british american tobacco p.l.c. sustainability report 2009 - Standards of Business Conduct in Nigeria


Our Standards of Business Conduct apply to all our operations and require that our business is conducted in an honest, responsible and transparent manner.

The Standards are important because they:

  • Help ensure that our actions are lawful and in accordance with the standards we expect of ourselves;
  • Assist us in making sound judgments and decisions; and
  • Give our business partners confidence to continue to work with us.

Operating in a developing market, British American Tobacco Nigeria has adopted the Standards and is required to apply them in the same way as every other company within the Group. In a business environment where the risk of bribery and corruption is a concern, the company sets high standards for managing its relations with third parties. For example, it manages procurement processes to help ensure that goods and services supplied to the business are of the best quality and price and, to help ensure transparency, suppliers are also subject to a rigorous tendering process. Payments to suppliers can only be made with the approval of the budget holder.

Following the update of the Standards in 2008, British American Tobacco Nigeria worked to help ensure that all employees understood the updated Standards and were able to apply them in their daily activities. Initiatives to support this included:

  • Training sessions in which the Standards were linked to real-life scenarios, highlighting what was required and the consequences of non compliance;
  • Integration of the Standards into the induction programme for new employees; and
  • Explicit inclusion of a requirement to adhere to the Standards in all third party contract agreements.

An audit is scheduled for the first quarter of 2010 to review the operation of the Standards in each department with a view to identifying any recurring issues, identifying the cause and, where appropriate, introducing enhanced measures to prevent recurrence. The company also intends to appoint compliance ambassadors within each department, to include Standards of Business Conduct updates in departmental monthly meetings and to maintain the communication of the Standards during induction for new employees.