Assignment 2 Final

Jagdeep Singh John Tucker, Zair Rashid
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Barclays Bank – Corporate Governance
Introduction
This report will assess the LIBOR scandals in relation to Barclays discussing what happened
who was prosecuted and why while discussing where Barclays failed in its corporate
governance strategy if it has failed. The impact of corporate governance, public policy and
financial regulation on the wider economy will be analysed all the while discussing the
impact of new regulatory frameworks on Barclays corporate governance and how Barclays
cope with this in light of globalisation. This report will finally look to evaluate whether the
new regulatory frameworks are effective.
LIBOR & Barclays
The London inter-bank offered rate (LIBOR) is a base rate by which banks can lend to each
other and deal in trillions of pounds worth of loans and contracts (BBC, 2013). This is
published on the British Bankers Association (BBA) and the highest/lowest 25% of data is
nullified averaging out the remaining in order to determine LIBOR over 10 different
currencies and 15 countries (CFR, 2013). The banking world is a global market and LIBOR will
affect global borrowing as when LIBOR rises, rates and payments on loans also rise and vice
versa. Many rates on products and services are affected by LIBOR for customers and
therefore the rigging of LIBOR has affected these for customers (CFR, 2013).
Barclays amongst others, RBS & HSBC for example were found to be rigging the LIBOR rate.
Barclays have done this for their own gain and is clear to see when banks such as RBS
needed to be ‘bailed out’ by governments or effectively tax payers, Barclays still appeared

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to be strong. However this is only an appearance as Barclays borrowed money from
sovereign lenders, foreign governments such as Dubai which means they have to pay back in
higher rates of interest than to if they were to borrow from UK governments. They have
done this to give the outward illusion and install confidence in the consumers as majority of
banks were falling around them (BBC, 2008). The LIBOR scandal for Barclays had involved
people in New York, Japan and London which shows the widespread of the scandal.
Initially swap traders asked Barclays employees to submit data that would benefit traders
instead of the correct figures (New York Times, 2013). Ronald Anderson from London School
of Economics explains that Barclays, after the global crisis of 2007, made themselves look
like a less risky and therefore safe bank by rigging LIBOR rates to be low. Because of this the
markets, so banks/consumers and suppliers, lose trust with Barclays and any bank involved
and therefore higher rates again are issued to Barclays when lending and customers in turn.
Barclays once having rigged the rate used the lower rate to borrow money and give it out to
customers with a higher rate of interest. This is how they gained money from LIBOR rigging
but another benefit to Barclays is by making them look as if they were not in financial
struggle they could impact a global market who are struggling at this point by being the
strongest and the benchmark for other banks.
This shows examples of operational failure for Barclays and systemic risk through the
market. Although the systematic risk would have arose by the bank run of Northern Rock
and financial crisis of 2007 Barclays managed to make themselves appear strong as were
HSBC who were known as the ‘tower of strength’ just by paying taxes and not needing a bail
out (Financial Times, 2015).

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Barclays began going to the financial services authority (FSA) and effectively telling on other
banks while not mentioning themselves to be doing this. The biggest advantaged group by
Barclays doing this were the shareholders, and no other stakeholder was given recognition
or ignored by Barclays. This is a clear indication that the stakeholder theory (Phillips, 2003)
was giving no value and Barclays are or at least were out to maximise shareholder profits.
Legislation at that time did not see the LIBOR rigging scandal as a criminal offense of
criminal sanction and therefore Ed Balls failed to regulate banks (Telegraph, 2012). He then
later argued in an interview that George Osborne and others pressured him saying he was
being too tough, which shows confusion and no clear leadership in government regulators.
This allows Barclays to get away with it and could be supporting Barclays culture to
maximise shareholder wealth at any cost to society.
Barclays are aware of the competition and know that although Barclays are not the most
ethical and have been involved in scandals before and, unless major changes will most likely
be involved in later scandals, almost all other banks are also involved in scandals. A lot of
the banks are doing scandals so people could move from one scandal into another – it’s still
quite hard for customers to move their money from bank to bank even after governments
made it easier in 2014. One reason why people do not move their accounts or shop around
is that it takes time. People are not bothered to move their mortgage from one bank to
another and will definitely not be bothered to move their accounts over especially those
who own their own business. This will therefore not act as a deterrent for Barclays to act in
scandals and could be another factor to the LIBOR scandal. Barclays would have gained in
the short term and still kept customers meaning a short term gain and long term stability
even after the fines and a lessened reputation.

