Barclays PLC

On November 1, 2021, Barclays disclosed that its Group Chief Executive, James E. “Jes” Staley, would be departing the Company, stating that “the preliminary conclusions from the FCA and the PRA of their investigation into Mr[.] Staley's characterisation to Barclays of his relationship with the late Mr[.] Jeffrey Epstein and the subsequent description of that relationship in Barclays’ response to the FCA” and “Mr[.] Staley’s intention to contest” those conclusions led to the mutual decision of his departure. On this news, Barclays’ stock price fell $0.25, or 2.2%, to close at $10.93 per ADR on November 2, 2021.

 Then, on November 12, 2021, the Financial Times reported that Staley had “exchanged 1,200 emails with Jeffrey Epstein over a four-year period” with “unexplained phrases”. On this news, Barclays’ stock price fell $0.05, or 0.5% to close at $10.62 on November 12, 2021.

 Then, on March 8, 2023, JPMorgan Chase Bank filed a third-party complaint against Staley for indemnity, contribution, breach of fiduciary duty, and breach of the faithless servant doctrine, alleging that “Staley knew without any doubt that Epstein was trafficking and abusing girls” and that he “personally spent time with young girls whom he met through Epstein on several occasions”; “personally visited young girls at Epstein’s apartments located at 301 East 66th Street”; “personally observed Epstein around young girls”; and personally observed “Epstein sexually grab young women in front of him.” On this news, Barclays’ stock price fell $0.29, or 3.4%, to close at $7.77 on March 9, 2023.

 Then, on October 12, 2023, the FCA announced that it had decided to fine Staley £1.8 million and “ban him from holding a senior management or significant influence function in the financial services industry” after finding that he “recklessly approved a letter sent by Barclays to the FCA, which contained two misleading statements, about the nature of his relationship with Jeffrey Epstein and the point of their last contact.” Specifically, “[t]he letter claimed that Mr[.] Staley did not have a close relationship with Mr[.] Epstein. In reality, in emails between the two Mr[.] Staley described Mr[.] Epstein as one of his 'deepest' and 'most cherished' friends.” On this news, Barclays’ stock price fell $0.39, or 5%, to close at $7.43 per ADR on October 12, 2023, thereby injuring investors further.

The complaint filed in this class action alleges that throughout the Class Period, Defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts about the Company’s business, operations, and prospects. Specifically, Defendants failed to disclose to investors that: (1) Contrary to his false public assertions, Jes Staley had a close relationship with Jeffrey Epstein; (2) Staley was reportedly aware of Jeffrey Epstein’s criminal activities and may have even sexually assaulted a victim who had previously been trafficked by Jeffrey Epstein; (3) Staley’s close, personal relationship with Jeffrey Epstein, and potential criminal activity, if discovered, could bring reputational, legal, and financial harm to Barclays; (4) as a result, Barclays response to the FCA’s inquiry regarding Staley’s relationship with Epstein was materially false; (5) Barclays, having become aware of information contradicting its response to the FCA’s inquiry, then failed to update the response so that it would be accurate, or otherwise take any meaningful action; and (6) as a result, Defendants’ positive statements about the Company’s business, operations, and prospects were materially misleading and/or lacked a reasonable basis at all relevant times.