BAT is committed to corporate transparency. As a responsible company all our engagement activities with external stakeholders will be conducted with transparency, openness and integrity. We have a legitimate contribution to make to policy related debate that affects our operations and our employees are required to engage in accordance with this policy.
The Group has a legitimate role to play
Civic participation is a fundamental aspect of responsible business and policy making, and BAT employees will participate in the policy process in a transparent and open manner, by complying with all laws and regulations of the markets in which they operate, including all lobbying registration and reporting requirements.
Engagement with politicians, policy makers and regulators, when carried out transparently and with high regard for accuracy, allows for the best information to be used as a foundation for decisions in policy making.
Transparency and high professional standards
When engaging with external stakeholders, Group companies and employees must ensure that:
- they participate in the policy process in an open and transparent manner, by complying with the laws and regulations of the markets we operate in;
- they always identify themselves by name and corporate affiliation;
- they do not directly or indirectly offer or give any payment, gift, or other benefit to improperly influence any decision by any person to the improper advantage of the Group or any Group company;
- they do not ask for or wilfully obtain from any person, confidential information belonging to another party, or obtain information by any dishonest means;
- they do not induce any person to breach a duty of confidentiality; and
- they offer constructive solutions that will best meet the objectives of regulation, while minimising any negative unintended consequences.
Accurate and complete information
When conducting external engagement activities, employees must endeavour to:
- share accurate and complete information with regulators, politicians and policy makers to best inform decision making.
BAT does support third parties on policy issues of mutual interest. In such cases, Group companies and employees must ensure that:
- they publicly acknowledge support of third party organisations, subject to commercial confidentiality requirements and data protection laws;
- they never ask a third party to act in any way that contravenes this Lobbying and Engagement policy; and
- they require all third parties to comply with laws and regulations of the markets in which they operate governing lobbying registration and reporting requirements.
Financial travel support to Public Officials
It is prohibited to provide financial travel and/or accommodation support to Public Officials (e.g. to pay for their travel/accommodation to attend an event or business meeting). If an exceptional circumstance arises which warrants a request for this rule to be varied, then it must be approved by the Group Head of Government Affairs and the Group Head of Business Conduct & Compliance in accordance with the Principles for Engagement guidance note.
See Conflicts of Interest Policy for definition of “Public Officials”
Who to talk to
Your line manager
Your local LEX Counsel
Head of Compliance: