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PUTTING SUSTAINABILITY FRONT AND CENTRE - SUSTAINABILITY STRATEGY REPORT 2019 - British American ...
PUTTING
                    SUSTAINABILITY
SUSTAINABILITY
                 FRONT AND CENTRE
STRATEGY
REPORT 2019
PUTTING SUSTAINABILITY FRONT AND CENTRE - SUSTAINABILITY STRATEGY REPORT 2019 - British American ...
INTRODUCTION                                 WHO WE ARE
01 Welcome
02 Letter from our Chief Executive           BAT is a leading, multi-category consumer
04 Our new Sustainability Agenda             goods business. Our purpose is to build
HEALTH IMPACT                                ‘A Better Tomorrow’ by reducing the health
06	Health impact: our principal ESG focus   impact of our business through offering a
07 What we’re doing
08 Vapour products
                                             greater choice of enjoyable and less risky
09 Tobacco heating products (THPs)           products for our consumers. Our ambition
10 Modern oral products
11 Our strategy for accelerated growth
                                             is to increasingly transition our revenues
                                             from cigarettes to non-combustible products
SUPPORTING ESG PRIORITIES
                                             over time.
12 Our supporting ESG priorities
13	Excellence in environmental
    management
                                                                              SUPPLY
                                                                         OBAL        CH
                                                                       GL
14 Delivering a positive social impact
15 Robust corporate governance                                       R                 AI
                                                                    U                    N
                                                                   O
CREATING VALUE
                                                                                           g                        Mode
                                                                                      eatin
16   Creating value for our consumers                                              oh                                   r
                                                                                                                    prod n ora
                                                                                acc ucts                                uc
18   Creating value for society                                                b
                                                                             To pro
                                                                                    d                                     ts l
20   Creating value for our employees
                                                                                             CT PORTF
                                                                                           DU

                                                                                                                                                Tr pro
22   Our contribution to the SDGs                                                                    O

                                                                                                                                                  ad duc
                                                                                          O
                                                                 prod ur
                                                                        s

                                                                                                                                                    itio ts
                                                                                                                             LI
                                                                               PR
                                                                     uct
                                                                      o

                                                                                                                               O
                                                                  Vap

                                                                                                                                                        nal
INDEPENDENT ASSURANCE

                                                                                                                                                            oral
                                                 Other direct
24 External recognition                             product
                                                   materials
                                                                                               53,000+                                                             Indirect goods
                                                                                                                                                                    and services
26 Commentary from our Stakeholder Panel                                                                                                                            from 30,000+
                                                                                              employees
                                                                            Our b

                                                                                                                                       s
                                                 from 1,500+                                                                                                           suppliers

                                                                                                                                      r ke t
29 Acting on the Panel’s feedback                  suppliers
                                                                                                                                      ma
                                                                                  ra n

                                                                                                                                 0+
                                                                                  ds

                                                                                         ar                                      20
                                                                                              ed
                                                                                                   istr                     ss
                                                                                                          ib ute d a c ro
                                                                            Co
                                                                                 mb                                                        ts
                                                                                         ust                         d                uc
                                                                                               ible to b a c c o pro

                                                                                                               400,000+ tonnes of tobacco
                                                                                                               leaf each year from 90,000
                                                                                                               directly contracted farmers;
                                                                                                               and from third-party
                                                                                                               suppliers

                                             OUR AMBITIOUS ESG TARGETS

                                             Increasing our consumers           Achieving carbon neutrality                                      Eliminating unnecessary
                                             of non-combustible                 by 2030 and accelerating                                         single-use plastic and
                                             products to 50 million             our existing environmental                                       making all plastic packaging
                                             by 2030                            targets to 2025                                                  recyclable by 2025

BAT Sustainability Strategy Report 2019
PUTTING SUSTAINABILITY FRONT AND CENTRE - SUSTAINABILITY STRATEGY REPORT 2019 - British American ...
Health                      Supporting                  Creating                       Independent
 Introduction                     impact                      ESG priorities              value                          assurance                                                          01

                                                WELCOME TO OUR SUSTAINABILITY
                                                STRATEGY REPORT 2019, WHICH
                                                FORMS PART OF OUR SUITE OF
                                                CORPORATE PUBLICATIONS.

Our reporting suite                             Our Annual Report 2019 provides details of our evolved Group
                                                strategy, with sustainability at its heart. This includes our clear
                                                corporate purpose to build ‘A Better Tomorrow’ by reducing the
                                                health impact of our business through offering a greater choice of
                                                enjoyable and less risky products.
                                                This Sustainability Strategy Report 2019 provides details
Annual Report 2019
                                                of our Sustainability Agenda, including a clear focus to reduce
                                                the health impact of our business; highlights of our approach and
                                                performance for our other environmental, social and governance
                                                (ESG) priorities; and how this creates shared value for our
                                                stakeholders towards our corporate purpose for
                                                ‘A Better Tomorrow’.
                                                This is complemented by our ESG Report 2019, which provides
Sustainability Strategy
Report 2019                                     more comprehensive details of our Sustainability Agenda and
                                                ESG priorities, including policies, accountability, management
                                                approach, targets and performance for each topic. We also
                                                map our disclosures against Global Reporting Initiative (GRI)
                                                Standards, the Sustainability Accounting Standards Board (SASB)
                                                framework and the World Economic Forum’s new ESG framework.
ESG Report 2019

                                                In addition, we publish our annual Modern Slavery
                                                Statement and UK Gender Pay Report, as well as periodic
                                                topic-specific Focus Reports and our biennial Science &
                         MODERN
                        SLAVERY
                           GENDER PAY
                      STATEMENT
                               REPORT
                            2019
                                 2019
                                                Technology Report.

Modern Slavery Statement
and UK Gender Pay Report 2019                             bat.com/reporting

About this Report and forward-looking statements
This is a Report by British American Tobacco plc.                These statements are often, but not always, made through         The material in this Report is provided for the purpose of
Associate companies are excluded. References to ‘British         the use of words or phrases such as “believe,” “anticipate,”     giving information about the Company to stakeholders only
American Tobacco’, ‘BAT’, ‘we’, ‘us’ and ‘our’ when denoting     “could,” “may,” “would,” “should,” “intend,” “plan,”             and is not intended for general consumers. The Company,
opinion refer to British American Tobacco plc (the Company,      “potential,” “predict,” “will,” “estimate,” “strategy” and       its directors, employees, agents or advisers do not
and together with its subsidiaries, the “Group”), and when       similar expressions. It is believed that the expectations        accept or assume responsibility to any other person to
denoting tobacco business activity refer to Group operating      reflected in this report are reasonable but they may be          whom this material is shown or into whose hands it may
companies, collectively or individually as the case may be.      affected by a wide range of variables that could cause           come and any such responsibility or liability is expressly
                                                                 actual results to differ materially from those currently         disclaimed. The material in this Report is not provided for
This Report contains certain forward-looking statements,         anticipated, including: the impact of adverse domestic or        product advertising, promotional or marketing purposes.
made within the meaning of Section 21E of the United             international legislation and regulation, changes in domestic    This material does not constitute and should not be
States Securities Exchange Act of 1934, regarding our            or international tax laws and rates and the impact of an         construed as constituting an offer to sell, or a solicitation
intentions, beliefs or current expectations reflecting           unfavourable ruling by a tax authority in a disputed area,       of an offer to buy, any of our products. Our products are
knowledge and information available at the time of               adverse decisions by domestic or international regulatory        sold only in compliance with the laws of the particular
preparation and concerning, among other things, prospects,       bodies and the inability to lead the development and             jurisdictions in which they are sold.
growth and strategies. BAT undertakes no obligation to           roll-out of BAT innovations (new category products and
update or revise these forward-looking statements, whether       combustibles), including as a result of unsuccessful research
as a result of new information, future events or otherwise.      and development or a failure to develop robust scientific risk
                                                                 assessment frameworks.

