Environmental performance

EN1 Materials used by weight or volume

Partially reported

  2013
 metric tonnes
2014
metric tonnes
2015
metric tonnes
2016
metric tonnes

2015/16 % change

Tobacco leaf 863,275 1,046,667 822,791 773,295 -6.02%
Direct materials
 (cigarette paper, wrapping, packaging, filters, glues, inks, plug wraps)
420,786 428,952 424,802 468,072 10.19%
Indirect materials
 (parts, cleaning materials, etc)
36,345 56,119 46,039 35,862 -22.11%
Total 1,320,407 1,531,738 1,293,632 1,277,229 -1.27%
Per million cigarettes equivalent 1.16 1.37 1.16 1.19 2.59%

In 2016, the Group’s total use of materials remained relatively stable compared to 2015 having decreased by 16,403 tonnes (-1.27%). This slight decrease was driven primarily by a reduction in the use of indirect materials and a decrease in tobacco leaf consumption (related to a reduction in production volume in some markets) only partially offset by an increase in direct materials driven by new products features (e.g. new filter types).

Leaf tonnage includes both unprocessed tonnage entering processing and processed leaf entering factories. The leaf tonnage measured for environmental reporting purposes is typically higher than tonnage used to manufacture product.

EN2 Percentage of materials used that are recycled input materials

Fully reported

The percentage of materials used which were reported as from recycled input materials decreased from 0.96% in 2015 to 0.47% in 2016 in line with manufacturing waste reduction initiatives. The recycled material used in cigarette production is mainly reconstituted tobacco created as a by-product of the manufacturing process. The percentage of recycled material used has decreased because manufacturing waste initiatives have caused less tobacco waste to be available for recycling.

EN3 Energy consumption within the organisation

Fully reported

  2013
gigajoules
2014
 gigajoules
2015
gigajoules
2016
gigajoules
2015/16 % change
Non-renewable energy consumed 8,602,218 8,929,008 8,712,306 7,032,708 -19.28%
Renewable energy consumed* 670,439 623,569 614,016 882,330 43.70%
Total 9,272,657 9,552,577 9,326,322 7,915,037 -15.13%
Per million cigarettes equivalent 8.15 8.53 8.38 7.73 -7.80%

* Sites and Offices

Direct energy consumption in the organisation includes the primary energy used (e.g. natural gas for heating and fuel for our own or leased fleet) and electricity and steam consumption by Group companies (WBCSD scopes 1 and 2).

Overall, our direct energy consumption reduced by 15.13% in 2016, primarily driven by factory footprint consolidation, a reduction in leaf volumes processed at our Green Leaf Threshing plants, and a continued focus on energy efficiency, alongside a fall in production volumes.

EN4 Energy consumption outside of the organisation

Fully reported

  2013
 gigajoules
2014
 gigajoules
2015
gigajoules
2016
gigajoules
2015/16 % change
Total 2,443,354 2,575,289 2,138,340 2,351,797 9.98%
Per million cigarettes equivalent 2.15 2.30 1.92 2.20 14.41%

The most relevant and material energy consumption outside the organization is associated with staff business travel and third party distribution (WBCSD scope 3).

Energy consumption outside of the organisation increased by 9.98% in 2016. This was mainly due to an increased amount of freight, as well as distances travelled following site closures and increased sales distribution. For example, there were three cigarette factory closures in Brazil. We are also now capturing more precise data on these areas from our supply chain network.

EN5 Energy intensity

Fully reported

We calculate energy intensity using the normalised output figure ‘cigarettes equivalent produced’. This includes manufacturing of tobacco products and materials, and green leaf threshing.

  2007
 baseline
2013
 gigajoules
2014
 gigajoules
2015
gigajoules
2016
gigajoules
2015/16 % change
Per million cigarettes equivalent 11.82 10.28 10.26 9.75 9.92 1.74%

Our new target to achieve by 2025 is to reduce energy use by 25% from our year 2007 baseline to 9.17 gigajoules per million cigarettes equivalent.

In 2016, energy intensity remained relatively steady compared to 2015 with a small 1.7% increase, despite changes in our footprint and a fall in production volumes.

Against our 2007 baseline, we have achieved a total reduction of 16%.

Examples of initiatives in our manufacturing operations include investing in energy-efficient technologies, switching to less carbon-intensive fuels or renewable energy sourcing. Currently, 8% of our Group energy use is from renewable sources and we now have a new target to increase this to 25% by 2025 (against year 2007 baseline).

