Barclays Bank PLC

Reference: page 42 (index page 107), with the substance incorporated by reference from pages 21, 24, 26, 27 and 34

The index lists GOV-1 twice, once as ESRS 2 GOV-1 and once as G1.GOV-1, both at page 42 and both marked with the asterisk meaning "some or all of the disclosure requirement has been incorporated by reference into the sustainability statement" (page 107).

Inside the statement GOV-1 is a routing table rather than a narrative: composition and diversity of the Board sit at pages 21, 24, 26 and 27; roles, responsibilities and skills in relation to sustainability matters sit at page 34 (page 42).

At page 34 the report states that "the Board Sustainability Committee supports and advises the Board in its oversight of climate and sustainability matters, including related risks and opportunities", that "The Chief Executive Officer is an Executive member of the Board Sustainability Committee", that "The Board Risk Committee oversees risk appetite and the management of principal risks, including climate risk", and that the Board Remuneration Committee's remit includes "the Fair Pay Agenda and gender and ethnicity pay gaps". Board expertise is described as built "through periodic briefings on key business developments and external developments provided by management", with the ability to "call on internal subject matter experts" (page 34). That page carries the triangle marker for "Information subject to limited assurance in accordance with (ISAE) (Ireland) 3000".

Reference: page 42 (index page 107), incorporated by reference from page 34

GOV-2 is listed in the content index at page 42 with the incorporation-by-reference asterisk (page 107). The statement itself gives cross-references rather than narrative: "For further information on how the Board and its Committees are informed about our material impacts, risks and opportunities, see page 34" and "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" (page 42).

Page 34 records that "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", and that "Each Committee has its own Terms of Reference... incorporating oversight of our IROs where appropriate".

One target is escalated by name: on the mandatory-training target, "Any material issues relating to performance against this target may be escalated to the Board Audit Committee, as appropriate" (page 42). Management bodies are set out at pages 42-43: the Group Sustainability Committee, the Group Risk Committee and its Climate Risk Committee, the Disclosure Committee chaired by the Group Finance Director, and the Group Reputation Risk Committee.

Reference: page 43 (index page 107, listed twice as GOV-3 and E1.GOV-3)

"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" (page 43).

For the 2025 incentive pools the measures considered were "progress towards Barclays' Sustainable and Transition Financing target, reductions in its financed emissions and progress against targets relating to achieving net zero operations", community investment through programmes such as LifeSkills, and "colleague-related measures including engagement, culture and inclusion" (page 43).

Most of this is unweighted: "Since the assessment is holistic, there is no predetermined weighting for sustainability-related measures" (page 43), and again for individual awards (page 44).

Two weightings are given, neither isolating climate. "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." And "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%" (page 44).

Reference: page 44 (index page 107)

The statement on due diligence is given as the ESRS mapping table required by ESRS 2 GOV-4, listing where each core element of the due diligence process is described (pages 44-45):

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

Due diligence is defined in the statement as "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", covering "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" (page 44).

Schedule A confirms the GOV-4 paragraph 30 datapoint is disclosed, pointing to "See page 44" (page 412).

Reference: page 45 (index page 107)

Internal control over sustainability reporting is anchored in the Operational Risk Framework: "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" (page 45).

The identification tool is named: "Risk and Control Self-Assessment (RCSA) is a Group-wide approach" to identify the risks inherent in each process, the effectiveness of controls, residual risk and remedial actions (page 45).

The reporting risks 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" (page 45). Mitigating controls listed are "data integrity checks, external disclosure checks, reconciliations, validations, analytical reviews, and management review/challenge".

Findings are classified through the "Risk and Issue Classification Matrix (RICM)" and, "Where applicable, any material findings are escalated and reported to the Barclays Bank PLC Board Risk Committee (BRC)" (page 46). The Disclosure Committee reviews and monitors the integrity of the BBPLC Annual Report including the sustainability reporting (pages 43, 45).

Reference: page 46 (index page 107), with products, markets and clients incorporated by reference from page 1 onward

"Barclays Bank Group's business model is aligned with the business model of Barclays Group" (page 46). Products, services, markets and clients "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".

