Barclays Bank PLC. Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Registered in England. Registered No: 1026167. Registered Office: 1 Churchill Place, London E14 5HP.

Barclays Capital Inc., an affiliate of Barclays Bank PLC, is a US registered broker/dealer and a member of SIPC, FINRA and NFA. Barclays Capital Inc. operates out of 745 Seventh Avenue, New York, NY 10019.

Barclays Bank Ireland PLC, is regulated by the Central Bank of Ireland. Registered in Ireland. Registered Number: 396330. Registered Office: One Molesworth Street, Dublin 2, D02 RF29.

Bond Auctions and Buybacks Disclosure for Rates Clients

This disclosure sets out certain information we provide to our clients in connection with bond auctions and buybacks. The contents of these disclosures should not be treated as investment, regulatory or legal advice.

Scope

This disclosure relates to Barclays’ participation in bond auctions and buybacks for government, sovereign, supranational and agency issuers in jurisdictions where Barclays operates.

For simplicity, we refer to “bids” in “auctions” of “government debt management offices”, but this disclosure also applies (where relevant) to offers in buybacks, as well as for other types of issuers such as sovereign, supranational and agency issuers and the disclosures should be construed accordingly.

Conflicts of interest

Barclays may face actual or potential conflicts of interest when participating as a primary dealer in bond auctions, including:

•        Client order vs. Barclays bid
When Barclays participates as a primary dealer in bond auctions, it has three main objectives: (i) to fill the client orders it has received, (ii) to satisfy its own inventory need and (iii) to fulfil its primary dealer obligations to the government debt management office. This creates a potential conflict between the interests of our clients and the interests of Barclays to the extent that knowledge of client orders could inform Barclays own submissions.

•        Client order vs. Barclays hedging activity
Barclays may hedge the risk of a client order either in the market ahead of the auction or in the auction itself. This is consistent with market practice, but it creates a potential conflict of interest because Barclays’ trading activity in the market may have an impact on the final auction results which could adversely impact a client.

•        Client order vs. Barclays primary dealer ranking
Barclays performance as a primary dealer in each country is typically assessed by the relevant government debt management office, and primary dealers with higher rankings may be granted certain privileges by a government debt management office (see Primary dealer obligations and privileges section below). As a result, Barclays may benefit from client business in government bond auctions.

How Barclays manages conflicts of interest and handles sensitive information

Barclays has policies, procedures and controls designed to identify, manage and mitigate conflicts of interest and to handle sensitive auction-related information appropriately. The application of controls can vary by jurisdiction and auction structure (including whether Barclays has implemented restrictions on client order information flow). This reflects differences in government debt management office rules, auction mechanics and local market practice, including whether the relevant government debt management office provides for segregation of certain client order types.

Clients should note that; (i) government debt management office rules and auction mechanics may limit the extent to which information flow in auctions can be restricted, and (ii) certain client instructions or order types may require Barclays personnel who manage Barclays’ risk to have knowledge of an order.

Where Barclays has implemented restrictions on client order information flow in relation to a specific price or yield order, the Barclays traders responsible for determining Barclays’ own bid will not have knowledge of that order prior to the auction.

Order types and execution outcomes

If a client places a specific price or yield order, whether and to what extent the order is filled by Barclays will depend on the auction outcome and applicable government debt management office rules.

Barclays may decline to accept a client’s order, including a specific price or yield order, if Barclays cannot reasonably apply appropriate controls for the relevant auction process, including any information restrictions required by the applicable government debt management office rules and auction mechanics.  Notwithstanding the foregoing, Barclays always reserves the right to decline to accept a client’s order.

Clients should consider the points set out above when selecting the order type they wish to place with Barclays.

Barclays role in auctions and buybacks

In some jurisdictions, Barclays participates as a primary dealer; in others, Barclays may participate as a dealer submitting bids or offers in accordance with the applicable government debt management office process.

In buybacks, Barclays may facilitate client participation by submitting offers, or by otherwise transacting with clients as principal, in accordance with the applicable government debt management office process, the relevant buyback structure, and Barclays’ internal controls.

