Corporate Information The Company is a public limited company incorporated under the name of British American Tobacco p.l.c. and is registered in England and Wales under registered number 3407696. It was incorporated in July 1997 under the laws of England and Wales as a public limited company and is domiciled in the United Kingdom. Its registered office is at Globe House, 4, Temple Place, WC2R 2PG, London. Telephone: +44 (0)20 7845 1000. The Company’s agent for service in the U.S. for the purposes of the registration statements on Form F-3 (registration no. 333-288448) is Puglisi & Associates, 850 Library Avenue, Suite 204, Newark, Delaware 19711 U.S. The U.S. Securities and Exchange Commission (the SEC) maintains an internet site that contains BAT’s reports and other information (for example, BAT’s Form 20-F and other documents) filed electronically with the SEC. BAT’s SEC filings are available to the public at the SEC’s website, http://www.sec.gov. BAT’s Form 20-F is also available on BAT’s website, http://www.bat.com. History and Development of the Group The Group has had a significant global presence in the tobacco industry for over 100 years. BAT Ltd. was incorporated in 1902, when the Imperial Tobacco Company and the American Tobacco Company agreed to form a joint venture company. BAT Ltd. inherited companies and quickly expanded into major markets, including India, Ceylon, Egypt, Malaya, Northern Europe and East Africa. In 1927, BAT Ltd. expanded into the U.S. market through its acquisition of B&W. During the 1960s, 1970s and 1980s, the Group diversified its business under the umbrella of B.A.T Industries p.l.c., with acquisitions in the paper, cosmetics, retail and financial services industries, among others. Various business reorganisations followed as the business was eventually refocused on the Group’s core cigarette, cigars and tobacco products businesses with BAT becoming a separately listed entity on the LSE in 1998. The following is a summary of the significant mergers, acquisitions and disposals undertaken since 1998: –1999 – global merger with Rothmans International; –2000 – acquisition of Imperial Tobacco Canada; –2003 – acquisition of Ente Tabacchi Italiani S.p.A., Italy’s state-owned tobacco company, Tabacalera Nacional in Peru and Duvanska Industrija Vranje in Serbia; –2004 – the U.S. assets, liabilities and operations, other than certain specified assets and liabilities, of BAT’s wholly-owned subsidiary, B&W, were combined with RJR Tobacco Company to form Reynolds American Inc. As a result of the B&W business combination, B&W acquired beneficial ownership of approximately 42% of the Reynolds American Inc. shares; –2008 – acquisition of Tekel, the Turkish state-owned tobacco company and the cigarette and snus business of Skandinavisk Tobakskompagni A/S; –2009 – acquisition of an effective 99% interest in Bentoel in Indonesia; –2011 – acquisition of Protabaco in Colombia; –2012 – acquisition of CN Creative Limited in the UK; –2013 – entered into joint operations in China and paved the way for the Group Transformation launching our first Vapour product; –2015 – acquisition of the shares not already owned by the Group in Souza Cruz in Brazil, and the acquisitions of the CHIC Group in Poland, and TDR d.o.o., a cigarette manufacturer in Central Europe. Also in 2015, the Group increased its investment in Reynolds American Inc. by US$4.7 billion to maintain the Group’s approximate 42% equity position following Reynolds American Inc.’s purchase of Lorillard Inc.; –2016 – acquisition of Ten Motives in the UK; –2017 – acquisition of the remaining 57.8% of Reynolds American Inc. the Group did not already own. Following completion of the acquisition, Reynolds American Inc. became an indirect, wholly-owned subsidiary of BAT and is no longer a publicly-held corporation. In 2017, the Group also acquired certain tobacco assets from Bulgartabac Holding AD in Bulgaria and Fabrika Duhana Sarajevo (FDS) in Bosnia, acquired Winnington Holdings AB in Sweden and acquired certain assets from Must Have Limited in the UK, including the electronic cigarette brand ViP; –2018 – acquisition of Quantus Beteiligungs-und Beratungsgesellschaft mbH in Germany; –2019 – acquisition of Twisp Proprietary Limited in South Africa and 60% of VapeWild Holdings LLC in the U.S.; –2020 – acquisition of the nicotine pouch product assets of Dryft Sciences, LLC (Dryft) in the U.S. and the acquisition of Eastern Tobacco Company for Trading in Saudi Arabia; –2021 – entry into a strategic research and product development collaboration agreement with Organigram Inc., a licensed producer of cannabis and cannabis-derived products in Canada and a wholly-owned subsidiary of publicly-traded Organigram Global Inc. (formerly known as Organigram Holdings Inc.) and acquisition of a 19.9% equity stake in Organigram Global Inc. Also in 2021, the Group disposed of its Iranian subsidiary, BAT Pars Company PJSC; –2022 – acquisition of a 16% equity stake in Sanity Group GmbH, a German cannabis company. In 2022, the Group also made an investment, via a convertible debenture in the amount of c.£48 million, into Charlotte’s Web Holdings, Inc., a U.S.-based hemp extract wellness products business; –2023 – disposal of the Group's businesses in Russia and Belarus; –2024 – partial sale of the Group's investment in ITC Ltd (ITC) in India, after which the Group's shareholding reduced to 25.45%. Also in 2024, further investments in Organigram Global Inc. in Canada, increased the Group's equity stake to c. 30.6%, and the acquisition of Beni Oral Nicotine LLC in the U.S.; and –2025 – further partial sale of the Group's investment in ITC, after which the Group's shareholding reduced to 22.91%. Following the demerger of ITC’s hotel business (ITC Hotels), that was completed on 1 January 2025, the Group recognised an initial direct stake in ITC Hotels of 15% as a non-current investment on the balance sheet held at fair value through Other Comprehensive Income. In December 2025, the Group sold 9% of ITC Hotels in a block trade with the retained direct stake reduced to 6.3%. Please refer to note 18 in Part III - Item 18 Notes on the Accounts. Also in 2025, the Group settled historical litigation in Canada (please refer to note 24 in Part III - Item 18 Notes on the Accounts). The Group also concluded the final tranche of investment in Organigram, increasing the equity stake to 36.8%, restricted to 30% voting rights (please refer to note 14 in Part III - Item 18 Notes on the Accounts. Since the launch of our first Vapour product in 2013, we have been on a transformation journey to become a truly multi-category consumer products business. We are creating new Smokeless products that encourage adult smokers, who would otherwise continue to smoke, to switch to scientifically- substantiated, reduced-risk*† alternative. Principal Capital Expenditures and Divestitures 19 British American Tobacco p.l.c. Form 20-F 2025 Gross capital expenditures include purchases of property, plant and equipment and purchases of certain intangibles. The Group’s gross capital expenditures for 2025, 2024 and 2023 were £648 million, £581 million and £541 million, respectively, representing investment in the Group’s global operational infrastructure (including, but not limited to, the manufacturing network, trade marketing and IT systems). In 2025, this included £8 million of investments in energy efficiency and renewable energy generation, water recycling and efficiency projects, waste reduction, and product innovation-led specification improvements to enhance technical recyclability as part of our sustainability commitments (2024: £30 million). We will continue to proactively assess the performance of our assets to ensure value is maximised through operational returns or through disposal. In 2026, the Group expects to invest around £750 million of gross capital expenditure to enhance our growth opportunities and deliver operational efficiencies, representing the ongoing investment in the Group’s operational infrastructure (as described above), including the continued investment in New Categories across the Group. This is expected to be funded by the Group’s cash flows and existing facilities. In addition, as part of our transformation, we invest in the Wellbeing and Stimulation space and through our venturing unit, Btomorrow Ventures, and in the cannabis space, including in Organigram. In 2025, we partially monetized our investment in ITC for £1,052 million in net proceeds. In 2024, a similar partial sale of our investment in ITC resulted in net proceeds of £1,577 million. In 2025, following the demerger of ITC Hotels that was completed on 1 January 2025, the Group recognised an initial direct stake in ITC Hotels of approximately 15% as a non-current investment on the balance sheet held at fair value through Other Comprehensive Income. In December 2025, the Group sold 9% of ITC Hotels in a block trade, realising net proceeds of £318 million, with the retained direct stake reduced to 6.3%. In 2023, we sold our businesses in Russia and Belarus for net proceeds in the amount of £266 million. For more information related to the most recent business developments and property, plant and equipment, please refer to notes 13, 14 and 27 in Part III - Item 18 Notes on the Accounts. Item 4.B - Business Overview Overview British American Tobacco p.l.c. is the parent holding company of the Group, a leading multi-category consumer goods business that provides tobacco and nicotine products to millions of adult consumers around the world. The Group, excluding the Group’s associated undertakings, is organised into three regions: – The U.S.; –Americas and Europe (AME), comprising markets operating in Europe, Latin America and Canada; and –Asia-Pacific, Middle East and Africa (APMEA), comprising markets operating in Asia-Pacific, Middle East, Central Asia, Caucasus and Africa. The Group’s range of combustible products covers all segments, from value-for-money to premium, with a portfolio of international, regional and local tobacco brands to meet a broad array of adult tobacco consumer preferences wherever the Group operates. The Group has also built a portfolio of