Disclose a conflict of interest


Disclose a new conflict

Login to the SoBC Portal  then navigate to ‘Disclosures’ and ‘Add a new disclosure.’

If you do not have access to the SoBC Portal, you should disclose the situation to your line manager. You can use an offline form for this.

You must disclose any actual or potential conflict of interest as soon as it arises, and update any disclosed conflicts if any of the details of your disclosure changes. You will also be required to review, update and and confirm your conflict(s) every year as part of the annual SoBC sign-off.


Update an existing conflict

This means you:

  • Review a conflict of interest you previously disclosed either online in the SoBC Portal   or offline to your line manager
  • Update the conflict if any of the details have changed, including if your line manager has changed or if the conflict is no longer applicable  
  • How to do this:
    • Login to the SoBC Portal and navigate to the 'Disclosures' tab where your conflict(s) will be listed
    • If the conflict is in 'Pending' status, you can immediately update any of the details using the 'Edit Disclosure' button
    • If the conflict is in 'Cleared' status then it has already been reviewed by LEX and is now 'locked' and cannot be edited. if you need to update a 'Cleared' conflict you will need to first make the existing disclosure inactive using the 'Make Inactive' button, and then redisclose another conflict with the new details using the 'Add New Disclosure' button
    • If you have disclosed your conflict of interest offline, then you will need to contact your local LEX team who will advise you on how to update the disclosure in the local Conflicts of Interest register

Update an existing conflict now 


Employee responsibilities

  • BAT recognises that many of us have relationships or outside interests, which should be disclosed as they could result in a conflict of interest.
  • Be transparent if you have personal circumstances where a conflict exists or might arise.
  • Disclose any actual or potential conflicts to your line manager, when it arises (don't wait until the year-end sign-off.)
  • Seek authorisation from your line manager.This could include agreed conditions to avoid a potential conflict arising. Make sure you act in accordance with the conditions agreed with your line manager. 
  • Update your disclosed conflicts in the SoBC Portal if the details of your conflict changes, and review and update any actual or potential conflict of interest in your annual SoBC sign-off.

Line manager responsibilties

  • Ensure all actual or potential conflict(s) disclosed to you by your direct report(s) are immediately recorded in the SoBC Portal. If your direct report does not have access to the SoBC Portal then report the potential conflict to your local LEX Counsel or the Company Secretary, including any conditions you have agreed with your report. Your LEX Counsel will include the disclosure in the offline conflicts disclosure register.
  • Consider what steps to take to manage the conflict. You might need to speak to your direct report to seek further information. It may be necessary to make such authorisation subject to conditions (e.g. ensuring relatives in the same reporting lines are not involved in their relative's performance review)
  • Seek guidance from your LEX Counsel if you’re uncertain about a disclosed conflict or whether certain conditions are appropriate.

LEX responsibilities

  • Maintain up-to-date Conflicts of Interest Registers (both offline and online) detailing all the conflicts and mitigation plans in your business units (BU)
  • Ensure line managers manage theireports' disclosed conflicts in accordance with the Conflicts of Interest policy
  • In accordance with the approach to conflicts management communicated by BC&C, review all disclosed conflicts in your BU in the SoBC Portal within the required timeframe during the annual SoBC sign-off. 
  • Please refer to the detailed guide: SoBC Portal: Conflicts of Interest Disclosure Management Guide for LEX
  • Also refer to Managing Conflicts in the SoBC Portal: Quick Guide