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Barclays Asset Management Limited

PRI reporting framework 2018

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.3. Indicate if the investment policy covers any of the following

Cluster munitions screening

01.4. Describe your organisation’s investment principles and overall investment strategy, and how they consider ESG factors and real economy impact.

As long-term investors, Barclays Asset Management Limited ("BAML") seeks to invest to generate superior returns for our investors as well as the creation of long term value for all stakeholders.

We believe this requires BAML to look deep into our investment process and investments to recognise our responsibility to society and all key stakeholders. We believe in the integration of environmental, social and corporate governance (ESG) considerations into our investment management processes and ownership practices, as these factors can have an impact on financial performance. We believe that as ESG considerations play out over a long horizon, and as they increasingly become a priority for company managers, they may help alleviate the pressure for short-termism and encourage a focus on long-term value creation - to the mutual benefit of firms, investors and the world at large.

BAML participates in industry initiatives and strengthens links with government and regulators to assist in investment process implementation and to encourage sustainable capital markets and a reduction in systemic risk.

These beliefs align with our purpose in Barclays of "helping people to achieve their ambitions - in the right way" and the Barclays Values of Respect, Integrity, Service, Excellence and Stewardship.

01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

BAML is committed to seeking to deliver the best possible risk-adjusted returns for our clients and we believe responsible investment supports this aim.

We view responsible investing as one approach within the wider discipline of impact investing, which recognises all investments have an impact that should be considered as part of the investment decision-making process. A Responsible approach, as distinct from Sustainable or Catalytic approaches, focuses primarily on the risks and opportunities highlighted by ESG factors. In addition, we see this approach as distinct from ethical investing which applies pre-determined criteria, based on religious beliefs, broadly-accepted global norms, or even an individual investor's personal values, to decide whether an investment is appropriate to hold.

We believe ESG considerations capture non-financial information that could affect financial performance. By considering these ESG factors, and consequently a broader set of data, we believe our investors are enabled to make a better judgement about the financial performance and longer term viability of an investment. Therefore, as part of the investment process, we seek to include any foreseeable risks and opportunities that arise from material ESG factors.

A majority of the assets we manage on behalf of our clients are invested indirectly, through third party fund managers. Nonetheless, our approach to undertaking responsible investment is relevant across all the asset classes, sectors and markets in which we invest.

SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Indicate if your organisation’s investment principles, and overall investment strategy is publicly available

02.4. Additional information [Optional].

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Barclays believes identifying and managing Conflicts of Interest is fundamental to the conduct of our business, our relationships with customers and clients, and the markets in which we operate.

As part of our Enterprise Risk Management Framework, Barclays has established policy, standards and guidelines which are designed to manage Conflicts of Interest that may emerge for existing or new activities. Areas of Conflict, or even the appearance of a Conflict, are identified on a Conflicts of Interest Register; and reviewed on an annual basis across the various relationships between Barclays, its Customers and clients, and Employees.

This approach is taken within the investment process across all teams, so that appropriate steps are taken to identify, assess and take appropriate action to address Conflicts of Interest on an on-going basis. Furthermore, we evaluate and evidence the extent to which relevant internal Controls (associated with the Conflict of Interest Standard) are designed and are operating effectively; risk is being effectively managed; and compliance is being maintained with laws and regulations.

Additionally, Barclays also has a Code of Conduct by which all employees are required to abide, and mandates that employees must identify and address real or perceived conflicts of interest.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)