Our policy is to respect and support the dignity, wellbeing and human rights of our employees, the workers in our supply chain and the communities in which we operate. We are committed to conducting our business in a responsible and sustainable way, seeking to mitigate the risks and impacts of human rights abuses both within our direct and indirect operations.

We have a collaborative approach to human rights, partnering with key stakeholders across our value chain to make positive societal impact. Our commitment to human rights extends through several Group policies. Our Code of Conduct and Supplier Code set out the foundations to our approach to human rights, which all our employees, suppliers and business partners are required to adhere to. We comply with all human rights law and where local law is less stringent, our Human Rights Policy will take precedent.



Respecting human rights is important in relation to our own employees, external reputation and supply chain sustainability. Our Policy and approach are guided by the international human rights principles in line with the International Bill of Human Rights, the International Labour Organization’s (ILO) core conventions and the principles and guidance contained within the United Nations Guiding Principles (UNGP) on Business and Human Rights.

We recognise that, along with our direct operations, our supply chain has the potential for human rights abuses, and we are committed to working with our suppliers and business partners to improve supply chain standards. The respect for human rights is predominately enabled through our requirements for supplier standards, business conduct and employment practices.

Our Human Rights policy sets out our Group-wide commitment and expectations in addressing human rights. Our due diligence processes enable us to monitor compliance with our policy commitments and identify areas for improvement. Further information on our due diligence processes for our tobacco supply chain and non-tobacco material supply chains can be found in our Modern Slavery Statement.



We reviewed our existing Human Rights Impact Assessment (HRIA) to better understand human rights in the context of our Next Generation Products (NGP) global supply chain. The combined study assessed around 940 entities across our operations, our tobacco leaf supply chain and across our first-tier non-tobacco material (NTM) and strategic NGP supply chains. The results of this assessment supported the development of our Human Rights Policy.

Following the results of the HRIA, we are actively seeking to: provide a safe working environment for our employees and those working for us and further mitigate the potential for modern slavery and child labour in our supply chains. We continue to respect all human rights, however our focus and drive for performance improvement is in these areas.

Whilst we operate in a number of countries where human rights are of particular concern, our global governance is the same. We respect the need and, as appropriate, facilitate individuals in having access to remedies should human rights be potentially breached. Mechanisms include concern reporting, grievance management and the communication of our Speaking Up (whistleblowing) policy.

We continue to engage with NGOs, including Human Rights Watch, on the issue of child labour, and in 2019 there was a particular focus on our sourcing activities in Zimbabwe. We welcome continued dialogue and are working collaboratively with a number of stakeholders to improve industry standards within our supply chain.




Child labour is unacceptable, and we make every effort to stop it happening in our supply chain.


We have partnered with the Slave Free Alliance to improve our processes for mitigating against modern slavery.


We seek to provide a safe working environment for our employees and those working for us.


Child labour is not acceptable. In accordance with the main international and legal instruments contained in the Conventions of the International Labour Organisation (ILO) and the Convention on the Rights of the Child (UNCRC), we define child labour as work that can harm children’s well-being and hinder their education, development and future livelihood.

Addressing child labour is a multi-stakeholder issue. We would like to see labour laws globally aligned to ILO conventions 138 (minimum age for admission to employment and work) and 182 (the worst forms of child labour).

Similar to other agricultural industries, the risk of child labour is highest in our tobacco growing supply chain. We address child labour through three main avenues;

(i) Leaf supplier programme known as STP; the ‘People’ pillar of STP is a critical element for the respect of human rights and is aligned with the relevant ILO conventions and the UN Guiding Principles.

(ii) Leaf Partnership Projects; working directly with our suppliers to fund projects in tobacco growing communities to help tackle child labour.

(iii) Our active support of the Eliminating Child Labour in Tobacco Growing Foundation (ECLT), which aims to tackle the root causes of child labour by improving access to education and providing alternatives to childhood working. It also has an advocacy role, raising awareness with governments and communities to galvanise positive action.

As an ECLT Board member we have signed a Pledge of Commitment and Minimum Requirements’, which affirms “ECLT Board Members respect and recognise the principles and rights enshrined in the ILO Conventions and recommendations on child labour. The pledge further affirms a sector wide commitment to uphold the robust policies on child labour”.

We are actively engaging with Human Rights Watch on the issue of child labour in agricultural supply chains.  We believe in constructive dialogue and transparency in dealing with this very important issue.

In addition to our STP, which covers all of our leaf suppliers, we operate a Supplier Qualification Programme for our key NTM and NGP suppliers. Suppliers are asked to complete a periodic compliance check, which includes questions on business conduct, environmental management and labour practices. We also encourage our suppliers to evaluate their suppliers and sub-contractors. We prioritise audits on the basis of risk assessment, quality and performance.

Further detail on how we address the issue of child labour in our agricultural supply chain is detailed in our Addressing Child Labour overview document. 


We recognise that modern slavery can include forced and child labour, servitude and human trafficking, all of which restrict a person’s freedom of movement whether that be physical or non-physical. Like all businesses, we run the risk of being exposed to modern slavery either within our direct operations or indirectly through our supply chain.

We published our first Modern Slavery statement, in accordance with the Modern Slavery Act, in February 2017. Our latest statement details how we continue to build upon and strengthen our approach to addressing modern slavery and potential human rights abuses and can be accessed here.

In 2019 we became founding members of the Slave-Free Alliance – the commercial arm of the international charity Hope for Justice. During the year subject matter experts from Slave-Free Alliance conducted a policy gap analysis and review of the policies and processes we have in place to mitigate against modern slavery. The review included stress testing processes, interviews with subject matter experts and testing the application of global policies on the ground.

We are committed to improving our processes and will work with relevant functions during 2020 to implement any findings and recommendations from Slave-Free Alliance.

We are proud to support Hope for Justice in pursuing its vision of a world free from slavery. Since our partnership began in 2014, Hope for Justice has rescued more than 500 victims of modern slavery in the UK, while also running anti-trafficking projects, community prevention initiatives, aftercare facilities and education/training programmes across nine countries.

During the year we rolled out our modern slavery e-learning course to support employees and key suppliers in understanding the issue and explaining how to raise concerns on suspected or actual human rights abuses. The e-learning was translated into German, Chinese, Dutch, French, Greek, Polish, Russian, Spanish and Ukrainian to ensure maximum coverage of our operations and suppliers that are identified as being at a higher risk of human rights breaches.

Want to know more?


Our sustainability strategy is integral to the long-term success of our business and underpins our drive to create shared value for our stakeholders.


Our case studies showcase our progress against our sustainability strategy. 


See the progress we’ve made against our key performance indicators during 2019.