Scope of Commercial Policy

Barclays Bank PLC, Barclays Capital Securities Limited and Barclays Bank Ireland PLC (together “Barclays”), in their capacities as Systematic Internalisers (SI), must make public firm quotes pursuant to the pre-trade transparency rules in Regulation 600/2014 (MiFIR) or any other applicable laws, rules or regulations.

How to Request Access

Barclays will publish quotes via Approved Publication Arrangements (APAs). Clients may request access to published quotes by utilizing their standard sales channels. When looking to access a published quote a client may only execute upon that quote in accordance with all originally quoted terms, including those not explicitly displayed on the APA.

Restriction on Access

Barclays will provide access to published quotes to clients with the same profile as the client who received the initial published quote. A client’s profile is based on a combination of:

• the client’s credit, risk, funding and capital profile;
• Barclays’ client tiering criteria; and/or
• other objective non-discriminatory factors.

The weight given to such factors may vary between different product types.

Additionally, to execute at a quote, the client must already be onboarded for the specific product being quoted. Barclays may refuse to enter into or discontinue business relationships with clients on the basis of commercial considerations such as the client’s credit status, counterparty risk and any risks associated with the final settlement of the transaction.

Execution Limits and Updates to Pricing

Barclays will establish non-discriminatory and transparent limits on the number of executions it permits against a published quote. Details of such limits are available on request. The number of executions may be limited to one. Where an instruction to execute against a published quote is received simultaneously from both the original requesting client and an additional client, priority shall be given to the original requesting client.

Barclays reserves the right to update pricing at any time and in justified cases may offer price improvement on the published quote. Quotes may be withdrawn under exceptional market conditions. Quotes published by the SI will be bound by all other relevant regulatory obligations.