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Insider dealing and market abuse

 
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We are committed to supporting fair and open securities markets throughout the world. Employees must not deal on the basis of inside information or engage in any form of market abuse

'Inside information' is information of a precise nature which:

  • is not generally available;
  • relates directly or indirectly to a publicly quoted company or to its shares or other securities; and
  • would, if generally available, be likely to have a significant effect on the price of that company‘s shares or other securities, or related investments

Market abuse

We must not commit any form of market abuse, including:
  • improper disclosure of inside information
  • dealing in securities on the basis of inside information
  • misuse of inside information
  • engaging in market manipulation

‘Market abuse’ means conduct which harms the integrity of financial markets and public confidence in securities and derivatives. Market abuse and insider dealing (committing it or encouraging it in others) is illegal in most countries.

For more information about behaviour that may constitute market abuse or insider dealing in the UK, see our Code for Share Dealing .

Handling inside information

If we have or receive information that may be inside information relating to any publicly traded Group company, we must disclose it immediately to our General Manager, Head of Function, or (if the information relates to a specific project) to the project leader. Otherwise, we must not disclose this information without specific authorisation, and then only to:
  • employees who require it to carry out their work
  • agents or representatives of a Group company who owe it a duty of confidentiality and require such information in order to carry out work on its behalf

Care is needed when handling inside information, as its misuse could result in civil or criminal penalties for Group companies and the individuals concerned.

If you are uncertain whether you possess inside information, contact the Company Secretary of British American Tobacco p.l.c., or of the company concerned.

Responsible share dealing

We must not deal in the securities of any publicly traded company (whether Group or non-Group), or encourage others to so deal, while having inside information relating to that company.
If you intend on dealing in the securities of any publicly traded Group company, and from time to time have access to inside information relating to that company, then you must comply with local share dealing laws and, if it applies to you, any share dealing code issued by that company.

'Securities' includes shares (including American Depository Receipts), options, futures and any other type of derivative contract, debts, units in collective investment undertakings (e.g. funds), financial contracts for difference, bonds, notes or any other investments whose value is determined by the price of such securities.

'Dealing' is widely defined and includes any sale, purchase or transfer (including by way of gift) as well as spread bets, contracts for difference, or other derivatives involving securities, directly or indirectly, whether on your own or someone else’s behalf.

Our Code for Share Dealing  sets out the rules applying to 'insiders' of British American Tobacco, for whom there are additional restrictions on dealing in the securities of British American Tobacco p.l.c. We are legally required to keep a list of all insiders, who will be individually notified of their status.

Who to talk to

Your line manager
Higher management
Your local LEX Counsel
Head of Compliance:
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