Supplier Code of Conduct
Agreement
Taking into account that in accordance with the Order of the General Director of UZBAT JV JSC (hereinafter referred to as "UZBAT") the Procedure on risk management in relation to Third Parties in financial crimes and the Supplier Code of Conduct, defining the basic provisions of good faith behavior of both UZBAT employees and all UZBAT business partners and their employees (hereinafter referred to as "Company") were approved,
The parties to this Agreement represented by UZBAT and the Company have agreed as follows:
The Company agrees to implement UZBAT's current Supplier Code of Conduct as set forth below and to ensure that all officers and employees of the Company comply with such Supplier Code of Conduct.
Company will Comply with applicable laws, including any such laws relating to bribery, corruption, money laundering, terrorist financing, illicit trade and/or tax evasion (including its facilitation) (including without limitation the UK Bribery Act 2010, the US Foreign Corrupt Practices Act 1977, the UK Criminal Finances Act 2017, the Proceeds of Crime Act 2002 and any applicable local laws (including local taxation laws).
In case of detection of the fact of improper performance by the Company of paragraphs 1-2 of this Agreement, all agreements concluded between the Parties and in force on the date of detection of the fact of improper performance may be terminated by UZBAT unilaterally immediately after the occurrence specified in this paragraph of the event. In the event of termination of existing agreements in accordance with this paragraph, the Parties, by a separate agreement, undertake to agree on further actions on unfulfilled contractual obligations.
Hereby the Company irrevocably agrees and confirms that it will take all legally significant actions available to it to prevent imposition of liability on UZBAT, and/or claims to UZBAT from third parties, including state bodies, arising from bad faith actions/inaction of the Company, including in case of non-performance by the Company of the terms of this Agreement. Besides, the Company shall be liable for any indirect, special, incidental or consequential damages (including loss of profit), incurred by UZBAT due to non-fulfillment by the Company of the terms of this Agreement.
Economic sanctions
1.1 In this clause:
“Affiliate” means, (i) an entity (other than Customer) that directly or indirectly, through one or more intermediaries, owns more than 50% of the outstanding voting securities of the Customer, and (ii) an entity that directly or indirectly through one or more intermediaries, is controlled by the Supplier, in each case where the term “control” means possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract interest or otherwise
"Associated Parties" includes Affiliates officers, directors, employees, contractors, shareholders, representatives or agents.
"Prohibited Territory" means Afghanistan, Belarus, Iran, Myanmar, North Korea, Russia, Syria and the non-Ukrainian-government-controlled areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts, and Crimea & Sevastopol, such list as may be updated and notified by UZBAT from time to time.
"Sanctioned Person" means a person or entity (including any bank) (i) listed on any applicable sanctions list as from time to time amended, including but not limited to the United Nations Consolidated Sanctions List, the United States' Office of Foreign Assets Control ("OFAC") List of Specially Designated Nationals and Blocked Persons, the United Kingdom's Consolidated List of Financial Sanctions Targets and UK Sanctions List, the European Union's Consolidated List of Persons, Groups and Entities Subject to Financial Sanctions, or (ii) incorporated, headquartered or based in Iran, Syria, Cuba, North Korea, the non-Ukrainian-government-controlled areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts, or Crimea & Sevastopol.
"Economic Sanctions" means any law, regulation, directive, decree or decision relating to economic, financial, trade or other sanctions, including but not limited to any trade restriction, embargo, import or export ban, prohibition or restriction on dealings with Sanctioned Persons, governments, countries, groups or territories and any prohibition on the provision, receipt or transfer of funds, assets or services, or equivalent measures imposed, administered, enacted or enforced from time to time by: (i) the European Union or any of its Member States; (ii) the United Kingdom including His Majesty's Treasury and the Department for Business and Trade; (iii) the United States including OFAC, the Bureau of Industry and Security and the United States Department of State; (iv) the United Nations including any United Nations Security Council Sanctions Committee; or (v) or any other relevant governmental or regulatory authority including of any country in which obligations under this Agreement are to be performed.
1.2 The Supplier represents, warrants and undertakes that:
(a) Neither it nor, to the best of its knowledge and belief, any of its Associated Parties is currently (i) a Sanctioned Person, (ii) owned or controlled directly or indirectly by a Sanctioned Person or (iii) incorporated or resident in, or owned or controlled by or acting on behalf of the government of a Prohibited Territory.
(b) Neither it nor, to the best of its knowledge and belief, any of its Associated Parties is aware of any circumstance, or has taken any action, directly or indirectly, that could result in a breach of any applicable Economic Sanctions by the Supplier, Supplier's Affiliates UZBAT and/or UZBAT's Affiliates.
(c) The Supplier shall maintain a bank account with a non-Sanctioned Person financial institution for the purpose of this Agreement and will procure that all funds transferred in connection with this Agreement, or arising as a result of this Agreement, shall be transferred using non-Sanctioned Person financial institutions exclusively (with no funds originating from or passing through any Sanctioned Person financial institution).
(d) Any transaction subject to this Agreement is conditional on UZBAT 's designated bank permitting the transfer of funds to or from the Supplier, , where the bank account provided by the Supplier is residing within a Sanctioned Person financial institution, the transfer may not be permitted and the Supplier would be required to provide a bank account with a non-Sanctioned Person financial institution.
(e) It conducts and has conducted its business in full compliance with applicable Economic Sanctions and has instituted and maintains policies and procedures designed to ensure continued compliance with Economic Sanctions.
