British American Tobacco - Standards of Business Conduct

Our values are a key driver to delivering our A Better Tomorrow™ purpose, as they guide our culture and behaviours across the entire Group.

These values and behaviours are enshrined in our Standards of Business Conduct (SoBC), which set out the high standards of integrity we are committed to upholding, provide guidance on workplace situations, and ensure we deliver our business results with integrity.

Our Standards of Business Conduct have been in place since the early 1990s. Every Group company and all staff worldwide are expected to live up to them and to ensure our business standards are never compromised for the sake of results.

We conduct a detailed, periodic reviews of our SoBC and Supplier Code of Conduct to ensure they remain at the forefront of best practice, with the most recent review taking place in 2023.

What our Standards cover

Our Standards of Business Conduct set out the Group policy, and provide guidance to staff, in the following specific areas:

•  Speak Up
•  Our people: respect in the workplace
•  Human rights
•  Health, safety and welfare
•  Environment
•  Conflicts of interest
•  Anti-bribery and corruption
•  Gifts and entertainment (G&E)
•  Lobbying and engagement
•  Political contributions
•  Community investments
•  Accurate books and records
•  Protection of corporate assets
•  Data privacy, ethics, and artificial intelligence
•  Cybersecurity, confidentiality and information security
•  Insider dealing and market abuse
•  Competition and antitrust
•  Sanctions and export controls
•  Anti-illicit trade in the Group’s products
•  Anti-tax evasion and anti-money laundering
   

Our Standards of Business Conduct are available in multiple languages.

Regularly reviewed and updated

In 2023 we expanded our Data privacy policy to cover ethics and artificial intelligence, and made further updates to a number of key chapters to keep pace with the external environment and simplified language to aid employee understanding.

We have also updated our SoBC Assurance Procedure, which complements our SoBC by setting out in more detail how allegations of wrongdoing or breaches of the SoBC should be followed up, to ensure that they are dealt with fairly and objectively.

Anti-bribery and corruption policy

Corruption causes distortion in markets and harms economic, social and political development, particularly in developing countries. Our Standards of Business Conduct make clear that it is wholly unacceptable for our companies and employees to be involved or implicated in any way in corrupt practices. It is our policy that Group companies and their employees must ensure that:

•  They do not offer, promise or give any gift, payment or other benefit to any person (directly or indirectly), to induce or reward improper conduct or directly or indirectly influence any decision by any person to our advantage;
•  They do not solicit, accept, agree to accept or receive any gift, payment or other advantage from any person (directly or indirectly) as a reward or inducement for improper conduct or which influences, or gives the impression that it is intended to influence, decisions of the Group; and
•  Their activities do not otherwise contravene any applicable anti-corruption measures.
   

Each Group company is required to maintain, as part of its books of account, a register of political donations, gifts, community investment and non-commercial sponsorships made by or on behalf of the company. Agents, consultants and other third parties engaged on behalf of any Group company are expected to apply standards of business conduct consistent with our Supplier Code.

Confidential Speak Up procedures

The Group’s Speak Up policy contained within our Standards enables staff to speak up and raise concerns, in confidence, about possible wrongdoing or breaches of our Standards, and to do so without fear of reprisal.

Raising concerns and reporting

Staff can raise concerns with their line manager, HR or one of the Group’s Designated Officers. Alternatively, they can use our confidential, independently managed external Speak Up channels via telephone or online. Our Speak Up channels are available 24 hours a day in local languages and are highlighted in our internal trainings and communications.

Our business partners are also welcome to report their concerns and can do so via our Speak Up portal, the details of which are available to suppliers.

The Audit Committee receives regular reports on Speak Up allegations, and remains satisfied that the policy and procedures in place incorporate arrangements for the proportionate and independent investigation of matters raised and for the appropriate follow-up action.

The link to our Speak Up whistleblowing portal is available below:

www.bat.com/speakup

Compliance

All Group companies have adopted our Standards of Business Conduct or local policies reflecting our SoBC. Information on compliance with the Standards is gathered at a global level and reported quarterly to the Audit Committee. For more information, including compliance figures, see Our Standards of Business Conduct compliance.