                                                                                                                                                  BAT Sustainability Strategy Report 2019
PUTTING SUSTAINABILITY FRONT AND CENTRE - SUSTAINABILITY STRATEGY REPORT 2019 - British American ...
02         Introduction

LETTER FROM                                         Our clear commitment to providing consumers with a
                                                    range of less harmful products is central to our corporate
OUR CHIEF                                           purpose, around which our long-term ambition is planned.
EXECUTIVE                                           And we’re also clear that our long-term sustainability will
                                                    be underpinned by successful delivery against our other
                                                    ESG priorities.

                                                                                             Strong foundations
                                                                                             We have a long and proud history of
                                                    WE HAVE A STRATEGY                       sustainability achievements, but today we are
                                                                                             transitioning from being a business where
                                                    WITH SUSTAINABILITY                      sustainability has always been important to one
                                                    AT ITS HEART AND                         where it is front and centre in all that we do.
                                                    I FIRMLY BELIEVE                         Over the last 20 years, we’ve made significant
                                                    IT WILL LEAD TO ‘A                       progress on our sustainability journey, as
                                                                                             evidenced by the highlights below, as well as
                                                    BETTER TOMORROW’                         our 18 consecutive years in the Dow Jones
                                                    FOR OUR CONSUMERS,                       Sustainability Indices (DJSI).
                                                    OUR EMPLOYEES,                           Yet our approach needs to constantly
                                                                                             develop, much as the world around us is
                                                    OUR SHAREHOLDERS                         evolving – from increasing expectations of
                                                    AND, UNDOUBTEDLY,                        the role of business in contributing to the UN
                                                    FOR SOCIETY.                             Sustainable Development Goals and addressing
                                                                                            climate change; to evolving consumer
                                                                                             preferences and the emergence of new
                                                                                             category products, such as vapour products
                                                                                             (e-cigarettes), that offer potentially reduced
                                                                                             risks for the estimated 19% of the world’s
                                                                                             population who continue to smoke cigarettes.
                                                                                             Clear priorities
                                                                                             Since taking over as CEO in April last
                                                                                             year, I have focused the business on three
                                                                                             clear priorities:
                                                                                             – Ensuring a step change in New Categories
                                                                                               performance with the aim of ultimately
                                                                                               generating an increasingly greater
                                                                                               proportion of our revenues from products
                                                                                               other than cigarettes, thereby reducing the
                                                                                               health impact of our business;
                                                                                             – Simplifying the business to be more flexible,
                                                                                               agile and efficient, while also releasing
                                                                                               valuable funds for reinvestment in New
                                                                                               Categories; and

2000–2005: ESTABLISHING                                            2006–2010: DEVELOPING
Transparent reporting               International                  Sustainability Agenda focused           External Scientific Panel formed
aligned to best                     Marketing Standards            on harm reduction, marketplace,         to guide our harm reduction research
practice frameworks                 and youth smoking              environment, supply chain, and
                                    prevention programmes          people and culture                      bat-science.com launched
Eliminating Child Labour
in Tobacco Growing                  Social Responsibility          First long-term targets for             Integrated supply chain
(ECLT) Foundation and BAT           in Tobacco Production          reducing our direct carbon emissions    sustainability strategy developed
Biodiversity Partnership            (SRTP) programme with          (CO2) by 50% by 2030                    in consultation with stakeholders
                                    minimum standards for
                                    tobacco leaf suppliers         First reduced-risk product, snus
                                                                   smokeless oral tobacco, launched

BAT Sustainability Strategy Report 2019
PUTTING SUSTAINABILITY FRONT AND CENTRE - SUSTAINABILITY STRATEGY REPORT 2019 - British American ...
Health                        Supporting                   Creating                      Independent
    Introduction              impact                        ESG priorities               value                         assurance                                                           03

WE ARE TRANSITIONING FROM A BUSINESS WHERE                                                                                                                  BUILDING
SUSTAINABILITY HAS ALWAYS BEEN IMPORTANT TO ONE WHERE                                                                                                        ON OUR
IT IS FRONT AND CENTRE IN ALL THAT WE DO.                                                                                                                  PROGRESS
                                                                                                                                                             WITH
                                                                                                                                                          STRETCHING
                                                                                                                                                          NEW TARGETS
– Driving value from combustible cigarettes                                Specifically, we are clear that reducing the health
  to enable continued investment to grow our                               impact of our business is our principal focus area, as
  New Categories business.                                                 well as placing a greater emphasis on the importance
                                                                           of addressing climate change and environmental
Our evolved strategy
                                                                           management. At the same time, we remain
To accelerate progress, we have evolved our Group                          committed to delivering a positive social impact
strategy with the purpose of building ‘A Better                            and ensuring robust corporate governance across
Tomorrow’ for all our stakeholders.                                        the Group.
                                                                                                                                                             Increasing our
                                                                                                                                                           consumers of non-
While combustible tobacco products will be at the                          Future ambition
core of our business for some time to come, we aim                                                                                                       combustible products
                                                                           Just as we are committed to making a step change                               to 50 million by 2030
to reduce the health impact of our business by using
                                                                           in our New Categories performance, we are
revenue from our cigarette business to generate an
                                                                           also committed to making a step change in our
ever-increasing proportion of our overall revenues
                                                                           sustainability ambition.
from our new category products.
                                                                           Recently, we have announced a number of stretching
And, to reflect the changes in both the world
                                                                           targets that we are confident will accelerate our
around us and our business, we have a dynamic new
                                                                           purpose to build ‘A Better Tomorrow’ for all our
corporate logo, as featured in this Report.
                                                                           stakeholders, including:
Our Sustainability Agenda                                                                                                                                 Achieving carbon
                                                                           – Increasing our consumers of non-combustible
Central to our evolved strategy is our Sustainability                                                                                                     neutrality by 2030
                                                                             products to 50 million by 2030;
Agenda, which has been refreshed to reflect the                                                                                                          and accelerating our
changing external environment.                                             – Achieving carbon neutrality by 20301 and                                   existing environmental
                                                                             accelerating our existing environmental targets to
                                                                             2025; and
                                                                                                                                                            targets to 2025
                                                                           – Eliminating unnecessary single-use plastic and
AT ITS HEART, OUR                                                            making all plastic packaging recyclable by 20252.
EVOLVED STRATEGY IS                                                        I am proud that we have a strategy with sustainability
ABOUT ANTICIPATING                                                         embedded at its heart and I firmly believe it will
                                                                           lead to ‘A Better Tomorrow’ for our consumers, our
AND SATISFYING                                                             employees, our shareholders and, undoubtedly,
THE EVER-EVOLVING                                                          for society.                                                                        Eliminating
CONSUMER: PROVIDING                                                                                                                                      unnecessary single-
                                                                                                                                                        use plastic and making
PLEASURE, REDUCING                                                                                                                                       all plastic packaging
RISK AND OFFERING AN                                                       Jack Bowles                                                                    recyclable by 2025
INCREASING CHOICE.                                                         Chief Executive, March 2020


2011–2015: EMBEDDING                                               2016–2019: GROWING                                                 2020: STEP CHANGE
First international tobacco company                                Range of potentially reduced-risk                                  Evolved our Group strategy
to launch a vapour product                                         products available across multiple markets                         with a clear corporate purpose to
                                                                                                                                      build ‘A Better Tomorrow’. See our
Human rights strategy developed                                    New science-based CO2 targets set,                                 Annual Report 2019 for details,
in consultation with stakeholders                                  having already achieved a 47% reduction in                         at bat.com/annualreport.
                                                                   direct emissions
Diversity and inclusion strategy                                                                                                      Evolved our Sustainability Agenda;
implemented across the Group                                       Thrive farmer livelihoods and sustainable                          see the following page for details
                                                                   agriculture programme developed
Sustainable Tobacco Programme
developed with the industry                                        Delivery with Integrity programme
                                                                   strengthening our compliance culture

1 Based on Scope 1 and 2 carbon dioxide equivalent (CO2e) emissions.
2	In full, our 2025 targets are to: eliminate all unnecessary single-use plastic packaging; 100% of plastic packaging to be reusable, recyclable or compostable; and 30% recycled content in
   plastic packaging – as well as having take-back schemes for all new category devices by end 2021.

