We require all staff to act with high standards of business integrity
Conducting our business with honesty, integrity and transparency is not only the right thing to do, but is also critical to the continuing development of a business that is responsible, successful and sustainable in the long term.
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, the Standards of Business Conduct apply those values and principles to specific situations which may arise in our day-to-day business life.
The Standards require all staff to act with high standards of business integrity, to comply with all laws and regulations wherever our companies operate and to ensure that our business standards are never compromised for the sake of results.
They also set out the Group policy, and provide guidance and support to staff, in the following specific areas:
- Conflicts of interest
- Bribery and corruption
- Entertainment and gifts
- Political contributions
- Charitable contributions
- Accurate accounting and record-keeping
- Protection of corporate assets
- Confidentiality and information security
- Insider dealing and market abuse
- Competition and anti-trust laws
- Money laundering and anti-terrorism
- Trade in the Group’s products
Standards of Business Conduct: September 2011 (764 kb)
The Standards of Business Conduct have been in place for many years and continue to be kept under review to ensure that they remain at the forefront of best business practice. Every Group company and every employee worldwide is expected to live up to them and guidance on them is communicated regularly throughout the Group, including through training and awareness programmes.
No manager has the authority to order or approve any action contrary to the Standards and violation of them is a disciplinary matter and may, where appropriate, result in dismissal.
While the Standards have been written for British American Tobacco Group companies and their employees, we are happy to publish them externally to continue promoting dialogue between our companies and their stakeholders on good corporate conduct.
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:
- They do not directly or indirectly offer, promise or give any gift, payment or other benefit to any person for the purpose of inducing or rewarding improper conduct or influencing any decision by a public official to the advantage of the Group or any Group company;
- They do not directly or indirectly solicit, accept or receive any gift, payment or other advantage from any person as a reward or inducement for improper conduct; and
- Their activities do not otherwise contravene any applicable anti-corruption measures.
Our Standards of Business Conduct were updated in September 2011 to ensure that the Group's policies and procedures remain at the forefront of best practice and to ensure alignment with the provisions of the UK Bribery Act 2010.
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 reporting procedures
The Group’s whistleblowing policy enables staff, in confidence, to raise concerns about possible improprieties in financial and other matters and to do so without fear of reprisal, provided that such concerns are not raised in bad faith. Details of this policy are set out in the Company’s Standards of Business Conduct. The policy is supplemented by local procedures throughout the Group and in the Group’s London headquarters, which provide staff with additional guidance and enable them to report matters in a language with which they are comfortable.
The Audit Committee receives regular reports on whistleblowing incidents. It remains satisfied that the policy and the procedures in place incorporate arrangements for the proportionate and independent investigation of matters raised and for the appropriate follow-up action.
All Group companies have adopted our Standards of Business Conduct or local policies embodying them. Senior managers in the Group must report annually on compliance with the Standards with regard to all employees in the company or department for which they are responsible. 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