Lobbying and Engagement
BAT is committed to corporate transparency. As a responsible company all our engagement activities with external stakeholders must be conducted with transparency, openness, and integrity. We have a legitimate contribution to make to policyrelated debate that affects our operations, and our Employees are required to engage in accordance with this chapter5.
The Group has a Legitimate Role to Play
Civic participation is a fundamental aspect of responsible business and policymaking, and BAT Employees must participate in the policy process in a transparent and open manner, by complying with all laws and regulations of the markets in which they operate, including all lobbying registration and reporting requirements.
Our engagement with politicians, policymakers and regulators is focused on providing them with accurate information, conveyed in a transparent manner. This creates a strong foundation on which external stakeholders can make policy decisions.
Quick Links
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Transparency and High Professional Standards
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Third Parties
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Accurate and Complete Communication
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Financial Travel Support to Public Officials
Transparency and High Professional Standards
When engaging with external stakeholders, Group Companies and Employees must ensure that:
- they participate in the policy process in an open and transparent manner by complying with the laws and regulations of the markets we operate in;
- they always identify themselves by name and corporate affiliation;
- they comply with our Anti-Bribery and Corruption chapter of this SoBC, including that they do not directly or indirectly offer or give any payment, gift or other benefit to improperly influence any decision by any person to the advantage of the Group or any Group Companies;
- they do not ask for or wilfully obtain from any person, confidential information belonging to another party, or obtain information by any dishonest means;
- they do not induce any person to breach a duty of confidentiality; and
- they offer constructive solutions that will best meet the objectives of regulation, while minimizing any negative unintended consequences.
Third Parties
BAT does support third parties on policy issues of mutual interest. In such cases, Group Companies and Employees must ensure that:
- they publicly acknowledge support of third-party organizations, subject to commercial confidentiality requirements and data protection laws;
- they never ask a third party to act in any way that contravenes this Lobbying and Engagement chapter or the Anti-Bribery and Corruption chapter of this SoBC; and
- they require all third parties to comply with laws and regulations of the markets in which they operate governing lobbying registration and reporting requirements.
Accurate and Complete Communication
When conducting external engagement activities, Employees must endeavor to:
- share accurate and complete information with regulators, politicians and policymakers to best inform decision-making.
Financial Travel Support to Public Officials
It is prohibited to provide financial travel and/or accommodation support to Public Officials (e.g. to pay for their travel/accommodation to attend an event or business meeting). If an exceptional circumstance arises which warrants a request for this rule to be varied, then it must be approved by the Group Head of Government Affairs and the AGC Business Integrity and Compliance in accordance with the G&E Procedure.
When engaging with external stakeholders, Group Companies and Employees must ensure that they participate in the policy process in an open and transparent manner, complying with all laws and regulations of the markets we operate in.
Who to Talk to
Your line manager
Higher management
Your local Legal Counsel
Head of Corporate Compliance: [email protected]
Speak Up Portal: bat.com/speakup
Speak Up Hotlines: bat.com/speakuphotlines