British American Tobacco - Robust corporate governance

Business ethics 

Ethical values form the basis of our culture and are expressed in our Standards of Business Conduct (SoBC). Our Delivery with Integrity programme builds on our already strong foundations to drive a consistent approach to managing key risks including bribery and corruption, such as by:

• Regularly reviewing and updating our SoBC to remain at the forefront of best practice;
• Providing comprehensive SoBC training and communications for all our employees every year;  
• Increasing the accessibility, awareness and understanding of our SoBC and Speak up channels, such as with our new SoBC app available in 12 languages; and 
• Developing procedures and tools to promote the consistent application of our SoBC policies across the Group – for example, our Third-Party Anti-Bribery and Corruption Procedure. 

Responsible marketing 

We’re committed to ensuring our products are marketed responsibly to adult-only consumers, such as through:  

• Our International Marketing Principles (IMP) governing our marketing across all our product categories, including strict requirements to be responsible, accurate and targeted at adult consumers only;  
• Expecting our markets to adhere to our global Youth Access Prevention (YAP) Guidelines wherever our products are  sold; and 
• Updating our IMP and YAP Guidelines to keep pace with best practice and our growing range of product categories.

Regulation and policy engagement 

We’re committed to conducting all our engagement activities with external stakeholders with transparency, openness and integrity, such as by:

• Incorporating our longstanding Principles for Engagement into a new Lobbying and Engagement Policy in our SoBC, to highlight the importance of these principles along with all other Group policies;  
• Applying robust procedures and controls for political contributions;  
• Monitoring of regulatory engagement activities across the Group by our governance committees; and 
• Respecting the WHO Framework Convention on Tobacco Control (FCTC) 5.3 provision, which calls for transparent and accountable interaction between governments and the tobacco industry.

Next steps 

• Continue to strive for 100% adherence to our SoBC and to increase the awareness, understanding and accessibility of our SoBC policies and Speak up channels; 
• 100% adherence to our International Marketing  Principles (IMP); 
• 100% adherence to our global Youth Access Prevention (YAP) Guidelines; and 
• Ensure all our engagement with regulators and other stakeholders is conducted in accordance with our SoBC Lobbying and Engagement Policy.

Highlights for 2019

• 100% employees completed our SoBC training and formal compliance sign-off procedures in 2019
• Updated our IMP to reflect developments in marketing, technology and our product portfolio
• 100% Youth Access Prevention compliance with activities in all our markets
• £41.4bn total taxes paid including taxes borne and collected in 2019