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Information asymmetry meaning Barclays knew more about their figures than the industry
and those overlooking the LIBOR rate at the time meant that Barclays and other banks were
allowed to do this for the time they did without getting caught. The regulators act on trying
to make it more transparent is a step to overcoming this and for it to not happen again. This
information asymmetry may also be what Barclays hide behind for customers when
charging them higher prices due to the LIBOR rigging for example on mortgages.
Governments Role in LIBOR
Governments have a role to protect customers and ensure stability in the markets. This is
found throughout Europe and UK regulatory bodies are taking influence in practice from
European regulatory bodies. They are currently working on a single rule book which could
lead to UK regulatory bodies being replaced by those of Europe. European Securities and
Markets Authority (ESMA) safeguard the stability by ensuring transparency and integrity
amongst other factors (ESMA, 2015). Which lines up with UK regulators and policies as
reforms from LIBOR are pushing for higher levels of transparency for safeguarding stability.
As regulatory bodies, governments should have been able to prevent such cases happening.
However governments are more reactive than proactive therefore change legislation after a
scandal has occurred. This is the case that happened after the LIBOR scandal, creating new
legislation for the sector to follow and prevent a scandal of such nature to occur again. From
the LIBOR scandal fines have been given to many banks including the £290m to Barclays
though could be argued that this isn’t enough as, although can’t be quantified, it could be
that Barclays have made much more than this by rigging the rate.

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The Commodity Futures Trading Commission and Barclays came to a settlement which
began the regulatory regime in the financial sector. This meant that Barclays would now
“base its submissions on the market price rather than some hazy estimate of borrowing
costs” (CFR, 2013).
MiFID
European legislation is important for the UK to follow as is demonstrated by the markets in
financial instruments directive (MiFID). This invests major fields including Barclays trading in
financial instruments, which would cover LIBOR. This has been applied to the UK from 1st
November 2007 but is now being revised in light of the scandal and financial crisis.
Fields MiFID covers:
 Authorisation, Regulation
 Client Categorisation
 Client Order Handling
 Pre/Post-Trade Transparency
 Best Execution
 Systematic Internaliser
These factors will help maintain stability in markets and create a network for UK regulation
to follow in regards to EU regulators (Europa, 2015).
Prosecutions
Price fixing is not found to constitute fraud as was found by the pharmaceutical group
‘Goldshield’ and therefore the Serious Fraud Office (SFO) have found it hard to prosecute
those involved in Barclays (The Telegraph, 2012). If the SFO can prove those traders’ LIBOR

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submissions were manipulated using different measures to usual then the 1986 Theft Act
can be used to prosecute (The Telegraph, 2012). 10 people, were charged by SFO and US
Department of Justice and another three are set to face more prosecutions. These
prosecutions are to be made on rigging the yen-LIBOR (Financial Times, 2014).
Protecting Customers
Governments have a role in protecting customers and regulating the banking sector helps.
This can be done by stopping the main banks monopolising, which is achieved by creating
and maintaining competition. The scandal adversely affects customers as Barclays are giving
mortgages on higher rates than it should to make more money. Transparency in the market
will allow this risk to be lessened for the customers. Splitting investment banking to retail
banking will protect depositor’s money and governments protect for up to £80,000.
Although this may deter Barclays from having another scandal governments may choose to
take on actions that are used in Germany. By this they can sit on the board and take part in
decision making. This may lead to companies working only to make money for the banks
and banks making money for governments instead of all stakeholders.
Stakeholder theory
The stakeholder theory for Barclays is important as once looking at the theory it is clear to
see that Barclays have favorited shareholder as their number 1 stakeholder priority. This
theory looks to give fairly equal weighting to many or all of the stakeholders and for this
case Barclays.

