It can take courage to Speak Up about wrongdoing. This Speak Up policy is there to support you in doing so, and give you trust and confidence in how we will treat your concerns
Local Designated Officers and SoBC Assurance Procedure
We have Designated Officers responsible for receiving concerns, based locally throughout the world.
This Policy is complemented by the Group SoBC Assurance Procedure, available on The Hub, which sets out how concerns or allegations of breach of the SoBC are escalated and investigated in more detail.
We encourage you to Speak Up
Anyone working for or with the Group who is concerned about actual or suspected wrongdoing at work (whether in the past, occurring, or likely to happen) should Speak Up.
Examples of wrongdoing include:
- criminal acts, including theft, fraud, bribery and corruption
- endangering the health or safety of an individual or damaging the environment
- bullying, harassment (including sexual harassment) and discrimination in the workplace, or other human rights abuses
- accounting malpractice or falsifying documents
- other breaches of the SoBC or other global policies, principles or standards of the Group;
- failing to comply with any legal obligation, by act or omission
- a miscarriage of justice
concealing any wrongdoing
Wrongdoing does not include situations where you are unhappy with your personal employment position or career progress. Grievance procedures are available in such cases, and details on how to raise a grievance are available on The Thrive portal.
If you are a line manager, you have an additional duty to raise any concerns brought to your attention. Those who ignore violations, or fail to correct them, could face disciplinary action.
Who you can speak to
You have several options to raise your concerns, and you can use the one you are the most comfortable with:
- A Designated Officer;
- An HR manager;
- Your line manager;
- Our confidential, independently managed external Speak Up channels (www.bat.com/speakup or 1 (800) 825-7213).
Four senior Group executives act as our Group Designated Officers. Anyone can raise a concern with them directly. They are:
the Group Head of Business Conduct and Compliance – Caroline Ferland
the Company Secretary of British American Tobacco p.l.c. – Paul McCrory
the Group Head of Internal Audit – Graeme Munro
the Group Head of Reward – Jon Evans
You can contact them by email (email@example.com), phone (+44 (0)207 845 1000), or by writing to them at British American Tobacco p.l.c., Globe House, 4 Temple Place, London WC2R 2PG.
Investigations and confidentiality
No matter how you choose to Speak Up, your identity will be kept confidential as we fairly and objectively investigate your concerns. You will also receive feedback on the outcome if we are able to contact you.
The Speak Up hotline is operated by an external service provider, independently of management. You can read more about how we will escalate and investigate your concerns in the Group SoBC Assurance Procedure, available on The Hub.
You will not suffer any form of reprisal (whether directly or indirectly) for Speaking Up about actual or suspected wrongdoing, even if you are mistaken.
We do not tolerate the harassment or victimisation of anyone raising concerns or anyone who assists them. Such conduct is itself a breach of the SoBC and will be treated as a serious disciplinary matter.
Who to talk to
Your line manager
Your local LEX Counsel
Head of Compliance: