Banking StandardsLetter from Sir David Walker, Chairman, Barclays

Barclays have provided redacted copies of (1) Simmons & Simmons LLP’s Phase 1 Report dated 18 January 2013, and (2) the report prepared by Genesis Ventures, entitled “Barclays Wealth America Cultural Assessment”, dated March 2012. The materials referred to in the Mail on Sunday article dated 20 January 2013 were the Genesis Ventures Report and Simmons & Simmons’ Interim Report dated 21 December 2012. The Phase 1 Report sets out Simmons & Simmons’ findings in relation to the same matters covered by the Interim Report, but after further investigation.

I have summarised below the background to the commissioning by Barclays Wealth of the Genesis Ventures Report, as well as some details relating to Simmons & Simmons’ investigation into the suppression of that written report. I have also explained the basis for the redactions to the reports. I hope that this information will assist the Commission’s understanding of the matters reported in the Mail on Sunday on 20 January 2013.

1. Genesis Ventures’ Work for Barclays Wealth

1.1 Genesis Ventures is an independent consultancy that has worked for Barclays Wealth for two years, helping to improve culture and performance by facilitating workshops, offsites, providing management coaching, feedback and appraisals. In February and March 2012, senior management at Barclays Wealth commissioned Genesis Ventures and another consultancy to carry out a piece of work focusing on culture at Barclays Wealth Americas (“BWA”). Genesis Ventures were asked to conduct a series of interviews with senior management in BWA to highlight cultural problems affecting the development of the business. The need for this work was identified when, after a six month examination in 2011, the U.S. Securities and Exchange Commission (“SEC”) issued Deficiency Letters to BWA in early 2012.

1.2 Genesis Ventures were engaged on the basis that the outcome of their work (and that of other consultants) into culture at BWA would determine a programme of remediation amongst BWA’s leadership. Genesis Ventures reported their findings both verbally in a series of meetings in April and May 2012 (and in a written report, sent only to the Chief Operating Officer of Barclays Wealth). Since then they have worked with the business and with other consultants to develop a programme of activities to address their conclusions.

1.3 These activities have included a series of focus groups and workshops to create plans for cultural development, a comprehensive programme for employee communication and engagement, executive coaching for senior leaders in BWA, re-alignment of individuals’ performance objectives and 3600 assessment of senior management. Within the last month Genesis Ventures and other consultants have conducted, and continue to conduct, a further series of interviews with senior and junior staff to monitor progress and senior management led an offsite event attended by business, office, control function and infrastructure heads, aimed at addressing the cultural issues within the BWA business. As this programme of activities makes clear, progress has been made, and continues to be made, towards improving culture within BWA.

1.4 As you will know, Antony Jenkins acknowledged very recently that there is a need to change culture across all areas of Barclays business. We have set out a plan for how we are going to do this. We see BWA’s ongoing programme of activities as an integral part of Barclays wider plan.

2. Simmons & Simmons’ Investigation and Reports

2.1 Simmons & Simmons LLP was instructed in November 2012 by the Group Litigation and Investigations unit of Barclays to undertake an internal investigation into matters relating to culture within Barclays Wealth, in light of issues raised in whistle blow emails and by staff within the business.

2.2 Phase 1 of their investigation focused on the allegation that a “Wealth cultural audit report” had been commissioned and suppressed. This allegation was made in two whistle blow emails received in September and October 2012.

2.3 Simmons & Simmons reported the findings of Phase 1 of the investigation to the regulators, first in its Interim Report dated 21 December 2012 and then more fully in its Phase 1 Report dated 18 January 2013. The conclusions are that:

(A)the Genesis Ventures Report had been commissioned by Andrew Tinney, the former Chief Operating Officer of Barclays Wealth;

(B)he had actively suppressed the existence of that Report;

(C)no other individuals within Barclays Wealth ever received the Report;

(D)there is no evidence that any other individuals participated actively or knowingly in the suppression of the Report; and

(E)although the existence of the Genesis Ventures Report itself was suppressed, the contents of the Report were, and continue to be, acted upon as part of BWA’s ongoing programme to improve culture, as I have described above.

3. Integrity of Continuing Investigations

3.1 It is extremely important to Barclays that the continuing activities within BWA and Barclays to improve culture, and particularly Simmons & Simmons’ ongoing investigations into matters relating to Barclays culture, are not undermined by the disclosure of information to the Commission. Simmons & Simmons have advised that, without appropriate safeguards, disclosure could potentially affect the integrity of the ongoing investigation, including the willingness of Barclays staff to co-operate with the investigation. It may also harm Barclays ongoing relations with those employees if these matters were subjected to scrutiny by the Commission. In addition, Barclays has a responsibility both to protect the privacy of its members of staff and to maintain the relationship of trust between Barclays and its staff which is central to our efforts to change culture.

3.2 With those matters in mind, we have redacted from the Phase 1 Report:

(A)matters which are the subject of ongoing investigation and of continuing reporting obligations to the FSA and other regulators; and

(B)various of the detailed findings in the Phase 1 Report which relate to existing employees of Barclays and which remain the subject of further enquiries.

3.3 For the same, and additional, reasons we have also redacted from the Genesis Ventures Report all direct quotations provided by BWA employees during interview with Genesis Ventures, the names of all individuals, and passages which may enable those familiar with BWA to determine the identities of those individuals. The direct quotations record comments made by individuals during confidential interviews with Genesis Ventures. Many of the interviewees and subjects of the comments remain employees of BWA and many will be unaware they have been named or criticised in the Genesis Ventures Report. It would be unfair to the interviewees or to the individuals referred to in the Genesis Ventures Report to quote them directly, or to reveal their identities. As the Genesis Ventures Report addresses exclusively matters relating to BWA, and not Barclays Wealth’s UK business, we do not consider that this will hinder the Commission’s investigation of matters within its remit.

4. Confidentiality

4.1 We request that you do not publish the Phase 1 Report, for the reason that the report is confidential, is not in the public domain and has been prepared for the benefit of regulators, including US regulators, in the context of an ongoing investigation.

4.2 We have provided a redacted version of the Genesis Ventures Report so that the Commission is able to appreciate the nature of the report which was suppressed. However, as is clear from section 1 of this letter, the content relates exclusively to Barclays Wealth America and contains direct quotes from members of staff provided during the course of strictly confidential interviews. Publication of this report would compromise ongoing investigations internally and by the authorities and would undermine Barclays ability to conduct further exercises of this nature in the future. For these reasons, we again request that the Genesis Ventures Report not be made public in any way.

Please do not hesitate to contact me if you have any queries about the reports in the information in this letter.

1 February 2013

Prepared 19th June 2013