Guidance for Line Managers
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What We Ask of Line Managers
What We Ask of Line Managers
- know BAT’s ethos and stand up for what is right
- coach their team to ensure they know how to ‘Deliver with Integrity’ and recognise consistent behaviours
- role model respect in the workplace
- foster an environment in which concerns are freely raised without fear of retaliation
- raise concerns when appropriate to do so
No line manager has authority to order or approve any action contrary to the SoBC, or against the law.
If a manager asks orders you to do something in breach of the SoBC or the law, raise this with higher management, your local LEX Counsel or a ‘Designated Officer’ ([email protected]). You can also report the matter through our confidential Speak Up hotline if you do not feel able to speak to someone internally
In no circumstances will we allow our standards to be compromised for the sake of results. How you deliver is as important as what you deliver.
Click on the tiles below to find out line managers’ responsibilities by SoBC policy:
Speak Up
Social and environment
Personal and business integrity
External stakeholders
Corporate assets and financial integrity
National and international trade
Click on the icons below to toggle between policies
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Group Speak Up policy
Group Speak Up policy
Your role in managing Speak Up:
- Encourage an environment where your team feels comfortable raising concerns freely and without fear of retaliation – we do not tolerate the harassment or victimisation of anyone raising concerns or anyone who assists them. Such conduct is itself a breach of the SoBC and will be treated as a serious disciplinary matter.
- Listen and support your team when they raise concerns, and address their concerns.
- Notify your local Legal and External Affairs team (LEX) of concerns brought to your attention – line managers have an additional duty to raise any concerns brought to their attention. Those who ignore such concerns, or stop or discourage someone from Speaking Up, could face disciplinary action.
Our people: respect in the workplace
Human rights
Health, safety and welfare
Environment
Our people: respect in the workplace
Your role in managing respect in the workplace
- Create an open and inclusive climate for your team, where harassment and bullying are not tolerated.
- Treat your reports fairly and inclusively, with dignity and respect.
- Respect your reports’ characteristics and opinions, and do not practice any form of unlawful discrimination.
- Encourage your team to Speak Up if they experience or witness Respect in the Workplace issues.
- Use the Manager’s D&I (diversity and inclusion) Toolkit to understand how to create an inclusive culture.
Resources
The Managers’ Diversity & Inclusion Toolkit – ask your local HR team
Human rights
Your role in promoting our Human rights policy
- If your reports work with suppliers, ensure they know how to access the Supplier Code so they can direct their supplier contacts to read our human rights requirements
Health, safety and welfare
Your role in promoting health, safety and welfare
Coach your team to:
- take reasonable care of the health and safety of themselves and others while at work;
- cooperate fully in all health and safety-related matters;
- not interfere with, or misuse equipment provided for, safety; and
- report any unsafe conditions in accordance with Global EHS Policy Manual
Resources
Environment
Your role in championing our Environment policy
Encourage your reports to contribute to our environmental management efforts by:
- understanding their personal environmental impact and identifying opportunities to use resources responsibly;
- ensuring they are familiar and comply with all environmental laws and regulations and our Global EHS Policy Manual;
- ensuring that our suppliers and partners comply with the minimum standards for environmental sustainability set out in our Supplier Code of Conduct; and
- reporting any non-conformances in accordance with the Global EHS Policy Manual
- undertake the Environmental Sustainability Foundation Programme, available on our employee learning platform, the GRID
Conflicts of interest
Anti-bribery and corruption
Gifts and entertainment
Conflicts of interest
Line managers play a critical role in managing Conflicts of interest
- Whether disclosed directly to you or in the SoBC Portal, via the SoBC app, or on hardcopy offline forms, you must consider what steps to take to manage each conflict of interest disclosed by your reports, including new joiners.
- For more information on risk levels and practical guidance on managing conflicts of interest, see the Conflicts of Interest Guide for Line Managers
Resources
Read the Conflicts of Interest Guide for Line Managers
Login to the SoBC Portal to disclose or update conflicts of interest
Anti-bribery and corruption
Your role in promoting the ABAC Policy
- Ensure your reports are aware that the ABAC Procedure has been replaced by the integrated Third Party Anti-Financial Crimes Procedure
- If your reports work with suppliers, ensure they know how to access the Supplier Code so they can direct their supplier contacts to read our anti-bribery and corruption rules
Gifts and entertainment
Your role in managing Gifts and entertainment
- You should only approve G&E in line with the SoBC G&E Policy and Procedure.
