively. We published version 5.0 of SFF and 2.0 of TFF in February 2026, with changes to product scope, eligibility criteria and transaction screening processes. Both frameworks are published on the Barclays website.

### Policies
We do not have a relevant policy in place, as the positive impact and opportunity are underpinned by our overall strategy that focuses on working with clients on their transition, financing our clients’ transition and scaling climate technology, and our role in contributing to the Barclays target of facilitating $1 trillion of Sustainable and Transition Finance between 2023 and the end of 2030. This financing approach is guided by our SFF and TFF, as referenced above.

### Actions

#### Sustainable and Transition Products
We continue to broaden our sustainable and transition finance offering, particularly developing our sustainability notes and deposits products in 2025 as well as launching the Carbon and Environmental Products trading desk within the Global Markets business. Sustainable and transition finance products also help us achieve our focus on working with clients on their transition. In 2026, we will continue to consider and evaluate additional sustainable and transition products.

#### Strategic Review
Our sustainable finance strategy was also refreshed during 2025 across key businesses. The review built upon both new and previously identified commercial opportunities. The output was considered in the financial planning process, including incremental revenue, cost and capital. Key opportunities continue to reside within Debt Capital Markets, Equity Capital Markets, Transaction Banking and lending.

We continue to embed key teams whilst hiring to grow our existing talent with a focus on expanding our product capabilities as we continue to drive performance against our selected Barclays targets. In particular, the Energy Transition

---

Group within Barclays continues to provide holistic and cohesive strategic advice and financing solutions through the energy value chain, with a particular emphasis on decarbonisation. These teams continue to enable further implementation of our climate strategy and increase co-ordination, with a focus on how they can help our customers and clients on the transition to a low-carbon economy.

We will continue to endeavour to further enhance how our sustainability strategy is embedded into the way we think about financial planning over the coming years – reflecting on the progress made during 2025.

### Tracking of our Sustainable and Transition Finance:
Barclays Bank Group tracks the amount of sustainable and transition finance we facilitate using the methodology outlined in both the SFF and TFF. Tracking finance enables us to measure progress towards financing the transition. These volumes are reported externally semi-annually, see the Metrics section below for 2025 volume.

### Targets
Barclays Group views sustainability as a global issue, which is best tackled with a top-down approach, with targets set by Barclays covering the whole of Barclays Group considered to be the most appropriate way to meet sustainability ambitions. As we are part of Barclays and contribute towards Barclays Group targets, we do not have our own specific targets relating to our sustainable products and services. Further, given the global footprint of many of our clients, who often engage with multiple Barclays entities, setting targets at the Barclays Group level ensures a more cohesive and aligned approach to achieve sustainability objectives.

Following analysis of the market opportunity for sustainable finance, together with a review of its capabilities, in 2022, Barclays announced a new target to facilitate $1trn of Sustainable and Transition Financing between 2023 and the end of 2030$^2$. Barclays Bank Group is expected to be a key contributor towards achieving this target. By tracking the amount of sustainable and transition finance we facilitate using the methodology outlined in both the SFF and TFF, we track the effectiveness of our actions and monitor progress against the target set at Barclays level of facilitating $1trn of Sustainable and Transition Finance between 2023 and the end of 2030.

### Metrics
In 2025, Barclays Bank Group facilitated $95.3bn (2024: $92.9bn) of Sustainable and Transition Financing$^{1,2}$, which contributed to the overall Barclays $1trn target. This contribution was calculated using the SFF and TFF methodologies outlined above.

For further details please see Barclays’ ESG Reporting Framework.

It should be noted that the methodology is reliant on a range of data sources including Dealogic and Bloomberg transaction listings and league tables, as well as other third-party data and verification sources including company disclosures to aid the classification of financing into eligible green and social categories. Legal entities for capital markets financing are identified using Dealogic ‘Issuer Nation/Deal Nationality’, while internal lending entities are mapped by the Financial Control team. Barclays Bank Group recognises that the quality, consistency and comparability of the data relied upon is not yet of the same standard as more traditional financial metrics and presents an inherent limitation to the performance reported. We will continue to review available data sources and enhance our methodology and processes to improve the robustness of the performance disclosed.