Headcount: "Barclays Bank Group had a workforce of 23,088 employees globally at the end of FY25 (FY24: 23,788)" (page 46).

The value chain is split into direct and indirect relationships (pages 46-47). Upstream: investors, since BBPLC "is a wholly owned subsidiary of the Barclays Group", and Third-Party Service Providers, which "are equivalent to suppliers as defined in Annex II... in ESRS". Downstream: "Investment banking clients include corporates, money managers, financial institutions, governments and global organisations", plus UK Corporate Bank clients, Private Bank high net-worth individuals and US Consumer Bank cards. Indirect: affected communities and workers in the value chain.

Goals are framed as a contribution to the parent, reflected in "Barclays' target to facilitate $1trn of Sustainable and Transition Finance between 2023 and the end of 2030" (page 47). Schedule A marks the SBM-1 fossil fuel, chemical production, controversial weapons and tobacco datapoints (paragraph 40(d) i-iv) "Not Material" (page 412).

Reference: page 48 (index page 107)

Six stakeholder groups are tabulated with engagement method, purpose and use of outcomes: Third-party service providers, Investors, Government/policy makers and regulators, Employees, Customers and clients, and "Affected Communities and Workers in the downstream value chain" (pages 48-49).

The investor row records the entity's position: "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" (page 48).

Engagement with affected communities is indirect: "On an ad hoc basis, we have engaged credible proxies and representatives to gain insight into the perspectives of affected communities... such as NGOs and civil society organizations" (page 49).

The link into the DMA is stated twice: views feed in "When assessing the appropriateness of the IROs that were taken forward for assessment under the DMA" and "During the stakeholder questionnaire" (page 48). In 2025 that questionnaire was completed by staff, not stakeholders: "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" (page 50).

Reference: pages 52-54 (index page 107; topic rows E1.SBM-3 p.55, S1.SBM-3 p.73, S2.SBM-3 p.89, S3.SBM-3 p.90, S4.SBM-3 p.92)

The table at page 53 lists 15 material IROs, each mapped to an ESRS standard or, for entity-specific matters, "the most appropriate ESRS standard", with type, value chain position and time horizon: E1 Climate Change Mitigation (negative impact) and Climate Change - Transition (risk); E4 Drivers of Biodiversity (negative impact); entity-specific Sustainable and Transition Products and Services (positive impact and opportunity); S1 Equal Opportunities for All and Working Conditions (positive impacts); S2 Labour Rights including Modern Slavery; three S3 rows (economic, social and cultural rights; civil and political rights; Indigenous Peoples rights); S4 Cybersecurity; and entity-specific Data Privacy - Accurate records, Data Privacy - Right to privacy of consumers and end-users, and Anti-Money Laundering and Sanctions.

Year-on-year change is disclosed: "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" (pages 52-53).

On resilience: "At this point in time, there are no material amendments to our strategy or business model required" (page 54). No quantified anticipated financial effects are given; the phase-in relief is claimed for "Quantitative disclosures on anticipated financial effects (ESRS 2 SBM 3)" (page 42).

Reference: page 49 (index page 107; also listed as E1.IRO-1 at page 49)

"During 2025, Barclays Bank Group updated its DMA using the steps outlined below" (page 49), across five steps.

Step 1 reused the prior year: "We relied on last year's process to identify activities, business relationships and geographies" (page 49). Step 2 drew the long list from eight manually reviewed document types, where "The sustainability matters identified were ranked based on the number of occurrences in the data sources and weighted" (page 50).

Scoring is explicit. For impacts, "The SMEs rated each parameter on a scale of 0-5, with the severity ratings then averaged and multiplied by the likelihood". For risks and opportunities the assessment "was qualitative and relied on their professional judgement", augmented "with quantitative thresholds, where available, such as stress test outcomes" (page 51). The threshold was set by the CSRD Steering Committee, which "reserved the right to amend the initial materiality decision", and the outcome was "presented to the BB PLC Audit Committee".

Two limitations are stated plainly: for environmental topics other than climate, IROs "were identified and assessed qualitatively based on expert judgement" (page 52); and "the DMA process itself is not currently integrated into our overall risk management processes or used to evaluate our overall risk profile and processes" (page 52). The same is said of opportunity management.

Reference: pages 107-108

The report prints a genuine ESRS content index, headed "List of Disclosure Requirements complied with in our Sustainability Statement" (pages 107-108), and IRO-2 in that index points to page 107. A note explains the marking convention: "*denotes that some or all of the disclosure requirement has been incorporated by reference into the sustainability statement. Additionally, information relating to the entity specific matter, cybersecurity, has also been incorporated by reference".

The index is short. Under ESRS 2 it lists BP-1, BP-2, GOV-1, G1.GOV-1, GOV-2, GOV-3, E1.GOV-3, GOV-4, GOV-5, SBM-1, SBM-2, SBM-3 plus five topic-level SBM-3 rows (E1, S1, S2, S3, S4), IRO-1, E1.IRO-1 and IRO-2. Under E1 it lists only E1-1 (p.55), E1-2 (p.58), E1-3 (p.63), E1-4 (p.65), E1-6 (p.66) and E1-8 (p.68). Under S1 it lists S1-1 (pp.76, 84), S1-2 (p.73), S1-3 (p.79), S1-4 (pp.78, 86), S1-5 (pp.81, 87), S1-6 (p.74), S1-9 (p.82), S1-10 (p.88) and S1-16 (p.83).

No E4, S2, S3, S4 or G1 topical disclosure requirement appears anywhere in the index, even though E4, S2, S3 and S4 carry material IROs. The company attributes that to the Quick Fix reliefs (page 42). The list of datapoints derived from other EU legislation is not in the index itself but in Schedule A, pages 412-418.

Reference: page 55 (index page 107)

E1-1 is listed in the content index, and the disclosure is a plain negative: "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" (page 55).

Schedule A repeats it against the E1-1 paragraph 16(g) datapoint on exclusion from Paris-aligned benchmarks: "No adopted Transition Plan, please see page 55 for further detail" (page 413).

What is offered instead is the parent's plan. "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", structured "around three themes... working with clients on their transition, financing clients' transition and scaling climate technology". The BTU is not reproduced; it "is published on the Barclays website" (page 55).

The entity's own levers are routed elsewhere: "The actions taken by Barclays Bank Group are grouped under decarbonisation levers and captured in the E1-3 (MDR-A) disclosure on page 63". No CapEx, OpEx or investment plan for the transition appears anywhere in the statement, and no locked-in emissions assessment is given.

Reference: pages 55-58. Back-filled from the E1 climate risk and scenario analysis subsection and ESRS 2 IRO-1 (page 49), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The DMA identified one material climate risk, and it is transition: "Barclays Bank Group may face material financial risk arising from transition-related impacts on its investments and financing activities" (page 55). Physical risk was assessed but not found material (page 56).

"Barclays Bank Group is exposed to climate-related risks indirectly through its downstream financing and investment activities" (page 55), assessed "across short (0-1 yr), medium (1-5 yrs) and long-term (>5yrs) timeframes" (page 56).

Two exercises ran in 2025: the Internal Stress Test (IST25) "featured a scenario with climate risk drivers over a five-year period", and "a climate-based Reverse Stress Test (RST) was run with a shorter-term focus", "each with its own scenario aligned to a less than 2°C pathway", benchmarked "against NGFS... short-term scenarios wherever narratives aligned" (page 56). Assumptions run stage by stage, with the "EU Emissions Trading System (ETS) price rising to $309/tCO2e" and losses "highest within the Investment Bank" (page 57).

Gaps: no high-emission physical scenario is named, no 1.5°C transition scenario is named, and no temperature projection per scenario is given.

Reference: pages 54, 56-58. Back-filled from ESRS 2 SBM-3 "Resilience of strategy and business model" (page 54) and the E1 scenario analysis results (pages 56-58), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results: "Based on the results of the scenario analyses performed to date, our view is that Barclays Bank Groups' strategy remains resilient to climate scenarios" (page 56). And: "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... The scenario confirms that the Group's capital and liquidity positions remain robust, with headroom above regulatory and internal thresholds" (page 58).

