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 (BATM 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 revised Standards are:

1. Conflicts of Interest
2. Bribery and Corruption
3. Whistleblowing
4. Entertainment and Gifts
5. Respect in the Workplace
6. Human Rights and Our Operations
7. Political Contributions
8. Charitable Contributions
9. Accurate Accounting and Record Keeping
10. Protection of Corporate Assets
11. Confidentiality and Information Security
12. Insider Dealing and Market Abuse
13. Competition Law and Anti-Trust Laws
14. Money Laundering and Anti-Terrorism
15. Illicit Trade
16. Sanctions
17. Principles for Engagement

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.

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 Standards of Business Conduct (8,222 kb) 

Bribery and Corruption

Third-Party Anti Bribery and Corruption Procedure

The Group has adopted zero tolerance approach on bribery and corruption. It is wholly unacceptable for the Group, its employees, business partners and suppliers to be involved or implicated in any way in bribery and corrupt practices.
The Group has implemented a new Third-Party Anti Bribery and Corruption Procedure (Procedure) which provides a framework for appropriately identifying, assessing, mitigating and monitoring bribery and corruption risk when dealing with any third party. This Procedure applies to all third parties with which the Group engages in the course of its business, including (but not limited to) all customers, distributors and suppliers (Third Parties).
All Third Parties will undergo a targeted due diligence which focuses on identifying and dealing with any Third Parties that pose any risk from a bribery and corruption perspective. Trainings were conducted to ensure adequate knowledge and competency to those employees executing this due diligence exercise. After due conduct of such due diligence, specified mandatory or discretionary risk mitigation requirements are followed. An example of such risk mitigation requirement is to ensure anti bribery contractual terms are included in the contract.

Employees are required to, at any time becoming aware of anything suspicious that may carry a bribery and corruption risk about a Third Party anywhere in the Group (whether proposed or already engaged) to promptly escalate and report their concerns.

Whistleblowing

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.

Raising concerns and reporting

Employees can raise concerns directly to their line manager, HR business partner or the Group’s Designated Officer who is the Head of Legal. Alternatively, employees can raise their concerns through a Speak Up whistleblowing portal which is confidential and independently managed via telephone or internet. The Speak Up portal are available 24 hours a day in English and Bahasa Malaysia. Our business partners are also welcome to report their concerns and can do so via out Speak Up portal.

The link to our Speak Up whistleblowing portal is available here: www.bat.com/speakup 

Investigation of concerns

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.