smokeless tobacco and nicotine products – including Vapour products, Heated Products (HPs) and Modern Oral products, which are collectively termed the New Categories, as well as Traditional Oral products. The Group manages a globally-integrated supply chain and its products are distributed to retail outlets worldwide. Multi-Category Portfolio BAT is a consumer-focused business operating internationally. Our portfolio reflects our commitment to meeting the evolving and varied preferences of today’s adult consumers. Category 2025 Revenue % of total revenue New Categories £3,621m 14.1% Traditional Oral £1,043m 4.1% Combustibles £20,201m 78.9% Other £745m 2.9% Total £25,610m 100.0% For a breakdown of total revenues by category of activity for the financial years 2025, 2024 and 2023, see note 2 in Part III - Item 18 Notes on the Accounts. Smokeless products Our smokeless portfolio comprises all brands within New Categories (Vapour, Heated Products and Modern Oral) and the strategic Traditional Oral brands in moist and snus. Vapour Vapour products contain an e-liquid, nicotine and flavours, and a battery-powered heating element. When activated, via puff or button, the heating element heats the liquid and forms an aerosol, commonly known as vapour. Vuse, our global Vapour brand, is the #1 brand in the category (in rechargeable closed system consumables and disposables in tracked channels). It provides cigarette smokers, who would otherwise continue to smoke, with the opportunity to transition to smokeless alternatives*†. Vapour revenue was down 10.4% to £1,542 million in 2025, largely driven by the continued proliferation of illegal single-use vapour products in the U.S. and Canada, and the Group exiting the category in a number of APMEA markets. However, there are encouraging signs for Vuse in the U.S. with the brand back to revenue growth in the second half of 2025 (compared to the first half of 2025 and full year 2024) – supported by increased enforcement against illicit single-use vapour products at a Federal and State level. Our new premium innovation, Vuse Ultra, offers adult consumers a differentiated, connected and personalised experience with a modern and stylish device. We are encouraged by the early performance of Vuse Ultra in Canada, Germany and France. As of the date of this Form 20-F, our Vapour brands are currently available in 57 markets. *Based on the weight of evidence and assuming a complete switch from cigarette smoking. These products are not risk free and are addictive. †Products sold in the U.S., including Vuse, Velo, Grizzly, Kodiak, and Camel Snus, are subject to FDA regulation and no reduced-risk claims will be made as to these products without agency clearance. Heated Products Heated Products (HPs) have two main functional parts: a battery-powered device and a consumable, which contains a plant-based (tobacco leaf or non- tobacco leaf) substance that is heated, not burned. Once the consumable has reached a certain temperature, it forms an aerosol releasing nicotine and flavours. 20 British American Tobacco p.l.c. Form 20-F 2025 Our flagship Heated Product brand, glo, offers an alternative to smoking that doesn't involve burning and, following scientific studies, produces lower levels of certain toxicants than cigarettes. Revenue for the category was down by 0.7%, due to a translational foreign exchange headwind of 1.7%. On a constant currency basis, revenue was up 1.0%. While growth in the category has been impacted by competitive pressure, momentum is building with the roll-out of glo Hilo in our largest profit pools. glo Hilo and glo Hilo Plus are our new premium connected devices which provide adult consumers with superior dual-heating technology and an integrated display, combined with a new consumables range, Virto and tobacco-free Rivo. We have continued the roll-out through 2025, with launches in Japan, Poland and Italy. As of the date of this Form 20-F, following a reassessment of our geographic footprint, glo is now available in 29 markets. Modern Oral Velo is our leading Modern Oral brand. Unlike inhalable products, Modern Oral products are nicotine pouches that are placed between the gum and upper lip so that nicotine can be absorbed effectively. They are typically manufactured tobacco leaf-free. Revenue for the category was up 47.4% to £1,165 million in 2025, largely driven by the successful roll-out of Velo Plus in the U.S. Modern Oral was the fastest growing New Category, with strong volume and value share growth reflecting the strength of our portfolio in all regions. In 2025, we launched our newest Modern Oral innovation, Velo Shift, offering adult consumers an innovative pouch shape and a new hexagonal can. Opportunities for these products in markets with established oral nicotine consumption and beyond, are vast – including in emerging markets. As of the date of this Form 20-F, our Modern Oral brands are currently available in 49 markets. Traditional Oral Traditional Oral products include snus and snuff. Snus is a moist form of oral tobacco originating from Sweden. It is available in loose form or as pouches. With Traditional Oral products, consumers take a single portion or pouch and place it within the mouth, between the lip and gum. The nicotine and flavours are then absorbed through the inner lining of the cheek. As of the date of this Form 20-F, our Traditional Oral brands are currently available in 3 markets. Combustibles The Group sold 465 billion cigarette sticks and 12 billion other tobacco products (stick equivalents) in 2025. With 36 fully integrated cigarette manufacturing facilities in 35 markets, the Group operates internationally. As of the date of this Form 20-F, our combustible products are sold in over 140 markets. Principal Markets The Group, excluding the Group’s associated undertakings, is organised into three complementary regions, with a balanced presence in both high-growth emerging markets and highly profitable developed markets. Regions 2025 Revenue United States of America (U.S.) £11,534m Americas and Europe (AME) £9,309m Asia-Pacific, Middle East and Africa (APMEA) £4,767m Total £25,610m For a breakdown of total revenues by geographic markets for the financial years 2025, 2024 and 2023, see Item 5.A on page 28 and note 2 in Part III - Item 18 Notes on the Accounts. Our in-depth marketplace analysis delivers insights on consumer trends and segmentation, which facilitates our geographic brand prioritisation across our regions and markets. The U.S. is one of our three regions and is also a Top Market across our product categories (other than HP). In AME, our Top Markets by category are Brazil, Germany, Mexico and Romania for Combustibles, Germany, Greece, Italy, Poland, Portugal, Romania, Spain and the Czech Republic for Heated Products, Canada, France, Germany, Poland, Spain and the UK for Vapour and Denmark, Norway, Poland, Sweden, Switzerland and the UK for Modern Oral. In APMEA, Japan and Pakistan are the Top Markets for Combustibles and Japan and South Korea for Heated Products. For a discussion of the Company’s financial condition, changes in financial condition and results of operations, see Item 5.A on page 28. Seasonality The Group’s business segments are not significantly affected by seasonality although in certain markets cigarette consumption trends rise during summer months due to longer daylight time and tourism. Raw Materials The Group does not own tobacco farms or directly employ farmers. However, it sources tobacco leaf directly from approximately 91,000 contracted farmers and third-party suppliers, primarily in emerging markets. We remain committed to enhancing the long-term sustainability and viability of our contracted farmers by focusing on improving quality, the distribution of more resilient hybrid seeds and the implementation of tailored mechanisation to reduce production costs and increased yields. In Brazil, for example, our Global Leaf Agronomy Development (GLAD) centre develops agronomic solutions supported by technology. These solutions improve crop management, optimise resource efficiency and help address challenges such as climate change and soil degradation. GLAD innovations are now applied in 12 countries. For example, automated curing barns have reduced fuel consumption by up to 50% and manual labour requirements by a similar proportion. We expect our third-party suppliers to uphold comparable standards in managing their farmer contracts. We conduct annual reviews of our contracts, taking into account projected Group requirements over the medium-term (2-3 years) to ensure stability of demand and supply on production volumes. The Group also purchases tobacco leaf from India through our associate ITC, where a portion of leaf purchase occurs via an auction system. ITC maintains full traceability of all purchases and monitors farmers for their adherence to required standards. 