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We must protect human rights and have a positive social impact in the communities in which we operate.
As we build A Better Tomorrow™, we respect people’s human rights in our own operations and across our broader supply chain.
Our business and supply chain span a variety of industries with significant human rights considerations, including agriculture, electronics and manufacturing. The global impact of COVID-19 means that human rights issues must now be tackled even more strongly. Whatever the product or process, our principles remain the same. We strive to promote, uphold and respect the human rights of the individuals involved.
We have a long-standing commitment to respecting fundamental human rights, as affirmed by the Universal Declaration of Human Rights. This commitment includes respecting the rights of our employees, the people we work with and the communities in which we operate, throughout our supply chains and business activities.
Protecting human rights is a clear priority in our Group Sustainability Agenda for delivering positive social impact. Our agenda also focuses on other important environmental, social and governance (ESG) topics related to human rights, including climate change, farmer livelihoods, health and safety, people, diversity and culture, and ethics and integrity.
Transparent reporting
In December 2020, we were the first tobacco company to publish a human rights report . The report presents the progress we have made, highlights our work in progress and outlines our plans for the future. It is aligned with the UN Guiding Principles Reporting Framework, which provides comprehensive guidance for companies to report on how they respect human rights in accordance with the UN Guiding Principles on Business and Human Rights. Watch our video below for more information.
BAT launches the tobacco industry’s first human rights report
In December 2020, on Human Rights Day, BAT was the first tobacco company to publish a Human Rights Report. The report highlights our commitment and actions to protect human rights throughout our global business and supply chain
In addition, we publish our Modern Slavery Statement every year, in accordance with the UK Modern Slavery Act. The statement describes the steps BAT plc and Group subsidiaries have taken to prevent modern slavery and human trafficking in our business and supply chains.
Our combined ESG annual report also provides extensive details about our approach to human rights and our performance for the year, in the context of our broader sustainability agenda.
Our approach to human rights
Our approach to human rights management is aligned with the UN Guiding Principles on Business and Human Rights (UNGPs). This includes following a defined process to identify our most significant and high profile human rights impacts, for which:
- We involve: to understand the views of and impact on our key stakeholders and rightsholders across our value chain, including extensive engagement with rightsholders in tobacco growing communities as part of our human rights impact assessments;
- We investigate: to understand our place in the big picture and identify emerging risks, trends and best practices; And
- We prioritize: to focus on the issues of greatest concern to our stakeholders and rights holders.
Our Chief Executive Board has overall responsibility for human rights. The Board is supported by the Audit Committee, which oversees performance, risk and compliance with our standards. This oversight is supported by our regional audit framework and CSR committees. Together, our governance framework provides a flexible channel for the structured information flow, monitoring and supervision of key issues, including those related to human rights, at all levels of the Group, from our local business units to the Board of Directors level.
We work to keep ourselves – and our supply chain – aligned and accountable through strong policies, due diligence and remediation programs.
Our Standards of Business Conduct (SoBC) set out the high standards we live by. It contains our main global policies, including our Workplace and Human Rights Policy, which outlines our support for the UNGPs and the ILO Declaration on Fundamental Principles and Rights at Work. Our Supplier Code of Conduct complements our SoBC by defining the minimum standards expected of all suppliers to any BAT Group company, including human rights criteria.
Due diligence in the supply chain
Our due diligence and remediation programs enable us to monitor the effectiveness and compliance with our policy obligations, and to identify, prevent and mitigate human rights risks, impacts and violations.
Due to inherent risks in agriculture, our tobacco supply chain is particularly vulnerable to human rights violations. We conduct extensive due diligence on all of our leaf tobacco and third-party supplier activities, including the industry-wide Sustainable Tobacco Program, systematic agricultural monitoring and human rights impact assessments. We also take a long-term and collaborative approach to mitigate risks and address root causes, including rural poverty.
See Human rights and child labor in tobacco farming for more details.
In addition to tobacco, we purchase product materials such as paper and filters for cigarettes; and for our New Category products, we have a growing supply chain in consumer electronics and e-liquids. Before working with a new supplier of product materials, they must undergo an independent audit by our partner Intertek . The audit assesses working conditions in the areas of forced labour, child labour, wages and hours, health and safety, environment and management systems. It is aligned with international standards, including those of the ILO, and we expect suppliers to achieve a minimum score of 70% to qualify.
We maintain a strict focus on human rights in the supply chain and perform an annual risk assessment on 100% of our existing material suppliers. Using independent human rights indexes developed by Definitely Maplecroft we assess the inherent risk exposure of suppliers based on their country location and the goods or services they provide. Suppliers identified as high risk are then prioritized for audits.
In 2022, we also partnered with third-party provider EcoVadis to expand our due diligence program. This means that suppliers of direct materials identified as being at higher risk are still monitored by Intertek, while all suppliers outside Intertek’s scope are assessed through EcoVadis.
We centrally monitor suppliers’ progress against corrective action plans. We have a zero tolerance for serious issues which, when identified during the audit process, are immediately rectified and validated by an independent auditor.
All other issues identified through Intertek or EcoVadis are resolved through revisits (Intertek) or through a desktop review (Intertek and EcoVadis), for which the supplier provides evidence.
Subsidiary operations due diligence
Each year, all of our employees and business entities must formally confirm compliance with the SoBC.
Our business entities conduct an annual review based on our key audit controls confirming that their business area or market has adequate procedures in place to support SoBC compliance. All of our employees must also complete our annual SoBC signature, reaffirming their commitment to and compliance with the SoBC and declaring or re-declaring personal conflicts of interest. As part of the annual sign-off process, employees also undergo SoBC training with examples of different scenarios they may encounter in their day-to-day work, covering topics such as discrimination, modern day slavery and freedom of association.
In addition, we have a defined process to identify and carefully monitor BAT operations in countries with a higher risk of human rights issues. This process includes an annual risk assessment of all countries around the world, using Verisk Maplecroft human rights indices (such as the Modern Slavery Index). Our companies in each identified high-risk country then conduct a human rights assessment, confirm compliance with Group policies, standards and controls and provide details of actions taken to improve human rights governance. The outcomes are presented to and noted by the Group Corporate Committee and Audit Committee, and by the relevant Regional Audit & Corporate Social Responsibility Committee (RACC), including details of action plans for areas of improvement identified.
Our SoBC Assurance Procedure details how to fairly and objectively investigate and handle allegations of misconduct or violations of the SoBC. Details of all reported allegations are reviewed year-round by our Regional Audit and CSR Committees, and quarterly by the Board Audit Committee.
Speak up channels
We encourage anyone working for or with the Group to raise concerns or complaints through us Speak up channels that are independently managed and available 24 hours a day online, by text or by phone. The channels can be used in confidence and anonymously and are available in multiple local languages, and their details are promoted through staff training and communication, the SoBC app and the Supplier Code of Conduct.
Our Speak Up Policy makes it clear that no one will suffer direct or indirect retaliation for speaking up about actual or suspected misconduct, even if they are in error. We do not tolerate harassment or victimization of anyone who raises concerns or helps them. Such conduct in itself is a violation of the SoBC and a serious disciplinary matter.
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