(f) In performing its obligations under this agreement or other agreements between UZBAT and the Supplier, the goods are not and will not be delivered from, to or via transhipment through any Prohibited Territory, or Cuba. If there is no other commercially viable alternative, the Supplier must obtain an express written consent from UZBAT for such transhipment and agrees to cooperate with UZBAT to ensure sanctions-compliant conditions for the entire transaction.
(g) It will promptly notify UZBAT in writing together with all relevant details if it is unable to perform its obligations under this Agreement as a result of the imposition of Economic Sanctions (including the imposition of Economic Sanctions against a country or person or the addition of an item or service to a list of sanctioned items or services under Economic Sanctions).
(h) Following notification in accordance with clause 1.2.g it will work with UZBAT to agree, within a reasonable period, a practical solution to permit continuity of this Agreement in a manner that is compliant with Economic Sanctions.
(i) No supply of services or goods under this Agreement is directly or indirectly destined to or sourced from Cuba, or intended to benefit persons in Cuba.
1.3 If the Parties do not agree a practical solution within [10] Business Days of receipt of notification under clause 1.2(g), or if UZBAT considers that such a risk is incapable of mitigation to its satisfaction, UZBAT may terminate this Agreement immediately by notice. During such 10 Business Days period the Parties' respective obligations under this Agreement are suspended.
1.4 The Supplier agrees that UZBAT may inspect or otherwise undertake an audit of the records relating to its obligations under this Agreement, including at the Supplier's premises. The Supplier will provide all relevant access, information and documentation to UZBAT to facilitate its audit as promptly as possible.
1.5 Notwithstanding any provision of this Agreement to the contrary, UZBAT shall not be obligated to make any payment or take any other action under this Agreement (and shall not be liable for failure to take or delay in taking any action under this Agreement) if UZBAT determines in its sole reasonable opinion that such action may constitute a violation or contribute to any violation of, or otherwise expose it to negative consequences under, Economic Sanctions.
1.6 UZBAT shall additionally have the right at any time to terminate its commercial relationship with the Supplier (including this and any other relevant agreement) by giving written notice to the Supplier in the event that:
(a) UZBAT reasonably believes the Supplier and/or its Affiliates:
(i) has breached or committed any offence under any Economic Sanctions; or
(ii) has taken any action which would cause UZBAT to breach any Economic Sanctions;
(b) UZBAT, in its sole discretion, determines that any action, performance, or non-performance by the Supplier and/or its Affiliates may be or is likely to be in violation of, inconsistent with or could expose UZBAT and/or its affiliates to any negative consequences under Economic Sanctions; or
(c) the Supplier and/or its Affiliates becomes a Sanctioned Person or owned or controlled by a Sanctioned Person. Prior to UZBAT issuing a notice of termination under clause 1.6(a) and (b),
the Supplier shall have the opportunity to respond to any breaches and /or violations alleged by UZBAT. If no time period for a response is notified, such response should be provided within 14 days of the date of the alleged breaches and / or violations being notified to the Supplier by UZBAT.
Supplier Code of Conduct
Terms and Definitions
“BAT”, “Group”, “we”, “us” and other forms of these pronouns mean British American Tobacco p.l.c. and all of its subsidiary companies.
“Standards of Business Conduct” means (i) the Group Standards of Business Conduct, available at www.bat.com/sobc and in our SoBC app, and/or (ii) local versions of the Standards of Business Conduct adopted by Group companies and available on their local websites.
“Code” means this Supplier Code of Conduct, available at www.bat.com/suppliercode and in our SoBC app.
“Suppliers” means any third parties that supply goods or services and have direct commercial relationships with any company within the BAT Group.
“Workers” means employees, workers, and contractors of Suppliers, including permanent, full-time and part-time employees, temporary workers, contract workers, subcontracted or agency workers, as well as seasonal workers.
Message from Our Chief Operating Officer
Transformation at BAT means reducing the impact of our business on people's health, while focusing on environmental and sustainability priorities, as well as social and commercial priorities.
Importantly, our sustainability approach extends beyond our own operations to the wider supply chain. To this end, we use our expertise and influence to encourage and support our Suppliers on their sustainability journeys.
The BAT Group works with an extensive network of Suppliers worldwide, ranging from small-scale farmers and international tobacco leaf Suppliers to Suppliers of materials such as paper and cigarette filters. For New Category Products, we have developed an evolving supply chain spanning consumer electronics and e‑liquids. We also work with a large number of Suppliers of indirect goods and services unrelated to our products, such as IT services and facilities management.
This Code has been updated to reflect our focus on sustainability and the constantly evolving external landscape in which we operate.
At the same time, we remain committed to delivering positive social impact and ensuring robust corporate governance across the Group. In 2024, we invited more than 750 Suppliers to participate in the CDP Supply Chain programme. This collaboration enables us to strengthen engagement with Suppliers, drive environmental progress, and further enhance sustainability.
We recognise that many global sustainability challenges—such as climate change, waste, the circular economy, biodiversity conservation, responsible water stewardship, and positive social impact—cannot be addressed in isolation. By working with our Suppliers, contracted farmers, and other stakeholders across the supply chain, we can develop solutions that deliver long-term change.
A key element of our relationships with Suppliers is confidence that concerns or issues can be raised if something does not seem right. BAT takes this Code and its Standards of Business Conduct very seriously. Therefore, if you become aware of any actual or potential breaches, please report them through any of the channels set out in this Code. I personally guarantee that all concerns raised will be handled under conditions of strict confidentiality. You will not face retaliation, even if you are unsure about your judgement.