21 British American Tobacco p.l.c. Form 20-F 2025 As with any global agricultural commodity, international tobacco prices fluctuate yearly. Prices are influenced by multiple factors including production costs (such as labour and agricultural inputs), local inflationary pressures, economic and political developments, and climatic conditions that affect the supply, demand and crop quality. Climate change-related risks may further contribute to tobacco price volatility. Even in a scenario in which global warming is limited to no more than 1.5°C above pre-industrial levels, we anticipate medium- to long-term increases in energy prices which are likely to exert upward pressure on raw material costs. Additionally, risks related to acute weather (e.g., extreme weather events, such as cyclones, floods or heatwaves) and chronic weather (continued change in climate, resulting in changes to precipitation patterns and temperatures in general) are expected in the long-term (with respect to acute weather effects) and in the short-term (with respect to chronic weather) to disrupt the agricultural supply chain further by reducing production capacity and yields, thereby increasing raw material costs. To mitigate the impact of leaf cost inflation, the Group maintains a diversified sourcing strategy built around multiple origins capable of supplying interchangeable quality grades. This flexibility enables us to optimise procurement decisions in response to market conditions and reduces reliance on any single geography. In addition, we operate a c,12‑month duration policy that provides forward visibility on pricing and availability, helping to smooth short‑term fluctuations in supply and manage volatility in international tobacco markets. This structured approach supports cost stability, strengthens supply resilience, and ensures continuity of high‑quality leaf for our manufacturing operations. At the time of this report, the Group believes there is an adequate supply of tobacco leaf in the world markets to satisfy its current and anticipated production requirements. We also source a number of other materials as part of our production requirements, covering areas that include wrapping materials and filters for our combustibles business and liquids, heaters and batteries for our New Categories products. We work closely with our suppliers to ensure a resilient supply chain, with contingency sourcing in place. Contracts and sourcing agreements are reviewed regularly, to ensure competitive trading terms while recognising that prices may be impacted by external factors. Our electronics supply chain includes multiple layers of suppliers, which create additional challenges for managing human rights risks. We take a risk-based approach to our human rights due diligence, which includes evaluation through an independent risk assessment platform and third-party audits, covering topics that are identified as the most relevant for the Group’s non-tobacco supply chain, such as working conditions and forced labour. Sustainability represents about 10-15% of the supplier evaluation criteria and is in progress to be embedded in the contract service levels agreements. In addition, our Supplier Code of Conduct applies to all our suppliers and outlines the actions we expect them to take in relation to responsible mineral sourcing, and we are committed to engaging with our suppliers to build on supply chain traceability, as appropriate. We are currently preparing for new regulatory requirements related to supply chain due diligence. Raw material sourcing strategies are reviewed frequently (to ensure continuity of supply and cost efficiency) with other productivity initiatives (including specification rationalisation) identified as part of the Group’s drive for productivity savings to further mitigate the impact of inflation and optimise cash flow. We also have a vast network of suppliers of indirect goods and services that are unrelated to our products, such as for IT services and facilities management. For more details on the volatility of raw material pricing as well as on the risks associated with the sourcing, please refer to Item 5.A - Raw materials and other consumables paragraph on page 31 and Item 3.D, respectively. Marketing 'Love our Consumer' is one of our values and consumers are the core of everything we do. Consumer-led product innovation is central to achieving our purpose and we believe that our multi-category approach is the most effective way to meet the diverse preferences of adult nicotine consumers worldwide. We engage with our adult consumers through extensive market research activities and sales interactions, led by our marketing teams across the Group. We use a globally responsible approach to marketing, seeking to raise standards and prevent underage access, while growing our market share by encouraging adult consumers to choose our products over those of our competitors. As one of the most established tobacco and nicotine businesses in the world, we truly understand adult consumers and their diverse preferences. This, combined with our data and analytics-led approach, helps us to gain insights and anticipate trends. These insights enable the development and responsible marketing of our products, so that they are fit to satisfy consumer preferences. Powered by our consumer insights platform, we focus on product categories and consumer segments across our global business that have the greatest potential for sustainable growth. In addition, we engage loyalty programmes and other incentives to reward our adult consumers. We work with customers to uphold responsible marketing and prevent underage access. Examples of our engagement with customers include: –Ongoing dialogue - this represents most of our customer engagement and includes regular business meetings and performance reviews. –Customer care portals and customer voice programmes - we operate helplines and websites for feedback and complaints, and survey retailers to assess satisfaction via our Customer Engagement Index. –Retail audits and engagements - we work with retail partners and conduct audits to help ensure adherence to our responsible marketing standards. Our Responsible Marketing Principles Our approach to responsible marketing is governed by our Responsible Marketing Principles (RMP) and Responsible Marketing Code (RMC). They apply to all BAT entities and marketing suppliers working on our behalf. We seek to uphold the same high standards in every market in which we operate, even when they are stricter than applicable local laws. Our RMP, RMC and supporting guidelines govern how we market our products, with a particular focus on designing products for adult smokers and adult nicotine consumers. Topics covered include Underage Access Prevention (UAP), mandatory health warnings and digital marketing content. The RMP and RMC are underpinned by detailed guidelines and toolkits to facilitate their consistent application. Processes are in place for reviewing and approving marketing content to facilitate compliance with both our standards and local laws. Marketing in a digital age We only use social media where the audience is predominantly adult. We do not use open social media for our combustibles brands. Where we use social media partnerships to promote Smokeless products, we only select third-parties whose audience is predominately adult. Our e-commerce and social media channels must also adhere to the requirements set out in the RMP and RMC. Our Digital Confidence Unit (DCU) is dedicated to monitoring social media content 24/7 for compliance and reputational management purposes. To provide oversight, the team reviews our social media posts to check for compliance with the RMP and RMC. The DCU engages with markets, as appropriate, to take swift, corrective action, in respect of any incidents identified. Reporting and resolving incidents of non-compliance Any allegations of non-compliance are managed and escalated by the relevant market. Regional Heads of Legal report any relevant findings to the Regional Audit Committee and remediation actions are implemented, as appropriate. In 2025, we identified two incidents of non-compliance with local marketing regulations resulting in a fine or penalty1. Notes: 1.The data for the number of marketing incidents resulting in a fine or penalty is based on cases submitted under applicable governance by Regions and Direct Reporting Business Units (DRBUs) throughout the year to the Responsible Marketing Committee. Incidents are only reported here when a fine is issued. 22 British American Tobacco p.l.c. Form 20-F 2025 Patents and Trademarks Our trademarks, which include the brand names under which our products are sold, are key assets which we consider, in the aggregate, to be important to the business as a whole. As well as protecting our brand names by way of trademark registration, we also protect our innovations by means of patents and designs in key global jurisdictions. In February 2024, we entered into a settlement agreement with an indirect wholly-owned subsidiary of Philip Morris International Inc. (PMI) regarding the infringement of certain patents and certain intellectual property rights, see Item 10.C. on page 88. New Manufacturing Processes As the Group increases its capabilities in new products, including New Categories, we are developing relationships with third parties to support the manufacture of certain components inherent within our New Category products. We have several development and commercial supply contracts, licences, and agreements with our supply partners to support our new manufacturing processes. Within these arrangements, IP ownership and lack of supply liability clauses are embedded within the framework documentation to ensure the risk exposure is managed accordingly and we are free to develop or source alternative manufacturing solutions to ensure continued supply for growth and/or profitability. We are also developing in-house manufacturing capabilities, including the manufacture of HP and Modern Oral products, and we continue to invest in the Group’s manufacturing infrastructure to support the Group in the future. Statements Regarding Competitive Position Statements referring to the competitive position of BAT and its subsidiaries are based on the Group’s belief and best estimates. In certain cases, such statements and figures rely on a range of sources, including investment analyst reports, independent market surveys, and the Group’s own internal assessments of market share. The Group uses certain non-financial measures to assess its competitive position: Volume Volume is defined as the number of units sold. Units may vary between categories. This can be summarised for the principal metrics as follows: –Factory-made cigarettes (FMC) – sticks, regardless of weight or dimensions; –Roll-Your-Own/Make-Your-Own – kilos, converted to a stick equivalent based upon 0.8 grams (per stick equivalent) for Roll-Your-Own and between 0.5 and 0.7 grams (per stick equivalent) for Make-Your-Own; –Traditional Oral – pouches (being 1:1 conversion to stick equivalent) and kilos, converted to a stick equivalent based upon 2.8 grams (per stick equivalent) for Moist Snuff, 2.0 grams (per stick equivalent) for Dry Snuff and 7.1 grams (per stick equivalent) for other oral; –Modern Oral – pouches, being 1:1 conversion to stick equivalent; –Heated sticks – sticks, being 1:1 conversion to stick equivalent; and –Vapour – units, being pods, bottles and disposable