Insider Dealing and Market Abuse

 
 
 

We are committed to supporting fair and open Securities markets throughout the world. Employees must not deal in shares or other Securities of British American Tobacco p.l.c. (the ‘Company’) on the basis of Inside Information, or engage in any form of Market Abuse.

Find the definition of Inside Information in the Glossary.

Market Abuse

We must not commit any form of Market Abuse, including:

  • improper disclosure of Inside Information;
  • dealing in Securities on the basis of Inside Information (‘insider dealing’);
  • misuse of Inside Information; and
  • engaging in market manipulation.

Market Abuse (committing it or encouraging it in others) is illegal.

For more information about behavior that may constitute Market Abuse or insider dealing in the UK, see the British American Tobacco Code for Share Dealing (the ‘Code’).

Quick Links
  • Handling Inside Information
  • Responsible Share Dealing
 

Handling Inside Information

If you have or receive information that may be Inside Information relating to the Company, and your role within the Group does not involve you having or receiving such information, you must immediately inform the Group Company Secretary.

If your role does involve you having or receiving such information, you must follow applicable requirements and Group processes.

Care is needed when handling Inside Information, as its misuse could result in civil or criminal penalties for the Group and the individuals concerned.

If you have or receive information relating to any other publicly traded Group Company that matches or is similar to the definition of ‘Inside Information’, or if you are unsure, immediately inform the Company Secretary of the company concerned.

Any Inside Information (or similar), whether relating to a publicly traded Group or non-Group Company should be treated with the utmost confidentiality.

 

Responsible Share Dealing

We must not deal in the Securities of the Company, or encourage others to so deal, while having Inside Information relating to it.

If you intend on dealing in the Securities of the Company, then you must comply with local share dealing laws and the ‘Code’, which applies to all Employees, contractors, and Directors of the Company.

Similarly, we must not deal in the Securities of any other publicly traded Group or non-Group Company, or encourage others so to deal, while having Inside Information (or similar) relating to that company. We must comply with all applicable share dealing laws and requirements.

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Care is needed when handling Inside Information, as its misuse could result in civil or criminal penalties for the Group and the individuals concerned.

 

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