Our Standards of Business Conduct, together with our Business Principles, underpin our commitment to high standards of corporate responsibility.
All Group companies have adopted these Standards or local policies embodying them. Senior managers in the Group must sign a letter annually reporting on compliance with the Standards for all employees in the company or department for which they are responsible. Information on performance against the Standards is gathered at a global level and reported quarterly to the Audit Committee.
SO4 Actions taken in response to incidents of corruption
In the year to 31 December 2007, 36 (2006: 22) instances of suspected improper business conduct, contrary to our Standards of Business Conduct, were reported to the Audit Committee, including 24 (2006:17) brought to attention through ‘whistleblowing’ reports from employees and ex-employees.
Following thorough investigations, 18 (2006:7) were established as breaches and appropriate action was taken. In 16 (2006:11) cases, investigation found no wrongdoing. In two cases (2006:4), investigation continued at the year end. No instances involved sums or matters considered material to the Group.
SO7 Total number of legal actions for anti-competitive behaviour, anti-trust and monopoly practices
In 2007, our Group companies have reported that legal proceedings or regulatory investigations involving allegations of anti-competitive behaviour, anti-trust, and/or monopoly practices were commenced or continuing against our companies in Brazil, Canada, Greece, Italy, Malta, USA and South Africa. Further details of each incident and their current status can be found in our full list of GRI indicators under Society.
SO8 Significant fines and sanctions for non-compliance with laws and regulations
In 2007, our company in Ukraine reported that it had received a fine of approximately £164,000 for non-compliance with local employment law. Further details of this incident can be found in our full list of GRI indicators under Society.
Amongst several other important requirements, the Standards include specific provisions on bribery and corruption which prohibit the giving or taking of bribes to or from any person and any other activity which contravenes any applicable anti-corruption measures.
In 2007, we reviewed and updated our Standards of Business Conduct to ensure that they continue to reflect best practice and also offer clear and practical guidance to staff in the following areas:
Conflicts of interest;
Bribery and corruption;
Entertainment and gifts;
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;
Group Principles and Standards
Throughout the Group, we also have other policies, principles and standards that guide the way our businesses are run. You can download copies of our Business Principles, the Framework for CSR, our Standards of Business Conduct and other Group policies and standards including those for Supplier Relationships, Environment, Health and Safety, Child Labour, our Employment Principles and our Biodiversity Statement on www.bat.com/principles .
We believe our Framework for CSR may provide a blueprint for a responsible tobacco company. It is available to read in full at www.bat.com/principles