**Notes:**
1 Key assumptions for Sustainable and Transition Financing:
Accounting basis:
- Financing volumes for the FY25 reported on a proportional bookrunner share basis;
- Share of capital markets transactions calculated as deal size divided by total number of bookrunners or league table credit Barclays role in the deal is further confirmed by the desk where unclear from underlying documents;
- Syndicated lending reflects Barclays’ share or hold of the overall transaction value; and
- Lending is calculated as total value of limits at issuance and any subsequent increases

Reporting Process:
- Financing eligible as sustainable financing, under the SFF, for the purpose of our targets, if Barclays determines that the core business of the recipient falls under the eligible green and social criteria.
- Wherein a pro-rated part of the transaction is counted against the target, the pro-rata calculation is based on an equally weighted allocation to each of the use of proceeds categories that Barclays identify within the issuer framework.
- When reviewing whether financing will be eligible as transition finance for the purpose of the TFF, Barclays will consider, amongst other factors:
  - the transition plans or decarbonisation strategies the client produces, including any just transition elements; and
  - the management of any identified environmental and social risks associated with the relevant purpose of the financing or, where the client is a pure play client, its activities as a whole.

2 In the 2026 update to the Barclays Sustainable Finance Framework the reference to the target has been updated to reference $1 trillion Sustainable and Transition Finance between 2023 and the end of 2030 (the "Target") and accordingly references to the Target in this Annual Report have been reflected as such other than in this reference.

---

# Schedule to the Directors' report: Sustainability statement
## Social Information

### Contents
Barclays Bank Group identified material IROs in the following social topical standards:

| ESRS Standard | Section | Page |
| :--- | :--- | :--- |
| S1 | Own Workforce | 73 |
| S2 | Workers in the Value Chain | 89 |
| S3 | Affected Communities | 90 |
| S4 | Consumers and End users | 92 |

## S1: Own Workforce$^1$

| Section | Page |
| :--- | :--- |
| **Strategy** | |
| Processes for engaging with own workforce and workers’ representatives about impacts | 73 |
| Channels to Raise Concerns | 74 |
| Characteristics of the undertaking’s employees | 74 |
| **Material IROs** | |
| **Equal Opportunities for All** | |
| Policies | 76 |
| Actions | 78 |
| Targets | 87 |
| Metric | 81 |
| **Working Condition** | |
| Policies | 84 |
| Actions | 86 |
| Targets | 87 |
| Metric | 87 |

**Note**
1 Within this ‘S1: Own Workforce’ statement, “colleague(s)” means the employees as set out and defined in the table at page 74, being: “Permanent/Regular”, “Graduate”, “Apprentice” and “Temp/Contractor Payroll (Fixed Term)” employees, unless stated otherwise.

### Strategy
Colleagues sit at the heart of Barclays’ three-year plan to becoming Simpler, Better and More balanced. Our shared Purpose, Values and Mindset underpin this strategy, while the identified positive impacts of Equal Opportunities for All and Working Conditions are both outcomes of and contributors to Barclays’ strategy. The effect of the identified positive impacts is an inclusive workplace, where colleagues feel safe to speak up, are supported in their career, feel listened to, and receive fair pay with equal opportunities to progress. The impacts both stem from and shape our strategy in the respective areas, detailed below, and are expected to be maintained year on year through a relationship with its workforce.

### Processes for engaging with own workforce and workers’ representatives about impacts
Sharing our strategy and how colleagues can contribute towards its delivery are key parts of Barclays’ engagement. Regular, two-way dialogue helps identify what is working well and where there is room for improvement across the organisation. Barclays' Bank Group CEO and Board are responsible for agreeing Barclays' workforce engagement methods and ensuring these remain effective. Engagement with colleagues is delivered through multiple channels such as townhalls, skip-level meetings, site visits, leader-led sessions, focus groups and surveys.

The key channels of engagement are outlined below.

**Annual Survey:** Through the biannual all-colleague (with the exception of Temp/Contractor/ Payroll (Fixed Term) colleagues as noted in the 'basis of preparation' for the Inclusion Index metric on page 82) Your View surveys (a Spring check-in survey and an Autumn census survey), colleagues can share their feedback on working at Barclays Bank Group. This is a voluntary and confidential survey. The 2025 Autumn census survey had a 67% participation rate. The 2025 survey covered questions focused on areas including engagement, inclusion, wellbeing and speak-up. Results are shared with leaders across the organisation (based on meeting minimum response thresholds to uphold confidentiality), including to Executive committees and Boards, and highlights are communicated back directly to colleagues.