At ESRS 2 level: "there are no material amendments to our strategy or business model required" (page 54).

Uncertainty is set out under "Challenges and limitations": "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" (page 58). In 2025 "Barclays conducted an exploratory exercise to extend climate scenario analysis from a 5-year period to a 10-year period".

Capacity to adapt is addressed only through ICAAP and management actions.

Reference: page 58 (index page 107)

Two policy sets are disclosed. The first addresses the mitigation impact: "Barclays Bank Group applies the Barclays position statement titled 'Climate Change Statement' to manage our downstream negative impact in certain high-emitting sectors" (page 58). Its limit is stated too: "The statement does not address climate change adaptation, energy efficiency or renewable energy deployment".

The statement sets "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" (page 58). Project-level and entity-level restrictions are tabulated at pages 60-62, including "We will not provide financing to Clients engaged in exploration, appraisal, development and production of oil and gas in the Amazon Biome" (page 61).

Accountability is named: "the BB PLC CEO is the most senior individual in the organisation that is accountable for the implementation of the statement", with review by the Group Sustainability Committee and escalation to the Board Sustainability Committee or Board (page 59).

The second policy set addresses transition risk: the Climate Risk Framework, "underpinned by the Climate Risk Policy and Climate Risk Standard", owned by the Group Head of Climate Risk (page 63).

Reference: page 63 (index page 107)

Actions are presented "grouped under decarbonisation levers" (page 63).

Sustainability Enhanced Due Diligence: clients in scope of public position statements complete SEDD questionnaires "used to evaluate their performance on a range of environmental and social issues", with outcomes determining whether further review by the Environmental and Social Risk Management team "may be required and the periodic review cycle (either annual or biennial)" (page 63).

Financed emissions tracking: "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" (page 63).

Client Transition Framework: "Clients who are assessed receive a CTF score of T1 (most developed) to T5". In 2025 the methodology "was extended... to include in-scope publicly listed corporate clients in all sectors across the Investment Bank and UK Corporate Bank", and "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" (page 64).

Quantification is refused: "The expected and achieved reduction in emissions from these above actions have not been calculated for Barclays Bank Group" (page 64), citing dependence on "our clients' ability to commercially decarbonise their business models". No CapEx or OpEx is attached to any action.

Reference: pages 65-66 (index page 107)

The entity has no targets of its own: "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" (page 65). Schedule A gives the same answer for the E1-4 paragraph 34 datapoint: "No targets set, please see page 65 for further detail" (page 413).

What is disclosed is the parent's target set, which BBPLC portfolios feed: "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" (page 65).

The table at page 66 gives boundary, scopes, gases, reference scenario, metric, unit, baseline year and target per sector: Upstream Energy, Scopes 1-3, IEA SDS and IEA NZE2050, absolute MtCO2e, 2020 base, "-15% by end of 2025, -40% by end of 2030"; Power, "-30% by end of 2025, -50% to -69% by end of 2030"; Cement "-20% to -26%" and Steel "-20% to -40%" by 2030; Automotive "-40% to -64%"; Aviation (MPP Prudent) "-11% to -16%"; UK Commercial Real Estate (CRREM II) "-51%"; UK Agriculture (CCC BNZ) "-21%". For UK Housing, "Barclays has identified a 2030 emission intensity convergence point... but has not set a formal target".

Reference: pages 66-67 (index page 107)

E1-6 is listed in the index, but what is reported is a single Scope 3 category. "We have disclosed Scope 3 Category 15 emissions in line with the results of our DMA and obligations under the ESRS", and "We have determined it appropriate to report absolute emissions only from activities where Barclays have set 2030 financed emissions reduction targets", on the grounds that these "represent the only relevant data points in relation evaluating the performance and effectiveness of the E1 IROs" (page 66).

The table at page 67 gives financed emissions in MtCO2e for December 2025 against December 2024: Upstream Energy 43.7 (41.1); Power 13.6 (14.0); Cement 1.5 (0.8); Steel 0.8 (0.9); Automotive manufacturing 3.6 (3.8); Aviation 4.6 (4.9); UK Commercial Real Estate 0.1 (0.1); UK Housing 0.2 (0.1); Total 68.1 (65.7).