We’re also optimising our logistics and fleet with standards for fuel efficiency, engine size and emissions, as well as increasing load capacity to reduce the number of journeys.

EN8 Total water withdrawal by source

Partially reported

  2013
cubic metres
2014
cubic metres
2015
cubic metres
2016
cubic metres
2015/16
% change
Total 4,209,080 4,134,817 3,959,902 3,667,979 -7.37%
Per million cigarettes equivalent 3.70 3.69 3.56 3.43 -3.77%

Our new target to achieve by 2025 is to reduce the total amount of water withdrawn by 35% from our year 2007 baseline (based on our intensity measure per million cigarettes equivalent). By the end of 2016, we had made significant progress with a 29% reduction from baseline.

In 2016, total water withdrawn decreased by 291,923 cubic metres, a 7.37% reduction in absolute terms. In intensity terms, we achieved a 3.77% reduction compared to 2015.

This reduction was primarily due to a planned reduction in green tobacco leaf processing in 2016 but there were further reductions as a result of temporary site closures in South America caused by the El Nino weather phenomenon.

Further reductions were achieved as a result of water initiatives at our manufacturing and commercial sites, including enhanced metering systems enabling faster response times to address leaks, and investing in further re-use of potable water whenever possible (e.g. such as in flushing, gardening, car washing, etc.).

Our manufacturing processes don’t use as much water as other industries but, with the realities of water scarcity increasingly being felt in many parts of the world, we have conducted water risk assessments at all our strategic, high-risk sites. Action plans are in place and we are now rolling this out to all our factories worldwide.

EN9 Water sources significantly affected by withdrawal of water

Not reported – information not collated at Group-level

EN10 Percentage and total volume of water recycled and reused

Fully reported

  2013
 cubic metres
2014
cubic metres
2015
cubic metres
2016
cubic metres
2015/16
% change
Total 312,641 328,255 351,218 419,899 19.55%
% of water withdrawn 7.4% 7.9% 8.9% 11.4% 29.07%

Total volume of water recycled and reused increased in 2016 by 19.5%. This was primarily driven by a continued focus on recycling water on-site and therefore a reduction of total water withdrawn.

EN11 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas

Partially reported

British American Tobacco does not own, lease or directly manage land for the growing of tobacco that is in, or adjacent to, protected areas and areas of high biodiversity outside protected areas.

However, although we don’t own any tobacco farms, we do have direct relationships with more than 90,000 contracted farmers. Using the biodiversity risk and opportunity assessment (BROA) tool we identified tobacco growing areas where our directly contracted farmers are near protected areas and areas of high biodiversity value outside protected areas.

Through our first round of BROAs (completed in 2010), we identified such areas in Chile, China, Kenya, Mexico, Peru, Uganda and Uzbekistan. In a few cases, biodiversity risks were identified, and action plans were put in place, including awareness-raising with farmers.

A second round of BROAs was completed in 2015 where we have identified some biodiversity risks related to soil management, water use, and wood use; in Cambodia, China, Kenya, Nigeria and Brazil. All our leaf companies have BROA action and monitoring plans in place to help address and manage identified biodiversity risks and opportunities.

EN12 Description of significant impacts of activities, products and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas

Fully reported

In 2006, we co-developed a biodiversity risk and opportunity assessment (BROA) tool which we use to identify potential issues and impacts in tobacco farming landscapes, before working with other stakeholders to find solutions.

Using the BROA tool, we conducted assessments in 100% of our leaf growing operations, which were all completed by the end of 2010. In 2012, we rolled out an updated version of the BROA tool to all our leaf growing operations. The second round of assessments, using the updated tool, was completed in all our leaf operations, by the end of 2015.

The biodiversity risks assessed in these landscapes – in relation to our business activities, products and services – include community dependence on natural forests for subsistence and wood fuel, unsustainable sourcing of native forest as a curing fuel for tobacco and loss of buffer vegetation along water bodies. The impacts are not necessarily exclusive to tobacco production or British American Tobacco directly contracted farmers, but the BROA highlighted the need for us to work with others to address wider dependency issues on biodiversity and ecosystem services within agricultural landscapes.

We are monitoring and addressing the impacts in these landscapes – first, by aiming to ensure that directly contracted farmers adopt and improve sustainable practices and second, by working with other stakeholders to address unsustainable practices.

The BROA tool has been recognised by the UN Food and Agriculture Organisation and World Business Council for Sustainable Development, and as an approach that is comprehensive enough to be used by any organisation operating in an agricultural landscape. That’s why in 2012 we made BROA freely available to be applied outside the tobacco sector.

During 2014 the first examples of BROA being used in the non-tobacco sector were seen in India and Bolivia. At the beginning of 2016 we transferred ownership of the BROA tool to our former NGO partners more information about the BROA tool is available at www.businessandbiodiversity.org .

In 2016, we continued to work towards our target of eliminating unsustainable sources of wood used by contracted farmers’ in their curing activities, with 99% coming from sustainable sources. See wood fuel sources data for more information.

EN13 Habitats protected or restored

Partially reported

British American Tobacco does not own, lease or directly manage land for the growing of tobacco.

However, although we don’t own any tobacco farms, we do have direct relationships with more than 90,000 contracted farmers. Through the former BAT Biodiversity Partnership  and local collaborations, in 2016 habitat restoration and associated research took place in Brazil, Bangladesh, Pakistan and Sri Lanka.

EN15 Direct greenhouse gas (GHG) emissions (scope 1)

Fully reported

  2013
 metric tonnes
2014
metric tonnes
2015
metric tonnes
2016
metric tonnes
2015/16 % change
Direct CO2 WBCSD 1 358,658 342,385 330,495 311,172 -5.85%
Per million cigarettes equivalent 0.32 0.31 0.30 0.29 -3.12%

Our scope 1 reporting includes: energy consumed at our factories and offices (coal, natural gas, wood, diesel and LPG) and fuel consumed by our fleet vehicles. You can read more about this in our data scope page.

Direct greenhouse gas (GHG) emissions (scope1) have decreased by 5.85% in absolute terms and 3.12% in intensity terms during 2016. This reduction was driven by lower volumes processed by our green leaf threshing plants, changes to our factory footprint and energy efficiency initiatives at our manufacturing sites.

EN16 Energy indirect greenhouse gas (GHG) emissions (scope 2)

Fully reported

  2013
 metric tonnes
2014
metric tonnes
2015
metric tonnes
2016
metric tonnes
2015/16 % change
Total direct CO2 WBCSD 2 390,242 370,724 363,501 374,976 3.16%
Per million cigarettes equivalent 0.34 0.33 0.33 0.35 6.13%

Our scope 2 reporting includes: electricity purchased and consumed at our factories and offices, purchased steam and hot water. You can read more about this in our data scope page.

In 2016, our scope 2 emissions increased by 3.16% (in absolute terms) and 6.13% (in intensity terms) primarily driven by changes in the energy matrix of some markets (e.g. countries where electricity was typically generated from hydropower plants and where thermal plants have provided more power to the local grid) and by the application of updated conversion factors with regards to electricity in our new environmental management system.

EN17 Other indirect greenhouse gas (GHG) emissions (scope 3)

Fully reported

  2013
 metric tonnes
2014
metric tonnes
2015
metric tonnes
2016
metric tonnes
2015/16 % change
Total indirect CO2 WBCSD 3 209,567 212,018 182,343 176,015 -3.47%
Per million cigarettes equivalent 0.18 0.19 0.16 0.16 2.75%

Our scope 3 reporting includes the most relevant and material areas of: freight (transport-related activities in vehicles not owned or controlled by the business), waste disposal, and business travel. You can read more about this in our data scope page.

In 2016, scope 3 emissions decreased by 3.47% (in absolute terms) and 2.75% (in intensity terms). This was primarily driven by freight optimisation initiatives and a reduction in business travel.

EN18 Greenhouse gas (GHG) emissions intensity

Fully reported

  2000
 baseline
2013
 tonnes
2014
 tonnes
2015
tonnes
2016
tonnes
2015/16 % change
Per million cigarettes equivalent 1.52 0.85 0.84 0.79 0.81 2.5%

Our long-term targets are to cut carbon dioxide equivalents (CO2e) emissions by 55% by 2025 and by 80% by 2050 from our year 2000 baseline (based on our intensity measure per million cigarettes equivalent).

