Lobbying and engagement
BAT is committed to corporate transparency. As a responsible company all our engagement activities with external stakeholders will be conducted with transparency, openness and integrity. We have a legitimate contribution to make to policy-related debate that affects our operations, and our Employees are required to engage in accordance with this policy5.
The Group has a legitimate role to play
Civic participation is a fundamental aspect of responsible business and policymaking, and BAT Employees will participate in the policy process in a transparent and open manner, in compliance with all laws and regulations of the markets in which they operate, including all lobbying registration and reporting requirements.
Engagement with politicians, policymakers and regulators, when carried out transparently and with high regard for accuracy, allows for the best information to be used as a foundation for decisions in policymaking.
Transparency and high professional standards
When engaging with external stakeholders, Group Companies and Employees must ensure that:
- they participate in the policy process in an open and transparent manner, in compliance with all laws and regulations of the markets we operate in
- they always identify themselves by name and corporate affiliation
- they comply with our Anti-bribery and Corruption Policy, including that they do not directly or indirectly offer or give any payment, gift or other benefit to improperly influence any decision by any person to the advantage of the Group or any Group company
- they do not ask for or wilfully obtain from any person, confidential information belonging to another party, or obtain information by any dishonest means
- they do not induce any person to breach a duty of confidentiality
- they offer constructive solutions that will best meet the objectives of regulation, while minimising any negative unintended consequences
Third parties
BAT does support third parties on policy issues of mutual interest. In such cases, Group Companies and Employees must ensure that:
- they publicly acknowledge support of third party organisations, subject to commercial confidentiality requirements and data protection laws
- they never ask a third party to act in any way that contravenes this Lobbying and Engagement Policy
- they require all third parties to comply with laws and regulations of the markets in which they operate governing lobbying registration and reporting requirements
Accurate, evidence-based communication
When conducting external engagement activities, Employees must endeavour to:
- share accurate, complete and evidence-based information with regulators, politicians and policymakers to best inform decision making
Financial travel support to Public Officials
It is prohibited to provide financial, travel and/or accommodation support to Public Officials (e.g. to pay for their travel/accommodation to attend an event or business meeting). If an exceptional circumstance arises which warrants a request for this rule to be varied, then it must be approved by the Group Head of Government Affairs and the Group Head of Business Conduct & Compliance in accordance with the G&E Procedure.
Who to talk to
- Your line manager
- Higher management
- Your local LEX Counsel
- Head of Compliance: sobc@bat.com