british american tobacco malaysia - Standards of Business Conduct

The Standards of Business Conduct (Standards) are a set of global policies adopted locally, which expresses the high standards of integrity that British American Tobacco (Malaysia) Berhad and subsidiaries (the Group) is committed to upholding. It is a fundamental policy of the Group which requires the Board of Directors (the Board) and its employees to observe and to comply with the laws and regulations applicable to them and also operate in accordance with the Standards. The Group believes that it must operate its business in a trustworthy and responsible manner.

The Standards are an integral part of the Group’s principles of corporate governance and are designed to:

• Ensure that decisions and judgements made by employees are lawful and comply with high ethical standards
• Set a tone and culture for the organisation which will enable it to be regarded as a good corporate citizen
• Help employees who are faced with making difficult judgements in the course of their work
• Give reassurance to the Group’s stakeholders with whom the Group comes into business contact

The areas covered by the Standards are:

(i) Whistleblowing
(ii) Conflicts of Interest
(iii)  Bribery and Corruption
(iv) Entertainment and Gifts
(v) Respect in the Workplace
(vi) Human Rights and Our Operations
(vii) Political Contributions
(viii) Charitable Contributions
(ix) Accurate Accounting and Record Keeping
(x) Protection of Corporate Assets
(xi) Confidentiality and Information Security
(xii) Insider Dealing and Market Abuse
(xiii) Competition Law and Anti-Trust Laws
(xiv) Money Laundering and Anti-Terrorism
(xv) Trade in Products
(xvi) Sanctions

The Board and the Audit Committee of British American Tobacco (Malaysia) Berhad regularly monitors compliance with the Standards. The Legal Department/Company Secretary is charged with the responsibility of reporting the aforesaid to the Board on an annual basis. Employees have a strict duty to fully commit to the Standards and report incidences of non-compliance with the Standards and any other incidences of wrongdoing at work.

The Standards are made available to our employees and the Board on the Group’s intranet (Interact website) and the Group’s corporate website at
Read more about our PDF: SOBC 2017 - SOBC 2017 (297 kb) Opens in new window

Bribery and Corruption

Anti-Corruption Toolkit

The Standards requires all employees to act with high standards of business integrity and strict compliance is therefore of significant importance to the Group. The Anti-Corruption Toolkit (Toolkit) identifies the key controls that the Group is to have in place in order to support strict compliance with the Standards. The Toolkit offers a guided approach as it identifies the applicable requirements of the Standards in different circumstances whilst providing training materials and useful documents as well as templates to facilitate compliance with the Standards and to support the Group in implementing the relevant procedures and controls.

The Toolkit is divided into the following sections:

(a) Bribery and Corruption
(b) Suppliers and Service Providers
(c) Entertainment and Gifts
(d) Political Contributions
(e) Charitable Contributions
(f) Whistleblowing
(g) Risk Assessment
(h) Compliance and Monitoring

Each of the abovementioned sections are structured to provide a statement of the key requirements of the Standards in the relevant area and a list of controls that are expected to support compliance, additional guidance on the implementation of such controls and additional materials which the Group may find useful in developing and rolling out relevant policies and procedures in training the employee.


Given the Standards on whistleblowing, the Group has set out a whistleblowing policy which details the procedures which must be followed to enable employees to voice their concerns without fear of retaliation and with the confidence that their complaints will be acted upon and their identity kept confidential. The policy is reviewed for enhancements from time to time.

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

To further enhance the whistleblowing 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 and informed to all employees during corporate on-boarding training. 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 has been reported.

All incidents which are reported will be investigated by an investigation team mandated by the EVT to ensure that all cases which have been reported or discovered are investigated upon promptly. The resulting reports of investigation are then forwarded 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 whistleblowing and breach of Standards incidences



Page last updated: 08/01/2018 08:44:49 GMT
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British American Tobacco (Malaysia) Berhad (4372-M)