I firmly believe that, through close collaboration with our Suppliers, we can continue to raise standards, improve sustainability practices, and create shared value.
Zafar Khan, Chief Operating Officer, Group
Introduction
BAT's Standards of Business Conduct (SoBC) set out the high standards of integrity and ethical conduct that we expect throughout our business. This Supplier Code of Conduct (the Code) complements the SoBC by establishing the minimum standards of behaviour that we require our Suppliers to meet and to cascade to their subsidiaries, subcontractors, and other business partners within their supply chains.
International Standards
This Code supports our ongoing commitment to respect human rights and is informed by internationally recognised standards, including:
The United Nations (UN) Guiding Principles on Business and Human Rights
The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work
The Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises
Legal Primacy
Where the requirements of this Code conflict with applicable local laws or regulations, local law shall take precedence.
Where this Code establishes standards that exceed the requirements of local law, Suppliers are expected to comply with the higher standards set out in this Code, except where doing so would be unlawful under applicable local law.
Scope and Application
All Suppliers are required to comply with this Code as a condition of supplying goods or services to BAT and any company within the BAT Group (together referred to as “BAT”).
Suppliers must comply with the requirements of this Code. These requirements shall be incorporated into BAT's contractual arrangements with Suppliers.
In addition, Suppliers must:
- take appropriate steps to ensure that all of their Workers, suppliers, agents, subcontractors, and other relevant third parties understand and comply with the requirements of this Code, including—where appropriate, having regard to the nature of the Supplier and the goods or services provided—maintaining adequate policies, procedures, due diligence processes, training, and support; and
- promote compliance with this Code and conduct appropriate due diligence within their own supply chains in respect of both new and existing suppliers (including farmers, where applicable).
Engagement with the Group:
Any information that Suppliers are required to provide to the Group under this Code must be communicated through one of the following channels:
the Group company contact responsible for the Supplier;
Group Head of Procurement: procurement@bat.com;
Speak Up reporting channels: www.bat.com/speakup;
Speak Up hotlines: www.bat.com/speakuphotlines.
A Better Tomorrow™, Together: How We Work with Suppliers
Our Suppliers are valued business partners, and we believe that—by working together—we can raise standards, embed sustainable practices, create shared value, and build A Better Tomorrow™ for all.
Commitment to Integrity
Our actions must always be lawful. However, integrity requires more than compliance with the law alone. It means that our actions, behaviours, and ways of doing business must be responsible, honest, transparent, and trustworthy. We are committed to meeting our contractual obligations to Suppliers and to acting fairly and in good faith.
Suppliers can expect clear and constructive engagement from BAT, as well as professional and inclusive treatment, dignity, and respect, in line with our Standards of Business Conduct (SoBC).
If a Supplier has a complaint or concern regarding the conduct of a BAT employee acting in breach of the SoBC, this should be reported to BAT via the channels set out in the “Engagement with the Group” section on the following page.
Aspiration to Best Practice
While this Code sets out the minimum standards that we expect our Suppliers to meet, we encourage them to strive for best practice and continuous improvement across their own operations and supply chains.
To support this, we seek to prioritise Suppliers that demonstrate strong performance aligned with the Group's sustainability priorities.
This approach is reflected in our Supplier programmes, including, but not limited to:
- the industry‑wide Sustainable Tobacco Programme for our tobacco leaf Suppliers, which incorporates a broad range of sustainability criteria—covering labour practices and human rights, as well as climate change and biodiversity; and
- our supply‑chain due‑diligence programmes for non‑tobacco Suppliers, which include human‑rights risk assessments and independent labour audits conducted in line with international standards.
Supporting Suppliers
We recognise that our Suppliers operate in diverse circumstances globally and that some may face legitimate challenges in fully meeting all the requirements of this Code.
As our objective is continuous improvement in supply‑chain standards, we are committed to supporting such Suppliers so that they can achieve compliance with this Code over time.
By working together and leveraging our respective resources and expertise, we aim to raise awareness, build capability, and support our Suppliers in achieving full compliance with this Code and in progressing towards leading practice.
BAT Sustainability Priorities
Further information on the Group's sustainability priorities is available in our annual Sustainability Report, accessible at: www.bat.com/investors-and-reporting/reporting/combined-annual-and-esg-report
Compliance with the Code
We are committed to monitoring compliance with this Code, investigating concerns, and ensuring that any issues identified are appropriately addressed.
Compliance with Laws
We expect our Suppliers to comply with all applicable laws, codes, and regulations and to conduct their business ethically.
Accordingly, Suppliers must:
- comply with all applicable laws, rules, and regulations in all jurisdictions in which they operate;
- promptly notify the Group of any material criminal or civil legal proceedings brought against them; and
- promptly notify the Group of any fines, penalties, or administrative sanctions imposed on them that relate in any way to the requirements set out in this Code.
Monitoring Compliance
We reserve the right to assess Suppliers' compliance with this Code through internal and/or external assessment and audit mechanisms.
Suppliers are required to provide full and reasonable cooperation with any review relating to this Code (conducted by the Group or third parties engaged by it), including the retention of relevant documentation and data for the period specified by the Group and/or applicable law, and granting independent access to relevant personnel, sites, documentation, and data.
These requirements do not override lawful restrictions applicable to commercially sensitive and/or confidential information. In such circumstances (and where such information is considered relevant to the review), Suppliers must work with the Group to agree mutually acceptable mechanisms for its lawful and secure disclosure.