**Engagement through Employee Resource Groups:** Barclays’ Employee Resource Groups (ERGs) are voluntary, colleague led communities that: amplify the experiences and unique perspectives of our colleague community; support a culture of inclusion by fostering connection, dialogue and awareness; and bring Barclays’ purpose to life – creating better financial

---

futures for our clients, colleagues and communities – through inclusive behaviours and storytelling. The ERGs are open to all colleagues no matter their gender, background or affiliation. The Barclays I&O team engages with the ERGs monthly. The Barclays I&O, Talent and Citizenship teams also partner with ERGs where relevant.

**Engagement with colleague representatives:** Barclays Bank Group, through Barclays, has a longstanding partnership with Unite in the UK which offers further insight into the views of colleagues. The Bank proactively engages with Unite on major change programmes impacting Unite recognised colleagues, with the aim of minimising compulsory redundancies and maximising opportunities for reskilling and redeployment. As part of that process, Unite formally engages with impacted colleagues, as appropriate, to enable their views to be reflected as part of the consultation process. In addition to engaging regularly with national works councils in some of its European jurisdictions, the Bank discusses transnational issues annually, at a minimum, with the Barclays Group European Forum (BGEF)$^1$, which represents the interests of colleagues in EU member states and the UK. The overall relationship with Unite and the BGEF is managed through Barclays Industrial Relations, with national works councils managed via local HR teams. The Barclays Workforce Change & Restructuring team oversees restructuring activity in all jurisdictions across Barclays Bank Group.

The Bank assesses the industrial relations climate on a quarterly basis to identify any issues and emerging risks in its engagement with workplace representatives considering factors such as the number of formal disputes or risks of such disputes. In the case of the partnership with Unite, the Bank is in regular dialogue on the effectiveness of the working arrangement and reviews aspects as necessary.

### Channels to Raise Concerns
Barclays Bank Group strives to create a respectful and inclusive environment where colleagues feel safe to speak up. The Raising Concerns process allows colleagues to raise concerns, including whistleblowing concerns, through a range of gateways (including on an anonymous basis). For more on channels to raise concern, refer page 79.

### Human Rights Commitments
Barclays Group's Statement on Human Rights expresses its commitment to respecting human rights as defined in the International Bill of Human Rights and the International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work (ILO Declaration). The approach to respecting human rights is guided by the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines).

**Note**
1 The Barclays Group European Forum (BGEF) is a forum designed to consult employees about transnational issues which affect their interest. The BGEF represents all Barclays Group employees within the European Union Member States, including the United Kingdom. The Forum’s purpose is to establish a meaningful dialogue and exchange of views on transnational issues. The BGEF does not cover issues that relate to a single country.

### Characteristics of the undertaking’s employees

| Most representative number in the financial statements. | Female | Male | Other | Non-disclosed | Total |
| :--- | :---: | :---: | :---: | :---: | :---: |
| **Headcount** | **2025** | **2024** | **2025** | **2024** | **2025** | **2024** | **2025** | **2024** | **2025** | **2024** |
| Number of employees | 9,530 | 9,750 | 13,229 | 13,611 | 258 | 341 | 71 | 86 | 23,088 | 23,788 |
| Number of permanent employees$^1$ | 9,484 | 9,699 | 13,179 | 13,576 | 258 | 341 | 64 | 81 | 22,985 | 23,697 |
| Number of temporary employees$^2$ | 46 | 51 | 50 | 35 | 0 | 0 | 7 | 5 | 103 | 91 |
| Non Guaranteed hours | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 |

See page 299 for most representative number in the financial statements.

