The Way We Work
Our Standards of Business Conduct is a global policy of British American Tobacco, expressing the high standards of integrity we are committed to upholding.
Local Versions of the SoBC
Each operating company in the Group must adopt the SoBC. If a Group Company wishes to implement its own version of the SoBC, it must be at least as stringent as this SoBC, and must be noted by the Global Legal Affairs Team following support and presentation by the applicable Regional Head of Legal Affairs, and further acknowledged in writing by the AGC Business Integrity and Compliance. If the SoBC conflicts with local laws, then the local laws take precedence.
SoBC Priority
In the event of a conflict or inconsistency between the SoBC (or local version, if applicable) and any other document issued by a Group Company (including employment contracts), the terms of the SoBC (or local version, if applicable) will prevail. The terms of all policies and procedures referred to in the SoBC (or local version, if applicable) are mandatory for all Employees of BAT.
Our Delivery with Integrity global compliance programme promotes an ethical culture and communicates expected behaviours as set out in our SoBC. At BAT, we recognise that the most stable and lasting relationships are based on trust and transparency.
For this reason, we always strive for our communication and marketing initiatives to be responsible across all channels, paying close attention to how, what and with whom we communicate; for marketing communications, this is governed by our Responsible Marketing Principles (RMP), which are independent from the SoBC.
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Commitment to Integrity
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Duty to Report a Breach
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Consequences of a Breach
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SoBC Annual Confirmation and Training
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Safe and Secure Environment
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Responsible Marketing
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Media and Use of Social Media
Commitment to Integrity
We must comply with the SoBC (or local equivalent) and all laws and regulations which apply to Group Companies, our business and to ourselves. We must always act with high standards of integrity.
Our actions must always be lawful. Having integrity goes further. It means that our actions, behaviour, and how we do business must be responsible, honest, sincere and trustworthy.
We must all know, understand and follow the SoBC or local equivalent.
The SoBC applies to all Employees of BAT, its subsidiaries and joint ventures which BAT controls. If you are a contractor, secondee, trainee, agent or consultant working with us, we ask that you act consistently with the SoBC and apply similar standards within your own organisation. The SoBC is complemented by the BAT Supplier Code of Conduct, which defines the minimum standards we expect our Suppliers to adhere to, and is incorporated into our contractual arrangements.
Duty to Report a Breach
We have a duty to report any suspected wrongdoing in breach of the SoBC or the law. We should also report any such conduct by third parties working with the Group.
Be assured that BAT will not tolerate any retaliation against people who raise concerns or report suspected breaches of the SoBC or unlawful conduct.
Consequences of a Breach
Disciplinary action will be taken for conduct that breaches the SoBC or is illegal, including termination of employment for particularly serious breaches.
Breaches of the SoBC, or the law, can have severe consequences for the Group and those involved. If conduct may have been criminal, it might be referred to the authorities for investigation and could result in prosecution.
SoBC Annual Confirmation and Training
Every year, all of our Employees and Group entities must formally confirm that they have complied with the SoBC and complete training.
Employees do so as part of our annual SoBC sign-off, when we reaffirm our commitment and adherence to the SoBC, and are reminded to declare or re-declare any personal conflicts of interest for the sake of transparency.
New joiners undertake a mandatory induction covering our SoBC, including Lobbying and Engagement, and are asked to disclose conflicts of interest.
Our Group entities do so within Control Navigator, in which they confirm that their business unit or market has adequate procedures in place to support SoBC compliance.
Safe and Secure Environment
Group Companies are responsible for maintaining the safety of our people and the security of assets, as further detailed in our Group Security Procedure.
Responsible Marketing
Group Companies and Employees shall ensure the responsible marketing of Group products, as governed by our Responsible Marketing Principles (RMP) which are independent from the SoBC.
Media and Use of Social Media
If you are contacted by a journalist or media outlet for comment, please refer such requests to your local External Communications team (the Group press office can be contacted at [email protected]).
Certain uses of social media by Employees can pose risks to BAT’s assets and reputation. Employees must exercise good judgment when using social media.
