bat malaysia - Standards of Business Conduct

British American Tobacco Malaysia's Standards of Business Conduct form an integral part of our corporate governance. Together with the Statement of Business Principles, they continue to underpin our commitment to high standards of corporate responsibility.

Our Group’s employees are governed by the Standards of Business Conduct (Standards) which form an integral part of our Group’s corporate governance. It is a fundamental policy of the Group and the Standards require all employees to observe and comply with the laws and regulations applicable to them as well as operate in accordance with high standards of business integrity. Employees must exercise honesty, objectivity and diligence in doing their work and must ensure that the Standards are never compromised for the sake of results. As such, the Standards continue to underpin our commitment to high standards of corporate responsibility.

The Standards are designed to:

(a) help employees who are faced with making difficult judgements in the course of doing their work and ensure that all decisions and judgements made by employees are lawful and comply with high ethical standards;

(b) set a tone and culture for the organisation which will enable it to be regarded as a good corporate citizen; and

(c) give reassurance to the Group’s stakeholders, with whom the Group comes into business contact.

The areas covered by the Standards are: 

  1. Whistleblowing
  2. Conflicts of Interest
  3. Bribery and Corruption
  4. Entertainment and Gifts
  5. Political Contributions
  6. Charitable Contributions
  7. Accurate Accounting and Record Keeping
  8. Protection of Corporate Assets
  9. Confidentiality and Information Security
  10. Insider Dealing and Market Abuse
  11. Competition Law and Anti-Trust Laws
  12. Money Laundering and Anti-Terrorism
  13. Trade in Products
  14. Sanctions

To ensure compliance, all management employees, including the Board of Directors are required to declare their compliance with the Standards and disclose any conflicts of interest on a yearly basis. Conflicts of interest to be declared in the compliance are in relation to whether the employee and/or immediate family have an interest in or association with the operations of the companies/business which may lead to a conflict of interest. Immediate family here includes parents, spouse, children, brothers and sisters as well as step and adoptive relations.

Among the conflicts of interest declared by employees of the Company is the declaration by Datuk Mohamad Salim bin Fateh Din (Datuk Salim), the Chairman of the Board, where the renting of space for siting of cigarette merchandising units to be entered into by Jutaria Gemilang Sdn Bhd (JGSB), which is a company indirectly owned by him through Gapurna Sdn Bhd pursuant to Section 131 of the Companies Act 1965. Gapurna Sdn Bhd holds 70% interest in JGSB and Datuk Salim in turn holds 98.25% of Gapurna Sdn Bhd.

The obligation to comply with the Standards also extends to the Group’s suppliers and service providers and is essential in ensuring high standards of business ethics amongst all suppliers and service providers of the Group, including the suppliers’ or service providers’ related companies. The applicable provisions in the Standards are incorporated in the agreements with the relevant suppliers or service providers. It is made clear in all agreements with suppliers and service providers that breaches of any provisions in the Standards of which the relevant supplier or service provider have been made aware of, may lead to immediate termination of the agreement with the said supplier or service provider.

Compliance with the Standards is monitored regularly by the Board of Directors and Audit Committee of the Company. The Legal Department/Company Secretary of the Group is charged with the responsibility of reporting to the Board of Directors on an annual basis, the compliance of these Standards by the Group and its employees. Employees have a duty to report incidences of non-compliance with the Standards and any other incidences of wrongdoing at work.

The Standards is made available to our employees and Board of Directors on the Company’s intranet (Interact website) and the Company’s corporate website.
Read more about our   PDF: Standards of Business Conduct - Standards of Business Conduct (356 kb) Opens in new window

Additional Information : Whistle-blowing policy 

The Company has adopted a whistle-blowing policy which serves as an early warning system to assist the Company in detecting wrongdoings and taking early corrective action. It is the Board’s belief that having a whistle-blowing procedure in place will increase investors’ confidence in the Company and is in line with the Company’s sound corporate governance practices.

The whistle-blowing policy is one of the key provisions in the Standards of Business Conduct and was established in 2004 and is reviewed by the Company for enhancements from time to time. The whistle-blowing procedure enables employees to make their concerns known without fear of retaliation and with the knowledge that their complaints will be acted upon and their identity is kept confidential.

To further enhance the whistle-blowing procedure framework, the Company had put in place the Procedures on Incident Reporting and Investigation (Incident Procedures). The Incident Procedures is made available to all employees via the Company’s intranet. The Incident Procedures formally set out the process and procedures for reporting, investigation and evaluation of any suspicion of wrongdoing or misconduct committed by any employee of the Company and non-employee who is a business partner/service provider of the Company in a prompt and effective manner. The evaluation of any incidences reported is conducted by a formal evaluation committee comprising a majority of the Company’s Leadership Team (EVT). The EVT is tasked to effectively drive and evaluate the investigation of any reported incident and decide on appropriate action to be taken arising from the investigation and is guided in its review of all investigation of incidents reported by a set of standard operating procedures (EVT SOP). The EVT SOP amongst others sets out clearly the roles and responsibilities of the EVT, the Head of Investigation, the Head of Legal and the timelines for the review to be completed to ensure that speedy action is taken after an incident hasbeen reported.

All incidents reported were investigated by an investigation team comprising of senior managers working closely with the EVT to ensure that all cases which have been reported or discovered are investigated upon promptly. The reports of investigation are then sent to the EVT for review and evaluation and if the case warrants it, police reports will be made, domestic inquiries will be conducted and appropriate disciplinary action including freezing of increments, issuance of warnings and termination will be taken. If any control weaknesses are identified by the investigation team such weaknesses will be rectified to prevent future occurrences.

The outcome of the investigations and the actions taken by the Company will be reported to the Audit Committee of the Company and further submitted to the Regional Audit Committee for the British American Tobacco p.l.c’s Main Board Audit Committee. The Company maintains a register of all whistle-blowing and breach of Standards incidences.

With the presence of the whistle-blowing procedure, Incident Procedures and stringent control measures, the Company detected seven incidents involving areas such as theft and the gross losses suffered by the Company arising from the incidents reported in 2013 were approximately RM77,687.62. Four employees were dismissed from the Company’s employment as a result of their misconduct.  This is an improvement from 2012 where eighteen incidents were reported and the gross losses suffered by the Company arising from those incidents were approximately RM547,700.00.


Page last updated: 17/09/2014 12:20:41 GMT
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British American Tobacco (Malaysia) Berhad (4372-M)