british american tobacco p.l.c. sustainability report 2009 - Policies, principles and standards


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Statement of Business Principles

Our Statement of Business Principles forms the basis on which we expect our businesses to be run in terms of responsibility. It was developed in consultation with stakeholders, involving dialogue on stakeholders’ expectations of a responsibly managed business. The Statement comprises three principles – Mutual Benefit, Responsible Product Stewardship and Good Corporate Conduct – and 18 Core Beliefs which explain in more detail what each principle means for the Group.

Framework for CSR

We believe that our Framework for CSR may provide a blueprint for a responsible tobacco business. Based on our Business Principles, it was also developed together with stakeholders in dialogue. The Framework takes each of our Core Beliefs and sets out how we see the different roles in each of these areas – where we should take the lead, where we should work with others and where we think others should take the lead.

Standards of Business Conduct

Our Standards of Business Conduct underpin our commitment to high standards of corporate behaviour. While our Statement of Business Principles sets out our beliefs and values, our Standards of Business Conduct apply these to specific situations which may arise in our day-to-day business life.

Our Standards of Business Conduct apply to all our businesses and employees. They require compliance with all applicable laws and regulations and conduct consistent with high standards of business integrity and also provide clear and practical guidance. They cover:
  • Whistleblowing
  • Protection of corporate assets
  • Conflicts of interest
  • Confidentiality and information security
  • Bribery and corruption
  • Insider dealing and market abuse
  • Entertainment and gifts
  • Competition and anti-trust laws
  • Political contributions
  • Money laundering and anti-terrorism
  • Charitable contributions
  • Trade in the Group’s products
  • Accurate accounting and record-keeping
  • Sanctions

Anti-bribery and corruption policy

Corruption can cause distortion in markets and harms economic, social and political development in developing countries. Our Standards of Business Conduct make clear that it is wholly unacceptable for any of our employees to be involved or implicated in corrupt practices in any way. 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 purposes of securing any improper business or other advantage;
  • They do not directly or indirectly solicit, accept or receive any gift, payment or other advantage from any person in return for providing any improper business or other advantage; and
  • 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 all 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.

Standards of Business Conduct compliance

All Group companies have adopted our Standards of Business Conduct or local policies embodying them. Senior managers in the Group must report on annual 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 to the regional audit and CSR committees and to the Board Audit Committee. The Board CSR Committee will also review any Group reputation-related issues arising from non-compliance with the Standards.

You can read more about the Standards of Business Conduct and download them in full on Opens in new window.

For Standards of Business Conduct compliance in 2009, see GRI indicator SO4.

Other policies, principles and standards

Other policies, principles and standards that guide the way our businesses are run include our International Marketing Standards, Philosophy for Supplier Partnerships, Environment, Health and Safety Policy, Child Labour Policy, Employment Principles and our Biodiversity Statement.

Product stewardship and quality

We aim to ensure that there are no aspects of our products that, under normal conditions of use, would significantly increase the risks to health associated with tobacco products. To help achieve this we have:

  • A number of processes covering ingredients, additives and materials, including review by our Additives and Materials Guidance Panel;
  • A Scientific Research Group which reviews external research and published opinion on tobacco-related science and associated health matters to guide the development of Group positions and product best practice guidelines; and
  • Product quality management systems to ensure that we provide our consumers with products that meet their expectations and satisfy regulatory requirements.

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