                                                                                                                                                  BAT Sustainability Strategy Report 2019
PUTTING SUSTAINABILITY FRONT AND CENTRE - SUSTAINABILITY STRATEGY REPORT 2019 - British American ...
04         Introduction

OUR NEW                                                    Our Sustainability Agenda is integral to our evolved
                                                           Group strategy and reflects our commitment to reducing
SUSTAINABILITY                                             the health impact of our business as our principal focus
AGENDA                                                     area. This is underpinned by excellence across our other
                                                           ESG priorities.

A key strength of our approach to                          This comprehensive approach to evolving                Along with our principal focus on reducing
sustainability is a robust process to identify             our Sustainability Agenda ensures we                   the health impact of our business, we retain
and understand the most material ESG topics                keep pace with emerging topics and                     a strong focus on other ESG priorities.
that drive our long-term business sustainability           stakeholder expectations.
                                                                                                                  Together, this approach helps to create
and value creation.
                                                           Outlined below are the priority areas identified       shared value for our consumers, society, our
Each year we engage with a wide range of                   in 2019 and which form the core of our                 employees and our shareholders. Ultimately,
stakeholders to understand what matters                    Sustainability Agenda. You can read more               it’s about building towards ‘A Better
to them most and complement this                           about how we identify and prioritise them              Tomorrow’ not just for BAT, but for all
with ongoing risk monitoring, research                     at bat.com/sustainabilityreport.                       our stakeholders.
and benchmarking.

                  Increasing our consumers                          Achieving carbon neutrality by 2030                   Eliminating unnecessary
               of non-combustible products to                          and accelerating our existing               single-use plastic and making all plastic
                      50 million by 2030                              environmental targets to 2025                     packaging recyclable by 2025

                           Reducing the HEALTH impact of our business
                          Consumer choice                          World-class science                         Standards and regulation

               Excellence in                                         Delivering a positive                           Robust corporate
               ENVIRONMENTAL                                         SOCIAL impact                                   GOVERNANCE
               management
                                                                         Human rights                                    Business ethics
                   Climate change                                        Farmer livelihoods                              Responsible marketing
                   Water and waste                                      Health and safety                               Regulation and
                                                                                                                         policy engagement
                   Sustainable agriculture                               People and culture
                   Circular economy

      This Report provides an overview of our strategic approach and we report in detail against all our ESG
      priorities in our ESG Report at: bat.com/sustainabilityreport

BAT Sustainability Strategy Report 2019
PUTTING SUSTAINABILITY FRONT AND CENTRE - SUSTAINABILITY STRATEGY REPORT 2019 - British American ...
Health                   Supporting             Creating   Independent
Introduction       impact                   ESG priorities         value      assurance                                         05

               CONSUMERS
               by responsibly offering them enjoyable
               and less risky choices to cigarettes.

                            SOCIETY
                            by addressing the overall health, social
                            and environmental impacts of our business,
                            and by raising standards for people
                            across our value chain.                                 OUR PURPOSE

                         CREATES SHARED
                           VALUE FOR

                            EMPLOYEES
                            by creating a dynamic, inspiring
                            and purposeful place to work that
                            values their wellbeing, embraces diversity
                            and respects their rights.

               SHAREHOLDERS
               by delivering sustainable, superior
               returns and long-term growth.

                                                                                            BAT Sustainability Strategy Report 2019
PUTTING SUSTAINABILITY FRONT AND CENTRE - SUSTAINABILITY STRATEGY REPORT 2019 - British American ...
Health
06           impact

HEALTH IMPACT:                                                   As our principal ESG focus area, we are committed to
                                                                 reducing the health impact of our business through
OUR PRINCIPAL                                                    offering a greater choice of enjoyable and less risky
ESG FOCUS                                                        products for our consumers.

New category alternatives to cigarettes, such as vapour, tobacco heating and modern oral
products, already have an estimated 68 million consumers worldwide and provide options for
the estimated 19% of the world’s population who continue to smoke3 to switch away from
cigarettes in significant numbers. To succeed in this, the following key enablers need to be
in place:

                                                 CONSUMER                                                  WORLD-CLASS
                                                  CHOICE                                                     SCIENCE

                                                Smokers are                                                 Robust scientific
                                            more likely to switch                                         evidence is needed
                                              to new category                                           to support the quality,
                                          products if they can find                                     safety and reduced-risk
                                           one that satisfies their                                         potential of new
                                            varying preferences.                                         category products, in
                                                                                     HARM                 order for regulators
                                                                                   REDUCTION               and consumers to
                                                                                      KEY                 have trust in them.
                                                                                   ENABLERS

                                                                             STANDARDS AND
                                                                               REGULATION

                                                                   The right regulatory and market
                                                                   conditions need to be in place to
                                                               enable wide availability of new category
                                                                products, alongside high standards and
                                                               responsible practices across the industry.

AS MOST OF THE HARM CAUSED                                                                                             OUR WORLD-CLASS AND
BY SMOKING ARISES NOT FROM                                                                                             TRANSPARENT SCIENCE
NICOTINE BUT FROM OTHER                                                                                                MEANS CONSUMERS
COMPONENTS OF TOBACCO                                                                                                  CAN TRUST IN THE
SMOKE, THE HEALTH AND LIFE                                                                                             PERFORMANCE, SAFETY AND
EXPECTANCY OF TODAY’S SMOKERS                                                                                          HARM REDUCTION POTENTIAL
COULD BE RADICALLY IMPROVED                                                                                            OF OUR PRODUCTS.
BY ENCOURAGING AS MANY AS                                                                                              

POSSIBLE TO SWITCH TO A SMOKE-                                                                                         Dr David O’Reilly
FREE SOURCE OF NICOTINE.                                                                                               Director, Research and Science


UK Royal College of Physicians4
3 Euromonitor International (2019). ‘World market for cigarettes: October 2019’.
4 Royal College of Physicians, Tobacco Advisory Group (2016). ‘Nicotine without smoke: Tobacco harm reduction’.

BAT Sustainability Strategy Report 2019
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Health                Supporting             Creating                  Independent
Introduction           impact                ESG priorities         value                     assurance                                              07

WHAT WE’RE                                      By enabling consumer choice through our range of new
                                                category products, supported by world-class science and
DOING                                           industry-leading standards, we are making significant
                                                progress in delivering our commitment to reducing the
                                                health impact of our business.

 CONSUMER                                          WORLD-CLASS                                         STANDARDS
 CHOICE                                            SCIENCE                                             AND REGULATION
 Our strategy is focused on making                 We apply our peer-reviewed scientific               We follow strict standards for product
 available a broad portfolio of different          framework to assess the emissions,                  safety and for ensuring all our product
 products that satisfy consumers by                exposure and risk of our products.                  marketing worldwide is aimed only at adult
 providing pleasure, reducing risk and             Product safety standards go hand-in-hand            consumers and does not engage or appeal
 offering an increasing choice.                    with sound science – we scrutinise all the          to youth. We openly share our approach,
                                                   ingredients and our products benefit from           and advocate for industry-wide standards
 We have a deep understanding of our
                                                   thousands of hours of testing before they           and regulation.
 consumers and anticipate trends with
                                                   reach the consumer.
 powerful foresights, data and analytics.                                                              We think regulation of new category
 We make significant investments in                We openly share our science, publish our            products should enable market availability,
 research and development (R&D) to                 findings in peer-reviewed journals and              apply the highest quality and safety
 deliver innovations that satisfy consumer         present at conferences and to government            standards, allow communication of the
 tastes and generate growth for the                advisory committees. We also publish                potential benefits and risks, and ensure
 business. And we’re opening up to                 comprehensive details of our research               affordability for consumers by taxing them
 radical new ideas and seeking out the             programme on our dedicated                          appropriately – all the while preventing
 inventiveness of others through strategic         bat-science.com website.                            youth appeal and access.
 investments and partnerships.
                                                   Our progress                                        Our progress
 Our progress                                      To date, we have published 59 peer-                 We’ve evolved our International
 Since launching our first vapour products         reviewed papers on new category                     Marketing Principles and Youth Access
 in the UK in 2013, we have made                   products. The results indicate that                 Prevention Guidelines to reflect our
 significant progress in developing,               our products have the potential to be               multi‑category portfolio.
 manufacturing and commercialising                 significantly less risky than cigarettes
                                                                                                       We’ve openly shared our approach to
 a range of new category products.                 and we’re continuing to establish more
                                                                                                       product stewardship and have worked as
                                                   evidence to support this.
 Today, our new category products are                                                                  part of multi-stakeholder groups on the
 available in 48 markets globally – see            In 2019, we presented at 32 scientific              development of industry-wide standards,
 pages 8–10 for details.                           conferences and meetings, and we will               including with the British Standards
                                                   publish our biennial Science & Technology           Institution, the EU standards body (CEN)
                                                   Report later in 2020.                               technical committee and the International
                                                                                                       Organization for Standardization (ISO).

 Comprehensive details of how we’re                Full details of our scientific framework            Find out more about our regulatory
 enabling consumer choice through                  and findings of our research, as well               engagement and views on an effective
 our range of new category products                as the growing independent evidence                 regulatory framework for new category
 can be found on pages 19–24 of our                base, can be found on pages 19–24 of                products that is based on relative risks,
 ESG Report.                                       our ESG Report.                                     on pages 20–21of our ESG Report.

        at.com/sustainabilityreport
       b                                                  at.com/sustainabilityreport
                                                         b                                                    at.com/sustainabilityreport
                                                                                                             b

                                                                                                                 BAT Sustainability Strategy Report 2019
Health
08         impact

      VAPOUR                                      Vapour products are battery-powered devices that heat
                                                  liquid formulations – e-liquids – to create a vapour which
      PRODUCTS                                    is inhaled. Most e-liquids contain water, propylene glycol
                                                  and glycerol, flavourings and nicotine, although some
                                                  e-liquids don’t contain any nicotine. The products contain
                                                  no tobacco and no combustion takes place.

      OUR PRODUCTS                                                                                                                               95%
                                                                                                                                               fewer toxicants
      Our flagship vapour brands include Vype                                                                                                emitted by our Vype
      and Vuse.                                                                                                                              product, compared
                                                                                                                                                to cigarettes5
      We continue to enhance our vapour products
      with new innovations – for example, we’re
      developing new distiller plate technology to
      heat the e-liquid more efficiently than the
      traditional ‘coil and wick’ often found in other
      vapour products.
      We plan to consolidate all our vapour products
                                                                                      27
                                                                              markets where
      under our global Vuse brand by the end of 2020.                       our vapour products
                                                                                are available

The scientific evidence
                                                    Vaping concerns in the US
There is growing consensus among many
public health bodies and academics that             In 2019, a number of cases of acute lung                         Food and Drug Administration’s (FDA) newly
vapour products can have a significantly            diseases among vapers were reported in                           released guidance on flavoured e-cigarettes.
reduced risk profile compared to smoking.           the US, including some deaths. The official                      Together with the FDA’s previously
In the UK, for example, Public Health England       investigations have so far found strong links                    announced requirement to submit Pre-
has published a series of expert reviews            with the use of Vitamin E acetate in e-liquids                   Market Tobacco Product Applications
of the latest evidence, drawing on peer-            and with illicit e-liquids not sourced from                      (PMTAs) by May 2020 for all products,
reviewed literature, surveys and other reports.     reputable manufacturers. Consistent with                         this is a positive step and will help ensure
They concluded that “based on current               our product standards, such ingredients are                      consumers have access to appropriately
knowledge, vaping is at least 95% less              not, and have never been, added to our                           regulated, quality-assured products that do
harmful than smoking”6. This is supported           Vype and Vuse vapour products.                                   not appeal or are accessible to youth.
by a wealth of other evidence reviews, studies
and reports from public health bodies,              Concerns were also raised regarding youth                        We are confident that, as required by the
regulators and academics in countries such          access to vapour products and that some                          PMTA process, all our Vuse products in
as Australia, Canada, France, New Zealand           e-liquid flavours, such as those resembling                      the US will be shown to be appropriate
and the US.                                         ‘kid-friendly’ food products, may play a role                    for the protection of public health. We will
                                                    in increasing youth appeal. We have strict                       continue to work with the FDA throughout
                                                    standards to ensure our products do not                          the implementation of this new regulatory
                                                    engage or appeal to youth.                                       framework to make sure consumers have
                                                                                                                     access to quality-assured products, while
IT IS WELL ACCEPTED                                 These cases clearly demonstrate the
                                                                                                                     doing our utmost to ensure that vaping
WITHIN THE PUBLIC                                   importance of having, and enforcing, robust
                                                                                                                     remains positioned as a credible option
HEALTH COMMUNITY                                    and effective regulations which ensure high
                                                                                                                     for adult smokers looking for an alternative
THAT, WHILE THE PRECISE                             product standards and prevent access and
                                                                                                                     to tobacco.
LONG-TERM EFFECTS OF                                appeal to youth – something we at BAT have
VAPING ARE UNKNOWN,                                 long been advocating. We welcome the US
IT IS NEVERTHELESS
SUBSTANTIALLY
SAFER THAN SMOKING
TRADITIONAL CIGARETTES.


The Royal Society
                                                  5	Comparison of smoke from a 1R6F reference cigarette (approx. 9 mg tar) and vapour from Vype ePen 3, with reference to nine
for Public Health7                                   harmful components the World Health Organization (WHO) recommends to reduce in cigarette smoke. This quality does not
                                                     necessarily mean this product is less harmful than other tobacco products.
                                                  6 Public Health England (2018). ‘Evidence review of e-cigarettes and heated tobacco products 2018’.
                                                  7 Royal Society for Public Health (2018). ‘Health on the High Street: Running on empty’.

BAT Sustainability Strategy Report 2019
Health                        Supporting                    Creating                      Independent
 Introduction                 impact                        ESG priorities                value                         assurance                                                           09

           TOBACCO                                               THPs heat tobacco to generate a nicotine-containing
                                                                 aerosol, with a tobacco taste, which the user inhales.
           HEATING                                               Because the tobacco is heated instead of burned, the
           PRODUCTS                                              resulting aerosol comprises mainly water, glycerol,
           (THPs)                                                nicotine and tobacco flavours – dramatically
                                                                 different to cigarette smoke.

      OUR PRODUCTS
                                                                                                                                                                       17
                                                                                                                                                                 markets where
                                                                                                                                                                 our THPs are
      Our THPs are available under our                                                                                                                             currently
      flagship glo brand.                                                                                                                                          available

      Our range includes battery-
      powered devices that heat specially
      designed tobacco sticks, as well as
      hybrid devices that combine vaping
      technology with real tobacco.

The scientific evidence
                                                                     Leading innovation
By heating tobacco rather than burning it,
THPs have the potential to be reduced-risk                           In 2019, we continued to expand our                          to cigarettes. We continue to push the
compared to smoking. Although most of                                portfolio with the launch of three innovative                boundaries of innovation to encourage as
the research to date has been conducted by                           new THPs in Japan and South Korea.                           many adult smokers as possible to choose
the industry, we are encouraged to see an                                                                                         a new category product with reduced-
increasing number of independent reports                             This included our ‘glo pro’ device which, for
                                                                                                                                  risk potential.
that are broadly aligned with our findings.                          the first time, used our new tobacco heating
                                                                     technology – induction heating – which
For example, a study commissioned by the                             significantly reduces the heating time for the
UK Department of Health in 2017 found that
people using the two available THPs on the
UK market were exposed to around 50–90%
                                                                     consumer. The new ‘glo sens’ product uses
                                                                     our cutting-edge innovation, called Taste                                     90–95%
                                                                     Fusion Technology, which combines vaping                                    Some chemicals found
less of the “harmful and potentially harmful”                        technology with real tobacco.                                             in cigarette smoke are not
compounds compared with conventional                                                                                                            in glo aerosol at all, and
cigarettes8. And, in 2018, a Public Health                           These products provide adult consumers
                                                                                                                                                many others are around
England report looked at current research                            with even greater and more satisfying
                                                                                                                                                  90–95% lower in the
on THPs and, while highlighting the need                             choice when looking for alternatives
                                                                                                                                                      glo aerosol10
for more research, found that “compared
with cigarettes, heated tobacco products
are likely to expose users and bystanders
to lower levels of particulate matter
and harmful and potentially harmful                              TESTS ON HEATED TOBACCO CARRIED OUT BY THE TOBACCO
compounds. The extent of the reduction                           INDUSTRY AND SCRUTINISED BY THE COMMITTEE...
found varies between studies”9.                                  FOUND A REDUCTION OF UP TO 90% IN THE NUMBER OF TOXIC
                                                                 CHEMICALS EMITTED BY HEATED TOBACCO COMPARED WITH
                                                                 COMBUSTIBLE CIGARETTES.
                                                                 

                                                                 David Jones
                                                                 MP and honorary life fellow of Cancer Research UK11

8	Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment (COT), Department of Health UK (2017). ‘Statement on the toxicological evaluation of novel heat-not-burn
   tobacco products’.
9 Public Health England (2018). ‘Evidence review of e-cigarettes and heated tobacco products 2018’.
10	Comparison of smoke from a 3R4F reference cigarette (approx. 9 mg tar) and vapour from heated tobacco in glo, with reference to nine harmful components the WHO recommends to reduce in
    cigarette smoke. This quality does not necessarily mean this product is less harmful than other tobacco products.
11 UK House of Commons Hansard, 26 June 2019, referencing findings of the COT in footnote 8.