units. There is no conversion to a stick equivalent. Volume is recognised in line with IFRS 15 Revenue from Contracts with Customers, based upon transfer of control. It is assumed that there is no material difference, in line with the Group’s recognition of revenue, between the transfer of control and shipment date. Volume is used by management and investors to assess the relative performance of the Group and its brands within categories, given volume is a principal determinant of revenue. Volume Share Volume share is the estimated number of units bought by adult consumers of a specific brand or combination of brands, as a proportion of the total estimated units bought by adult consumers in the industry, category or other sub-category. Sub-categories include, but are not limited to, Heated Products, Modern Oral, Traditional Oral, Total Oral or Cigarettes. Except when referencing particular markets, volume share is based on our Top markets. Top markets are those markets that management determines are strategic in each category, with reliable share data from third parties. Management notes that the markets that form the definition of Top markets may change between periods as this will reflect the development of the category within markets including their relative revenue sizes. Where possible, the Group utilises data provided by third-party organisations, including NielsenIQ, based upon retail audit of sales to adult consumers. In certain markets, where such data is not available, other measures are employed which assess volume share based upon other movements within the supply chain, such as sales to retailers. This may depend on the provision of data by customers including distributors/wholesalers. Volume share is used by management to assess (and management believes that it is useful to users of the financial statements to understand) the relative performance of the Group and its brands against the performance of its main competitors in the categories and geographies in which the Group operates. This measure is also useful to understand the Group’s performance when seeking to grow scale within a market or category from which future financial returns can be realised. Volume share provides an indicator of the Group’s relative performance in unit terms versus competitors. Volume share in each period compares the average volume share in the period with the average volume share in the prior year (using the current year Top markets). This is a more robust measure of performance, removing short-term volatility that may arise at a point in time. Due to the timing of available information, volume share for 2025 is for the year ended 31 December 2025 unless otherwise stated. However, in certain circumstances, related to periods of introduction to a market, in order to illustrate the latest performance, data may be provided as at the end of the period rather than the average in that period. In these instances, the Group states these at a specific date (for instance, December 2025). Please refer to page 20 for the Top Markets by region and by product category. Value Share Value share is the estimated retail value of units bought by adult consumers of a particular brand or combination of brands, as a proportion of the total estimated retail value of units bought by adult consumers in the industry, category or other sub-category in discussion. Except when referencing particular markets, value share is based on our Top markets. Top markets are those markets that management determines are strategic in each category, with reliable share data from third parties. Management notes that the markets that form the definition of Top markets may change between periods as this will reflect the development of the category within markets including their relative revenue sizes. Where possible, the Group utilises data provided by third-party organisations, including NielsenIQ, based upon retail audit of sales to adult consumers. In certain markets, where such data is not available, other measures are employed which assess value share based upon other movements within the supply chain, such as sales to retailers. This may depend on the provision of data by customers (including distributors and wholesalers). Value share is used by management to assess (and management believes that it is useful to users of the financial statements to understand) the relative performance of the Group and its brands against the performance of its competitors in the categories and geographies in which the Group operates, specifically indicating the Group’s ability to realise value relative to the market. The measure is particularly useful when the Group’s products and/or the relevant category in the market in which they are sold has developed or achieved scale from which value can be realised. 23 British American Tobacco p.l.c. Form 20-F 2025 Value share in each period compares the average value share in the period with the average value share in the prior year (using the current year Top markets). This is a more robust measure of performance, removing short-term volatility that may arise at a point of time. Due to the timing of available information, value share for 2025 is for the year ended 31 December 2025 unless otherwise stated. However, in certain circumstances, related to periods of introduction to a market, in order to illustrate the latest performance, data may be provided as at the end of the period rather than the average in that period. In these instances the Group states these at a specific date (for instance, December 2025). Please refer to page 20 for the Top Markets by region and by product category. Our Top Markets are defined as the Top markets by industry revenue. These markets represent: –c.80% of total industry vapour revenue (rechargeable closed systems consumables and disposables in tracked channels) in 2024. –c.80% of total industry HP revenue in 2024. –c.90% of total industry Modern Oral revenue in 2024. –c.60% of total industry cigarettes revenue in 2024. Regulation of the Group’s business Overview The tobacco and nicotine industry remains one of the most heavily regulated consumer goods sectors globally, with manufacturers operating under diverse and often complex regulatory frameworks. Nearly all markets impose restrictions on the manufacture, pricing, sale, marketing, packaging and use of tobacco products. At the same time, regulation of new, innovative, non-tobacco nicotine products continues to evolve as governments seek to establish appropriate frameworks for these categories. In some markets, entirely new regulatory regimes are being developed, while in others, emerging products are being brought under existing rules that were not originally designed for them – for example, Modern Oral products being treated under pharmaceutical legislation or regulated as food products. The Group continues to engage proactively with governments, regulators and other stakeholders to provide advice and experience that can help to shape balanced, evidence-based policies and achieve reasonable and proportionate regulation across all product categories. Broadly, regulation of tobacco and New Categories falls into the following categories: Category bans: Prohibitions on the sale, import, possession, or use of specific products, including newer nicotine or tobacco alternatives. Product regulation: Regulations governing product composition, ingredients, format, design and attributes – such as nicotine strength or flavour – along with product safety standards and disclosure requirements. Packaging and labelling: Requirements mandating health warnings and other information on packaging, as well as requirements regarding pack design, including shape, size, weight, and colour and plain packaging requirements. Advertising and sponsorship: Partial or comprehensive restrictions on advertising, promotion and sponsorship, including on brand stretching (the association of tobacco brands with non-tobacco products) and limitations on the use of certain descriptors or brand names. Retail regulation: Controls on where and how products can be sold, such as outlet types (e.g. specialists, supermarkets or vending machines), display restrictions (e.g. above or below the counter), and requirements for age verification and adult purchase. Place-based restrictions: Bans on smoking or vaping in designated public or private spaces. Price-related measures: Policies influencing product prices, including excise taxes, minimum pricing, and other fiscal measures. Responsibility obligations: Requirements under Extended Producer Responsibility (EPR) schemes, such as waste management initiatives, and actions to combat illicit trade. In addition to complying with local laws and regulations, the Group implements a range of global policies and standards that may go beyond local requirements, reflecting its commitment to responsible business practices and high regulatory compliance standards. The Group recognises and supports the objectives of governments and policymakers in reducing smoking rates and the associated health impacts, as well as the role of regulation in achieving these goals. Accordingly, the Group endorses tobacco and nicotine regulations that are grounded in robust evidence, tailored to local circumstances, effectively achieve intended policy objectives, and which avoid unintended consequences, such as the expansion of illegal markets. Progressive, science-based regulation—including forward-looking policies for Smokeless products – is essential to achieving a smokeless world and supporting governments’ smoke-free ambitions, helping to build A Better Tomorrow™. The Group believes that the development of regulations for Smokeless products, should follow the below principles: –be based on science and evidence, and proportionate to the products’ risks compared with those of combustible tobacco –facilitate adult awareness of smokeless alternatives and allow adult-only access –ensure high product quality and environmental sustainability, while ensuring consumer relevance; and –enable effective enforcement. World Health Organization’s Framework Convention on Tobacco Control A large proportion of the regulation of tobacco products has been driven at global level by the World Health Organization (WHO)’s international treaty: the Framework Convention on Tobacco Control (FCTC). The FCTC came into force in 2005 and contains provisions which seek to reduce tobacco consumption and exposure to smoke. The original treaty is supplemented by one protocol on illicit trade and guidelines on the implementation of several of the treaty obligations. While the guidelines are not legally binding, they provide a framework for Parties to the treaty on implementing specific policies that target tobacco consumption. To date, the FCTC has been ratified by 183 countries - not including the U.S. Over time there have been growing efforts by tobacco-control advocates and public health organisations to encourage governments to regulate the tobacco and nicotine industries in ways that go beyond the measures originally agreed in the FCTC. As a result, the scope of regulation is expected to continue to expand, potentially encompassing products and areas not envisaged when the treaty was first adopted. In recent years, the WHO and other public health bodies have been advancing what has been described as a broader interpretation of the FCTC, reframing its objectives to encompass nicotine use rather than focusing solely on tobacco consumption. This is despite the original text referring to nicotine solely in the context of dependence among tobacco users, not as a subject for wider regulation. All engagement efforts by the tobacco industry are closely monitored by these organisations and are often erroneously characterised as unlawful. In turn, this has an impact on the willingness of Parties to engage with the industry, which limits the opportunity for the tobacco industry to provide its experience and expertise in the development of regulation around nicotine products. The Eleventh Session of the Conference of the Parties to the WHO Framework Convention on Tobacco Control (COP11) took place in November 2025. Among other debates, proposals and decisions, COP11 featured a debate on Tobacco Harm Reduction (THR), in which a number of Parties expressed 24 British American Tobacco p.l.c. Form 20-F 2025 support for a recommendation that Parties should consider it as a policy option when establishing national tobacco control frameworks and strategies. However, no consensus was reached on the proposals. A decision on Article 19 (liability) was adopted, inviting Parties to consider recommendations from the Expert Group – the Expert Group was created to examine the reasons for low implementation of Articles 9 and 10 (regulation of product contents and disclosure) and related partial guidelines. Regarding environmental protection under Article 18, COP11 adopted a decision focusing on research, data collection, awareness-raising and examination of potential regulatory pathways. Earlier proposals such as filter bans, mandatory classification of tobacco waste as hazardous, and assertions of FCTC primacy in environmental fora were not included in the final text. Instead, the decision emphasises coordination with environmental agreements and the preparation of a detailed report for COP12. No new guidelines were adopted at COP11. The next Conference of the Parties (COP12) will take place in Armenia in November 2027. EU Tobacco and Related Products Directive (2014/40/EU) The most recent version of the EU Tobacco and Related Products Directive (2014/40/EU – colloquially called TPD2), which is the current main framework for tobacco and nicotine product regulation for EU Member States, was adopted in April 2014 for transposition by May 2016. TPD2 seeks to ensure that the same rules apply across all Member States, though they are also able to go beyond its requirements provided such measures are compatible with EU law. For tobacco products, the main provisions of TPD2 include: a ban on the sale of cigarettes and roll-your-own tobacco with a characterising flavour, including menthol flavours; requirements for combined pictorial and textual health warnings covering 65% of the two main pack surfaces (front and back) for cigarettes; restrictions on pack shape and size, as well as ingredients reporting and ‘tracking and tracing’ requirements. The Directive also regulates vapour products by introducing a nicotine limit of 20 mg/ml, a premarket notification requirement and ingredient reporting requirements and advertising restrictions. In May 2021, the European Commission published a report reviewing the implementation of the Directive which concluded it had been successful in reducing tobacco use but that more action was required, particularly on new categories such as vapour and tobacco heated products (THPs). Stricter rules for THPs have already been adopted by way of a delegated act (Commission Delegated Directive 2022/2100), which removed the exemption for THPs from the ban on tobacco products with characterising flavours and the requirement to carry certain health warnings (see the Regulation of Ingredients, including Flavoured Tobacco Products section for details). A revised legal instrument (TPD3), which may come in the form of an EU Regulation which would be immutable and directly applicable without any transposition into national law, is currently being drafted. The European Commission is expected to propose a revision to the existing EU tobacco control framework (both TPD2 and the Tobacco Advertising Directive) in 2027. The process of reviewing the tobacco control framework has been underway for the last three years. A future framework will most likely take the form of a revised Directive, although directly applicable EU regulations are possible. Specific provisions in any new Directive are yet to be confirmed. Recent Commission statements and publications - such as the EU’s Beating Cancer Plan and Cardiovascular Health Plan - suggest that further restrictions will apply to traditional combustible tobacco products, which could include standardised packaging, stricter ingredient rules and a ban on the use of plastic-containing filters. For vapour products, and where still permitted for THPs, changes could include restrictions on flavours, packaging, communications and ingredients, and the extension of regulation to nicotine-free products. A revised TPD2 could seek to regulate nicotine pouches, either by creating a new framework or potentially banning the category. Herbal Products for Heating are likely to also be addressed by any Directive, although details on specifics are less clear for this category. EU Single-Use Plastics and Environmental Regulation The Single Use Plastics Directive (EU) 2019/904 (the SUP Directive) entered into force in July 2019. It mandates Member States to establish Extended Producer Responsibility (EPR) schemes to cover the costs of litter clean-up and to implement on-pack marking requirements for tobacco product filters. Member States were required to transpose the SUP Directive into national law by 3 July 2021, with an implementation deadline of 3 July 2021 for pack marking requirements and of 5 January 2023 for EPR schemes. However, several Member States experienced delays in transposing and implementing the SUP Directive, resulting in EPR schemes becoming operational months - or in some cases years - behind schedule. Spain, for instance, only published its implementing regulations in late 2024, while Greece began discussing its own in early 2025. At the EU level, the European Commission issued long-awaited guidance in 2025 to assist Member States in defining cost criteria for litter clean-up. It also confirmed plans to evaluate the SUP Directive by 2027 to assess its impact and determine whether revisions are required. A public consultation and call for evidence was launched in December 2025, open for feedback through to March 2026. The European Commission also held consultations on a proposed Circular Economy Act in 2025 and on reducing administrative burdens arising from environmental legislation. Internationally, the UN Environment Programme’s Intergovernmental Negotiating Committee failed to reach agreement on a legally binding treaty on plastic pollution, after opposition to a cap on plastic production from countries including Russia, India and the United States. The Committee is expected to reconvene in 2026. Restrictions on the Use of Tobacco and Vapour Products in Public and Private Places The Group operates across various markets where restrictions are in place on smoking and vaping in certain private, public, and workplace settings, such as restaurants, bars, beaches, and nightclubs. While the specifics of these restrictions vary, comprehensive bans on smoking, vaping and the use of THPs in public and workplace environments have been established in markets such as the U.S., Canada, the UK, France, Spain, New Zealand, and Australia. More recently, new restrictions have included restrictions on the use of such products within a specified distance from designated public areas, such as primary schools, and/or in private places such as vehicles when children are present or balconies in shared housing. Regulation of Ingredients, including Flavoured Products Some countries have restricted or banned the use of certain flavours or ingredients in cigarettes and other tobacco, vapour and nicotine products. These actions are typically based on claims that flavoured products disproportionately appeal to minors, encourage youth smoking initiation or can increase the addictiveness or toxicity of products. In these cases, permitted flavours are often limited to tobacco and/or menthol variants only. Such restrictions have been enacted in markets including the U.S., Canada, Australia and Türkiye. The EU’s TPD2 similarly banned the sale of cigarettes, roll-your-own tobacco and THPs, with characterising flavours other than tobacco. However, some regulations relating to flavours currently face legal challenges. In Brazil, for example, a proposed ban on ingredients with flavouring or aromatic properties, including menthol, remains unenforced due to ongoing litigation. Additionally, regulators in Europe are increasingly examining restrictions on flavours and other ingredients for RRPs*† . For example, Finland, the Netherlands, Denmark, Spain and the UK have adopted, or are considering adopting, restrictions on flavours for vapour products. In 2023, an instrument (called a Delegated Directive), issued by the European Commission, extended the ban in the TPD2 on characterising flavours for tobacco products to also apply to THPs. Member States were required to apply the Directive from October 2023. A growing number of countries have restricted, or are considering restrictions on flavours for nicotine pouches, including Canada, Denmark, Latvia and Poland, while a very limited number, such as Spain, are considering flavour restrictions for Herbal Products for Heating. In a few cases, some countries have sought to restrict flavours for all “nicotine products”, thereby seeking to capture all categories under flavour provisions. Further legislation on ingredients for both cigarettes and RRPs*† is expected. The Conference of Parties to the FCTC has tasked a Working Group to expand the partial guidelines on the regulation of the contents of tobacco products and tobacco product disclosures (Articles 9 and 10 of the FCTC). This Working Group’s activity was suspended in 2018 and an Expert Group was created to examine the reasons for low implementation of Articles 9 and 10 and related partial guidelines. Although the Expert Group reported back in 2021, COP10 could not agree on whether to proceed through a Working Group or an Expert Group. COP11 again failed to resolve this question, deferring it to COP12 in 2027. 