Raising Concerns
Suppliers must support the identification, investigation, risk mitigation, remediation, and reporting of potential or actual breaches of this Code and/or the Standards of Business Conduct.
Accordingly, Suppliers must:
- have effective grievance mechanisms or equivalent procedures that enable their Workers, in confidence and without fear of retaliation, to ask questions, raise concerns, and/or report suspected or actual breaches—either to the Supplier or directly to the Group—with the option to do so anonymously;
- promptly investigate any substantiated concerns regarding potential or actual breaches of this Code and take appropriate action to prevent potential breaches and/or mitigate their impacts and to address any actual breaches; and
- notify the Group of any suspected or actual breaches of the requirements of this Code and/or the SoBC as soon as they become aware of them, as outlined in the “Speak Up” section below.
Speak Up Channels
Actual or suspected breaches of this Code or the SoBC may be reported to the Supplier's usual Group contact or through our confidential, independently managed Speak Up reporting channels, available at: www.bat.com/speakup
Our Speak Up channels are independently operated and available online (via written submissions and telephone hotlines) 24 hours a day, 7 days a week, in multiple languages. Reports may be made confidentially (and anonymously, if you choose), without fear of retaliation. If you choose to use a hotline, you can select your location on the website to identify the appropriate international number for your country.
You will not be subject to any form of retaliation (direct or indirect) for raising concerns about actual or potential breaches, even if the concern ultimately proves to be unfounded. We do not tolerate any retaliation, harassment, or victimisation of anyone who raises a concern, supports someone in doing so, or participates in an investigation.
Investigations
We take all concerns, allegations, and reports of potential or actual breaches of this Code and/or the Standards of Business Conduct seriously. Where appropriate, we will investigate such matters fairly and objectively in accordance with our internal policies and procedures.
In other cases, we may request that the Supplier conducts an investigation in line with its own procedures.
At BAT's request, the Supplier must cooperate with BAT and keep us informed of the scope, progress, and outcome of any investigation, including any wider issues, concerns, or potential or actual adverse impacts identified through such investigation, subject to confidentiality obligations and other applicable legal requirements.
Consequences of Non‑Compliance
In the event of non‑compliance with any requirement of this Code, the Group reserves the right to require the relevant Supplier to:
- demonstrate meaningful progress towards meeting such requirements within a defined and reasonable timeframe; and/or
- bring its practices fully into compliance with such requirements within a defined and reasonable timeframe.
In cases of serious, material, and/or persistent non‑compliance, or where a Supplier otherwise demonstrates a lack of commitment, ongoing inaction, or failure to improve, we reserve the right to terminate our business relationship with that Supplier.
Engagement with the Group:
Your usual contact within the relevant Group company
Group Head of Procurement: procurement@bat.com
Speak Up reporting channels: www.bat.com/speakup
Speak Up hotlines: www.bat.com/speakuphotlines
Human Rights
We are committed to applying the United Nations Guiding Principles on Business and Human Rights and to respecting human rights across our own operations and throughout our supply chain.
Respect for Human Rights
We expect our Suppliers to conduct their business in a manner that respects fundamental human rights, as reflected in the International Bill of Human Rights. This expectation extends, without limitation, to their own Workers and to individuals working for their suppliers.
Suppliers must take appropriate steps to identify and assess actual or potential adverse impacts on human rights and to act on the findings.
They must take appropriate measures to:
- ensure that their operations, activities, and business relationships do not cause, contribute to, or become directly linked to human‑rights abuses; and
- prevent, mitigate, and remediate any adverse human‑rights impacts.
Where an adverse human‑rights impact is identified, Suppliers must take appropriate action in the circumstances to bring such impact to an end or, where this is not immediately possible, to minimise its severity and extent.
We expect Suppliers, in relation to their own Workers, to meet at least the following requirements.
Equality and Non‑Discrimination
Suppliers must provide equal opportunities and fair treatment to all Workers.
This must include:
- measures to prevent and eliminate all forms of harassment and bullying in the workplace (including sexual, verbal, non‑verbal, or physical); and
- treating all Workers with dignity and respect and ensuring that no form of unlawful discrimination occurs.
Discrimination may include, but is not limited to, unfair decisions relating to recruitment, employment, training, development, promotion, or termination on grounds such as race, ethnic origin, colour, sex, age, disability, sexual orientation, gender identity or expression, social class, religious or political beliefs, marital status, pregnancy, trade‑union membership, or any other characteristic protected by applicable law.
Health and Safety
Suppliers must provide and maintain a safe and healthy working environment.
This must include, without limitation:
- procedures to identify, assess, and address occupational health and safety hazards and associated risks, and to implement safe working practices;
- conducting fire‑risk assessments appropriate to the workplace, premises, and/or activities, and implementing fire‑safety plans with appropriate fire‑prevention systems and emergency‑evacuation procedures;
- providing appropriate personal protective equipment (PPE), where required, to prevent work‑related injury or ill health;
- implementing appropriate controls, where required, to ensure the safe handling, storage, transportation, and disposal of substances hazardous to health or the environment, including flammable materials;
- providing appropriate and regular training and communication, including—where necessary—consultation for Workers on health risks, safety matters, and working procedures; and
- where accommodation is provided, ensuring that it is clean, safe, and meets basic standards of acceptable living conditions and Workers' needs.
Freedom of Association
Suppliers must respect the rights of all Workers, in accordance with applicable law, to freedom of association and collective bargaining.
This includes the right to representation by recognised trade unions or other legitimate worker representatives, in line with applicable laws, regulations, established labour relations, practices, and agreed company procedures. Such Workers and representatives must be able to carry out lawful activities in the workplace without detriment.