                                                                                                                                                   BAT Sustainability Strategy Report 2019
Health
10           impact

                MODERN                                           In recent years, a new category of modern oral products
                                                                 has emerged. These come in the form of nicotine pouches
                ORAL                                             that are placed under the lip so that nicotine can be
                PRODUCTS                                         absorbed by the body.

                                                                                                                                                                  18
                                                                                                                                                            markets where
                                                                                                                                                           our modern oral
      OUR PRODUCTS                                                                                                                                           products are
                                                                                                                                                               available
      Our modern oral products are white in colour and contain high-
      purity nicotine, water and other high-quality food-grade ingredients,
      including eucalyptus and pine tree fibres, flavouring and sweeteners.
      These are likely to appeal more broadly than traditional oral
      tobacco. And, due to affordability and other factors like not relying
      on batteries, they may be more consumer-acceptable than our
      other new category products for low to middle income developing
      countries, such as for our recent launches in Kenya and Pakistan.
      We plan to consolidate all our modern oral products under our
      global Velo brand by the end of 2020.

The scientific evidence
                                                                     Traditional oral products
A wealth of epidemiological evidence from
Sweden over many decades shows that use                              We also sell a range of traditional oral                     Our Camel Snus product is currently
of snus, a type of traditional oral tobacco, is                      products, including Swedish-style snus and                   undergoing a process with the US FDA
substantially less risky than smoking. This has                      American moist snuff, available in loose                     to be classified as a modified-risk tobacco
been confirmed by the US FDA which, in                               tobacco form or as prepacked pouches.                        product, which we expect to be completed
2019, in response to an application made                             We have long sold snus in Sweden and                         in 2020. If our application is accepted,
by the company Swedish Match, formally                               Norway through our Fiedler & Lundgren                        we will be able to communicate the
recognised that switching completely from                            business, whose brands include Granit and                    health benefits of switching from cigarettes
cigarettes to the snus products assessed can                         Mocca; and in the US we market snus under                    to Camel Snus directly to consumers.
significantly lower the risks of mouth cancer,                       the Camel brand. Our American moist snuff
heart disease, lung cancer, stroke, emphysema                        products include our flagship Grizzly brand
and chronic bronchitis12.                                            in the US, as well as the premium moist
Already our chemical studies have shown                              snuff brand Kodiak.
that our modern oral products have even
fewer and lower levels of toxicants than snus,
and our toxicological studies have shown
that the effect of this is to have even lower
toxicological impact on human cells than                         ST [SMOKELESS TOBACCO] PRODUCTS ARE MUCH CLEANER
snus. We’re confident that further research                      AND LESS HAZARDOUS THAN CIGARETTES. THEIR USE COULD
will confirm that consumers of modern oral                       REDUCE HARM TO SMOKERS IF THEY SWITCHED ENTIRELY
products will be exposed to even fewer                           TO THESE PRODUCTS. THIS APPEARS TO BE THE CASE WITH
toxicants than snus users. Ultimately, we                        SNUS USE IN SWEDEN.
believe that modern oral products present                        

significantly less risk to users than cigarettes.                Prof Neal Benowitz
                                                                 Professor of Medicine at the University of California, San Francisco13

12	https://www.fda.gov/news-events/press-announcements/fda-grants-first-ever-modified-risk-orders-eight-smokeless-tobacco-products (accessed March 2020).
13 Benowitz, N. L. (2011). ‘Smokeless Tobacco as a Nicotine Delivery Device: Harm or Harm Reduction?’ Clinical Pharmacology & Therapeutics 90, no.4: 491–93. doi:10.1038/clpt.2011.191.

BAT Sustainability Strategy Report 2019
Health                      Supporting                    Creating                     Independent
Introduction                   impact                      ESG priorities                value                        assurance                                                           11

OUR                                                             While we’re proud of how much we’ve already achieved,
                                                                we need to accelerate progress in order to generate an
STRATEGY FOR                                                    increasingly greater proportion of our revenues from
ACCELERATED                                                     products other than cigarettes, thereby reducing the
GROWTH                                                          health impact of our business.

In 2019, we grew our New
Categories business by 37%
to £1.3 billion14 – we aim to                                                                         Today

achieve at least £5 billion in New
Categories revenues in 2023/2024.
                                                                                         11 million
                                                                                        consumers
Opportunities for growth                                                                 regularly use one of our
   New category products have grown rapidly                                             non-combustible products
   across the world, with an estimated 54 million                                           across 48 markets
   vapour consumers and 15 million THP
   consumers; and
   With the right regulation in place, alongside
   technological innovation, it is expected that
   growth will continue to accelerate as the
   products better meet consumer preferences
   and demands.

More innovation, greater choice
   Consumer preferences and technology are
   evolving rapidly, and we are staying ahead of
   the curve by building new capabilities around
   the world focused on science and innovation;
   We are also leveraging the expertise of our
   external partners to further strengthen our
   world-class R&D capabilities – such as our
   partnership with McLaren where we are
   actively working with McLaren Applied on
   a number of projects to enhance our future
   product pipeline; and
   Our new corporate ventures team will also
   accelerate the creation, development and
   commercialisation of new-to-world innovation
   on a test-and-learn basis.

Growing reach and availability
   Of the 48 markets where our new category
   products are currently available, 15 are among
   the top 30 countries with the highest smoking
   prevalence globally15;                                                                                                                    Our ambition is to
   We’re committed to expanding to further                                                                                                      increase to
   markets as quickly and practically as we can; and
   We prioritise markets with the right regulatory
                                                                                                                                        50 million
   frameworks in place, and where there is
   consumer awareness and demand – countries
                                                                                                                                       consumers
   we expanded to in 2019 include Kenya,                                                                                                            by 2030
   Malaysia, Pakistan, Slovakia and South Africa.

14 At current rates of exchange.
15 Based on World Bank data (2016) measuring smoking prevalence as a percentage of the total population. The 15 countries and smoking rates are: Greece (43.4%), Russia (39.3%), Serbia
   (38.9%), Bulgaria (37%), Croatia (37%), Czech Republic (34.3%), France (32.7%), Germany (30.6%), Hungary (30.6%), Slovakia (30.1%), Romania (29.7%), Austria (29.6%), Spain (29.3%),
   Ukraine (28.9%) and United Arab Emirates (28.9%). https://data.worldbank.org/indicator/SH.PRV.SMOK (accessed March 2020).

                                                                                                                                                 BAT Sustainability Strategy Report 2019
Supporting
12         ESG priorities

OUR                                         As well as our commitment to addressing the health
                                            impact of our business, we are also clear that our
SUPPORTING                                  long-term sustainability and value creation will be driven
ESG PRIORITIES                              by ensuring a best-in-class approach to managing our
                                            other ESG focus areas.

