Defining our corporate behaviour
Conducting our business with honesty, integrity and transparency is not only the right thing to do, it is also critical to the continuing development of a business that is responsible, successful and sustainable in the long term.
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, our Standards of Business Conduct provide guidance on workplace situations, based on those values and principles.
Our 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.
In 2019 we included a new policy on lobbying and engagement, as well as a new policy area on tax evasion to reflect the Group’s legal obligations under the UK Criminal Finances Act. We also made further updates to a number of key global polices, to keep pace with regulatory developments and reflect areas identified for improvement following external benchmarking.
The amendments include:
We have also introduced an SoBC Assurance Procedure, which complements our SoBC by setting out in more detail how allegations of wrongdoing or breach of the SoBC should be followed up to ensure that they are dealt with fairly and objectively.
Our Standards of Business Conduct set out the Group policy, and provide guidance to staff, in the following specific areas:
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:
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.
The Group’s Speak Up 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.
Staff can raise concerns with their line manager, HR or one of the Group’s Designated Officers. 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:
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.