British American Tobacco

Our Standards of Business Conduct express the high standards of business integrity that we require from our employees worldwide. As such, they play a key role in the British American Tobacco Group strategy.

Together with our Statement of Business Principles, our Standards of Business Conduct underpin our commitment to high standards of corporate behaviour. While the Statement of Business Principles sets out our beliefs and values as an organisation, the Standards of Business Conduct apply those values and principles to specific situations, which may arise in our day-to-day business life.

The Standards of Business Conduct have been in place for many years and are kept under review to ensure they remain at the forefront of best business practice. Every Group company and all staff worldwide are expected to live up to them and to ensure our business standards are never compromised for the sake of results.

Regularly reviewed and updated

We updated our Standards of Business Conduct in 2014 to reflect a new policy area of workplace and human rights, covering many of the themes in our Employment Principles. ‘Respect in the workplace’ renews our commitment to treating each other respectfully, and as equals. ‘Human rights and our operations’ defines our role as a good corporate citizen, particularly in the supply chain.

In 2016, the Standards were further updated to reflect the provisions of the Market Abuse Regulation and again in July 2017, following BAT’s acquisition of Reynolds American Inc., to reflect various US legal requirements to which the Group is now subject (in particular, the US Foreign & Corrupt Practices Act). In 2018 our Standards of Business Conduct were once again reviewed, and updates made to the Political Contributions policy.

In 2019 we will update our policies on whistleblowing, entertainment and gifts, and financial interests, and include a new policy area on tax evasion, to reflect the Group’s legal obligations under the Criminal Finances Act

What our Standards cover

The Standards set out the Group policy, and provide guidance and support to staff, in the following specific areas:

• Whistleblowing
• Conflicts of interest
• Bribery and corruption
• Entertainment and gifts
• Respect in the workplace
• Human rights and our operations
• 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
• Illicit trade in the Group’s products
• Sanctions. 

Standards of Business Conduct 2018 (1.8 mb)

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 our companies and 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 offer, promise or give any gift, payment or other benefit to any person (directly or indirectly), to induce or reward improper conduct or directly or indirectly influence any decision by any person to our advantage;
• They do not solicit, accept, agree to accept or receive any gift, payment or other advantage from any person (directly or indirectly) as a reward or inducement for improper conduct or which influences, or gives the impression that it is intended to influence, decisions of the Group; 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 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.

Confidential whistleblowing procedures

The Group’s whistleblowing policy contained within our Standards enables staff to speak up and raise concerns, in confidence, about possible wrongdoing or breaches of our Standards, and to do so without fear of reprisal. The policy is supplemented by local whistleblowing procedures throughout the Group and in the Group’s London headquarters, which provide staff with additional guidance and enable them to report matters in a language they are comfortable with.

Raising concerns and reporting

Staff can raise concerns with their line manager, HR or one of the Group’s Designated Officers for whistleblowing based locally throughout the world. Alternatively, they can use our confidential, independently managed external Speak Up channels via telephone or online. Our Speak Up channels are available 24 hours a day in local languages and are highlighted in our internal trainings and communications.

Our business partners are also welcome to report their concerns and can do so via our Speak Up portal, the details of which are available to suppliers.

The Audit Committee receives regular reports on whistleblowing, and remains satisfied that the policy and procedures in place incorporate arrangements for the proportionate and independent investigation of matters raised and for the appropriate follow-up action.

The link to our Speak Up whistleblowing portal is available below:

www.bat.com/speakup 

Compliance

All Group companies have adopted our Standards of Business Conduct or local policies embodying them. Information on compliance with the Standards is gathered at a global level and reported quarterly to the Audit Committee. For more information, including compliance figures, see Our Standards of Business Conduct compliance.