Fair Wages and Benefits
Suppliers must provide fair wages and benefits.
At a minimum, Suppliers must comply with applicable minimum‑wage legislation and all other relevant laws or collective agreements.
Zero Tolerance for Child Labour
We are committed to working with Suppliers to prevent the use of child labour in our supply chain and to ensuring that, where instances are identified, appropriate remediation is implemented.
In particular, International Labour Organization (ILO) standards must be observed, including:
- work that is considered hazardous or likely to harm the health, safety, or morals of children must not be performed by persons under the age of 18; and
- the minimum age for employment must not be lower than the legal age for completion of compulsory education and, in any event, must not be less than 15 years.
Subject to local law, children aged between 13 and 15 may engage in light work, provided that such work does not interfere with their education or vocational training and does not involve any activity that is hazardous or likely to harm their health or development (for example, work involving mechanical equipment or agrochemicals).
By exception, we also recognise training or apprenticeship programmes approved by a competent authority.
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Child Labour in Agriculture The realities of agricultural life in many parts of the world mean that certain types of work can play a formative, cultural, social, and family role for children.According to Article 118 of the Labour Code of the Republic of Uzbekistan, for the purpose of preparing young people for work, students of general secondary, secondary specialised, and vocational educational institutions may be employed to perform light work that does not harm their health or moral development and does not disrupt their education, during their free time from studies, upon reaching the age of fifteen and with the written consent of one of their parents or a legal guardian. According to Article 412 of the Labour Code of the Republic of Uzbekistan, the employment of persons under the age of eighteen is prohibited in work with unfavourable working conditions, underground work, and other types of work that may harm the health, safety, or morality of this category of workers. Persons under eighteen are not permitted to lift or carry loads exceeding established limits. The list of prohibited work for persons under the age of eighteen, as well as maximum permissible loads for lifting and carrying, is approved by the Ministry of Employment and Poverty Reduction of the Republic of Uzbekistan and the Ministry of Health of the Republic of Uzbekistan, in coordination with the Republican Tripartite Commission on Social and Labour Issues. Accordingly, under local law, children over the age of 15 may assist their family, provided that they are engaged only in light work that does not interfere with their education or vocational training and does not involve any activity that is considered hazardous or likely to harm their health or development (for example, work involving mechanical equipment or agrochemicals). |
Elimination of Modern Slavery and Labour Exploitation
Suppliers must implement effective policies and procedures to reduce the risk of modern slavery and labour exploitation.
This includes ensuring the absence of slavery, servitude, forced or compulsory labour, human trafficking, or exploitative labour practices.
Accordingly, Suppliers—and any recruitment agents or labour intermediaries acting on their behalf-must not require Workers to:
- pay recruitment fees, take out loans, or make unreasonable payments for employment‑related services; or
- surrender identity documents, passports, or have work permits retained.
Where national law or recruitment procedures require the use of identity documents, Suppliers must handle such documents strictly in accordance with applicable law. Identity documents may be held only for safekeeping or security purposes and only with the Worker's informed, genuine, and written consent. Workers must have unrestricted access to their personal documents at all times and without limitation.
Conflict Minerals
Conflict minerals are minerals originating from conflict‑affected or high‑risk areas that may directly or indirectly finance armed groups or contribute to human‑rights abuses.
Where products or materials supplied to the Group contain columbite‑tantalite (coltan), cassiterite, gold, wolframite, cobalt, or their derivatives (including tantalum, tin, and tungsten), we expect Suppliers to take appropriate steps to ensure that conflict minerals are not used, including by:
- conducting appropriate due diligence;
- making reasonable country‑of‑origin inquiries, including requiring their own suppliers to carry out equivalent due diligence; and
- providing the Group, upon request, with any information required by BAT to meet its conflict‑minerals reporting obligations.
Working Hours
Suppliers must comply with all applicable working‑time laws and any other relevant laws or collective agreements, including all legally mandated requirements relating to maximum working hours.
Engagement with the Group:
Your usual contact within the relevant Group company
Group Head of Procurement: procurement@bat.com
Speak Up reporting channels: www.bat.com/speakup
Speak Up hotlines: www.bat.com/speakuphotlines
Environmental Sustainability
We are committed to adopting behaviours and practices aligned with leading environmental standards and to reducing the Group's impact on the natural environment, both within our own operations and across our supply chain.
Environmental Impacts
We expect Suppliers to proactively identify, assess, and actively address, minimise, and mitigate their impacts on the natural environment.
Where practicable, this should include the development and implementation of an environmental policy and an environmental management system.
Environmental impacts may include, without limitation, those associated with emissions to air, water, land, and forests, the use of materials, consumption of natural resources, and waste‑management practices.
Where relevant, Suppliers should also take into account the need to protect biodiversity, including preventing deforestation and habitat fragmentation, and protecting endangered and threatened species.
Environmental Management
We expect Suppliers to consider environmental factors in product design, operations, and/or the provision of services, and to comply with all applicable local legal and regulatory environmental requirements. These expectations should also extend throughout their supply chains. Where appropriate, environmental policies and practices should be integrated into business strategy and day‑to‑day operations.
Suppliers should strive for continuous improvement in environmental performance, supported—where appropriate and practicable—by the implementation of recognised environmental standards and management practices, such as ISO 14001 or an equivalent standard.
In addition, we encourage Suppliers to report on and publicly disclose their environmental performance and progress, including through international initiatives such as the Science Based Targets initiative (SBTi), the Science Based Targets Network (SBTN), and the Carbon Disclosure Project (CDP).
