We are committed to monitoring compliance to the requirements of this Code, and ensuring any issues identified are investigated and remediated.


Legal compliance

We expect our Suppliers to comply with all relevant laws, codes and regulations, and to act in an ethical manner.

As such, Suppliers must:

  • Comply with all applicable laws, codes and regulations wherever they operate and however they may apply to them;
  • Promptly notify the Group of any significant criminal or civil legal actions brought against them; and
  • Promptly notify the Group of any fines or administrative sanctions brought against them which relate in any way to the requirements set out in this Code.

Compliance monitoring

We reserve the right to verify new and existing Suppliers’ compliance with the requirements of this Code through internal and/or external assessment and audit mechanisms.

Suppliers must provide all reasonable cooperation with any verification activity linked to this Code (whether carried out by the Group or by third parties engaged by the Group), including ensuring relevant documentation and data is held for as long as required by the Group and/ or relevant laws and the granting of independent access to relevant personnel, sites, documentation and data.

Such cooperation shall be discussed and agreed to by the Group and the Supplier, to ensure that it is performed within working hours and that reasonable notice is given in advance.

This is notwithstanding legitimate restrictions applicable to commercially sensitive and/or confidential information – in such cases (and where such information is believed to be of material relevance to verification activity), Suppliers should work with the Group to try to identify mutually acceptable mechanisms for its safe and legitimate disclosure.


Reporting concerns

Suppliers are expected to support the identification, investigation, addressing and reporting of suspected or actual breaches of the requirements of this Code and/or the SoBC.

As such, Suppliers must:

  • Have effective grievance or equivalent procedures in place to enable their Workers, in confidence and without fear of reprisal, to ask questions, raise concerns and/or report suspected or actual breaches – either to the Supplier itself or directly to the Group;
  • Promptly investigate any credible concerns about suspected or actual breaches of the requirements of this Code and take appropriate action to avoid any potential breaches taking place, and/or minimise the impact of, and stop, any actual breaches; and
  • Report any suspected or actual breaches of the requirements of this Code and/or the SoBC to the Group as soon as they become aware of them as explained under Speaking Up.

Speaking Up

Any actual or suspected breaches of this Code or the SoBC can be raised with the Supplier’s usual Group contact, or through our confidential, independently managed Speak Up channels available at

Our Speak Up channels are managed independently and available online, by text and telephone hotlines, 24 hours a day, seven days a week and in multiple local languages. They can be used in confidence (and anonymously, if you prefer to do so), without fear of reprisal. If you prefer to use the hotline, you can choose your location from the list provided on the website for the international number assigned to your country.

You will not suffer any form of reprisal (whether directly or indirectly) for raising concerns 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.



We take any concerns, allegations or reports of suspected or actual breaches of this Code and/or our SoBC seriously. Where appropriate, we will investigate such matters fairly and objectively in accordance with our internal policies and procedures.

In other cases, we may ask a Supplier to lead investigation of the matter in accordance with its own procedures.

Where required by BAT, the Supplier is expected to liaise with BAT and keep us informed as to the scope, progress and outcomes of its investigation (subject to confidentiality or other applicable legal requirements).


Consequences of a breach

In the event of noncompliance with any of the requirements of this Code, the Group reserves the right to require the Supplier in question to:
  • Demonstrate material progress towards compliance with the requirement(s) in question within a defined and reasonable time period; and/or
  • Bring itself into full compliance with the requirement(s) in question within a defined and reasonable time period.

In the event of serious, material and/or persistent non-compliance, or where a Supplier otherwise demonstrates inadequate commitment, persistent inaction or a lack of improvement, we reserve the right to terminate the business relationship with the Supplier in question.


Contacting the Group