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The above diagram shows the stakeholders in Barclays such as society and customers being
the same. Others stakeholders could be negatively affected for example, customers would
have been getting charged higher rates than needing to when focusing on shareholder
wealth. Many could say that governments and employees were also advantaged as
governments didn’t have to bail the bank out meaning tax payers money could have been
spent elsewhere. Unfortunately for this case it was spent by buying shares in other banks. In
this case suppliers were negatively affected as suppliers would have been other banks’
lending to Barclays at the lower rate Barclays leads them to believe they had.
The PPI misselling scandal is another scandal against Barclays that supports the notion that
Barclays are not acting ethically and morally correct towards their customers. Although

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others argue that business should be kept separate Freeman (1994) has argued ethics and
the way everyday business is run overlap.
Limitations to Stakeholder Theory
 Financial output is the main aim for Barclays
 Managers or board members act for themselves (replaced by Anthony Jenkins to
overcome this?)
 All stakeholders seen and treated equally – Governments can put more pressure to
Barclays that customers
These limitations along with their counter arguments are appearing to be true with Barclays
as LIBOR was under regulated and the FCA were perhaps too afraid as members are after
their own gain. Members in the FCA once moving their careers from here move to banks
and therefore act in the interest of themselves when regulated the sector. This point is
supported by Hector Sants, former head of FSA joining Barclays as head of compliance (The
Guardian, 2012).
The Stakeholder Theory is used alongside Mendelows stakeholder mapping (1991) in order
to give importance to certain stakeholders who hold high levels of interest and high levels of
power by grouping them together. Demonstrated by the below table. Barclays could use this
to overcome one negative from the stakeholder theory which is that all stakeholders are
given equal authority. Can also tell Barclays which pressure to fall to.

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Structure of Barclays
(Forbes, 2014)
Although Bob Diamond (CEO of Barclays at time of LIBOR) was not involved in rigging the
rate it would have been corporate governance and culture passed by him that led to the
scandal. This diagram showing the new structure of Barclays and further supports their page
to show an increase in importance for 4 core areas:
 Personal and Corporate
 BarclayCard

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 Investment Banking
 Africa
The old structure shows, at a glance, the many different levels in place before reaching the
country in which Barclays work. This could be one of the factors that lead to the LIBOR
scandal as improper governing bodies and management were in place or not being able to
see through the levels to see the problem. Barclays have been dealing with this as in 2013
they employed a new chief executive Anthony Jenkins (Sky, 2013). This occupational failure
could lead to a reputational risk for Barclays in turn losing the money coming in from
customers/depositors. The new board could also be a measure to overcome this and
Barclays could use corporate social responsibility (CSR) policies to make themselves seem
better in the eyes of society who are the customers.
Personal & Corporate
 Traditional banking models, deposit accounts, mortgages and so on
 Technology now provides real opportunities – not only for cost savings, but also to
build a seamless end to end client offer
What it tells us
Appear to have taken a closer look at the Stakeholder Theory and are looking at customers
as an equal to shareholders
PESTLE & SWOT analysis leads to technological developments
BarclayCard
 Market dependent on scale, innovation, analytics and risk management
 Invest for growth and believed to be strong throughout
What it tells us