We expect Suppliers to provide the Group, upon request, with available information relating to their environmental performance, as we seek to reduce the environmental impact of our operations, products, and services.
Where relevant, this may include (without limitation):
- life‑cycle assessments relating to Group products;
- data and information relating to waste associated with Group products;
- plans to reduce the Group's Scope 3 carbon emissions; and
- data and information relating to the origin of timber or wood‑pulp‑based materials.
In line with the BAT Group Environmental Policy, we encourage Suppliers to consider environmental impacts across the following priority areas:
- addressing climate change;
- reducing waste and supporting the transition to a circular economy;
- protecting biodiversity and forests; and
- responsible water stewardship.
Addressing Climate Change
We expect Suppliers to manage, monitor, and maintain records of their environmental performance in relation to greenhouse gas (GHG) emissions, in order to:
- understand their own GHG emissions (Scope 1 and Scope 2);
- reduce their own GHG emissions;
- understand GHG emissions within their supply chains (Scope 3); and
- work with their own suppliers to reduce GHG emissions across the supply chain.
Our minimum expectations of Suppliers include:
- making reasonable efforts to source 100% of purchased electricity from renewable sources by 2030; and providing BAT, upon request, with reporting on Scope 1 and Scope 2 emissions.
We also expect Suppliers to make efforts to:
- provide BAT, upon request, with reporting on Scope 3 emissions.
Where relevant and practicable, Suppliers should aim to:
- implement a GHG or energy management system (for example, ISO 50001);
- achieve net‑zero emissions across the value chain no later than 2050;
- provide externally assured reporting on Scope 1, 2, and 3 emissions; and improve primary data for products and services using activity‑specific emission factors (for example, through full life‑cycle assessment).
Further information on GHG accounting and reporting standards is available at:
https://ghgprotocol.org
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Understanding Scope 1, Scope 2 and Scope 3 Emissions Carbon emissions are categorised into three scopes in accordance with the Greenhouse Gas (GHG) Protocol of the World Business Council for Sustainable Development: · Scope 1 covers direct emissions from sources that are owned or controlled by the organisation. · Scope 2 covers indirect emissions from the generation of purchased electricity, steam, heating, and cooling consumed by the organisation. · Scope 3 includes all other indirect emissions that occur across the organisation's value chain, including emissions associated with purchased goods and services. |
Responsible Water Stewardship
Where relevant, we expect Suppliers to reduce water abstraction and increase water reuse within their operations.
Suppliers should be aware of the level of water risk in the areas in which they operate, as defined by recognised sources such as the World Resources Institute (WRI).
We expect Suppliers to make efforts to understand their dependence on water and the impacts of their operations and value chains on water resources, with particular attention to areas facing water scarcity.
Where relevant and practicable, Suppliers should aim to reduce operational and supply‑chain water‑related risks, ideally by applying the Alliance for Water Stewardship (AWS) Standard or an equivalent standard of comparable rigour.
Protection of Biodiversity and Forests
Where applicable, we expect Suppliers to take measures to protect, conserve, and restore nature, and to work towards zero deforestation across the supply chains for products and materials supplied to the BAT Group.
We expect our Suppliers to adhere to responsible‑sourcing principles that support our ambition to establish supply chains that do not result in deforestation or ecosystem conversion.
Suppliers must ensure that pulp‑ and paper‑based materials are sourced from deforestation‑free origins.
Farmers within our tobacco supply chain must ensure that any wood used is not derived from deforestation or land conversion. Where possible, independent certification should be obtained.
Where relevant and practicable, Suppliers should seek to understand their dependence on biodiversity and the impacts of their operations and value chains on biodiversity.
Waste Reduction and Transition to a Circular Economy
Over time, we expect Suppliers to use fewer resources, generate less waste, and enable reuse, recycling, and circularity in their products and processes.
Suppliers must ensure that all materials supplied to the BAT Group for packaging are fully reusable, recyclable, or compostable.
We expect Suppliers to make efforts to increase the use of recycled content in packaging materials supplied to the BAT Group.
Where relevant and practicable, Suppliers should aim to design products in line with circularity principles, including—without limitation—increasing the use of renewable inputs and reducing reliance on virgin materials.
Engagement with the Group:
Your usual contact within the relevant Group company
Group Head of Procurement: procurement@bat.com
Speak Up reporting channels: www.bat.com/speakup
Speak Up hotlines: www.bat.com/speakuphotlines
Marketing and Trade
We are committed to upholding the principles of responsible marketing and responsible trade of the Group's products.
Responsible Marketing
We adhere to the principles of responsible marketing for all our products intended for adult consumers aged 21 and over. Our marketing activities are governed by our International Marketing Principles and Responsible Marketing Code, available at:
www.bat.com/imp and https://bat.uz/otvetstvennyj-podhod/mezhdunarodnye-printsipy-marketinga/
Accordingly, we expect Suppliers involved in the marketing and sale of our products to comply with the following requirements:
- the Group's Responsible Marketing Principles and Responsible Marketing Code as the minimum standard, where these are more stringent than local laws; or applicable local laws or other local marketing regulations, where these are more stringent than, or override, the Group's marketing principles.
Illicit Trade
Tackling illicit trade in our products is a key priority for the Group. Illicit trade in contraband and counterfeit products, as well as the unlawful resale of genuine BAT products, damages our business and undermines BAT's reputation.