**Basis of Preparation:**
1. Number of Permanent Employees (HC) in the table includes Permanent/Regular, Graduate and Apprentice, Operational and Non-Operational.
2. Number of Temporary Employees (HC) in the table includes Temp/Contractor Payroll (Fixed Term), Operational and Non-Operational.
Data is as at 31 December 2025

| Breakdown by country (countries in which the undertaking has 50 or more employees representing at least 10% of its total number of employees) | 2025 | 2024 |
| :--- | :--- | :--- |
| **Headcount** | | |
| United Kingdom | 7,021 | 7,060 |
| United States of America | 11,314 | 11,460 |

| **Turnover Metrics** | 2025 | 2024 |
| :--- | :--- | :--- |
| Number of employees | 3,528 | 3,833 |
| Rate of turnover | 15 % | 16 % |

---

**Basis of Preparation:**
1. Number and Percentage of total leavers, based on a rolling 12-month period ended 31 December 2025.
2. Data is captured at the end of each month, e.g. 31 December 2025.
3. Data is reported as a total number of leavers in the reporting period and as volume of leavers for the last 12 months divided by the average headcount for the last 12 months.
4. Employees that leave for voluntary and involuntary reasons such as dismissal are included in this metric.

### Definition of employment types:

| Worker Type | Colleague / Non-Perm | Definition |
| :--- | :--- | :--- |
| Colleague | Permanent/Regular | Employee, paid by Barclays Bank Group payroll, engaged on Barclays Bank Group contract (contract open-ended for indefinite period with pre-set working hours). |
| | Graduate | Employee, paid by Barclays Bank Group payroll, engaged on Barclays Bank Group contract (contract open-ended for indefinite period with pre-set working hours). Working in Barclays via a formal Graduate Trainee programme. |
| | Apprentice | Employee, paid by Barclays Bank Group payroll, engaged on Barclays Bank Group contract (contract open-ended for indefinite period with pre-set working hours). Working in Barclays via a formal Apprentice Trainee programme. |
| | Temp/Contractor Payroll (Fixed Term) | Employee, paid by Barclays Bank Group payroll, engaged on Barclays Bank Group contract (contract temporary for pre-defined period with pre-set working hours). |

| Operational Status | Definition |
| :--- | :--- |
| Non-Operational | Colleagues will be considered Non-operational when they are still employed by Barclays but are not actively working – which is defined as an absence or non-working period of 60 consecutive days or more. |
| Operational | All employees are considered Operational unless they fall under the Non-Operational category. |

Non-employees are either people with contracts with the undertaking to supply labour (“self-employed people”) or people provided by undertakings primarily engaged in “employment activities.”

The table below describes which policies and standards apply to each colleague type. Note that local laws, rules and regulations mean that the application of policies and standards may differ in some countries in which Barclays operates.

| | Permanent/ Regular | Graduate | Apprentice | Temp/ Contractor Payroll (Fixed Term) |
| :--- | :---: | :---: | :---: | :---: |
| Inclusion and Opportunity strategy | ü | ü | ü | ü |
| Whistleblowing Standard | ü | ü | ü | ü |
| Employee Relations Policy – Working at Barclays Standard | ü | ü | ü | ü |
| Learning Policy & Learning Mandatory Training Standard | ü | ü | ü | ü |
| Performance Management Policy and Standard | ü | ü | ü | ü |
| Employee Relations Policy – Health Services and Wellbeing Standard | ü | ü | ü | ü |
| Retirement and Benefits Standard | ü | ü | ü | ü |
| Employee Relations Policy – Industrial Relations Standard | ü | ü | ü | ü |
| Culture Measurement Policy | ü | ü | ü | |
| Employee Relations Policy – Workforce Change and Restructuring Standard | ü | ü | ü | ü |
| Fair Pay Agenda (living wages) | ü | ü | ü | ü |

---

### Basis of preparation for metrics in this section
Unless otherwise stated, for each Own Workforce metric, no significant assumptions have been made and the methodology has no data limitations.

