The way we work
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.
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 and is incorporated into our contractual arrangements.
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 of a 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 be referred to the authorities for investigation and could result in prosecution.
SoBC annual confirmation and training
Every year, all of our Employees and Group entities must formally confirm that they have complied with the SoBC.
Employees do so as part of our annual SoBC sign-off, in which we reaffirm our commitment and adherence to the SoBC and are reminded to declare or re-declare any personal conflicts of interest for the sake of transparency.
New joiners undertake a mandatory induction covering our SoBC policies, including lobbying, and are asked to disclose conflicts of interest.
Our Group entities do so within Control Navigator, in which they confirm that their business unit or market has adequate procedures in place to support SoBC compliance.
Safe and secure environment
Group companies are responsible for maintaining the safety of our people and the security of assets and information as further detailed in our Group Security Procedure.
Group companies and Employees shall ensure the responsible marketing of Group products as governed by our International Marketing Principles which are independent from the SoBC.
Media and use of social media
If you are contacted by a journalist or media outlet for comment, please refer such requests to your local External Communications team (Group press office can be contacted at email@example.com).
Use of social media by Employees can pose risks to BAT’s assets and reputation. Employees must exercise good judgement when using social media and ensure they comply with the SoBC.