Standards of Business Conduct

Our Standards of Business Conduct express the high standards of business integrity that we require from our employees worldwide. As such, they play a key role in the British American Tobacco Group strategy. Together with our Statement of Business Principles, our Standards of Business Conduct underpin our commitment to high standards of corporate behaviour. While the Statement of Business Principles sets out our beliefs and values as an organisation, our Standards of Business Conduct provide guidance on workplace situations, based on those values and principles. Our Standards of Business Conduct have been in place for many years and are kept under review to ensure they remain at the forefront of best business practice. Every Group company and all staff worldwide are expected to live up to them and to ensure our business standards are never compromised for the sake of results.

Regularly reviewed and updated

In 2019 we included a new policy on lobbying and engagement, as well as a new policy area on tax evasion to reflect the Group’s legal obligations under the UK Criminal Finances Act. We also made further updates to a number of key global polices, to keep pace with regulatory developments and reflect areas identified for improvement following external benchmarking. The amendments include:

• 1. Guidance to line managers as key role models of the SoBC;
• 2. Replacing ‘whistleblowing’ with ‘Speak Up’ so that the policy becomes the Group Speak Up policy, because ‘whistleblowing’ can have negative connotations and it is crucial that people Speak Up and raise concerns if they feel something isn’t right;
• 3. Adding harassment and discrimination to the list of wrongdoings to highlight that any such allegations will be treated seriously and investigated as potential breaches of the SoBC (see the Speak Up policy);
• 4. Extending guidance to prevent facilitation of tax evasion, reflecting the requirements of legislation in the UK (the Criminal Finances Act. See the Anti-Money Laundering and Tax Evasion policy);
• 5. Making amendments to highlight our support and commitment to comply with the ILO’s Declaration on Fundamental Principles and Rights at Work and the UK Modern Slavery Act (see Respect in the Workplace and Human Rights in Our Operations policies);
• 6. Making improvements to reflect increasing focus on data privacy across the world (see Data Privacy, Confidentiality and Information Security policy);
• 7. Clarifying the Conflicts of Interest policy;
• 8. Revising the gifts and entertainment approvals process and spend thresholds (see Gifts & Entertainment policy).

We have also introduced an SoBC Assurance Procedure, which complements our SoBC by setting out in more detail how allegations of wrongdoing or breach of the SoBC should be followed up to ensure that they are dealt with fairly and objectively.

What our Standards cover

Our Standards of Business Conduct set out the Group policy, and provide guidance to staff, in the following specific areas:

•  1. Speak Up
•  2. Conflicts of interest
•  3. Anti-bribery and corruption
•  4. Gifts and entertainment
•  5. Respect in the workplace
•  6. Human rights and our operations
•  7. Lobbying and engagement
•  8. Political contributions
•  9. Charitable contributions
•  10. Accurate accounting and record-keeping
•  11. Protection of corporate assets
•  12. Data privacy, confidentiality and information security
•  13. Insider dealing and market abuse
•  14. Competition and anti-trust
•  15. Anti-money laundering and tax evasion
•  16. Anti-illicit trade in the Group’s products
•  17. Sanctions.

Standards of Business Conduct 2020 (2.0 mb)  Our Standards of Business Conduct are also available in 13 languages, other than English.

Anti-bribery and corruption policy

Corruption causes distortion in markets and harms economic, social and political development, particularly in developing countries. Our Standards of Business Conduct make clear that it is wholly unacceptable for our companies and employees to be involved or implicated in any way in corrupt practices. It is our policy that Group companies and their employees must ensure that:

• 1. They do not offer, promise or give any gift, payment or other benefit to any person (directly or indirectly), to induce or reward improper conduct or directly or indirectly influence any decision by any person to our advantage;
• 2. They do not solicit, accept, agree to accept or receive any gift, payment or other advantage from any person (directly or indirectly) as a reward or inducement for improper conduct or which influences, or gives the impression that it is intended to influence, decisions of the Group; and
• 3. Their activities do not otherwise contravene any applicable anti-corruption measures.

Each Group company is required to maintain, as part of its books of account, a register of political donations, gifts, charitable contributions and non-commercial sponsorships made by or on behalf of the company. Agents, consultants and other third parties engaged on behalf of any Group company are expected to apply standards of business conduct consistent with our Standards.

Confidential Speak Up procedures

The Group’s Speak Up policy contained within our Standards enables staff to speak up and raise concerns, in confidence, about possible wrongdoing or breaches of our Standards, and to do so without fear of reprisal.

Raising concerns and reporting

Staff can raise concerns with their line manager, HR or one of the Group’s Designated Officers. Alternatively, they can use our confidential, independently managed external Speak Up channels via telephone or online. Our Speak Up channels are available 24 hours a day in local languages and are highlighted in our internal trainings and communications. [Our business partners are also welcome to report their concerns and can do so via our Speak Up portal, the details of which are available to suppliers.] The Audit Committee receives regular reports on whistleblowing, and remains satisfied that the policy and procedures in place incorporate arrangements for the proportionate and independent investigation of matters raised and for the appropriate follow-up action. The link to our Speak Up whistleblowing portal is available below: www.bat.com/speakup 

Compliance

All Group companies have adopted our Standards of Business Conduct or local policies embodying them. Information on compliance with the Standards is gathered at a global level and reported quarterly to the Audit Committee. For more information, including compliance figures, see Our Standards of Business Conduct compliance.