Our International Marketing Principles
A fundamental requirement of our marketing principles is that our marketing is aimed only at adult consumers and is not designed to engage or appeal to children.
We agree that our industry should be regulated, but we also think we should be able to communicate in a responsible way with adult consumers about our tobacco and nicotine products.
For a business like ours, it is imperative that we provide clear and meaningful information about the different risk profiles of our products to help consumers make informed choices.
Ensuring we market our products responsibly to adult consumers only is also key.
At BAT, we have International Marketing Principles which provide guidance on key aspects of our marketing of our conventional combustible tobacco products and our potentially reduced-risk products.
As part of our ambition to transform tobacco for our consumers, our business and our shareholders, we have expanded our portfolio in recent years to include, in addition to conventional combustible tobacco products, a range of potentially reduced-risk products (PRRPs), including vapour, tobacco heating products and oral tobacco. To reflect this multi-category approach, our International Marketing Principles apply across all our products, not just conventional combustible tobacco products.
Our International Marketing Principles require that our marketing, across all our products, must be:
Given that PRRPs have the potential to deliver reduced risks compared with conventional combustible tobacco products, we believe that they should be afforded greater marketing freedoms, so long as the content is accurate, responsible and not misleading. As with our marketing of conventional combustible tobacco products, our marketing of PRRPs will always be directed at adults and will never target youth. The International Marketing Principles are our minimum standard and will be applied even when they are stricter than local laws. However, if local laws or other voluntary codes in markets are stricter than or override our International Marketing Principles, then we will abide by those laws or voluntary codes.
We are committed to aiming for 100% IMP compliance worldwide. All our marketing materials have to be formally reviewed and approved by our Legal and External Affairs function and we provide training to our marketing employees and trade representatives, as well as any external agencies we work with, to ensure they are effectively applied.
In 2018, no incidents of non-compliance were identified through our internal procedures. However, each year, we do receive a small number of external allegations about our marketing practices which concern alleged breaches of our IMP or of local advertising regulations. When we receive any external allegations, we conduct detailed investigations and where any instances of non-compliance or opportunities to further strengthen our internal controls are identified, immediate action plans are put in place to address them.
We welcome information from anybody who believes that any of our companies are not living up to the Principles. You are welcome to send any concerns through Contact us.
We are very clear that our marketing is aimed only at adult consumers of our products and is not designed to engage or appeal to youth. Our global approach to youth access prevention to our products focuses on engagement with governments to adopt minimum age laws of 18 for tobacco sales where none exist and, where they do, to effectively enforce them.
Beyond our strict requirement for adult-only marketing, we also expect all our markets, where possible, to conduct youth access prevention activities for the sales of our tobacco and nicotine products. In 2018, we launched our revised YAP Guidelines that now cover all our product categories (including all PRRPs) and broadened their scope to also include markets where our products are distributed through third parties. It is now also mandatory for all markets – unless there is a government ban in place – to provide retailers with point-of-sale materials with YAP messaging. To support their application, we rolled out new training for our Trade Marketing and Distribution employees and strengthened governance procedures at Group level to ensure compliance.
Other activities to prevent underage access include supporting proof-of-age schemes and providing training and awareness raising to shop staff. For example, in the U.S., Reynolds American Inc. is a founding member of ‘We Card’, an organisation that provides retailer education for age-restricted products. It also funds projects such as ‘Right Decisions Right Now: Be Tobacco Free’, an evidence based youth tobacco prevention education programme designed for middle-school educators, parents and community groups.
To drive change across the industry, we also advocate to governments for minimum age laws of 18 where these aren’t already in place, and for tougher penalties for those who breach them.
We believe our comprehensive approach allows us to be consistent and robust on youth access prevention, demonstrating high standards of corporate behaviour in every market in which we operate.