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Innovation is a way of staying ahead of the competition and although is flash may not offer
the competitive advantage to Barclays (costly at first but long term saves costs)
Money gone into research will be quickly copied by other banks as seen by contactless
technology (waste of money? Does is bring in new customers?)
http://smallbusiness.chron.com/advantages-disadvantages-innovative-technology-
24267.html
Investment Bank
 The strength from here is the differentiator
 Focusing on achieving high quality and higher returning clients
 Focusing on highly liquid investments
 Focusing on where they are already strong and improving and with key clients
 Focusing Asian operations on global rather than local business
What it tells us
Not being very risky with money which shows they are looking out for customers (not losing
their money)
Highly liquid investments means that another crisis like 07/08 will be better dealt with as
products can be moved quicker
Africa
 Already positioned in Africa and markets now growing
 Keeping all these together  retail, cards, wealth, corporate and investment banking
– better highlighting the strength of our proposition in Africa
 Committed to maximizing its value for all our shareholders
What it tells us

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As investment banking and retail banking have been separated in America from events in JP
Morgan and Morgan Stanley, Barclays could be accused of being irresponsible and moving
trading to another country in order to avoid laws
Truly focusing on shareholders and maximising profits which although is good business
sense the money comes from customers and by not paying employees enough (maximising
profits, minimising costs)
(Data from Barclays 2015)
Corporate Governance
The FRC sets standards of good practice that boards follow in terms of remuneration
accountability and shareholders (FRC, 2015). Barclays have been slated for offering too high
a bonus to the board. Governments have set out to say that bonuses will no longer be
higher than wage which could see wage increase or bonus decrease. It could also mean
commission based products could be highly supported as agency problem may make
Anthony Jenkins want to act for himself.

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Barclays create transparency and the board members of Barclays create strategic guidelines.
The purpose of the auditing committee to govern from within Barclays is to:
 Review reports
 Monitor policies
 Monitor internal environment
 Help external auditors
Although Barclays have been seen to be favouring shareholders the most, their recent
corporate governance reports shows many factors where the board are taking other
shareholders into account. The board are responsible for the below as well as other matters
 Interests in Barclay’s employees
 Impact of Barclays on the community and the environment

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 The need to act fairly as between shareholders of Barclays
This last bullet point is a contradiction to them as their past conduct and further statements
in the report as is stated that Barclays are “promoting success for the benefit of the
shareholders as a whole” (Barclays, 2013).
The board are also responsible for making sure the management team keep their peers and
those working beneath them within law and regulation and work efficiently. Corporate
governance is usually seen to be proactive therefore fighting the problems before they arise
instead of reactive which is how governments react to things. This is evident as Basel II is
announced after a crisis asking banks to keep higher reserves (10% of assets). However
Barclays and other banks are reacting to a crisis which begs the question that corporate
governance within companies needs to be stronger.
All in all the corporate governance of Barclays has been set out to follow or meet guidelines
set by the regulatory bodies prudential regulation authority (PRA) and financial conduct
authority (FCA). Board members are approved and act under the Financial Services and
Markets Act 2000 which is not the latest and drawn up years before the major financial
crisis of 2007/08 which could suggest it is dated and open to failure.
Succession planning in Barclays in set out by the board and nominations committee and
plan for the chairman and chief executive with an annual review which may be too long and
new structures could be needed for Barclays. This could be another factor as to why a
scandal such as LIBOR occurred with Barclays bank as board members may not have known
what was happening at the time. Although if Barclays bank were telling the FSA what other
banks were doing in this same period it could be argued that Barclays intentionally went

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about the LIBOR scandal and therefore the culture of Barclays affected them more than the
operational failure.
Barclays are a multinational company and the LIBOR scandal took place worldwide meaning
that many different authorities and rules were broken across the world with different ways
of dealing with this. The UK’s financial regulation is principle based meaning their guidelines
are harder to fall out of. For example a financial person must act with integrity and to the
best of their ability for the customer would be hard to find a loophole. Whereas America
have a rule based system making it a little easier to find loopholes in the system. However
America has allowed Barclays to follow the UK’s code of practice providing any significant
changes are explained. This could act as a way of lessening the barriers for Barclays to enter
America but still benefits America by having money generated in that country and other
factors such as head office may apply but job creation and tax are generated for American
governments. The HSBC tax scandal is another case to show this as Indian governments
were taking the approach of not bothering with the scandal which implies corruption (BBC,
2015). This could also be due to the fact that banks have too much power in an economy
and therefore governments fight to keep them running even when doing wrong. This could
be a positive attribute for running cultures of banks as the Co-Operative bank is the only
bank that is actively being ethical (Co-Operative, 2015).
It could be argued that this is not the jobs bank and the do not need to be the ones
responsible for supplying water or playgrounds for kids or even thinking of co2 emissions.
This is done when looking at the society as a stakeholder but as is seen with the near
collapse of the Co-Operative bank (Independent, 2014) this is very costly and the society as

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a whole seem not to care at this point and look to go for the cheapest and brand named
banks.
Independent Commission on Banking
The role of the commission is to make recommendations on internal structure of Barclays
and the banking system aiming to increase competition and maintain financial stability. This
could have impacts on the corporate governance of Barclays as changes could imply major
changes to the internal running of Barclays. For example in June 2011 banks had to separate
investment banks from consumer banks. This lead to a change in Barclays in the UK in order
to protect customers but in Africa this is not yet the case (Gov, 2015). This would further
support that Barclays are out to make money from shareholders and are not grouping
customers as high in their priority.
Code of Conduct
With Anthony Jenkins being appointed as chief executive Barclays set a code of conduct and
made all senior members of staff sign this

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Barclays Auditors
Risk Management
Risk management in Barclays would allow Barclays to avoid all major types of risk such as:
 Credit risk
 Liquidity risk
 Interest rate risk
 Foreign currency risk
The liquidity risk has been further supported as a major risk for banks by governments and
therefore the Basel II and Basel III are put in place meaning banks have to keep a certain
amount of reserves. This is also a main risk faced by Northern Rock with the bank run and
the reactive nature of governments forced this move. The FCA ask for those in higher power
to be fit and proper and therefore the compliance department is in place to comply by law

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and legislation set by UK governments. This department will be in control to help the
business achieve goals though scandals still persist so aren’t doing job correctly, which may
mean Barclays aren’t following stakeholder theory.
Balanced ScoreCard
A balanced scorecard uses KPIs as a measurement meaning that Barclays can set targets
against KPIs and could help with the corporate governance of Barclays. This would also
mean that bonus based items may be less sold but could mean that employees take more
care in the aim of Barclays. This will help Barclays to:
 Approve and monitor their strategy
 Decline/approve and edit decisions
 Evaluate members of the board, importantly the CEO – Anthony Jenkins
 Provide support for Anthony Jenkins
 Ensure compliance (aiding the compliance department)
This will allow the board to work more efficiently with the increase of their job load and
making better use of their time. The scorecard will help the board’s decision for
remuneration and succession (HBS, 2006). Barclays board may now be working more
efficiently on their tasks but this could mean working more efficiently on scandals and
hiding information a lot easier.
Cadbury Report
Cadbury report released by each organisation is important. This is because the report
contains suggestions to raise standards in corporate governance. It can be used for Barclays

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to strengthen gaps left in their governance and keep from scandals happening again
(ICAEW, 2015). These suggestions come from the financial aspect of corporate governance
and can also help for budgeting in Barclays.
PESTLE & SWOT
PESTLE and SWOT have showed that Barclays as a business understand the wider
environment while the sustainability indices show that Barclays have taken the correct steps
to ensure the long term survival. A PESTLE & SWOT analysis tells Barclays about the
implications to arise in the near future and will also alert them of their weaknesses and
could be an indicator on how to deal with this from their opportunities. A clear show of the
volatile nature of the banking industry is the political and legal field of the PESTLE which is
demonstrated by the upcoming election. At any election there is a threat, as such, for
Barclays as a new government would almost certainly lead to new legislation and reforms to
the regulatory bodies. For example the Conservative party favours the free market economy
and would rather supply and demand rule. This would mean that banks would not get bailed
out as easily as Labour have in the past done so but could also mean a lower regulatory
strength. For now regulatory changes are not as volatile as Europe regulations still need to
be followed by banks and UK government. Should UK vote, from the referendum, to leave
the EU and Conservatives come into power they may lighten up the regulations and then
our banks perhaps make more profit but as they don’t need to keep as much reserves they
may have a systemic risk and other banks in Europe may be stronger long term. Corporate
governance within Barclays should mean that they keep their own reserves but is not always
the case as is evident by many previous scandals i.e. LIBOR scandal.

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Overlap
Through the business day-to-day and the ethical side of a business there is overlap of many
different factors that Barclays would have to concern themselves with. One of these factors
is the shareholder who overlaps over how Barclays corporate governance differs when
keeping shareholders in mind and even the culture of Barclays making them always want to
increase shareholder wealth. It could be argued that gaps leading to the LIBOR scandal were
purposely there due to the culture of Barclays to always make money for the wealth of
shareholders. There is no clear evidence for this, although the fact that Barclays alerted the
FSA of what other banks were doing could be inkling toward making this assumption.
Shareholders are now much more aware and block shareholders take much more of an
interest as to why ‘big bosses’ are getting ‘big bonuses’ and high salaries which overlaps the
remuneration packages received by the CEO and the kind.
Recommendations and Changes
British Bankers Association has foreseen that it would transfer the regulation of LIBOR to
the UK regulators. Wheatley, CEO-designate of FCA, recommends that the Tender
Committee (independent organisation with government regulator representatives) should
manage the process of setting LIBOR rates to make it more transparent and accountable.
This should mean that the LIBOR will be highly regulated and another scandal of such should
not occur again. However this is if there is no corruption, no incentives for those in higher
positions to act immorally and if the ethical morals are clearly laid out. It is recommended
that banks report on their LIBOR submissions but after every three months as to not

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become a measure of banks credit worthiness. Criminal Sanctions should also be warranted
from such acts as the LIBOR scandal as to deter from this happening again.
Strengthening their compliance department by changing culture at Barclays and becoming
more ethical should be a concern for Barclays to ensure that they are not involved in
scandals of this nature in the future. Firstly to identify gaps or weaknesses in Barclays
model, such as the information asymmetry between heads of practice and floor workers. It
could even be for the bonus system offered to incentive staff to sell more of a particular
product whether it’s good for customers or not. Once this has been identified the corporate
governance system will be in charge of new strategies and pushing a business model
through the system. The compliance department will ensure that this is being acted upon
correctly meaning Barclays can strength their business. A greater use of Mendelow’s
stakeholder mapping will enable Barclays to group stakeholders and therefore make a
business model catering towards those of high power and high interest although these may
change and will need to be monitored.
Cooley argues that central banks should be responsible for monitors the integrity of rates
and although the New York Federal Reserve suggested recommendations to the Bank of
England it never followed it up which is negatives on both countries central banks. This
could be a lack of effort or time and would need to be properly dealt with and if not the
followed up before the outcome of a crisis. Although both countries had knowledge of
LIBORS weaknesses it was never acted upon which begs for a corporate governance change
in central banks. This would mean governments need to be stricter. However stricter
banking regulations may not always lead to safer banking sector as new loopholes and
creative ideas to find ways round will be found. Either this or nobody will want to work in

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this sector acting as a barrier to entry and lowering profits making it harder for banks to
compete or survive.
Changes that have lead from this in the Basel II have led to the Basel III to further improve
the banks’ ability to cope with financial crisis. Basel III also aims to (Bank for International
Settlement, 2015):
 Improve governance in Barclays and risk management
 Improve the transparency of banks
 Improve the bounce back ability of banks in periods of stress
 Help to overcome systematic risk
Conclusion
This report has identified Barclays corporate governance changes in light of globalisation
and regulatory changes such as a new board and CEO and moving trade and investment into
Africa. It’s also discussed the gaps in corporate governance and asked questioned that imply
Barclays have purposely left gaps for such scandals to happen. A new Basel accord and
MiFID will strengthen corporate governance internally by making it law for Barclays.

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