25 British American Tobacco p.l.c. Form 20-F 2025 Plain and Standardised Packaging and Design Plain (or ‘standardised’) packaging typically involves restrictions on using trademarks, logos, and colours on product packaging, allowing only a single approved base colour and specifying the font, size, and placement of the brand name and variant. Tobacco control advocates have tended to prioritise these measures, with non-binding FCTC guidelines suggesting that Parties "should" consider adopting plain packaging. As of November 2025, 28 countries have either implemented or passed legislation for plain packaging requirements impacting cigarettes, including Australia, Belgium, Canada, Denmark, France, Ireland, New Zealand, the Netherlands, Saudi Arabia, Singapore, Türkiye and the UK. A number of other countries, including but not limited to Spain, South Africa and potentially Indonesia, are currently actively considering introducing similar legislation. More recently, some regulators and tobacco control advocates have examined measures which could apply to individual cigarettes, such as mandatory on- product health messages. A series of such messages was approved in Canada and Australia, and regular cigarettes were required to carry the messages as of April 2025 in both jurisdictions. Notes: *Based on the weight of evidence and assuming a complete switch from cigarette smoking. These products are not risk free and are addictive. †Products sold in the U.S., including Vuse, Velo, Grizzly, Kodiak, and Camel Snus, are subject to FDA regulation and no reduced-risk claims will be made as to these products without agency clearance. Product Display Bans at Point of Sale and Licensing Regimes Product display bans at the point of sale and licensing regimes have become relatively commonplace for combustible tobacco products and have been implemented for several years in a number of countries, including in Norway, Iceland, Finland, New Zealand, Thailand, Canada, Australia, and the UK. A small number of countries have also sought to extend these provisions to apply to RRPs*†. Some countries, such as Hungary, Finland and Spain, have also sought to restrict the supply of tobacco products, including through the adoption of licensing regimes limiting the number of retail outlets from which it is possible to purchase tobacco products or by prohibiting the sale of tobacco products within a certain distance of specified public places. Illicit Trade The illegal market for tobacco products is an increasingly important issue for governments and the industry across the world with an increasing number considering or adopting regulation to support anti-illicit trade activities. These regulations may include mandatory "tracking and tracing" systems to help regulators identify where seized products entered the supply chain, security features to prevent counterfeiting, and inspection and authentication requirements for seized products. For instance, the TPD2 mandates that all unit packets of tobacco be marked with a unique, indelible identifier that provides various details about the product’s route-to-market when scanned. In November 2012, FCTC Parties adopted the protocol to Eliminate Illicit Trade in Tobacco Products (Protocol), which includes a range of supply chain control measures, such as the implementation of "tracking and tracing" technologies. As of November 2025, 72 parties, including the EU, have ratified the Protocol. Regulation of Reduced-Risk Products*† (RRPs) The vapour products category has grown rapidly in both size and complexity in the past decade. However, there is still no consensus on how RRPs*† should be regulated. The EU’s TPD2, for example, establishes frameworks for the regulation of novel tobacco products and vapour products by introducing nicotine limits, health warning requirements, advertising restrictions and pre-market notification and post-market disclosure obligations. As noted above, the World Health Organization and other public health organisations have also sought to widen the scope of the FCTC to include RRPs*†. In countries where sales of vapour products are permitted, governments are seeking to regulate them more strictly, including by adopting bans on vaping in public places, restrictions on flavours, requiring plain packaging and retail display bans. An increasing number of governments have moved to ban the sale of single-use vapour products, with Belgium, the UK and New Zealand implementing bans in 2025. Other RRPs*† such as nicotine pouches and THPs are also facing increasing scrutiny. In many jurisdictions, existing legislative definitions of ‘tobacco products’ are interpreted as applying to THPs, thereby subjecting them to the same restrictions as those designed for traditional combustible tobacco products, often without any need to change existing laws. Countries including Brazil, India and Mexico, have expressly banned all RRPs*† while others, such as Australia and Japan, regulate vapour products as medicinal products, thereby heavily restricting or effectively banning their sale. A number of countries, including Netherlands, Belgium, France and Germany, have implemented or have passed regulations to ban Modern Oral products, either through provisions banning their sale outright, or via classification as foodstuffs, meaning their sale is de facto prohibited. Certain European countries, such as Spain and Luxembourg, have sought to de facto ban sales of nicotine pouches by limiting the amount of nicotine permitted in the products to levels so low that the products would be unsatisfying for consumers. Other jurisdictions have sought to implement bans via their classification as tobacco substitutes or medicinal products. It is considered likely that tobacco-free nicotine pouches will be regulated at a European level as part of the next revision of the Tobacco Products Directive (TPD). It is also possible that Herbal Products for Heating could be addressed in the TPD. Additional measures Generational Sales Bans (GSBs) are among the latest significant developments under discussion in tobacco control policy. These measures seek to prohibit the sale of tobacco products - and in some cases nicotine products - to anyone born after a specified date, meaning affected individuals would never legally be permitted to purchase such products in their lifetime. The most prominent example is in the United Kingdom, where legislation proposes to ban the sale of tobacco and THPs to anyone born on or after 1 January 2009. The concept has attracted some international attention: the Maldives passed legislation to implement a similar ban in 2025; the Turkish Government is reportedly drafting a bill with comparable provisions; and the Australian and Norwegian Governments have indicated they are assessing similar approaches. In several other countries, individual lawmakers have also attempted to introduce GSB proposals, though none have yet been enacted. The real-world implications of a full generational ban - including any impact on illicit trade - remain uncertain. New Zealand became the first country to legislate for a GSB in 2022, introducing a ban on tobacco sales to anyone born on or after 1 January 2009. However, these provisions were repealed by a subsequent government due to enforcement concerns and fears of fuelling an illicit market. Likewise, the Malaysian Government sought to include GSB provisions in a 2023 bill, but they were later removed amid concerns over their constitutionality. Another key measure that has garnered attention from regulators in recent years is the proposal to gradually reduce the nicotine content in combustible tobacco products to levels that are ‘minimal’ or ‘non-addictive’. Notable countries that have initiated significant discussions on these proposals include New Zealand, where the measure was approved in Parliament but subsequently repealed by the successor government, with concerns expressed as to the efficacy of such a method for cessation and its potential to contribute significantly to illicit trade. In the U.S., plans to introduce a similar policy have been removed from the Government’s list of immediate priorities. Cannabis The regulatory environment and consumer sentiment towards cannabis is also evolving. From the reclassification of medical cannabis in Germany, to the roll-out of recreational pilot programs in Switzerland and the Netherlands, we are seeing progress across the globe. Such developments are essential to further exploration of the category, and we will continue to monitor the changes in the regulatory environment as it evolves. 26 British American Tobacco p.l.c. Form 20-F 2025 The U.S. Through the Reynolds American Inc. (RAI) subsidiaries, the Group is subject to U.S. federal, state, and local laws and regulations. The Family Smoking Prevention and Tobacco Control Act (FSPTCA), which was enacted in 2009, grants the U.S. Food & Drug Administration (FDA) broad authority over the manufacture, sale, marketing, and packaging of tobacco products but initially limited the FDA’s authority to cigarettes, smokeless tobacco products, cigarette tobacco and roll-your-own tobacco products. Elements of the FSPTCA include: filing of facility registrations, product listing, constituent testing and ingredient information; obtaining the FDA's clearance for new products and product modifications; banning all characterising flavours other than tobacco or menthol in cigarettes; establishing ‘user fees’ to fund the FDA’s regulation of tobacco products; requiring large pictorial warnings to be included on cigarette packaging and advertising; directing FDA to establish good manufacturing practices; revising the labelling and advertising requirements for smokeless tobacco products; and requiring the study of menthol. The U.S. Congress did limit the FDA’s authority in various ways, including prohibiting it from: –Banning categories of tobacco products; and –Requiring the reduction of nicotine yields of a tobacco product to zero. On 10 May 2016, the FDA issued a final regulation, referred to as the Deeming Rule, deeming all remaining products that are “made or derived from tobacco” to be subject to the FDA’s regulatory authority under the FSPTCA. The Deeming Rule became effective as of 8 August 2016, though some requirements of the Deeming Rule had their own compliance dates. Such ‘deemed’ tobacco products subject to the FSPTCA include, among others, electronic nicotine delivery systems (including e-cigarettes, e-hookah, e-cigars, vape pens, advanced refillable personal vapourisers, electronic pipes and e- liquids mixed in vape shops), certain dissolvable tobacco products, cigars, pipe tobacco, and nicotine pouches. The ‘pre-existing products’ date under the Final Rule for newly deemed products remained the same as the ‘pre-existing products’ date for those tobacco products already subject to the FSPTCA – 15 February 2007 (known as ‘Pre-Existing Tobacco Products’). Any tobacco product that was not legally marketed as of 15 February 2007 is considered a new tobacco product subject to premarket review by the FDA. The FDA established a compliance policy allowing all newly deemed new tobacco products that were on the market as of 8 August 2016 to remain on the market so long as the manufacturer filed a Premarket Tobacco Product Application (PMTA) by a specific deadline (9 September 2020). In October 2019, R. J. Reynolds Vapor Company filed PMTAs for Vuse Solo. Based upon requirements of the FSPTCA that must be addressed in PMTAs, and the FDA’s Guidance regarding the type of evidence required for such applications, the costs of preparing a PMTA are significant. R. J. Reynolds Vapor Company thereafter filed PMTAs for the remaining Vuse products (Vibe, Ciro, and Alto) and the Velo products (pouch and lozenge) by the September 2020 deadline. Certain additional data from ongoing research relevant to the Alto and Velo applications were submitted as amendments to the PMTAs during the FDA review process. The FDA issued marketing granted orders for the Vuse Solo device and its tobacco (‘original’) flavour in October 2021, but issued a marketing denial order for Vuse Solo flavours other than menthol (which were not on the market). That denial is being appealed with the FDA. In May 2022, the FDA issued marketing granted orders for the Vuse Vibe device and its tobacco flavour and the Ciro device and its tobacco flavour but issued a marketing denial order for flavours other than menthol (which were not on the market). R. J. Reynolds Vapor Company has appealed the denials issued for the relevant Vuse Vibe and Ciro products by requesting further Agency review. We have received and are challenging the FDA's marketing denial orders dated January 2023 related to Vibe and Ciro (menthol variants) and the FDA’s marketing denial orders dated March 2023 related to Solo (menthol variants). In October 2023, the FDA issued a marketing denial order for Vuse Alto menthol and mixed-berry (the latter of which was not on the market). As with Vibe, Ciro, and Solo, we challenged the denial order in court with retailers as co-petitioners. We have received court-ordered stays of enforcement of the FDA’s denial orders for currently marketed menthol Vuse Alto, Solo, and Vibe products, which means these Vuse menthol products can continue to be marketed and sold while the judicial review process continues. In the U.S., menthol variants account for 75% of total Vuse consumables (2024: 73%). In a case called FDA v. Wages & White Lion Investments, L.L.C, the U.S. Supreme Court concluded that with respect to dessert, candy, and fruit-flavoured e-cigarettes sold by another company, the FDA had not unlawfully changed positions on what evidence was required for those products, and the denial of the marketing authorisation was rightful. We have arguments that the facts and circumstances of our cases are different from Wages & White Lion. There can be no assurance, however, that the Vuse menthol or other flavours-related appeals will succeed. The U.S. Supreme Court ruled in 2025 on an important aspect of R.J. Reynolds Vapor Company’s challenge to the FDA’s denial of menthol and mixed-berry Alto. Specifically, the Supreme Court held that retailers are “adversely affected” and thus have a cause of action to challenge an FDA denial order. So the retailers affected by the FDA’s denial orders for Vuse menthol products could validly challenge those orders in the Fifth Circuit Court of Appeals. In two subsequent decisions, the Fifth Circuit held that venue is proper so long as just one of the petitioners has its principal place of business in the circuit, which, assuming it is applied in the Vuse cases, would allow R.J. Reynolds Vapor Company’s challenges to remain in the Fifth Circuit. The Vuse cases are now being held in abeyance until May 2026. The FDA agreed to review a new application for menthol Vuse Alto, which R. J. Reynolds Vapour Company submitted in August 2025. The menthol Vuse products can therefore remain on the market until at least May 2026. In May 2026, if the FDA has not decided the new application, the parties may agree to continue holding the cases in abeyance for longer, or may proceed to merits briefing. In July 2024, the FDA issued marketing granted orders for the Vuse Alto device as well as Vuse Alto Rich Tobacco and Golden Tobacco. The Group’s Velo products remain on the market in the U.S., pending the FDA's decisions on their premarket tobacco product applications and there can be no assurance these applications will be granted. If the FDA denies a marketing authorisation, then the relevant product(s) would need to be withdrawn from the market (unless a court, or the agency via supervisory review, intervenes). Legislation granting the FDA authority over synthetic nicotine products (products containing nicotine not ‘made or derived from tobacco’) went into effect in April 2022, which required manufacturers of such products to file PMTAs by a May 2022 deadline to continue marketing those products. In July 2024, the Group acquired the marketing rights to synthetic nicotine pouch products that had submitted PMTAs by the May 2022 deadline. Those products are marketed as Velo Plus Pouches and Grizzly Pouches. The applications for those products remain pending with the FDA and the products are on the market in the U.S. pending the FDA’s review. There can be no assurance that the application will be granted. Comprehensive Plan for Tobacco and Nicotine Regulation In March 2018, the Agency issued three Advance Notices of Proposed Rulemaking, seeking information on (1) the lowering of nicotine levels to non- addictive or minimally addictive levels, (2) the impact of flavours (including menthol) in increased initiation among youth and young adults as well as assisting adult smokers to switch to potentially less harmful forms of nicotine delivery, and (3) the patterns of use and public health impact of premium cigars. In April 2022, the FDA published a proposed product standard that would ban menthol as a characterising flavour in cigarettes. The FDA accepted public comment on this proposed rule through August 2022. RAI Services Company submitted a detailed comment to the FDA (available on the U.S. Government's Regulations.gov website) opposing the proposed rule as unsupported by existing scientific evidence and with the potential for negative unintended consequences. The Biden Administration initially announced a non-binding target date of August 2023 for issuing the final rule. The administration then pushed the target date back to March 2024. Then, in April 2024, the Biden Administration announced that the final rule would be further delayed, and the final rule has yet to be issued. The rule has now been withdrawn from the FDA’s list of priorities. Additional regulation In December 2022, the sale of all tobacco products with characterising flavours other than tobacco (including menthol) were banned in the state of California. This has negatively impacted the Group's volumes in the U.S. In January 2025, California extended the prohibition to cover tobacco products that produce a 27 British American Tobacco p.l.c. Form 20-F 2025 “cooling sensation” and instituted a registry for all “unflavored” tobacco products that can be sold in the state – this includes combustibles, Traditional Oral, Modern Oral and Vapour products. The list took effect on 1 January 2026. In April 2019, the FDA issued a proposed rule on the format and content of reports to demonstrate substantial equivalence. This follows on from the FDA’s previous statements regarding the development of foundational rules so as to provide clarity and predictability to the tobacco product submission process, including not only substantial equivalence applications but new product applications as well as MRTP applications. In September 2019, the FDA published a proposed rule on the format and