English Supplier Code of Conduct- How to Speak Up - BAT Standards of Business

How to Speak Up

Quick Links

Speak to someone
Call a confidential Speak Up hotline
Speak Up online
Email the Group Designated Officers (GDOs)

Speak to someone

If you feel comfortable, report the matter directly to your usual Group company contact. You can also raise concerns with BAT’s Group Head of Procurement.

Call a confidential Speak Up hotline

Find your local hotline number

Speak Up online

Raise your concern on the Speak Up portal www.bat.com/speakup which is independently managed

Email the Group Designated Officers (GDOs)

Send an email to [email protected]
Four senior Group executives act as our Group Designated Officers. Anyone can raise a concern with them directly. They are:
- Tamara Gitto, AGC Business Integrity & Compliance
- Caroline Ferland, Company Secretary, BAT plc
- Graeme Munro, Group Head of Internal Audit
- Jon Evans, Group Head of Reward

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Anyone working for or with the Group who is concerned about actual or suspected wrongdoing at work (whether in the past, occurring or likely to happen) should Speak Up.

How to Speak Up

Glossary

Close Relative

means spouses, partners, children, parents, siblings, nephews, nieces, aunts, uncles, grandparents, grandchildren and cousins (including where arising by marriage, such as mother-in-law or son-in-law). Close Relative also means any person in the Employee’s household.
Collusion

any arrangement with competitors that could restrict, or aims to restrict, competition. It includes formal and informal agreements whether direct or brokered by a third party, understandings, exchanging commercially sensitive information (directly or indirectly) and decisions/recommendations of trade associations.
Community Investments

voluntary activities beyond our commercial and core business activities and our legal obligations, that contribute to the economic, social and environmental sustainability of the countries and communities in which we operate. These investments address a wide range of issues and causes in the communities where we operate, often involving charities, non-government organisations (NGOs) and ‘civil society’, and include expenditure on community projects or charitable contributions, in-kind donations and Employee volunteering.
Dealing

is widely defined in the Code for Share Dealing and includes any sale, purchase or transfer (including by way of gift), as well as spread bets, contracts for difference or other derivatives involving Securities, directly or indirectly, whether on your own or someone else’s behalf.
Employees

includes, where the context admits, directors, officers and permanent Employees of Group Companies.
Entertainment

‘Entertainment’ includes any form of virtual or face-to-face hospitality, such as food or drink, attendance at any cultural or sporting events, travel or accommodation offered or given to or received from a person or entity outside of BAT.
G&E

means Gifts and/or Entertainment.
G&E Tracker

an automated prior approval and record-keeping solution, which is mandatory for Public Official and Private Sector Stakeholder G&E above the Threshold.
Gifts

includes anything of value, even if the monetary value cannot be easily ascertained, offered or given to, or received from a person or entity outside of BAT that is not Entertainment.
Group Company

means any company in the British American Tobacco Group.
Group and BAT

means British American Tobacco p.l.c. and all of its subsidiaries.
Improper Conduct

means performing (or not performing) a business activity or public function in breach of an expectation that it will be performed in good faith, impartially or in line with a duty of trust.
Inside Information

in relation to BAT p.l.c. is information of a precise nature, which is not generally available; relates directly or indirectly to BAT p.l.c. or to its shares or other Securities; and would, if generally available, be likely to have a significant effect on the price of BAT p.l.c.’s shares or other Securities, or related investments.
Instant Messaging

means any form of instant or temporary messaging between communication devices using third-party applications (including social media direct messaging functionalities) where messages do not facilitate Group records and information management capabilities.
M&A Transactions Compliance Procedure

means the Group Mergers and Acquisitions Transactions Compliance Procedure.
Market Abuse

means conduct which harms the integrity of financial markets and public confidence in Securities and derivatives.
Private Sector stakeholder

shall mean all other entities and individuals excluding Public Officials.
Public Official

includes anyone employed by or acting for any government or public body/agency, or anyone performing a public function. This includes, for example, people working for a national, regional or local government or a public department or agency (such as an official within a government ministry, the military or police); people holding a public position; employees of state-owned or state-controlled enterprises (e.g. a state-owned tobacco company); employees of public international organisations, such as the United Nations; officials of a political party; candidates for public office; any member of a royal family; and magistrates and judges.
Record

information in any media created or received by an individual in the course of business regardless of its location or physical form.
References to ‘laws’

includes all applicable national and supra-national law and regulations.
Sanctioned Party

is an individual or entity with whom business is restricted or prohibited under the sanctions regimes implemented and/or enforced by the UN, US, EU, UK and other international organisations and national governments, which includes but is not limited to individuals or entities residing or located in, or organised under the laws of, a Sanctioned Territory, identified on sanctions lists maintained by the foregoing jurisdictions or who are otherwise the subject or target of sanctions.
Sanctioned Territory

includes territories subject to comprehensive or broad territory-wide sanctions imposed by the UN, US, EU, UK and/or other international organisations or national governments.
Securities

is widely defined in the Code for Share Dealing and includes shares (including American Depository Receipts), options, futures and any other type of derivative contract, debts, units in collective investment undertakings (e.g. funds), financial contracts for difference, bonds, notes or any other investments whose value is determined by the price of such Securities.
SoBC Portal

the platform for capturing, maintaining and managing the disclosure of conflicts of interest.
Standards and SoBC

can mean the Group Standards set out in this document and/or Standards adopted locally by a Group Company.
Suppliers

means any third party that supplies or provides direct product materials or indirect goods or services to any BAT Group company, including consultants, independent contractors, agents, manufacturers, primary producers, sub-contractors, distributors and wholesalers.
Tax

all forms of direct and indirect taxes, including corporate and personal income taxes, social security contributions, customs and excise duties, VAT and sales taxes, and any other form of taxes.
The Company

means British American Tobacco p.l.c.
Third Party AFC Procedure

means the Group Third-Party Anti-Financial Crime Procedure.
Third-Party Communications Applications

means any form of communications (e.g., email, voice memos, chats or text messages) using third-party applications (including social media applications that have direct messaging functionalities) where such communications cannot be retained or accessed per the Group Records & Information Management Procedure. This includes but is not limited to applications such as WhatsApp, WeChat, Facebook, Facebook Messenger, Instagram, iMessage, SMS text messages, Gmail, Yahoo, Hotmail, Telegram, Viber, Signal and any other similar applications.
Threshold
in relation to G&E offered, given or received, means:
- Public Officials: above £20 – prior approval must be obtained via the G&E Tracker
- Private Sector Stakeholders: G&E above £20 to £200 must be recorded in the G&E Tracker. Above £200 – prior approval must be obtained via the G&E Tracker
Group Companies should provide guidance on what is modest and lawful in their markets, not exceeding these amounts and reflecting local purchasing power and regulations.