Salz Review - Wall Street Journal

Salz Review
An Independent Review of Barclays’ Business Practices
96
― Clearly explain both the benefits of complying with, and the consequences for
breaching, the high standards;
― Commit to assurance, reporting and review in a way which supports
implementation of the code.
8.69 In preparing the code, Barclays may find it helpful to:
― Consider issues which may cause concern for its staff, customers and others
with whom it deals;
― Explain to whom staff should address concerns;
― Understand external standards and good practice;
― Distinguish between “must do” and aspiration;
― Explicitly address potential conflicts of interest: one way of doing this is to
prepare representative questions and answers to relevant day-to-day dilemmas.
8.70 Whether part of the code of conduct, or as part of documentation to support it, we
would expect Barclays to consider defining its expectations of senior management
and the reinforcing role to be played by its people management and compensation
approaches. Importantly, Barclays should be clear about how its code of conduct will
be implemented and embedded into the organisation’s culture and business practices.
Recommendation 6: Code of conduct
Barclays should maintain and publish a global code of conduct, based on the
bank’s statement of purpose and values, outlining the high standards of conduct
expected of all employees. This code should be regularly updated and provide
clear guidance to employees about how the bank’s standards can be applied on
a day-to-day basis. Employees should attest to their compliance with this code
annually.
8.71 We looked at the Lord George Principles for Good Business Conduct, developed by
The Worshipful Company of International Bankers, and approved and circulated to
all of its members in 2005. We found the principles to be relevant and compelling to
the Review and would suggest that they be reflected in this code of conduct.
Exhibit 6. The Lord George Principles for Good Business Conduct
Introduction
The core purpose of international financial service providers is to promote global
economic and social welfare by aggregating financial resources, converting them into
specific services and products and delivering them in accordance with the mandates of
their clients, customers and counterparties. Both the public good and the personal
interest that stands behind this purpose and the capacity of providers to fulfil their
mandates on a competitive, efficient and cost-effective basis can be substantially
impaired, even frustrated, by dishonesty or by a lack of professional integrity,
transparency and accountability. Accordingly, financial service firms and their officers
and employees have both a collective and an individual commercial interest in the