Two exclusions are stated: "Scope 3 categories 1-14 have been considered not significant for reporting", and "For other business activities where Barclays have not set targets, the Barclays Bank Group has not disclosed metrics" (pages 66-67).

No gross Scope 1 or Scope 2 figure for Barclays Bank Group appears anywhere in the Sustainability Statement, and no total combining scopes is given. PCAF data quality scores range from 2.0 (Cement, reported emissions) to 4.3 (UK Housing) (page 67).

Reference: page 68 (index page 107)

E1-8 is listed in the content index and answered as a nil return: "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" (page 68).

That is the whole of the disclosure. No shadow price, no internal levy and no carbon price assumption for investment appraisal is given. A carbon price does appear elsewhere in the statement, but as a scenario input rather than an internal price: in the 2025 Internal Stress Test "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" (page 57), and the scenario narrative assumes "Existing emissions trading schemes are strengthened to align with a 1.5°C pathway, triggering a significant carbon price shock in 2028" (page 57).

Reference: pages 76 and 84 (index page 107)

The index routes S1-1 to two places, the Equal Opportunities for All policies (page 76) and the Working Conditions policies (page 84).

Policies are tabulated with content, accountability and availability. The Inclusion and Opportunity strategy: "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)", with three priorities, "Empowering colleagues, Engaging communities, Driving company success", owned by "The Barclays Head of I&O" (page 77). The Whistleblowing Standard covers a "Zero tolerance approach to whistleblower retaliation" (page 77).

Working conditions policies include the Health Services and Wellbeing Standard, covering "Stress and Mental Ill Health, Workplace Adjustments, Display Screen Equipment (Eyecare)"; the Retirement and Benefits Standard, which "governs the approach to benefits, including provision of private medical cover"; the Industrial Relations Standard; the Culture Measurement Policy; the Workforce Change and Restructuring Standard; and the Fair Pay Agenda (pages 84-86). A matrix at page 75 shows which policies apply to each colleague type.

Human rights commitments sit at page 74: the Barclays Group Statement on Human Rights "expresses its commitment to respecting human rights as defined in the International Bill of Human Rights and the... (ILO) Declaration".

Reference: page 73 (index page 107)

"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" (page 73).

The main survey is described with coverage and participation: "Through the biannual all-colleague... 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" (page 73). Response rate is also carried as a metric, 67% in 2025 against 73% in 2024 (page 88).

Representative engagement is set out at page 74: "Barclays Bank Group, through Barclays, has a longstanding partnership with Unite in the UK", engagement "on major change programmes impacting Unite recognised colleagues, with the aim of minimising compulsory redundancies", plus "national works councils in some of its European jurisdictions" and the Barclays Group European Forum, which "represents the interests of colleagues in EU member states and the UK".

Monitoring is periodic: "The Bank assesses the industrial relations climate on a quarterly basis to identify any issues and emerging risks in its engagement with workplace representatives" (page 74).

Reference: page 79 (index page 107)

"The Raising Concerns process allows colleagues to raise concerns, including whistleblowing concerns, through a range of gateways: email, webform, telephone or via the Navex Ethicspoint portal. Concerns may be raised on an anonymous basis, subject to jurisdictional requirements. The Barclays Way includes advice and guidance on speaking up and the raising concerns process" (page 79).

A second route is described: "Colleagues can also use the HR issue resolution service that covers a range of HR topics... to help colleagues resolve issues informally at an early stage". For formal grievances, "an independent grievance manager is assigned to take the grievance forward and provide an outcome. Depending on local rules, colleagues may have the right to appeal" (page 79).

Trust is assessed rather than assumed: "As part of our annual colleague engagement survey, we ask colleagues for their views on speaking up and raising concerns to assess their levels of understanding and confidence in our processes" (page 79). In 2025 awareness activity included "a CEO sponsored awareness campaign on World Whistleblower Day".