We do not condone or tolerate any involvement in illicit trade in our products, and it is critical that Suppliers do not directly or indirectly engage in, facilitate, or support illicit trade involving our products.
Accordingly, Suppliers must:
- refrain from knowingly engaging in, or supporting, illicit trade in our products;
- implement effective controls to prevent illicit trade, including:
- robust due‑diligence procedures for all customers and/or suppliers;
- measures to ensure that product supplies to the market are aligned with legitimate demand; and
- procedures, where appropriate, to investigate, suspend, and terminate relationships with customers, suppliers, or other parties suspected of involvement in illicit trade; and
- cooperate with authorities in any official investigation into illicit trade, provided that such cooperation is lawful and fully consistent with our zero‑tolerance approach to bribery, corruption, and fraud, recognising the heightened bribery and corruption risks associated with interactions with public officials.
Forms of Illicit Tobacco Products
Counterfeit products: unauthorised copies of branded products manufactured without the knowledge or permission of the trademark owner.
Products on which local taxes have not been paid: unlawfully imported goods or goods that evade local taxes, including products legally manufactured in one country for the purpose of illegal sale in another country without payment of applicable taxes and duties.
Smuggled products: products (genuine or counterfeit) that are moved across borders without payment of taxes or duties in the intended retail market, or in breach of laws prohibiting their import or export.
Engagement with the Group:
Your usual contact within the relevant Group company
Group Head of Procurement: procurement@bat.com
Speak Up reporting channels: www.bat.com/speakup
Speak Up hotlines: www.bat.com/speakuphotlines
Business Ethics
We are committed to the highest standards of business integrity in everything we do. Commercial success must never take precedence over our ethical standards.
Definitions
“Improper conduct” means performing (or failing to perform) business activities or public functions in a manner that is inconsistent with principles of integrity, impartiality, or other applicable obligations.
“Facilitation payments” are small payments made to expedite or secure the performance by a public official of a routine action to which the payer is already entitled. In most countries, facilitation payments are prohibited by law. In some countries, such as the United Kingdom, facilitation payments made by nationals of those countries overseas also constitute a criminal offence.
Conflicts of Interest
Suppliers must avoid conflicts of interest in their business dealings and act with full transparency in relation to any situations in which a conflict of interest arises or may arise.
Accordingly, Suppliers must (and must require the same of their Workers):
- avoid situations in which their personal and/or business interests, or the interests of their officers or employees, conflict or are likely to conflict with the interests of the BAT Group;
- disclose to the Group any interest in their business, or economic relationship with them, held by BAT employees or members of their close family; and
- promptly notify the Group of any situation that constitutes, or may reasonably be perceived as, an actual or potential conflict of interest, and provide transparency regarding how such conflict is being managed.
These provisions are not intended to prevent Suppliers from conducting lawful and legitimate business with competitors of the Group.
Bribery and Corruption
It is unacceptable for Suppliers (or their Workers or agents) to be involved in bribery or any other form of corruption.
Accordingly, Suppliers must never engage in any conduct that could constitute bribery, including:
- under no circumstances offering, authorising, promising, or giving any gift, payment, or other benefit (such as hospitality, kickbacks, employment or internship offers, or investment opportunities) to any person, directly or indirectly, in order to induce or reward improper conduct or to improperly influence any decision for their benefit or for the benefit of the Group, nor encouraging others to do so;
- under no circumstances requesting, accepting, agreeing to accept, or approving the receipt of any gift, payment, or other value or benefit from any person, directly or indirectly, where the purpose is to induce improper conduct, reward it, or influence Group decisions (or where it may create the appearance of such influence);
- under no circumstances offering, promising, or giving any gift, payment, or other benefit to a public official with the intention of influencing them in their official capacity for their own benefit or for the benefit of the Group;
- under no circumstances making facilitation payments (directly or indirectly) in connection with the Group's business, except where strictly necessary to protect the health, safety, or liberty of any Worker; and
- implementing proportionate and effective controls to prevent the offering, making, requesting, or receipt of unlawful payments by third parties providing services to or on behalf of the Supplier or the Group.
Fraud
Fraud includes any dishonest statement or deliberate concealment of material information made for the purpose of obtaining an undue advantage or causing loss to another party.
Fraud also includes the deliberate abuse of business relationships, deception of creditors, submission of false reports, and misleading public authorities. Fraud may be committed even if no actual benefit is obtained or loss incurred; the making of a false statement or other dishonest act alone may constitute an offence.
Accordingly, Suppliers must:
- always act honestly in dealings with third parties, including refraining from making false statements, concealing information, submitting false reports, evading taxes, or deceiving business partners; and
- maintain proportionate and effective controls to ensure that no fraudulent activity is carried out for their benefit or for the benefit of the Group.
Gifts and Entertainment (G&E)
The occasional giving or receiving of gifts and participation in entertainment may be an acceptable business practice. However, inappropriate or excessive gifts or entertainment may constitute bribery or corruption and can seriously damage BAT and our Suppliers.
Suppliers must not offer or accept gifts or entertainment where this could constitute, or be perceived as, bribery or another form of corrupt conduct. In this regard:
- Suppliers are expected, when doing business with Group companies and employees, to comply with the Group's Gifts and Entertainment principles set out in the Standards of Business Conduct;
- the exchange of gifts or entertainment between BAT employees and Suppliers is prohibited during tenders, bids, or competitive procurement processes involving the Group; and
- Suppliers must not directly or indirectly attempt to influence a public official on behalf of the Group by providing gifts, entertainment, or other personal benefits to that official or to any other person, such as close family members, friends, or associates. Gifts to public officials above a token value are rarely appropriate.
