british american tobacco p.l.c. sustainability report 2011 - Policies, principles and standards

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Sustainability Report 2011

Statement of Business Principles

Our Statement of Business Principles Opens in new window sets out our expectations for the responsible management of the Group’s business. It was developed in 2002 in consultation with stakeholders, supported by the Institute of Business Ethics. 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.

Standards of Business Conduct

Our Standards of Business Conduct Opens in new window underpin our commitment to high levels 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 that may arise in our day-to-day business life.

Our Standards of Business Conduct apply to all our Group companies and employees. They require all staff to act with high standards of business integrity, to comply with all applicable laws and regulations and to ensure that business standards are never compromised for the sake of results. They also provide clear and practical guidance covering:

  • Whistleblowing
  • Conflicts of interest
  • Bribery and corruption
  • Entertainment and gifts
  • Political contributions
  • Charitable contributions
  • 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
  • Sanctions

All Group companies have adopted our Standards of Business Conduct or local policies embodying them. They are applicable to all employees, including senior management, and to the Board of Directors. Senior managers in the Group must report on annual compliance with the Standards with regard to the company or department for which they are responsible. 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.

Information on compliance with the Standards is gathered at a global level and reported to the regional audit and corporate social responsibility (CSR) committees and to the Board Audit Committee. The Board CSR Committee also reviews 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 2011, see GRI indicator SO4.

Anti-bribery and corruption policy

Corruption causes distortion in markets and harms economic, social and political development, particularly in developing countries. Our Standards of Business Conduct make clear that it is wholly unacceptable for any of our companies or employees to be involved or implicated in any way in corrupt practices. 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 purpose of inducing or rewarding improper conduct or influencing any decision by a public official to the advantage of the Group or any Group company;
  • They do not directly or indirectly solicit, accept or receive any gift, payment or other advantage from any person as a reward or inducement for improper conduct; and
  • Their activities do not otherwise contravene any applicable anti-corruption measures.

Our policy also makes clear that Group companies and their employees are prohibited from making facilitation payments (directly or indirectly), save in exceptional circumstances where necessary to protect the health, safety or liberty of any employee.

Our Standards of Business Conduct were updated with effect from 1 September 2011 to ensure that they remain at the forefront of best practice and to ensure alignment with the provisions of the UK Bribery Act 2010, which came into effect on 1 July 2011, and associated guidance. We continue to keep our anti-corruption policies and procedures under review and, where appropriate, to update them, to ensure that they remain in line with best practice.

Each Group company is required to maintain a register of all political donations, charitable contributions and non-commercial sponsorships made by or on behalf of the company. In addition, subject to materiality limits, each Group company must maintain a record of all corporate hospitality given and received.

Other policies, principles and standards

Other policies, principles and standards that guide the way our Group companies are run include our:

  • International Marketing Standards;
  • Philosophy for Supplier Partnerships;
  • Health & Safety Policy;
  • Child Labour Policy;
  • Employment Principles; and
  • Biodiversity Statement.

You can read these from the Our principles and standards Opens in new window page on

Board diversity

In February 2011, Lord Davies of Abersoch published his report entitled ‘Women on Boards’, which reviewed the issue of gender diversity on the boards of UK listed companies and made a number of recommendations.

The Company’s Board has considered the report and its recommendations in detail and has approved the following statement by the Chairman, on behalf of the Company, on this issue, which you can download below.

PDF: Statement on Board Diversity - Statement on Board Diversity (23 kb) Opens in new window

Product stewardship and quality

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

  • A number of processes covering ingredients, additives and materials, including our Additives and Materials Guidance Panel’s review process; 
  • A Scientific Research Group which assesses external research and published opinion on tobacco-related science and associated health matters so as to guide the development of our products, 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.

You can read more about this on Opens in new window.

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