Our Standards of Business Conduct are a set of global policies of British American Tobacco, expressing the high standards of integrity we are committed to upholding.
In this document:
‘Group‘ means British American Tobacco p.l.c. and all of its subsidiaries, including RAI and its subsidiaries
‘Group company‘ means any company in the British American Tobacco Group
‘RAI’ means Reynolds American Inc.
‘RAI company’ means RAI and any direct or indirect subsidiary of RAI
‘Standards‘ and ‘SoBC‘ can mean the Group Standards set out in this document and/or Standards adopted locally by a Group company
‘employees‘ includes, where the context admits, directors, officers and permanent employees of Group companies
references to ‘laws‘ includes all applicable national and supra-national law and regulations
‘LEX’ means Legal and External Affairs
Local versions of the SoBC
Each operating company in the Group must adopt the SoBC, or its own standards reflecting them. If a Group company wishes to implement its own version of the SoBC it must be at least as stringent as this SoBC or receive prior notification from the Group LEX Leadership Team. If the SoBC conflicts with local laws, then the laws take precedence.
In the event of a conflict or inconsistency between the SoBC (or local version, if applicable) and any other document issued by a Group company (including employment contracts), the terms of the SoBC (or local version, if applicable) will prevail.
Commitment to integrity
We must comply with the SoBC (or local equivalent) and all laws and regulations which apply to Group companies, our business, and to ourselves. We must always act with high standards of integrity.
Our actions must always be lawful. Having integrity goes further. It means that our actions, behaviour, and how we do business must be responsible, honest, sincere, and trustworthy.
We are all expected to know, understand and follow the SoBC or local equivalent.
The SoBC applies to all employees of BAT, its subsidiaries and joint ventures which BAT controls. If you are a contractor, secondee, trainee, agent or consultant working with us, we ask that you act consistently with the SoBC and apply similar standards within your own organisation. The SoBC is complemented by the BAT Supplier Code of Conduct which defines the minimum standards we expect our suppliers to adhere to.
A legacy of leaders
Creating a legacy of leaders is a key component of our strategy. When we manage others, we must lead by example, showing by our own behaviour what it means to act with integrity and in line with behaviours expected under the SoBC.
The role of line managers
Our SoBC, policies and procedures apply to everyone, whatever their role or seniority. Managers are key role models of the SoBC. If you manage people, you must ensure that all your reports read the SoBC and receive the guidance, resources and training they need to understand what is expected of them.
Line managers are expected to:
- Know the BAT’s Values and stand up for what is right
- Coach your team to ensure they know how to ‘Deliver with Integrity’ and recognise consistent behaviours
- Role model respect in the workplace
- Foster an environment in which concerns are freely raised without fear of retaliation
- Raise concerns when appropriate to do so
No exception or compromise
No line manager has authority to order or approve any action contrary to the SoBC, or against the law. In no circumstances will we allow our standards to be compromised for the sake of results. How you deliver is as important as what you deliver.
If a manager orders you to do something in breach of the SoBC or the law, raise this with higher management, your local LEX Counsel, or a ‘Designated Officer‘. You can also report the matter through our confidential Speak Up hotline if you do not feel able to speak to someone internally.
Our own ethical judgement
The SoBC cannot cover every situation we may encounter at work. Above all, we must choose what we truly believe to be the right course of action and if this is unclear ask yourself:
- Is it legal?
- Is it consistent with our internal rules and guidance that may apply to the situation?
- Does it feel right?
- would I be comfortable explaining my conduct to the company board, my family and friends, or the media?
- who does my conduct affect and would they consider it fair to them?
If the answer to any of these questions is ‘no’ or you are ‘not sure’ then don’t proceed and discuss the issue with your line manager, higher management your local LEX Counsel or contact the Head of Compliance at email@example.com
Duty to report a breach
We have a duty to report any suspected wrongdoing in breach of the SoBC or the law. We should also report any such conduct by third parties working with the Group.
Be assured that BAT will not tolerate any retaliation against people who raise concerns or report suspected breaches of the SoBC or unlawful conduct.
Consequences for breach
Disciplinary action will be taken for conduct that breaches the SoBC or is illegal, including termination of employment for particularly serious breaches.
Breaches of the SoBC, or the law, can have severe consequences for the Group and those involved. If conduct may have been criminal, it might l be referred to the authorities for investigation and could result in prosecution.
Every year, all of our people and business entities must formally confirm that they have complied with the SoBC.
As individuals, we do so in our annual SoBC sign-off, in which we re-affirm our commitment and adherence to the SoBC and declare or re-declare any personal conflicts of interest for the sake of transparency.
Our business entities do so within Control Navigator, in which they confirm that their area of the business, or market, has adequate procedures in place to support SoBC compliance.