In 2016, CO2e intensity remained relatively steady compared to 2015, with a small 0.6% increase. This was despite footprint changes, such as closures of operations in countries with a less intensive energy mix and opening of new sites with a greater reliance on fossil fuels, alongside a fall in production volumes.

Against our 2000 baseline, we have made significant progress with a 47% reduction.

In 2016, we developed a new set of environmental targets to achieve by 2025, including a new target to increase the amount of renewable energy we source to 25% (against year 2007 baseline). Currently, 8% of our Group energy use is from renewable sources.

We believe this focus on increasing the ratio of renewable energy will naturally contribute towards achieving further CO2e reductions against our long-term targets.

For details of what is included in this metric, see our data scope page.

EN19 Reduction of greenhouse gas (GHG) emissions

Not reported – information not collated at Group-level

We do not currently collect data on the amount of GHG emissions reduced as a direct result of initiatives; however, we’re a global company, which means we have a global footprint. Reducing the environmental impacts of what we do is a key priority, and something that involves every single person who works for us.

We have had a comprehensive Environmental, Health & Safety (EHS) management system for many years. We monitor and reduce our direct environmental impacts by making our operations more efficient. We also seek to address our indirect impacts by choosing suppliers with strong environmental credentials and encouraging our existing suppliers to improve their environmental performance.

To assess our environmental efficiency, we have set targets relative to the volume of cigarettes we produce, and we report our progress against these (see relevant indicators in this section and the environment page).

EN20 Emissions of ozone-depleting substances (ODS)

Not reported – information not collated at Group-level

EN21 NOx, SOx, and other significant air emissions

Not reported – information not collated at Group-level

EN22 Total water discharge by quality and destination

Fully reported

  2013
 cubic metres
2014
cubic metres
2015
cubic metres
2016
cubic metres
2015/16 % change
Total water withdrawn 4,209,080 4,134,817 3,959,902 3,667,979 -7.37%
Total waste water discharged by Group companies 2,075,380 2,072,126 1,967,234 2,156,265 9.61%
Per million cigarettes equivalent 1.82 1.85 1.77 2.01 13.78%
Process and sewage waste water 2,093,493 2,090,962 1,957,757 2,108,443 7.70%
Total water consumption 2,133,700 2,062,690 1,992,668 1,511,714 -24.14%

In 2016, total water withdrawn decreased by 291,923 cubic metres, a 7.37% reduction in absolute terms, while total water consumption decreased by 24.14%. These metrics are heavily influenced by the volume of green leaf processed annually. This reduction was primarily due to a planned reduction in green tobacco leaf processing in 2016 but there were further reductions as a result of temporary site closures in South America caused by the El Nino weather phenomenon. Water consumption is expected to rise in these sites in 2017 with increased processing, we will therefore focus on improving water reuse.

Further reductions were achieved as a result of water initiatives at our manufacturing and commercial sites, including enhanced metering systems enabling faster response times to address leaks, and investing in further re-use of potable water whenever possible (e.g. such as in flushing, gardening, car washing, etc.).

Process and sewage waste water increased in 2016 vs 2015 by 7.7%, mainly due to changes in our footprint (closure of sites with good water recycling and acquisition of sites with a different profile). As new sites become integrated into the business and adopt our Group Water Roadmap tool, as well as green leaf processing plants returning to normal operating conditions (following El Nino), we expect to see water reuse increase and lower levels of waste water discharged.

Within our industry, unplanned discharges of water are unusual. We track reports of unplanned water discharge by our companies and will report on any incidents where there has been a breach of local regulation.

Our new target to achieve by 2025 is to reduce the total amount of water withdrawn by 35% from our year 2007 baseline (based on our intensity measure per million cigarettes equivalent). By the end of 2016, we had made significant progress with a 29% reduction from baseline. We also have a new target to increase the total amount of water we recycle to 15% by 2025 (against our year 2000 baseline).

EN23 Total weight of waste by type and disposal method

Fully reported

  2013
 metric tonnes
2014
metric tonnes
2015
metric tonnes
2016
metric tonnes
2015/16 % change
Non-hazardous waste sent to landfills 13,915 9,088 8,931 8,857 -0.83%
Non-hazardous waste recycled 113,798 116,558 119,997 119,847 -0.13%
Non-hazardous waste incinerated 237 132 211 586 177.50%
Other non-hazardous waste 7 2 1 0 -100.00%
Hazardous waste sent to approved landfills 175 159 184 70 -61.97%
Hazardous waste recycled 1,888 1,558 1,496 1,125 -24.83%
Hazardous waste incinerated 25 20 68 51 -24.35%
Other hazardous waste 17 20 20 39 96.21%
Total 130,060 127,537 130,908 130,575 -0.25%
Per million cigarettes equivalent 0.11 0.11 0.12 0.12 4.81%

In 2016 total waste generated remained relatively stable with a small 0.25% reduction, despite the incorporation of new sites with recycling rates below our Group average. We also generated less hazardous waste in 2016 compared to 2015.

We approach waste as another raw material and we recycle or reuse it within our business or that of others. In 2016, 92.6% of Group waste was recycled.

The percentage of materials used which were reported as from recycled input materials decreased from 0.96% in 2015 to 0.47% in 2016 in line with manufacturing waste reduction initiatives. The recycled material used in cigarette production is mainly reconstituted tobacco created as a by-product of the manufacturing process. The percentage of recycled material used has decreased because manufacturing waste initiatives have caused less tobacco waste to be available for recycling.

In 2016, Group waste to landfill decreased by 2% in absolute terms compared to 2015 (8,927 vs 9,115 tonnes), primarily due to a fall in production volumes. However, in intensity terms, our performance has remained steady at 0.008 tonnes per million cigarettes equivalent.

Our new targets, to achieve by 2025, are to reduce our waste to landfill intensity by 80% and reduce the total volume of waste generated by 10% from our year 2007 baselines (based on our intensity measure per million cigarettes equivalent). We also have a target to recycle at least 95% of our total waste generated each year.

Please note: This metric does not currently include waste data for a small number of sites where the waste is incinerated on site without energy recovery due to recycling and landfill facilities being unavailable. In these areas we continue to engage with local regulators to identify the most effective waste management solution.

EN24 Total number and volume of significant spills

Not reported – information not collated at Group-level

EN25 Weight of transported, imported, exported, or treated waste deemed hazardous under the terms of the Basel Convention Annex I, II, III, and VIII, and percentage of transported waste shipped internationally

Not reported – information not collated at Group-level

EN26 Identity, size, protected status and biodiversity value of water bodies and related habitats significantly affected by the reporting organisation’s discharges of water and runoff

Not reported – information not collated at Group-level

EN27 Extent of impact mitigation of environmental impacts of products and services

Not reported – information not collated at Group-level

While in-use, the main environmental impact of our core product range is second-hand smoke for which we are unable to provide data. We talk about the end-use environmental impact of our products below in EN28.

We support regulation that accommodates the interests of both non-smokers and smokers and limits non-smokers’ involuntary exposure to second-hand smoke.

We favour restrictions on smoking in enclosed public places. We believe that governments, employers, the hospitality industry, the tobacco industry, consumers and others can work together on practical initiatives. These include providing separate smoking and non-smoking areas and ventilation to reduce involuntary exposure to second-hand smoke.

Air filtration systems can also make a room more comfortable. Although they cannot completely remove the smoke, they do offer a relatively inexpensive alternative where built-in fresh air ventilation systems are less feasible, perhaps because of the size and complexity of a building.

EN28 Percentage of products sold and their packaging materials that are reclaimed by category

Partially reported

The main environmental impact of our core product at end of use is cigarette butt littering.

For over 25 years we’ve researched the degradability of our cigarette filter tips to test for breakdown depending on the physical environment, e.g. on concrete, in water, in soil. Our current research shows that some constituents of our filters, such as papers, can degrade over a month to three-year time-period, in certain environments. However, for other constituents in our filters, for example polymers or glues, research is inconclusive and requires further ecotoxicity and degradation testing. Therefore, our current conclusion is we know of no practical way of making consumer acceptable filters that would degrade over a duration that would not cause short-term littering problems.

We continue to explore further research, including collaborating with the industry and other partners on agreed standards for degradability and ecotoxicity testing and risks of filters to the environment. 

To address cigarette butt littering, our companies in Canada and Switzerland have initiatives in partnership with TerraCycle. Founded in 2001, TerraCycle  is a global leader in the collection and further treatment of previously non-recyclable materials, including cigarette butts.

Additionally, our companies in Australia, Germany, Japan, the Netherlands, New Zealand and the UK ran butt littering campaigns in 2016. This included working with a variety of stakeholders on activities such as butt littering communications campaigns, promoting the use of portable ashtrays and the production of marketing material designed to support bins replacement/cleaning and new cleaning machines.

We are also exploring ways to reduce the environmental impact of our packaging. For example, some of our brands are sold in packs that use no cellophane or are made from recyclable paper.

For our Vapour Products (e-cigarettes) that we sell within the EU, we follow the Waste Electrical and Electronic Equipment Regulations (the WEEE Regulations) and encourage consumers to recycle e-cigarettes by providing postal recycling services and product incentives.

EN29 Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with environmental laws and regulations

Fully reported

In 2016, there were no reported incidents of environmental non-compliance.

EN32 Percentage of new suppliers that were screened using environmental criteria

Fully reported

All our new and existing first-tier leaf and direct materials suppliers are screened using environmental criteria as part of our supplier programmes.

We conduct due diligence on our tobacco leaf supply chain through the Sustainable Tobacco Programme  (STP), which assesses and monitors suppliers’ performance in meeting industry-wide standards, including key environmental criteria. The programme assesses first-tier suppliers we buy tobacco leaf from and checks if they have the appropriate systems, governance and procedures in place to ensure high environmental and human rights standards on the farms they source from.

STP was developed in 2015 in collaboration with five other tobacco manufacturers to bring together best practice from across the industry. Implementation began in June 2016, replacing our Social Responsibility in Tobacco Production programme, which ran for more than 15 years.

The programme is aligned to important external standards, such as those of the International Labour Organisation (ILO), and includes strengthened processes and more frequent on-site reviews.

Suppliers complete an annual self-assessment covering 178 different criteria under the key areas of: crop, environment, people and facilities. They must also show that they have good governance underpinning all four areas and are required to assess, identify and mitigate any significant risks which may affect their ability to meet the criteria. The environmental criteria include: sustainable water, soil and forest management, pollution control, waste and recycling, fuel and energy efficiency, greenhouse gas emissions, and biodiversity.

As well as the self-assessments, independent on-site reviews will be carried out every three years, including in-depth analyses of suppliers’ policies, processes and practices and visits to the tobacco farms they source from.

We will use the results of the self-assessments and on-site reviews to work collaboratively with suppliers to drive corrective action and improvements.

In addition to tobacco leaf, the other direct materials we buy to make our products, such as paper and filters and the components that go into our Next Generation Products, represent our highest value strategic supply chain.

All these strategic direct materials suppliers have to undergo an on-site audit, conducted by our independent audit firm, Intertek, in order to be appointed as a new supplier to BAT. They are then re-audited every three to four years.

The Intertek audit includes criteria covering forced labour, child labour, wages and hours, health and safety, environment and management systems.

EN33 Significant actual and potential negative environmental impacts in the supply chain and actions taken

Partially reported

Our most significant environmental impacts are in our tobacco leaf supply chain and are reviewed against the ‘Environment’ pillar of the Sustainable Tobacco Programme (STP) – see EN32.

In addition, we’ve completed biodiversity risk and opportunity assessments  (BROAs) for 100% of our leaf operations twice, in 2010 and 2015. We use these assessments to identify potential issues and opportunities in tobacco farming landscapes, before working with local stakeholders to produce defined action and monitoring plans.

For example, the BROA in Kenya in 2015 identified risks to freshwater ecosystems and land use along the edges of farmland. As a result, our local company is working with local communities and stakeholders on risk mitigation actions. Their action and monitoring plans include improved management of forest cover through strategic tree planting and working with local NGOs and government to implement two wetland management plans for key wetlands in the Malakisi and Amukura areas. This is assisting with future decision making and helping us to better understand our wider dependencies on ecosystem services.

EN34 Number of grievances about environmental impacts filed, addressed, and resolved through formal grievance mechanisms

Not reported - information not collated at Group-level

The Group’s Standards of Business Conduct  set out our Whistleblowing Policy which enables staff, in confidence, to raise concerns about possible improprieties or wrongdoings, including damage to the environment. They can do so without fear of reprisal, provided that such concerns are not raised in bad faith. The policy is supplemented by local procedures throughout the Group, which provide staff with additional guidance and enable them to report matters in a language with which they are comfortable. The Board Audit Committee receives regular reports on whistleblowing.

See LA16, HRR3 HR12 and SO5 for details of suspected improper business conduct, contrary to our Standards of Business Conduct, reported in 2016.

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