Insider dealing and market abuse
We are committed to supporting fair and open securities markets throughout the world. Employees must not deal in shares or other securities of British American Tobacco p.l.c. (‘BAT plc’) on the basis of inside information, or engage in any form of market abuse.
Market abuse
We must not commit any form of market abuse, including:
- improper disclosure of Inside Information
- dealing in securities on the basis of inside information (‘insider dealing’)
- misuse of inside information
- engaging in market manipulation
‘Market abuse’ means conduct which harms the integrity of financial markets and public confidence in securities and derivatives. Market abuse and insider dealing (committing it or encouraging it in others) is illegal.
Handling Inside Information
If you have or receive information that may be Inside Information relating to BAT plc, and your role within the Group does not involve you having or receiving such information, you must immediately inform the Company Secretary of BAT plc.
If your role does involve you having or receiving such information, you must follow applicable requirements and Group processes.
Care is needed when handling inside information, as its misuse could result in civil or criminal penalties for the Group and the individuals concerned.
If you have or receive information relating to any other publicly traded Group company that matches or is similar to the definition of ‘inside information’ or if you are unsure, immediately inform the Company Secretary of the company concerned.
Any inside information (or similar), whether relating to a publicly traded Group or non-Group company, should be treated with the utmost confidentiality.
Responsible share dealing
We must not deal in the securities of BAT plc, or encourage others to so deal, while having inside information relating to it.
If you intend on dealing in the securities of BAT plc, then you must comply with local share dealing laws and the British American Tobacco Code for Share Dealing (the ‘Code’), which applies to all employees.
Similarly, we must not deal in the securities of any other publicly traded Group or non-Group Company, or encourage others so to deal, while having inside information (or similar) relating to that company. We must comply with all applicable share dealing laws and requirements.
Who to talk to
- Your line manager
- Higher management
- Your local LEX Counsel
- Head of Compliance: sobc@bat.com