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.

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.

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.

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.

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

‘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.

means Gifts and/or Entertainment.

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

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.

means any company in the British American Tobacco Group.

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

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.

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.

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.

means the Group Mergers and Acquisitions Transactions Compliance Procedure.

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

shall mean all other entities and individuals excluding Public Officials.

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.

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

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

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.

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.

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.

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

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

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.

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.

means British American Tobacco p.l.c.

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

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.

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.