Primary dealer obligations and privileges

When acting as a primary dealer, Barclays may be required by a government debt management office to satisfy certain obligations or meet certain targets in respect of its performance in auctions. In return for satisfying these obligations or meeting these targets, government debt management offices may grant certain privileges to a primary dealer (for example, eligibility for syndication roles).

Certain government debt management offices and US government sponsored enterprises may pay a fee to primary dealers for their performance in auctions and other primary distribution duties.

Non-Competitive Subscriptions (NCS / “Greenshoe”) and cash-equivalent alternatives

In some jurisdictions, the relevant government debt management office may grant primary dealers a non-competitive subscription, often referred to as a “greenshoe”. Where Barclays is granted such an option, a client placing an order in the auction may request, or Barclays may offer client(s), a portion of that option, where permitted (i) by applicable law or regulation, (ii) by government debt management office rules and/or (iii) subject to Barclays’ internal constraints.

Where a client requests that Barclays offers it a portion of the non-competitive subscription, such request must be received at the same time as the client’s order for the competitive auction to be considered by Barclays.

Where permitted by applicable law or regulation, Barclays may instead offer to client(s) a cash-equivalent representing the economic value of that option, rather than transferring the option itself.

Notwithstanding the foregoing, Barclays will exercise sole and absolute discretion in deciding whether to provide to client(s) any portion (or cash-equivalent) of a non-competitive subscription.

Discounts and similar commercial terms

In some jurisdictions and for certain order types, Barclays may agree with a client commercial terms linked to auction outcomes, for example, a discount or other economic term. Barclays will exercise sole and absolute discretion in deciding whether to offer any such terms to a client.

The availability of any such terms is subject to government debt management office rules, applicable market practice and Barclays’ internal policies and may be prohibited or restricted in certain jurisdictions. Any such terms are not a client entitlement and are separate from any non-competitive subscription / greenshoe option (or any cash-equivalent of such an option) that may be permissible in a particular jurisdiction.

Submission and handling of client orders

In many cases, and absent express instructions from clients, an order may be submitted into the government debt management office’s auction system in Barclays’ name or executed by Barclays through other means (for example, from existing inventory), depending on the auction structure, government debt management office rules and order type.

If a client’s preference is for an order to be submitted directly into a government debt management office’s auction system, the client should communicate that preference to the relevant Barclays representative at the time the order is placed.

For UK government bond auctions, if Barclays receives a client order and the order is accompanied by a DMO ID code, Barclays will assume the client is instructing Barclays to submit the order to the UK government debt management office.

Barclays always acts as principal, not a client’s agent, in respect of client orders for auctions and buybacks.

Primary dealer reporting obligation

Some government debt management offices require primary dealers to report certain information about purchases and sales on the primary and secondary markets of the bonds issued by that government debt management office. The reporting format set by a government debt management office may require primary dealers to specify a counterparty type and country of counterparty incorporation for each purchase or sale. If you would like more information about any of the reports that Barclays is required to submit as a primary dealer, please contact Barclays.

Handling of client information

Auction-related information may include, for example, information about bids (such as yields / prices, amounts and timing) and related positioning or trading activity in the securities being auctioned or related instruments.

Barclays has policies, procedures and controls to restrict the inappropriate sharing of sensitive auction-related information. For example, Barclays restricts the communication of specific yields, prices, rates or amounts that clients may be bidding to other clients, and restricts the sharing of certain position information, except where required or permitted by applicable rules (for example, government debt management office rules) and applicable law or regulation.

Barclays may provide general market colour to clients around auctions, provided that such information is based on general, anonymised and aggregated impressions of market conditions and does not disclose, or enable the identification of, specific client information.

Guidelines for handling information related to US Treasury auctions

This disclosure also serves as a high-level summary of Barclays’ approach to handling US Treasury auction-related information in response to relevant US Treasury guidance. US Treasury auction participation is subject to US-specific rules and procedures regarding information handling and communications.

Please contact Barclays if you have any queries about any of the disclosures set out above.

Updated June 2026