Political contributions

A transparent and controlled policy

We have a clear policy and compliance procedures on political dcontributions, set out in our Group-wide Standards of Business Conduct. Contributions from our companies to political parties and organisations, their officers, elected politicians and candidates for elective office are actively discouraged, and may only be made subject to specific controls.

Contributions are not permitted to be made in order to achieve any improper business or other advantage or to influence any decision by a public official to the advantage of the Group or any Group company. In addition, they must not be intended personally to benefit the recipient or his or her family, friends, associates or acquaintances and must be permissible under all applicable laws.

Controls on political contributions

Any donation must be authorised by the board of the company making it, must be fully documented in the company’s books and, if required by local law, must be put on the public record.

Details must be notified in writing each year to the Company Secretary of British American Tobacco p.l.c. and these are monitored by the Board Audit Committee. Donations to political organisations and political expenditure within the European Union may only be made out of funds previously authorised by shareholders at a General Meeting.

Although neither the Company nor its subsidiaries have any current intention of making political donations to political parties in the EU or incurring EU political expenditure, it remains possible that circumstances may arise in which it would be in the interests of the Company or its subsidiaries to do so, or where expenditure may be categorised as such. We therefore seek an annual authority to make such donations (up to £100,000 in aggregate) at our Annual General Meeting.

Group companies must return a certificate to the Company Secretary each year stating either that no payment has been made or giving details where a payment has taken place. These results are reported annually to the Audit Committee of British American Tobacco p.l.c., with an interim report to the Committee at the half year in respect of those countries where payments were reported or made in the preceding year.

Political contributions by Group companies in 2017

The total amount of political contributions made to non-EU political parties in 2017 was £4,832,321 (2016: £20,208) as follows:

Reynolds American Inc. (RAI) Companies reported political contributions totalling £4,826,416 (US$6,221,250) for the full year 2017 to US political organisations, non-federal-level political party committees and to campaign committees of various non-federal candidates, in accordance with their contributions programme established prior to the acquisition of RAI by the Group. No corporate contributions were made to federal candidates or political party committees and all contributions were made in accordance with applicable laws.

All political contributions made by RAI Companies are assessed and approved in accordance with RAI’s policies and procedures to ensure appropriate oversight and compliance with applicable laws.

In accordance with the US Federal Election Campaign Act, RAI Companies continue to support an employee-operated Political Action Committee (PAC), a non-partisan committee registered with the US Federal Election Commission that facilitates voluntary political donations by eligible employees of RAI Companies. According to US federal finance laws, the PAC is a separate segregated fund and is controlled by a governing board of individual employee-members of the PAC. In 2017, RAI Companies incurred expenses, as authorised by US law, in providing administrative support to the PAC.

Carreras Limited reported a contribution to the Jamaica Labour Party of £5,905 in 2017.

No other political contributions were reported.