Independent assurance statement to British American Tobacco management
The British American Tobacco p.l.c. Sustainability Report 2009 (the Report) [ ] has been prepared by the management of British American Tobacco, which is responsible for the collection and presentation of the information it contains, and reviewed by the Board CSR Committee. Our responsibility, in accordance with the management’s instructions, is to carry out the following assurance activities:
- Provide a ‘limited level’ assurance opinion on the Report’s content with respect to the AA1000AS (2008) assurance principles of Inclusivity, Materiality and Responsiveness.
- Provide a ‘limited level’ assurance opinion on the completeness and accuracy of the claims and performance data presented in the Report.
- Provide a ‘reasonable level’ assurance opinion on the information presented in the Report on the London based supply chain stakeholder dialogue session.
Our responsibility in performing our assurance activities is to the management of British American Tobacco only and in accordance with the terms of reference agreed with them. We do not accept or assume any responsibility for any other purpose or to any other person or organisation. Any reliance any such third party may place on the Report is entirely at its own risk.
What we did to form our conclusions
Our assurance engagement has been planned and performed in accordance with ISAE 3000 [ ] and to meet the requirements of a Type 2 assurance engagement as defined by AA1000AS (2008) [ ]. The AA1000AS (2008) assurance principles of Inclusivity, Materiality and Responsiveness have been used as criteria against which to evaluate the Report.
In order to form our conclusions we undertook the steps outlined below:
- Interviewed a selection of executives and senior managers at British American Tobacco’s headquarters in London to understand the current status of social, ethical, environmental and health and safety activities, and progress made during the reporting period.
- Reviewed British American Tobacco’s approach to stakeholder engagement through interviews with employees at headquarters, regional and local company level, and reviewed selected associated documentation.
- Reviewed a selection of external media reports and conducted a high-level benchmarking exercise of the material issues and areas of performance covered in the environmental and social reports of British American Tobacco’s peers, to test the coverage of topics within the Report.
- Reviewed selected headquarters documents relating to social, ethical, environmental and health and safety aspects of British American Tobacco’s performance, to understand progress made across the organisation and to test the coverage of topics within the Report.
- Reviewed information or explanations about the Report’s data, statements and assertions regarding British American Tobacco’s sustainability performance.
- Reviewed data samples and processes relating to environmental, health & safety (EHS), the corporate social responsibility (CSR) survey, the ‘Your Voice’ employee opinion survey, machinery destroyed, the Business Enabler Survey Tool (BEST), Social Responsibility in Tobacco Production (SRTP) and local succession coverage and leadership diversity to test whether they had been collected, consolidated and reported appropriately at headquarters level.
- Reviewed disaggregated data reported on balanced scorecards for five regions and nine markets to assess whether the data had been collected, consolidated and reported accurately.
- Reviewed and challenged supporting evidence from local companies for a selection of data points, covering EHS and the CSR survey.
- Reviewed British American Tobacco’s processes for determining material issues to be included in the Report.
In order to form our conclusions on the information regarding the supply chain stakeholder dialogue, we:
- Attended the independently facilitated stakeholder dialogue session held in London.
- Reviewed the independent facilitator’s minutes of the dialogue to form conclusions that they provided a fair representation of the issues raised and British American Tobacco’s response.
- Reviewed the section in the Report relating to the London based stakeholder engagement session, as described in the Supply chain section, to form conclusions that it is an accurate and balanced summary.
Level of assurance
The extent of evidence gathering procedures for a ‘limited level’ of assurance is less than that of a ‘reasonable’ assurance engagement (such as a financial audit) and therefore a lower level of assurance is provided for the full Report than the section relating to the London held stakeholder dialogue session.
The limitations of our review
With the exception of selected telephone interviews with regional and local staff and the review of selected local documentation, our work was limited to headquarters activities. We did not visit any local companies.
Based on the scope of our review our conclusions are outlined below:
Has British American Tobacco been engaging with stakeholders across the business to develop its approach to sustainability?
- We are not aware of any key stakeholder groups which have been excluded from engagement. However, we are aware of stakeholder groups who are most critical of the tobacco industry and who have not accepted invitations to engage.
- We are not aware of any matters that would lead us to conclude that British American Tobacco has not applied the inclusivity principle in developing its approach to sustainability.
Has British American Tobacco provided a balanced representation of material issues concerning its sustainability performance?
- With the exception of the subject areas listed below, we are not aware of any material aspects concerning British American Tobacco’s sustainability performance which have been excluded from the Report.
- We consider that British American Tobacco could have covered the following subject areas in more depth in the Report:
- British American Tobacco’s economic impacts in countries of operation.
- More detailed explanations of reasons why the target on full adherence to the IMS by 2009 had not been met.
- Nothing has come to our attention that causes us to believe that British American Tobacco management has not applied its processes for determining material issues to be included in the Report, as described in the Materiality section.
How has British American Tobacco responded to stakeholder concerns?
- With the exception of the issues highlighted in relation to Materiality, we are not aware of any additional issues of stakeholder interest that are not currently included in the Report’s scope and content.
Completeness and accuracy of Performance Information
How plausible are the statements and claims within the Report?
- We have reviewed information or explanations on the statements on British American Tobacco’s sustainability activities presented in the Report and we are not aware of any misstatements in the assertions made.
How complete and accurate is data on EHS, the CSR survey, the ‘Your Voice’ employee opinion survey, machinery destroyed, BEST, SRTP, local succession coverage and leadership diversity in the Report?
- We are not aware of any material reporting units that have been excluded from the headquarters level data relating to the topics above.
- Nothing has come to our attention that causes us to believe that the data relating to the above topics has not been collated properly at headquarters or regional levels.
- We are not aware of any errors that would materially affect the data as presented in the Report.
Has British American Tobacco provided a fair representation of the issues raised and response to the London held stakeholder engagement session?
- Text in the Report regarding the independently facilitated stakeholder dialogue session held in London provides a fair summary of the engagement at this session and the actions agreed by British American Tobacco.
Observations and areas for improvement
See the following page to view our observations and areas for improvement.
This is the third year that Ernst & Young LLP has provided independent assurance services in relation to British American Tobacco p.l.c.’s Sustainability Report. We have provided no other services relating to British American Tobacco’s approach to sustainability reporting.
Our assurance team
Our assurance team has been drawn from our global environment and sustainability network, which undertakes engagements similar to this with a number of significant UK and international businesses. The work has been led and reviewed by Lead Sustainability Assurance Practitioners.
Ernst & Young LLP
- This includes the printed and online Reports, including the case studies and balanced scorecards for nine key markets, and selected sustainability web content on www.bat.com , marked with the Ernst & Young footnote.
- ISAE 3000 – International Federation of the Accountants’ International Standard for Assurance Engagements Other Than Audits or Reviews of Historical Financial Information.
- AA1000AS (2008) – The second edition of the AA1000 assurance standard from the Institute of Social and Ethical Accountability.