content of PMTAs. The final foundational rules for substantial equivalence and PMTAs were published on 5 October 2021 and became effective on 4 November 2021. The FDA has not yet promulgated its proposed rule for MRTP applications. Under the FSPTCA, for a manufacturer to launch a new tobacco product or modify an existing tobacco product after 15 February 2007, the manufacturer must obtain an order from the FDA authorising the new or modified product to be marketed. One exception is that a manufacturer that introduced a cigarette or smokeless tobacco product between 15 February 2007 and 22 March 2011 could file a substantial equivalence report with the FDA demonstrating either (1) that the new or modified product had the same characteristics as a product commercially available as at 15 February 2007, referred to as a predicate product, or (2) if the new or modified product had different characteristics than the predicate product, that it did not raise different questions of public health. A product subject to such report is referred to as a provisional product. A manufacturer may continue to market a provisional product unless and until the FDA issues an order that the provisional product is not substantially equivalent, in which case the FDA could then require the manufacturer to remove the provisional product from the market. Many of the RAI subsidiaries’ cigarette and smokeless tobacco products currently on the market are provisional products. In January 2017, the FDA issued its first proposed product standard whereby it would require the reduction, over a three-year period, of the levels of N- nitrosonornicotine (NNN) contained in smokeless tobacco products. Since issuing this proposal, the FDA has simply stated that it is evaluating submitted comments. The FDA’s semi-annual regulatory agenda has not listed the NNN proposal since its publication. Thus, it is not known whether or when this proposed rule will be finalised, and, if adopted, whether the final rule will be the same as or similar to the proposed rule. On 18 March 2020, the FDA issued a rule mandating the incorporation on cigarettes packages and advertising of graphic health warnings. The rule required eleven new textual warnings, each accompanied by a specific graphic image, on the top 50% of the front and back of all cigarette packages, on the left 50% of the front and back of cigarette cartons, and on 20% of all cigarette advertising in a location at the top of each advertisement, beginning 18 June 2021. On 3 April 2020, RAI subsidiaries R. J. Reynolds Tobacco Company and Santa Fe Natural Tobacco Company, in conjunction with several cigarette manufacturers and retailers, filed a lawsuit seeking an order and judgment holding unlawful, enjoining, and setting aside the rule in its entirety. The court, following multiple orders to delay the implementation of the rule, invalidated it as unconstitutional in December 2022. In February 2023, the FDA appealed this decision to the U.S. Court of Appeals for the Fifth Circuit. On 21 March 2024, the U.S. Court of Appeals for the Fifth Circuit issued its opinion reversing the court’s decision, and concluding that the warnings are constitutional. On 25 November 2024, the U.S. Supreme Court declined to review the Fifth Circuit’s decision. Plaintiffs continue to pursue their remaining statutory claims against the rule. On 13 January 2025, the District Court entered an order postponing the effective date of the rule pending final disposition of the remaining statutory claims. The FDA appealed that order to the U.S. Court of Appeals for the Fifth Circuit; briefing has concluded and the court has not yet scheduled oral argument. In the meantime, on 29 August 2025, in a separate case, the U.S. District Court for the Southern District of Georgia entered an order vacating the rule due to the FDA’s failure to follow notice-and-comment procedures. The FDA has appealed that order to the U.S. Court of Appeals for the Eleventh Circuit, and the appeal remains pending. Under the prior Biden Administration, the FDA announced its intention to issue a final rule to ban menthol as a characterising flavour in cigarettes. The Trump Administration has listed the rule as withdrawn on the Spring 2025 Unified Agenda. It is not known whether or when this rule will be finalised, and, if adopted, whether the final rule will be the same as or similar to the proposed rule. On 15 January 2025, in the final days of the outgoing Biden Administration, the FDA issued a proposed product standard whereby the agency would limit nicotine levels in cigarettes following a two-year effective date from publication of any final rule. The proposed rule was subject to public comment. RAI companies submitted a detailed comment opposing the proposed comment deadline. The Trump Administration has listed the rule as “withdrawn” on the Spring 2025 Unified Agenda. Cigarettes and other tobacco products are subject to substantial taxes in the U.S. All states and the District of Columbia currently impose cigarette excise taxes. Certain city and county governments, such as those of New York City, Philadelphia, and Chicago, also impose substantial excise taxes on cigarettes sold in those jurisdictions. Also, all states and the District of Columbia currently subject smokeless tobacco products to excise taxes. Various states and the District of Columbia impose a tax on Vapour products, such as e-cigarettes, and many other states have proposed taxes on Vapour products. Currently, there is no federal tax on Vapour products. State and local governments also consider and implement other legislation and regulation regarding the sale of tobacco products. Measures include, among others, limiting or prohibiting the sale of flavours in tobacco products, restricting where tobacco products may be sold and increasing the minimum age to purchase tobacco products. The Group believes that, as a responsible business, it can contribute through information, ideas and practical steps, to help regulators address the key issues regarding its products, including underage access, illicit trade, product information, product design, involuntary exposure to smoke and the development of potentially less harmful products, while maintaining a competitive market that accommodates the significant percentage of adults who choose to be tobacco consumers. The Group is committed to working with national governments and multilateral organisations and welcomes opportunities to participate in good faith to achieve sensible and balanced regulation of traditional tobacco and potentially RRPs. See also the Group’s risk factors related to legal, regulatory and compliance risks under Item 3.D. Notes: *Based on the weight of evidence and assuming a complete switch from cigarette smoking. These products are not risk free and are addictive. †Products sold in the U.S., including Vuse, Velo, Grizzly, Kodiak, and Camel Snus, are subject to FDA regulation and no reduced-risk claims will be made as to these products without agency clearance. Item 4.C - Organizational structure British American Tobacco p.l.c. is the Group’s parent company. We have a number of direct and indirect subsidiaries, incorporated across the globe. A complete list of our subsidiaries is filed as Exhibit 8 to this Form 20-F. 28 British American Tobacco p.l.c. Form 20-F 2025 Item 4.D - Property, plant and equipment The Group uses a combination of in-house and contract manufacturers to manufacture its products. BAT-owned manufacturing facilities1 United States AME APMEA Total Fully integrated manufacturing 1 13 22 36 Other processing sites (including leaf threshing and OTP) — 6 9 15 Sites manufacturing other products (including Snus, Modern Oral and Liquids) 2 5 — 7 Research and development facilities 1 2 3 6 Total 4 26 34 64 Note: 1.As of 31 December 2025. The plants and properties owned or leased and operated by the Group’s subsidiaries are maintained in good condition and are believed to be suitable and adequate for the Group’s present needs. The technology employed in the Group’s factories is sophisticated, especially in the area of cigarette-making and packing where throughputs can reach between 500 and 1,000 packs per minute. The Group can produce many different pack formats (e.g., the number of cigarettes per packet) and configurations (e.g., bevel edge, round corner, international) to suit marketing and consumer requirements. New technology machines are sourced from the leading machinery suppliers to the industry. Close cooperation with these organisations helps the Group support its marketing strategy by driving its product innovations, which are brought to the market on a regular basis. The Group utilises quality standards, processes and procedures covering the entire end-to-end value chain to help to ensure quality products are provided to its customers and adult tobacco consumers according to the Group’s requirements and End Market regulatory requirements. In 2025, the Group manufactured cigarettes in 36 cigarette factories in 35 countries. These plants and properties are owned or leased and operated by the Group’s subsidiaries. The Group’s factory outputs and establishments vary significantly in size and production capacity. In line with our corporate commitment to fight climate change, our factories have decarbonisation, water usage and waste optimisation programmes. Also in 2025, the Group used third-party manufacturers to manufacture the components required, including the devices, related to New Categories. The Group also used third-party manufacturers to supplement the Group’s own production facilities in the U.S. and Poland to bottle the liquids used in Vapour products. Further, in 2025, the Group’s manufacturing facilities in Poland and Sweden (included in the above analysis) also undertook research and development activities, but were not distinct sites from the manufacturing activities. As such, they were not recorded in the research and development facilities to avoid the risk of double counting. For more information on property, plant and equipment, please refer to note 13 in Part III - Item 18 Notes on the Accounts. Item 5 - Operating and Financial Review and Prospects