Highlights for each of our ESG priorities   WHY THESE TOPICS MATTER
can be found on the following pages.
Comprehensive details for all our
ESG topics, including our policies,
management approach, targets                 EXCELLENCE IN ENVIRONMENTAL MANAGEMENT
and performance, can be found
in our ESG Report.                          Good environmental management                    ddressing our water and waste
                                                                                            A
                                            is not only the right thing to do, it           impacts has environmental benefits and
      b
       at.com/sustainabilityreport
                                                                                            delivers financial savings and efficiencies;
                                            makes business sense given our
                                            dependence on natural resources.                Implementing sustainable agriculture
                                                                                             practices with our 90,000+ contracted
                                              limate change has long been part of
                                             C                                               farmers helps to address environmental
                                             our wider approach to environmental             impacts and secure our tobacco leaf
                                             management and we’ve now elevated it            supply chain; and
                                             to a standalone priority in recognition of     In response to increasing concerns
                                             the growing climate emergency;                  regarding plastics and post-consumption
                                                                                             waste, we’ve established circular
                                                                                            economy as a new priority area.

                                             DELIVERING A POSITIVE SOCIAL IMPACT

                                            As one of the world’s most                       y enhancing farmer livelihoods, we
                                                                                            B
                                            international businesses, we have               can help address rural poverty, which is a
                                                                                            primary root cause for issues such as child
                                            an important role to play in delivering
                                                                                            labour and urban migration, and so help
                                            a positive societal impact for our              secure our supply chain;
                                            employees and people across our
                                                                                             rotecting the health and safety of our
                                                                                            P
                                            supply chain.                                   people and contracted farmers enables
                                                                                            them to thrive while also enhancing
                                              uman rights risks exist across our
                                             H
                                                                                            business productivity; and
                                             business and supply chain, particularly
                                             in tobacco growing due to the inherent         Investing in our people and creating a
                                             challenges in agriculture;                      diverse, inclusive and engaging culture is
                                                                                             crucial to our business success.

                                             ROBUST CORPORATE GOVERNANCE

                                            Robust corporate governance is key               esponsible marketing practices are
                                                                                            R
                                            to our sustainable, long-term growth.           crucial for ensuring adult-only consumers
                                                                                            use our tobacco and nicotine products
                                              pplying high standards of business
                                             A                                              and that they do not appeal to youth; and
                                             ethics and operating with honesty,              ruly effective regulation needs
                                                                                            T
                                             integrity and transparency is not only         cooperation between governments and
                                             the right thing to do, it is critical to the   industry, and we have a legitimate role to
                                             continuing success of our business;            play in policy-related debate that affects
                                                                                            our business.

BAT Sustainability Strategy Report 2019
Health                   Supporting            Creating                Independent
Introduction           impact                   ESG priorities        value                   assurance                                                13

                                                                                                      Next steps
  EXCELLENCE IN                                                                                       Building on our progress, we’re
  ENVIRONMENTAL MANAGEMENT                                                                            now setting ourselves even more
                                                                                                      ambitious and stretching targets:

We are committed to reducing                       Sustainable agriculture                                  Carbon neutral by 2030;
                                                   We’re supporting 90,000+ directly
impacts across our operations                      contracted farmers worldwide to address the               educe our Scopes 1 and 2 CO2e
                                                                                                            R
and supply chain and preparing                     environmental impacts of tobacco growing                 emissions by 30% by 2025;
our business for the risks ahead.                  such as by:
                                                                                                             ource 30% of our direct energy
                                                                                                            S
                                                       iving them access to technologies
                                                      G                                                     from renewable sources by 2025;
 limate change
C                                                     developed by our Leaf Science & Research
Having achieved a 47% carbon dioxide                  centre, like drip irrigation and floating              educe the total amount of water
                                                                                                            R
equivalent (CO2e) reduction towards our               seedbeds that help to reduce water and                withdrawn by 35% and increase
original intensity-based targets, from a 2000         agrochemical use;                                     water recycling to 15% by 2025;
baseline, we then set new science-based                romoting the sustainable use of forest
                                                      P
targets to reduce our direct emissions, from          resources as fuels for tobacco curing to
                                                                                                             educe waste sent to landfill by
                                                                                                            R
a 2017 baseline, against which we’ve already          tackle deforestation;                                 40% by 2025 and recycle at
achieved a 9.5% reduction, such as by:                                                                      least 95% of our total waste
                                                      Reducing carbon emissions from tobacco
  Improving the energy efficiency of our              curing with more efficient curing                    each year;
   factories, such as by upgrading to more             technologies that use up to 30% less                 E liminate the use of unsustainable
   efficient and lower-impact equipment;               fuel – these have been introduced to our
                                                       contracted farmers in eight countries, with
                                                                                                             wood sources by our contracted
	
 Increasing our use of renewable energy                                                                      farmers for curing fuels;
 through green energy certificates and on-             trials underway in two more; and
 site energy-generation projects; and                  roviding ongoing training and capacity
                                                      P                                                	Eliminate unnecessary single-use
	
 Optimising our logistics and fleet, such as          building on environmental best practice.           plastic packaging by 2025;
 through improving vehicle performance             Circular economy                                    	100% of plastic packaging
 and fuel efficiency.                              We’re developing a new Group-wide                     to be reusable, recyclable or
Given our supply chain (Scope 3) emissions         circular economy strategy for all our product
                                                                                                         compostable by 2025; and
represent 90% of our total carbon footprint,       categories, through a Management Board-led
we’re engaging with our largest direct             cross-functional project team:                      	30% average recycled content
product materials suppliers and conducting             s a start, we’ve removed silicon caps
                                                      A                                                  across all plastic packaging
climate change impact assessments for our             from our Vype e-liquid pods, saving the            by 2025.
major tobacco leaf sourcing countries.                equivalent of around 1,000 tonnes of CO2
 ater and waste
W                                                     per year, and we plan to have removed all      ESG Report
We’ve reduced water withdrawals across our            unnecessary plastic from Vuse packaging        Find full details of our policies, management
                                                      by the end of 2021;                            approach, performance and targets for these
operations by 13.1% from our 2017 baseline,                                                          focus areas in our ESG Report.
such as by:                                            rialling take-back schemes for new
                                                      T                                                      b
                                                                                                              at.com/sustainabilityreport
  Improving water efficiency and controls            category products in France, Japan,
   across our sites; and                              Mexico, South Korea and the UK, and we
                                                      plan to implement take-back schemes for
  Increasing water recycling rates to 13.7%.          all our new category devices by 2021; and
We’ve reduced waste sent to landfill by 13.8%          etting ambitious new targets aligned to
                                                      S
since 2017 by recycling over 90% of our               the UK Government’s ‘Plastics Pact’.
waste each year across all our sites worldwide.


HIGHLIGHTS FOR 2019

              9.5%                               13.1%                                    99%                                1,000
         REDUCTION                            REDUCTION                            OF WOOD FUEL                             TONNES
   in direct CO2e from 2017             in water withdrawals from                used by our contracted            of CO2 equivalent saved
   baseline and aiming to be              our 2017 baseline and                  farmers for curing was             annually by removing
    CARBON NEUTRAL                         aiming to reduce by                      from sustainable                   silicon caps from
           BY 2030                           35% BY 2025                             sources in 2019                  Vype e-liquid pods

