A transparent and controlled policy
We have a clear policy and compliance procedure, set out in our Group-wide Standards of Business Conduct, that must be followed before any political contributions are made.
Contributions from any BAT Group company to political parties and organisations, their officers, elected politicians and campaigns for candidates for elective office may only be made where expressly permitted by local law, generally accepted as part of local business practice and subject to strict controls.
Contributions are never permitted to be made in order to achieve any improper business or other advantage or to influence any decision by a public official to the advantage of the Group or any Group company. In addition, they must not be intended to personally benefit the recipient or his or her family, friends, associates or acquaintances.
Controls on political contributions
Any donation must be expressly permitted by local law, authorised in advance by the board of the company making it, fully documented in the company’s books and, if required by local law, placed on the public record.
Details must be notified in writing each year to the Group Head of Business Conduct and Compliance of British American Tobacco p.l.c. These are reported annually to the Audit Committee of British American Tobacco p.l.c., with an interim report to the Committee at the half year in respect of those countries where payments were reported or made in the preceding year.
Donations to political organisations and political expenditure, as such terms are defined in the Companies Act 2006 (2006 Act) sections 366 and 367, of more than £5,000 in total in any period of twelve months may only be made out of funds previously authorised by shareholders at a General Meeting. Although neither the Company nor its subsidiaries have any current intention of making political donations to any political party, or independent electoral candidate as such terms are defined in the 2006 Act, it remains possible that circumstances may arise in which it would be in the interests of the Company or its subsidiaries to do so, or where expenditure may be categorised as such. We therefore seek an annual authority to make such donations (up to £100,000 in aggregate) at our Annual General Meeting.
Political contributions by Group companies in 2020
The Group does not make contributions to UK or EU political organisations or incur UK or EU political expenditure. The total amount of political contributions made to non-UK and non-EU political parties in 2020 was £4,851,616 (2019: £4,466,171) as follows:
Reynolds American Companies reported political contributions totalling £4,851,616 (US$6,229,475) for the full year 2020 to US political organisations and to non-federal-level political party and candidate committees, in accordance with their contributions programme. No corporate contributions were made to federal candidates or party committees, and all contributions were made in accordance with applicable laws.
All political contributions made by RAI Companies are assessed and approved in accordance with RAI’s policies and procedures to ensure appropriate oversight and compliance with applicable laws. In accordance with the US Federal Election Campaign Act, RAI Companies continue to support an employee-operated Political Action Committee (PAC), a non-partisan committee registered with the US Federal Election Commission that facilitates voluntary political donations by eligible employees of RAI Companies. According to US federal finance laws, the PAC is a separate segregated fund and is controlled by a governing board of individual employee-members of the PAC. In 2020, RAI Companies incurred expenses, as authorised by US law, in providing administrative support to the PAC. No other political contributions were reported.