Coverage is reported at 100% in both 2025 and 2024, as is completion of the Whistleblowing mandatory training module (page 83). Schedule A routes the S1-3 grievance datapoint (paragraph 32(c)) to "See page 74" (page 416).

Reference: pages 78 and 86 (index page 107)

Actions are split between the two material positive impacts.

For Equal Opportunities for All (pages 79-80): continued use of Employee Resource Group communities, "a Careers Week powered by WIN, the gender resource group", and "a four-month rotational ex-officio position on the Barclays Group Executive Committee". Mandatory training was "Monitored and tracked... consistently achieving =>97% completion within 65 days". Learning actions include graduate programmes (Expert and Explorer), apprenticeships "across England and Scotland", "Accelerator programs for high-potential colleagues", access to "LinkedIn Learning, Coursera and Pluralsight", and "Required 360 feedback reviews for Directors and Managing Directors". Policies were updated "to address FCA findings".

For Working Conditions (pages 86-87): Occupational Health services, "The Workplace Adjustment service", Employee Assistance Programmes providing "24/7 confidential support"; review of benefits including private medical cover; management of the Unite relationship; "pre-deployment, redeployment and outplacement support" on restructuring; hybrid working; and living wages, where "we conduct a 'living wage review' at least annually".

Effectiveness is tracked but not quantified by outcome: teams "track and assess the effectiveness of these actions annually, at minimum, by monitoring workforce data and insights" (page 86).

Reference: pages 81 and 87 (index page 107)

The disclosure is largely a nil return with one exception.

Inclusion and opportunity: "There are no targets to manage the potential positive impacts." The previous measures were withdrawn: "The percentage of employees from underrepresented ethnicities (US and UK), the number of underrepresented Managing Directors (US and UK), and the representation of women in senior leadership roles (Managing Director and Directors) are no longer considered measures for the effectiveness of the strategy. Instead, the effectiveness of our strategy and actions is monitored through regular engagement and feedback from relevant stakeholders, including through our Inclusion Index" (page 81).

Working conditions: "Barclays Bank Group does not have specific targets in place to manage the potential positive impacts on colleague working conditions. We instead track the effectiveness of our Policies, Standards and actions through annual reviews and feedback from relevant stakeholders" (page 87).

The one quantified target is on mandatory training, disclosed with baseline and type: "The completion target was set prior to 2019 and is reviewed annually... The baseline value has remained the same and is set as =>97%, this target is absolute." Performance is stated: "The performance against this target shows BBPLC exceeded the target in 2025" (page 81).

Reference: page 74 (index page 107)

Headcount at 31 December 2025 is 23,088 (2024: 23,788), split 9,530 female (2024: 9,750), 13,229 male (13,611), 258 other (341) and 71 non-disclosed (86). Of these, 22,985 are permanent (23,697) and 103 temporary (91), with non-guaranteed hours reported as 0 in both years (page 74). The same total is cross-referenced from SBM-1 at page 46 and to page 299 for "the most representative number in the financial statements".

Countries with 50 or more employees representing at least 10% of the total are given: United Kingdom 7,021 (2024: 7,060) and United States of America 11,314 (11,460) (page 74).

Turnover is reported as 3,528 leavers and a 15% rate (2024: 3,833 and 16%), on the basis of "Number and Percentage of total leavers, based on a rolling 12-month period ended 31 December 2025", where "Employees that leave for voluntary and involuntary reasons such as dismissal are included in this metric" (pages 74-75).

Definitions are set out for Permanent/Regular, Graduate, Apprentice and Temp/Contractor Payroll (Fixed Term), and for Operational versus Non-Operational status, where colleagues are "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" (page 75). Non-employees are defined but not counted.

Reference: page 82 (index page 107)

Gender distribution at top management level, defined as "Total Directors and Managing Directors... the two most senior grades in the organisational hierarchy": females 1,169, 25.7% (2024: 1,145, 25.3%); males 3,344, 73.5% (3,337, 73.9%); other 23, 0.5% (26, 0.6%); not disclosed 12, 0.3% (8, 0.2%) (page 82).