                                                                                                                   BAT Sustainability Strategy Report 2019
Supporting
14         ESG priorities

                                                                                                        Next steps
  DELIVERING A POSITIVE                                                                                     ublish a new Human Rights
                                                                                                           P
  SOCIAL IMPACT                                                                                            Focus Report in 2020, including
                                                                                                           details of human rights impact
                                                                                                           assessments in tobacco-growing
We are committed to delivering                         elping our contracted farmers to increase
                                                      H
                                                                                                           areas in India and Indonesia;
                                                      efficiency and productivity with new
a positive social impact for our                      technologies, such as for tobacco curing;             onduct two further human
                                                                                                           C
employees and people across our                     	
                                                     Educating and supporting our contracted               rights impact assessments
supply chain.                                        farmers to grow other crops for food or as            in Mexico and Mozambique
                                                     additional sources of income; and                     in 2020;
Human rights                                           easuring progress via our global
                                                      M
We’re committed to protecting the human               Thrive programme, which assesses over                 ontinue working with the
                                                                                                           C
rights of our employees and people across our         250,000 farmers in our supply chain                  industry to develop and evolve
supply chain, such as:                                against core indicators aligned to the               the Sustainable Tobacco
                                                      internationally recognised ‘Five Capitals’           Programme with a stronger focus
   ur Human Rights Policy and Supplier
  O                                                   livelihood framework.
  Code of Conduct are aligned to the UN                                                                    on risks and impacts;
  Guiding Principles on Business and Human          Health and safety                                       ontinue to enhance farmer
                                                                                                           C
  Rights (UNGPs);                                   We’re committed to ensuring a safe working
                                                    environment for our employees and
                                                                                                           livelihoods, such as by helping
   uman rights criteria are included in due
  H                                                                                                        to increase yields and improve
                                                    contractors, as well as for tobacco farmers in
  diligence procedures for our tobacco leaf
                                                    our supply chain, such as through:                     farm productivity;
  suppliers via the industry-wide Sustainable
  Tobacco Programme;                                   roup-wide health and safety programmes
                                                      G                                                     ontinue to aim for zero accidents
                                                                                                           C
                                                      and employee training;                               for all our employees and
   nnual human rights risk assessments for
  A
  all our other suppliers, with independent            ailored initiatives for higher-risk areas of
                                                      T                                                    contractors Group-wide; and
  audits for those with the highest risks;            our business, such as manufacturing and
                                                      Trade Marketing & Distribution;                       ignificantly increase the
                                                                                                           S
   trengthening our farm monitoring with
  S
                                                                                                           representation of women and
  our new global digital system that enables           roviding our contracted farmers with best
                                                      P
  issues to be tracked in real time for prompt        practice health and safety training, and             focus nationalities in senior
  remediation;                                        access to personal protective equipment              management.
                                                      (PPE); and
   articipating in multi-stakeholder groups,
  P
                                                                                                        SG Report
                                                                                                       E
  such as the ECLT Foundation and Slave-Free           eveloping a new operational standard for
                                                      D                                                Find full details of our policies, management
  Alliance; and                                       PPE in tobacco growing to drive a consistent     approach, performance and targets for all
                                                      approach across our supply chain.                our focus areas in our ESG Report, including
   onducting human rights impact
  C
                                                                                                       more details on these topics, as well as on
  assessments, aligned to the UNGPs, in             People and culture                                 anti-illicit trade.
  tobacco-growing countries.                        We’re creating a fulfilling, rewarding and               b
                                                                                                              at.com/sustainabilityreport
                                                    responsible workplace culture by:
Farmer livelihoods
We’re helping to enable prosperous                    Implementing Group-wide diversity and
livelihoods for our contracted farmers, such           inclusion initiatives;
as by:
                                                      L istening and responding to our employees’
   eveloping new tobacco seed varieties that
  D                                                    views via our Group-wide workforce
  offer greater yields, as well as higher quality      engagement channels; and
  and resistance to diseases, and so help
                                                      Investing in world-class training and
  boost farmers’ profits;
                                                       development programmes.

HIGHLIGHTS FOR 2019

                                          12–20%                                                                       82% EMPLOYEE
              5,000+
                                      INCREASE IN                                                                        ENGAGEMENT
         HUMAN RIGHTS                                                            18% REDUCTION IN
                                TOBACCO CROP YIELDS                                                                      score in our 2019
     TRAINING SESSIONS                                                           TOTAL ACCIDENTS
                                  thanks to our new seed                                                               ‘Your Voice’ survey,
     for farmers in our tobacco                                                     to employees and
                                 varieties covering 57% of                                                              7% higher than the
      leaf supply chain in 2019                                                    contractors in 2019
                                  our 2019 volumes from                                                                 FMCG comparator
                                    contracted farmers

BAT Sustainability Strategy Report 2019
Health                    Supporting            Creating               Independent
Introduction           impact                    ESG priorities        value                  assurance                                                 15

                                                                                                        Next steps
  ROBUST CORPORATE                                                                                           ontinue to strive for 100%
                                                                                                            C
  GOVERNANCE                                                                                                adherence to our SoBC and
                                                                                                            to increase the awareness,
                                                                                                            understanding and accessibility
We are committed to achieving                       Responsible marketing
                                                                                                            of our SoBC policies and
                                                    We’re committed to ensuring our products
our business objectives in                          are marketed responsibly to adult-only                  Speak up channels;
an honest, transparent and                          consumers, such as through:
                                                                                                             00% adherence to our
                                                                                                            1
accountable way, and sustaining                         ur International Marketing Principles
                                                       O                                                    International Marketing
a culture of integrity in                              (IMP) governing our marketing across all             Principles (IMP);
                                                       our product categories, including strict
everything we do.                                      requirements to be responsible, accurate              00% adherence to our global
                                                                                                            1
                                                       and targeted at adult consumers only;                Youth Access Prevention (YAP)
Business ethics                                      	
                                                      Expecting our markets to adhere to our                Guidelines; and
Ethical values form the basis of our culture          global Youth Access Prevention (YAP)
and are expressed in our Standards of                 Guidelines wherever our products are                  E nsure all our engagement with
Business Conduct (SoBC). Our Delivery with            sold; and                                              regulators and other stakeholders
Integrity programme builds on our already                                                                    is conducted in accordance
strong foundations to drive a consistent             	
                                                      Updating our IMP and YAP Guidelines
approach to managing key risks including              to keep pace with best practice and our                with our SoBC Lobbying and
bribery and corruption, such as by:                   growing range of product categories.                   Engagement Policy.

   egularly reviewing and updating our SoBC
  R                                                 Regulation and policy engagement
                                                                                                       ESG Report
  to remain at the forefront of best practice;      We’re committed to conducting all our              Find full details of our policies, management
                                                    engagement activities with external                approach, performance and targets for all
   roviding comprehensive SoBC training
  P                                                 stakeholders with transparency, openness           our focus areas in our ESG Report, including
  and communications for all our employees          and integrity, such as by:                         more details on these topics as well as for
  every year;                                                                                          Board diversity, executive remuneration,
                                                       Incorporating our longstanding Principles      tax transparency, stakeholder engagement
  Increasing the accessibility, awareness and                                                         and materiality.
   understanding of our SoBC and Speak up               for Engagement into a new Lobbying
                                                        and Engagement Policy in our SoBC, to                b
                                                                                                              at.com/sustainabilityreport
   channels, such as with our new SoBC app
   available in 12 languages; and                       highlight the importance of these principles
                                                        along with all other Group policies;
   eveloping procedures and tools to
  D
  promote the consistent application of              	
                                                      Applying robust procedures and controls
  our SoBC policies across the Group – for            for political contributions;
  example, our Third-Party Anti-Bribery and          	
                                                      Monitoring of regulatory engagement
  Corruption Procedure.                               activities across the Group by our
                                                      governance committees; and
                                                     	
                                                      Respecting the WHO Framework
                                                      Convention on Tobacco Control (FCTC)
                                                      5.3 provision, which calls for transparent
                                                      and accountable interaction between
                                                      governments and the tobacco industry.

HIGHLIGHTS FOR 2019

     100% EMPLOYEES
                                                UPDATED
      COMPLETED OUR                                                                       100%                          £41.4BN TOTAL
                                                OUR IMP
       SoBC TRAINING                                                                 COMPLIANCE                           TAXES PAID
                                         to reflect developments
     and formal compliance                                                        with our Youth Access               including taxes borne
                                        in marketing, technology
      sign-off procedures                                                         Prevention Guidelines               and collected in 2019
                                        and our product portfolio
            in 2019

                                                                                                                    BAT Sustainability Strategy Report 2019
Creating
16          value

CREATING                                               Our consumers are at the core of everything we do
                                                       and our success is underpinned by addressing their
VALUE FOR OUR                                          preferences; offering them a choice of enjoyable,
CONSUMERS                                              innovative and potentially less risky products.

