Examples of wrongdoing include:

• criminal acts, including theft, fraud, bribery, corruption and violation of sanctions;
• endangering the health or safety of an individual or damaging the environment;
• bullying, harassment (including sexual harassment) and discrimination in the workplace, modern slavery or other human rights abuses;
• accounting malpractice or falsifying documents;
• other breaches of the SoBC or other global policies, principles or standards of the Group;
• failing to comply with any legal obligation, by act or omission;
• a miscarriage of justice;
• concealing any wrongdoing; and
• causing others to commit any of the above.

Wrongdoing does not include situations where you are unhappy with your personal employment position or career progress. Grievance procedures are available in such cases, and details on how to raise a grievance are available from HR.

If you are a line manager, you have an additional duty to escalate any concerns brought to your attention to Legal Affairs. Those who ignore such concerns, or stop or discourage someone from Speaking Up, could face disciplinary action.

You have several options to raise your concerns, and you can use the one you are the most comfortable with:

• Designated Officer;
• an HR manager or Legal Counsel;
• your line manager; and
• our confidential, independently managed external Speak Up channels (www.bat.com/speakup), which are operated independently of management, enable you to raise concerns online or via telephone (anonymously if you prefer).

Four senior Group executives act as our Group Designated Officers. Anyone can raise a concern with them directly.

• the AGC Business Integrity and Compliance: Tamara Gitto;
• the Company Secretary of British American Tobacco p.l.c.: Caroline Ferland;
• the Group Head of Internal Audit: Graeme Munro; and
• the Group Head of Reward: Jon Evans.

You can contact them by email ([email protected]), phone (+44 (0)207 845 1000) or by writing to them at British American Tobacco p.l.c., Globe House, 4 Temple Place, London WC2R 2PG.

No matter how you choose to Speak Up, your identity will be kept confidential as we fairly and objectively investigate your concerns.

Where appropriate, BAT will take action which may include disciplinary action against individuals found to have breached the SoBC.

Where feasible and appropriate, you will also receive feedback on the outcome of the investigation, if we are able to contact you.

You can read more about how we will escalate and investigate your concerns in the Group SoBC Assurance Procedure.

We have Designated Officers responsible for receiving concerns, based locally throughout the world.

This SoBC policy is supplemented by the Group SoBC Assurance Procedure, which sets out in more detail how concerns or allegations of breach of the SoBC are escalated and investigated. The Group SoBC Assurance Procedure forms an integral part of the SoBC and must be complied with as if it was part of the SoBC.

You will not suffer any form of reprisal (whether directly or indirectly) for speaking up about actual or suspected wrongdoing, even if you are unsure.

We do not tolerate any retaliation, harassment or victimisation of anyone who raises a concern, provides assistance to those raising concerns or participates in an investigation. Such conduct is itself a breach of the SoBC and will be treated as a serious disciplinary matter.