Disclosure Statement relating to The UK Stewardship Code

In July 2010, the UK’s Financial Reporting Council published “The UK Stewardship Code.” This Code comprises a set of guidelines aimed at improving the ways in which institutional investors interact with the management of companies in which they invest. In addition it proposes measures to increase the level of transparency surrounding institutional investors’ activities as shareholders for the benefit of the investors’ underlying clients.

This document explains how Barclays Wealth addresses the measures proposed in these guidelines.

Barclays Wealth is the wealth management division of Barclays Bank PLC. Investment management is carried out for professional investors in the UK by Barclays Bank PLC. Investment management activity is predominantly carried out in the form of multi-manager and fund of fund arrangements. That is to say that we choose to outsource the selection of assets, including shares, to other investment managers, by either investing into a fund or by giving a number of managers a portion of the money that we raise for investment from underlying fund investors. These managers we select through a thorough due diligence process, focusing in every case on identifying a manager that we believe can generate the best risk-adjusted returns in the asset class or strategy in relation to which we are seeking to delegate management.

As part of the manager selection process, and on an ongoing basis, we will consider numerous factors around the manager’s proposed investment strategy and their performance against that strategy.

Across all of our UK investment management activity, Barclays Wealth will not generally exercise voting rights. However, where Barclays Wealth does exercise its discretion to vote for or against a particular proposal it will be in a manner consistent with its customers’ best interests. We do not therefore directly commit to observe the Stewardship Code, though we do support its aims. Our main goal in fund management is to ensure that we select managers and funds that seek to maximise investor returns within the constraints they operate under given their particular specialism.