     WE ENABLE                                                   WE COMMUNICATE AND
     CONSUMER CHOICE                                             MARKET RESPONSIBLY
     Our global community of consumers is diverse and has        We provide clear and accurate product information for
     differing needs. We aim to satisfy evolving consumer        consumers in a responsible way, enabling them to make
     preferences with a broad portfolio that considers           informed choices, while not appealing to youth.
     geographic and market differences.
                                                                 – Strict IMP compliance procedures in place,
     – 150 million daily consumer interactions give us             including a requirement for all marketing materials to
       a deep understanding of our consumers, enabling us to       be formally reviewed and approved by our Legal and
       develop products that meet their different needs.           External Affairs function.
     – Wide range of products to choose from, including          – IMP training provided for our marketing employees
       traditional cigarettes, vapour products, THPs, and          and trade representatives, as well as any external
       modern and traditional oral products.                       agencies we work with.
     – 48 markets where our new category products are            – Digital marketing hub and toolkits to help our
       available and plans to launch in further markets as         markets apply our IMP online, such as regarding digital
       quickly as possible, prioritising those with the right      age verification and the use of social media.
       conditions in place.
                                                                 – Responsible flavours and features, such as for
     – ‘Test and learn’ strategy helps us get the right            e-liquids, to avoid appealing to youth.
       mix of communication, product and price to maximise
                                                                 – Youth access prevention (YAP) activities,
       the harm reduction potential of new category products.
                                                                    such as supporting proof-of-age schemes and providing
                                                                    training for retailers and point-of-sale materials with
                                                                    YAP messaging.

     WE PRIORITISE                                               WE ADDRESS THE ENVIRONMENTAL
     CONSUMER SAFETY                                             IMPACTS OF OUR PRODUCTS
     Ensuring high quality and consumer safety is at the heart   We are committed to addressing our consumers’ concerns
     of how we design, develop and manufacture our products.     about the environmental impacts of our products,
                                                                 including post-consumption waste and the use of plastics
     – 1,500+ scientists focused on researching and
                                                                 and other materials.
       developing our new category products.
                                                                 – 13 markets with cigarette butt recycling and anti-litter
     – Decades of product stewardship experience
                                                                   programmes in collaboration with local governments,
       at our world-class R&D centre in the UK.
                                                                   NGOs and other third parties.
     – Thousands of hours of testing undertaken before
                                                                 – New projects to reduce plastic waste in packaging
       our products reach the consumer.
                                                                   and explore opportunities to improve the recyclability of
     – New world-class battery and product safety lab              our products.
       opened in 2019 in our R&D centre.
                                                                 – Take-back and recycling schemes being trialled
     – E-liquids manufactured in Europe and using                 for new category products in France, Japan, Mexico,
        pharmaceutical-grade nicotine.                             South Korea and the UK. For example, in Mexico we
                                                                   incentivise consumers to return their Vype by e-liquid
     – Openly sharing our approach and expertise
                                                                   pods by rewarding them with 50% off their next pack
       for the development of robust, industry-wide product
                                                                   for every two pods returned and a free pack for every
       quality and safety standards.
                                                                   10 pods returned.

BAT Sustainability Strategy Report 2019
Health               Supporting            Creating         Independent
Introduction   impact               ESG priorities        value            assurance                                         17

                OUR STRATEGY PUTS THE                                  WE WILL BECOME A BUSINESS
                CONSUMER FIRST, FOCUSING ON                            THAT DEFINES ITSELF NOT BY THE
                UNDERSTANDING ADULT CONSUMER                           PRODUCTS IT SELLS BUT BY THE
                CHOICE AND ENJOYMENT.                                  CONSUMER NEEDS IT MEETS.
                                                                      

                Kingsley Wheaton
                Chief Marketing Officer

                             11m
                          consumers regularly
                          use one of our non-
                        combustible, potentially
                         reduced-risk products

                                                                     VALUE CREATED
                                                                     FOR OUR CONSUMERS
                                                                     - A
                                                                         wide choice of superior and
                                                                        stimulating products for every
                                                                        mood and moment;
                                                                     - B
                                                                         rands they can trust that are
                                                                        manufactured to high quality
                                                                        and safety standards;
                                                                     - A
                                                                         lternatives to cigarettes with
                                                                        reduced-risk potential;
                                                                     - T
                                                                         ransparent, clear and
                                                                        accurate information, based
                                                                        on robust science, about the
                                                                        relative risks; and
                                                                     - R
                                                                         esponsible marketing that
                                                                        doesn’t engage or appeal
                                                                        to youth.

                                             100%
                                            compliance with our
                                          Youth Access Prevention
                                                 Guidelines

                                                                                         BAT Sustainability Strategy Report 2019
Creating
18          value

CREATING                                               Protecting the environment, enhancing farmer livelihoods,
                                                       respecting human rights and supporting the communities
VALUE FOR                                              where we operate adds value to society and is a pragmatic
SOCIETY                                                and commercial approach that secures the long-term
                                                       sustainability of our business.

     WE PROTECT THE ENVIRONMENT                                   WE RESPECT HUMAN RIGHTS
     Through our long-standing environmental management           Our integrated human rights strategy is aligned to the UN
     systems, we are addressing a wide range of issues, with a    Guiding Principles and includes policies, due diligence,
     particular focus on climate change, energy use, water use,   grievance channels and remediation procedures for our
     waste management and sustainable agriculture.                own business operations and supply chain.
     – Steady progress towards our ambitious new                  – Industry-wide Sustainable Tobacco Programme
       target to be carbon neutral by 2030, as well                 includes human rights criteria for our leaf suppliers.
       as alignment with the Task Force on Climate-related
                                                                  – Regular farm monitoring by our Extension Services,
       Financial Disclosures (TCFD) by 2022.
                                                                     with over 90% of our contracted farmers monitored
     – Increasing our use of renewable energy                        using our new global digital system.
       through green energy certificates and on-site energy
                                                                  – Raising farmers’ awareness of human rights
       generation projects.
                                                                     issues and overcoming any cultural barriers, through
     – Optimising water use in our factories including               over 5,000 training sessions in 2019, with more than
       recycling water used in manufacturing processes.              350,000 attendances.
     – Recycling over 90% of our total waste                    – Multi-stakeholder partnerships to find collaborative
         and working towards zero waste to landfill.                 solutions to address the root causes of human rights
                                                                     issues, including 20 years in the global ECLT Foundation.
     – Tackling deforestation by promoting the
       sustainable use of forest resources among contracted       – Human rights impact assessments in tobacco-
       tobacco farmers, as well as helping them reduce               growing areas in Indonesia and India in 2019, with two
       agrochemical use and use water more efficiently.              more planned in Mozambique and Mexico in 2020.
     – Engaging with our largest product materials                – Annual human rights risk assessments on 100%
       suppliers to manage climate risk and reduce Scope 3           of suppliers of other product materials and indirect
       carbon emissions in our supply chain.                         goods and services, with independent audits for those
                                                                     with the highest risk.

     WE SUPPORT COMMUNITIES                                       WE ENHANCE FARMER LIVELIHOODS
     Around the world, we partner with NGOs and other             We support our 90,000+ contracted farmers through the
     stakeholders on projects that support the communities and    work of Leaf Science & Research and our Extension Services
     landscapes where we operate.                                 of expert field technicians.
     – £46.1 million invested in community projects and         – Increasing yields by 12–20%, depending on
         charitable donations in the last three years.                growing conditions, thanks to our quality tobacco seed
                                                                      varieties and agronomy support, so helping to boost
     – Afforestation and environmental programmes in
                                                                      farmers’ profits.
        25 countries, including in Bangladesh and Pakistan that
        have planted over 183 million tree saplings since the     – Business management training for farmers
        early 1980s, and are among the largest private sector-        delivered by our Extension Services and strategic
        driven programmes in the countries.                           suppliers, including over 2,700 sessions in 2019 with
                                                                      more than 76,000 attendances.
     – Rural infrastructure programmes in eight countries
       to help provide access to clean drinking water, solar      – Increasing farm efficiency and productivity
       energy, healthcare and other basic amenities, such as in       through technology such as automated curing barns that
       Pakistan where our mobile doctor units bring free health       use 30% less fuel and are 50% less labour intensive.
       services for people across six farming regions.
                                                                  – Enhancing food security by educating and supporting
     – Empowerment programmes in 53 countries that                    tobacco farmers to grow other crops, such as vegetables,
       provide scholarships, training and skills development,         maize and soy, which can also bring additional
       micro-financing and support for small businesses and           sources of income.
       social enterprises.

BAT Sustainability Strategy Report 2019
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