Standards of Business Conduct

Our values are a key driver in 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 help us to deliver our business results with integrity.

Our Standards of Business Conduct have been in place since the early 1990s. Every Group company and employees worldwide are expected to live up to them and to recognise our business standards are not to be compromised for the sake of results.

We conduct an annual review of our SoBC and Supplier Code of Conduct to keep them in line with compliance developments and best practice.

What our Standards cover

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

As a part of our review of the SoBC and its associated procedures, we have 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 managed fairly and objectively.

Anti-bribery and corruption

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

• They do not offer, approve, 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 (or encourage others to do so);
• 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 if it 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 or laws and regulations related to anti-financial crime topics.

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 SoBC enables staff to speak up and raise concerns, in confidence, about possible wrongdoing or breaches of our policy, 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 and members of the public 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 of BAT p.l.c. receives regular reports on Speak Up allegations and provides oversight that the policy and procedures in place incorporate arrangements for the proportionate and independent investigation of matters raised and for the appropriate remedial action.

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

www.bat.com/speakup

Compliance

All Group companies adopt 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.