Distribution by age group: under 30 years old 4,524, 19.6% (2024: 4,615, 19.4%); 30-50 years old 14,013, 60.8% (14,544, 61.3%); over 50 years old 4,519, 19.6% (4,581, 19.3%).

Basis of preparation: gender is self-declared, "As part of the hiring and onboarding process, colleagues are asked to voluntarily disclose their gender; if this is not declared gender will be recorded as unknown"; data is held in Workday and "extracted through the People Insights reporting tool"; and "BBPLC staff are identified through BBPLC Company Codes as validated by Finance" (page 82).

Metrics were also removed this year: "Following our strategic review, these metrics no longer measure our refreshed positive impact on all employees... and are not material" (page 82), referring to ethnicity representation and female hiring measures. They were replaced by an Inclusion Index score of 79 in both 2025 and 2024 (page 83).

Reference: page 88 (index page 107)

"The 2025 living wage review confirmed that as of 31 December 2025, all colleagues across our locations are paid at least an 'adequate wage' in line with applicable benchmarks" (page 88).

The benchmarks are named: "Living wage benchmarks are sourced from external living wage data providers - the Living Wage Foundation for the UK, Caritas Jersey (a charity affiliated with the Living Wage foundation) for Jersey and the Fair Wage Network for all other countries" (page 88).

Method is set out: "Each colleague's fixed pay as at 31 December 2025 is used to calculate their hourly pay, taking into account their working hours. This hourly pay is compared against the relevant living wage benchmark for the location in which they are based. Country-level benchmarks are applied across all locations, except in the United States, where state-level data is used... and in the UK, where separate living wage rates apply for London and outside of London" (page 88).

The remedy is stated: "For any colleagues who are paid below the relevant living wage benchmark, or the minimum pay level / collective bargaining rate for the location, if higher, fixed pay is typically increased to at least meet the benchmark during the annual pay review" (page 89).

Reference: page 83 (index page 107)

The gender pay gap is reported as a median of 31.9% in 2025 (2024: 32.5%) and a mean of 47.0% (2024: 46.4%) (page 83). The mean gap widened year on year while the median narrowed.

The calculation is set out in full: "pay data consisting of fixed pay and bonus awards for the reporting year is taken from the HR system for all colleagues... Bonus is annualised based on the proportion of the year for which the colleague was bonus eligible. The sum of fixed pay and annualised bonus is then converted into hourly figures by dividing it by the colleagues' working hours over the year." The formula is given as "Pay gap=(A-B) *100/A", with A the mean or median hourly pay of male colleagues and B that of female colleagues. A note records that "Hourly pay includes bonus payments but does not include other pay elements such as pension and benefits" (page 83).

The second limb of S1-16, the ratio of highest paid individual to median employee compensation, is not reported. Schedule A marks the "ESRS S1-16 Excessive CEO pay ratio paragraph 97 (b)" datapoint as "Not Material", while routing the unadjusted gender pay gap datapoint to "See page 83" (page 416).

Reference: pages 95 and 98

G1-3 as a standalone targets requirement did not exist under the 2023 ESRS this statement was prepared against, where business conduct targets fell under MDR-T. ESRS G1 was not material for Barclays Bank Group (page 53), so there is no G1 chapter. The content below comes from the two entity-specific matters the report places in its Governance information chapter, and answers MDR-T's second limb, effectiveness tracked in the absence of a target.

Data Privacy: "We do not set targets for this impact because we instead track the effectiveness of our policies and actions that manage this risk (and therefore the impacts) through the Compliance Risk Dashboard, the tool used by Business Senior Management to manage and oversee the compliance risk profile for their business. The Compliance Risk Dashboard provides a quarterly holistic view of the control environment and risk profile (residual risk) using both qualitative and quantitative measures" (page 95).

Anti-Money Laundering and Sanctions: "The nature of money laundering and sanctions breaches makes it difficult to establish fixed, measurable, and time-bound targets for managing this impact. We instead track the effectiveness of our policies and actions that manage this impact through the Financial Crime Risk Dashboard" (page 98).

No numeric target, baseline or milestone is set for either matter, and no incident, breach or fine count is published.