Human rights and modern slavery

In addition, each year we publish our Modern Slavery Statement, in accordance with the UK Modern Slavery Act. The statement details the steps taken by BAT plc and subsidiary Group companies to prevent modern slavery and human trafficking in our business and supply chains.

Our Combined Annual ESG Report also provides comprehensive details of our approach to human rights and performance for the year, in the context of our broader Sustainability Agenda.

Our approach to human rights

Our approach to human rights management is aligned to the UN Guiding Principles on Business and Human Rights (UNGPs). This includes following a defined process to identify our most important and salient human rights impacts, for which:

•  We engage: to understand the views of, and impacts upon, our key stakeholders and rights-holders across our value chain, including extensive engagement with rights-holders in tobacco-growing communities as part of our human rights impact assessments;
•  We research: to understand our place in the big picture and identify emerging risks, trends and best practice; and
•  We prioritise: to focus on the issues of greatest importance to our stakeholders and rights-holders.
  

Our Main Board of Directors has overall responsibility for human rights. The Board is supported by the Audit Committee, which monitors performance, risks and adherence to our standards. This oversight is underpinned by our Regional Audit and CSR Committee framework. Together, our governance framework provides a flexible channel for the structured flow of information, monitoring and oversight of key issues, including those relating to human rights, at all levels of the Group from our local business units to the Board level.

We work to keep ourselves – and our supply chain – aligned and accountable through strong policies, due diligence and remediation programmes.

Our Standards of Business Conduct (SoBC) sets out the high standards we are committed to upholding. It comprises our core global policies, including our Workplace and Human Rights Policy detailing our support for the UNGPs and the ILO’s Declaration on Fundamental Principles and Rights at Work. Our Supplier Code of Conduct complements our SoBC by defining the minimum standards expected of all suppliers to any BAT Group company – including human rights criteria.

Supply chain due diligence

Our due diligence and remediation programmes enable us to monitor the effectiveness of, and compliance with, our policy commitments, as well as to identify, prevent and mitigate human rights risks, impacts and abuses.

Due to the inherent risks in agriculture, our tobacco supply chain is particularly vulnerable to human rights issues. We have extensive due diligence in place for all our tobacco leaf operations and third-party suppliers, including the industry-wide Sustainable Tobacco Programme, systematic farm monitoring and human rights impact assessments. We also take a long-term and collaborative approach to mitigating the risks and tackling the root causes, including rural poverty.

See Human rights and child labour in tobacco growing for more details.

Beyond tobacco, we source product materials like paper and filters for cigarettes; and for our New Category products, we have a growing supply chain in consumer electronics and e-liquids. Before we start working with a new product materials supplier, they must undergo an independent audit by our partner Intertek. The audit assesses workplace conditions covering forced labour, child labour, wages and hours, health and safety, environment, and management systems. It is aligned with international standards, including those of the ILO, and we expect suppliers to achieve a minimum score of 70% to qualify.

We maintain a rigorous focus on human rights in the supply chain and conduct an annual risk assessment on 100% of our existing materials suppliers. Using independent human rights indices developed by Verisk Maplecroft, we assess suppliers’ inherent risk exposure based on their country location and the goods or services they provide. Suppliers identified as high risk are then prioritised for audits.

In 2022, we have also partnered with external provider EcoVadis to expand our due diligence programme. This means that direct materials suppliers identified as higher risk continue to be audited by Intertek, while all suppliers outside Intertek's scope are assessed through EcoVadis.

We track suppliers’ progress against the corrective action plans centrally. We have zero tolerance to serious issues, which, when identified through the audit process, are promptly remediated and validated by an independent auditor.

All other issues, identified either via Intertek or EcoVadis, are completed either by revisits (Intertek) or through a desktop review (Intertek and EcoVadis), for which the supplier provides evidence.

Subsidiary operations due diligence

Every year, all our employees and business entities must formally confirm that they have complied with the SoBC.

Our business entities complete an annual assessment against our key audit controls in which they confirm that their area of business, or market, has adequate procedures in place to support SoBC compliance. All our employees must also complete our annual SoBC sign-off, in which they reaffirm their commitment and adherence to the SoBC and declare or redeclare any personal conflicts of interest. As part of the annual sign-off procedure, employees also undergo SoBC training with examples of different scenarios they may face in their daily work, covering topics such as discrimination, modern slavery and freedom of association.

In addition, we have a defined process to identify and carefully monitor BAT operations in countries with a higher risk for human rights issues. This process includes an annual risk assessment of all countries worldwide, using Verisk Maplecroft’s human rights indices (such as its Modern Slavery Index). Our businesses in each high-risk country identified then complete a human rights assessment, confirming compliance with Group policies, standards and controls, and providing details of measures in place to enhance human rights management. The outcomes are submitted to and noted by the Group Corporate Committee and Audit Committee, and, by the relevant Regional Audit & Corporate Social Responsibility Committee (RACC), including details of action plans for any areas for improvement identified.

Our SoBC Assurance Procedure sets out in detail how allegations of wrongdoing or breaches of the SoBC should be investigated and dealt with fairly and objectively. Details of all reported allegations are monitored through the year by our Regional Audit and CSR Committees, and quarterly by the Board Audit Committee.

Speak Up channels

We encourage anyone working for, or with, the Group to raise concerns or grievances through our Speak Upchannels which are independently managed and available 24 hours a day online, by text or telephone. The channels can be used in confidence and anonymously and are available in multiple local languages, and their details are promoted through staff training and communications, the SoBC app and the Supplier Code of Conduct.

Our Speak Up Policy makes it clear no one will suffer any direct or indirect reprisal for speaking up about actual or suspected wrongdoing, even if they 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 a serious disciplinary matter.