- Ensure your direct reports understand the SoBC G&E Policy.
- If your reports work with suppliers, ensure they know how to access the Supplier Code so they can direct their supplier contacts to read our G&E rules
Resources
G&E Tracker (www.bat.com/ge only available when on BAT’s O365 network)
Lobbying and engagement
Political contributions
Community investment
Lobbying and engagement
Your role in managing Lobbying and engagement
- If relevant to their roles, ensure that your reports who engage with Public Officials, politicians, policy makers or regulators, and any Third Parties who lobby or engage on our behalf, do so transparently, in accordance with the SoBC Lobbying and Engagement Policy
Resources
Political contributions
Your role in managing Political contributions
- If you or your reports engage with Public Officials, politicians or policy makers, ensure you are all familiar with the Political Contributions Policy.
- The SoBC Political Contributions Policy states under Personal political activity that employees should notify their line managers in advance if they plan to seek or accept public office. As a line manager you should discuss this with your report to establish whether such official duties may affect their work, and cooperate to minimise any such impact.
Resources
Community investment
Your role in managing Community investment
- If relevant to their roles, ensure your reports are aware that the Charitable Contributions Policy has been renamed the Community Investment Policy, and any community investment should only be made in accordance with the Group Community Investment Framework
Resources
Protection of corporate assets
Data privacy, confidentiality and information security
Protection of corporate assets
Your role in managing Protection of corporate assets
- When your direct reports’ employment with BAT ends, ensure you complete the necessary administrative tasks to deactivate their access rights to BAT systems.
- Contact IDT and / or HR for more information if you’re unsure how to deactivate access rights.
Data privacy, confidentiality and information security
Your role in managing Data privacy
- Where relevant, identify which roles in your team involve the handling of personal data, and ensure your relevant reports complete the Data Privacy training.
Anti-illicit trade
Competition and anti-trust
Sanctions and export controls
Anti-tax evasion and anti-money laundering
Anti-illicit trade
Your role in managing Anti-illicit trade
If relevant to your roles:
- make sure your team makes our position on illicit trade clear to our customers and relevant Third Parties.
- coach your team to regularly monitor and assess illicit trade in our markets.
- maintain controls to prevent our products being diverted into illicit trade channels – read the ‘Supply Chain Compliance Procedure’ and other relevant guidance
Competition and anti-trust
Your role in managing Competition and antitrust
- Where relevant, coach your team to understand that competition and antitrust is not only relevant to Marketing teams – it can also be relevant to roles in HR and Procurement
- Identify who in your teams the Competition and Antitrust Policy is most relevant to and encourage them to complete the Competition Law training.
- Contact your local LEX team for information on additional local training.
Resources
Competition and antitrust eLearning (Login to the SoBC Portal)
Find Competition Quick Guides on the Competition and antitrust SharePoint site
Sanctions and export controls
Your role in managing Sanctions
Where relevant:
- identify which of your reports might be exposed to Sanctions risks and ensure they read and comply with the Sanctions Policy, Procedure, and Sanctions Compliance Framework
- ensure relevant suppliers your team works with are also familiar with our Sanctions rules in the Supplier Code
Resources
Sanctions eLearning (Login to the SoBC portal)
Find the Sanctions Compliance Framework on the Sanctions SharePoint page
Anti-tax evasion and anti-money laundering
Your role in managing Anti-tax evasion and anti-money laundering
- Identify who in your team is at risk of encountering possible money laundering or tax evasion, and ensure they are familiar with red flags to look out for. There are several examples of red flags in the Anti-Tax Evasion and Anti-Money Laundering Policy.
- If your reports work with suppliers, ensure they know how to access the Supplier Code so they can direct their supplier contacts to read our anti-tax evasion and anti-money laundering rules