### Equal Opportunities for All
The below table describes the impacts for the material sustainability matters related to Equal Opportunities for All, as identified during the DMA process:

| Material Impacts | | Value Chain | Time Horizon |
| :--- | :--- | :--- | :--- |
| Description | Type | Upstream | Own Operations | Downstream | Short (0-1 year) | Medium (1-5 years) | Long (>5 years) |
| **Equal Opportunities for All**<br>Barclays Bank Group has a positive impact on employees by enabling a culture of inclusion and equal opportunity for all, where colleagues can speak up with confidence, and within which we foster development and career opportunities. Barclays Bank Group does this by:<br>• Implementing efforts to embed employee inclusion and opportunity in its policies and programmes.<br>• Committing to gender equality which positively impacts Barclays' culture.<br>• Aiming to create a workplace culture with the highest standards of conduct and integrity and where employees feel able to speak up about actions and behaviours that are not aligned to Barclays culture and/or values.<br>• Providing training, development and performance management helps up-skill and re-skill employees. | Positive Impact | | * | | * | * | * |

### Strategy and Policies related to equal treatment and opportunities for all
This section details the policies, standards and strategy related to equal treatment and opportunities for all colleagues across Barclays Bank Group. Our policies and standards have been developed taking account of the interests of our key stakeholders, informed by colleague engagement and workforce insights, together in accordance with legal and regulatory obligations.

Unless otherwise stated, the scope of all policies, standards and strategy outlined below is Barclays Bank Group (including any consolidated entity where Barclays Bank Group has legal or operational control) and employees as defined on page 75.

### Strategy Update in 2025
Following a strategic review, we announced in 2025 that promoting and embedding an inclusive workplace at Barclays will be referred to as Inclusion and Opportunity (I&O) moving forward.

We are committed to creating a workplace where everyone feels valued and respected, within a culture of belonging and equal opportunity for all. Our approach to I&O continues to evolve, with a focus on empowering our colleagues and leaders, engaging our communities and driving company success. We continue to monitor colleague engagement in relation to I&O through a range of feedback channels, including those that allow for anonymous input, to support the evolution of the strategy.

The effectiveness of the I&O strategy and actions are now assessed through regular engagement and feedback. This includes confidential feedback on our inclusive culture obtained through our colleague sentiment survey, Your View.

This means our approach to Equal Opportunities for All has been refreshed. During the Double Materiality Assessment (DMA) review process, the relevant material impacts were updated to reflect this shift and accurately capture the positive impacts Barclays has on its employees.

---

| Policies/ Standards | Description of key content/ objectives | Accountability & stakeholder | Availability to stakeholders |
| :--- | :--- | :--- | :--- |
| **Inclusion and Opportunity Strategy** | For the purpose of this disclosure, where 'policy' is mentioned, it refers to the I&O strategy.<br>Following a strategic review, we announced in 2025 that promoting and embedding an inclusive workplace at Barclays will be referred to as 'Inclusion & Opportunity' (I&O). The general objective of the refreshed I&O strategy is to create a workplace where inclusion is the key principle. This means everyone feels valued and respected, within a culture of belonging and equal opportunity for all. The strategy supports the organisation in embedding practices that cultivate high-performing teams and generate rich opportunities to progress. We aspire to hire from the broadest global talent pools available to deliver against our strategy.<br>The three strategic priorities are:<br>• Empowering colleagues<br>• Engaging communities<br>• Driving company success | The Barclays Head of I&O is accountable for the implementation of these priorities. Stakeholders in the business, including senior leaders, are responsible for embedding the I&O strategy.<br>The Barclays I&O team review the I&O strategy on a regular basis, including engaging with the Barclays Group Executive Committee and BPLC Board, where appropriate.<br>The BPLC Board engaged with management on the evolution of the I&O strategy, and new I&O strategy was agreed with the BPLC Board and the Barclays Group Executive Committee. | The Barclays approach to I&O is available to colleagues through the external website and internal colleague communications from the Barclays CEO and business leaders.<br>We continue to monitor colleague engagement in relation to I&O through a range of feedback channels, including those that allow for anonymous input, to support the evolution of the strategy. |
| **Whistleblowing standard** | Outlines controls related to the following.<br>1. To encourage individuals to raise concerns about inappropriate conduct<br>2. Whistleblowing concerns are dealt with appropriately<br>3. The confidentiality and anonymity of whistleblowers are protected<br>4. Zero tolerance approach to whistleblower retaliation<br>5. Oversight of whistleblowing arrangements | The Head of Compliance Framework and Policies Team is accountable for approving and implementing the content of the Standard. | The standard is available to colleagues through Barclays’ intranet channel. |
| **Employee Relations Policy - Working at Barclays standard** | Outlines