Sanctions and Export Controls
Suppliers must ensure that their business activities comply with all applicable international sanctions and export‑control regimes and must not engage with sanctioned territories or parties where such dealings are prohibited or restricted.
Accordingly, Suppliers must:
- understand and strictly comply with all applicable sanctions and export‑control regimes relevant to their activities; and
- implement effective internal controls to minimise the risk of sanctions or export‑control breaches (including breaches by the Group), and provide appropriate training and support to ensure that Workers understand and apply these controls—particularly where their roles involve sourcing from sanctioned territories, international financial transfers, cross‑border shipments, or the purchase of products, technologies, or services.
What Are Sanctions and Export Controls?
Sanctions are restrictions or prohibitions on trade or transactions, including financial transfers, involving certain countries or individuals, imposed by individual states such as the United States and the United Kingdom, or by supranational bodies such as the United Nations and the European Union, against other countries, legal entities, or individuals.
Some sanctions regimes are very broad. For example, US sanctions may apply to non‑US persons in relation to activities conducted outside the United States. In particular, US sanctions prohibit the use of US dollars and US banks for payments between non‑US parties involving sanctioned parties, as well as the export or transfer of US‑origin products to, from, or for the benefit of sanctioned territories or persons.
Anti‑Money Laundering and Counter‑Terrorist Financing
It is unacceptable for Suppliers (or their Workers or agents) to engage in, or be associated with, money laundering or terrorist‑financing activities.
Suppliers must have effective controls in place to prevent any activity that constitutes money laundering or terrorist financing in any relevant jurisdiction, or that could cause BAT to commit such an offence. This includes, without limitation, concealing or converting illicit funds or property, possessing or dealing in the proceeds of crime, knowingly facilitating the financing of terrorist groups or activities, transferring assets for their benefit, or otherwise providing support.
Business Records and Confidentiality
To conduct business with the Group, Suppliers may be required to access confidential and sensitive information relating to our business.
Accordingly, Suppliers must:
- safeguard and protect the confidentiality of such information;
- not disclose confidential information without the Group's prior authorisation; and
- remain mindful of the risk of inadvertent disclosure of confidential information when discussing or handling documents in public places.
Suppliers must also maintain accurate and up‑to‑date business records (both financial and non‑financial) in accordance with applicable laws and ensure that personal data is processed in compliance with all relevant data‑protection and privacy laws. Any records relating to the Group's business must be retained for the period required by the Group.
Data Privacy and Cybersecurity Risks
We are committed to protecting the integrity and security of our systems and data (including personal data) throughout our supply chain.
Suppliers must implement appropriate systems and controls to protect Group data, including personal data, and—where relevant—to access Group systems. Many Suppliers store or process Group personal data or confidential information.
In addition to complying with global data‑privacy laws, such as the General Data Protection Regulation (GDPR), adherence to good “cyber hygiene” practices is critical to safeguarding Group data and systems and protecting the Group's business. Accordingly, we expect our Suppliers to comply with applicable data‑protection and cybersecurity laws, regulatory guidance, and recognised industry best practice (including data‑protection impact assessments, where legally required, and cyber‑threat assessments).
Cybersecurity threats and risks associated with how data (including personal data) is managed are continually evolving. It is therefore essential that Suppliers implement appropriate technical measures, policies, and processes to protect Group data and to ensure that any access to Group systems and any data processing activities are secure and controlled in accordance with documented procedures.
Accordingly, Suppliers must:
- implement and maintain appropriate data‑protection, information‑security, and cybersecurity policies and keep them regularly updated;
- continuously monitor compliance with such policies and promptly implement any necessary corrective actions;
- promptly investigate any suspected breaches of data‑protection policies or security incidents and notify the Group without delay of any such incidents or events that may affect Group data or systems; and
- where required, implement any remedial actions reasonably requested by the Group.
Data‑Protection and Cybersecurity Risk Assessments
Suppliers must regularly assess risks to their organisation and the potential impact on the processing of Group data (including personal data) or access to Group systems and data.
Suppliers should take into account risks relating to Group data in their possession, as well as any access to Group systems, in line with recognised threat‑modelling and risk‑assessment frameworks.
Fair Competition and Antitrust Compliance
We support free and fair competition in accordance with competition (or “antitrust”) laws.
Accordingly, Suppliers must compete fairly and ethically and comply with competition laws in every country and economic area in which they operate.
Tax Evasion
Suppliers must comply with all applicable tax laws and regulations in the jurisdictions in which they operate and act openly and transparently in dealings with tax authorities.
Under no circumstances must Suppliers engage in, or facilitate, deliberate unlawful tax evasion for themselves or on behalf of others.
Accordingly, Suppliers must implement effective controls to minimise the risk of tax evasion or facilitation thereof, and provide appropriate training, support, and reporting mechanisms to ensure that Workers understand and apply such controls effectively and are able to raise relevant concerns.
Engagement with the Group:
Your usual contact within the relevant Group company
Group Head of Procurement: procurement@bat.com
Speak Up reporting channels: www.bat.com/speakup
Speak Up hotlines: www.bat.com/speakuphotlines
To Find Out More
Please contact:
Group Head of Procurement: procurement@bat.com
British American Tobacco p.l.c.
Globe House
4 Temple Place
London WC2R 2PG
United Kingdom
Tel: +44 (0)20 7845 1000
Link to the previous version of the document:
https://bat.uz/en/about-us/for-our-business-partners/supplier-code-conduct/