Group Speak Up policy


Group Speak Up policy

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.


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.

This includes Employees, contractors contingent workers, business partners, customers, suppliers and their workers.

You Speak We Listen We Act


Examples of wrongdoing

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, modern slavery 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 from HR.

If you are a line manager, you have an additional duty to raise any concerns brought to your attention. Those who ignore such concerns, or stop or discourage someone from Speaking Up, 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 or LEX manager
  • your line manager
  • our confidential, independently managed external Speak Up channels ( ), which are operated independently of management, enable you to raise concerns online or via telephone (anonymously if you prefer)

Four senior Group executives act as our Group Designated Officers. Anyone can raise a concern with them directly. They are:

  • the AGC Business Integrity & Compliance: Tamara Gitto
  • the Company Secretary of British American Tobacco plc: Caroline Ferland
  • the Group Head of Internal Audit: Graeme Munro
  • the Group Head of Reward: Jon Evans

You can contact them by email (, phone (+44 (0)207 845 1000) or by writing to them at British American Tobacco plc, 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.

Where appropriate, BAT will take action which may include disciplinary action against individuals found to have breached the SoBC.

Where feasible and appropriate, you will also receive feedback on the outcome of the investigation if we are able to contact you.

You can read more about how we will escalate and investigate your concerns in the Group SoBC Assurance Procedure.


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, which sets out in more detail how concerns or allegations of breach of the SoBC are escalated and investigated.


Protection for those who Speak Up

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
  • Higher management
  • Your local LEX Counsel
  • Head of Compliance: