We are committed to aiming for 100% compliance with our global Marketing Principles worldwide, as well as ensuring all our product marketing complies with local legislation.
Since 2001, all our cigarette marketing, wherever these are sold, has been governed by our voluntary International Marketing Principles (IMP). With our shift towards a multicategory portfolio of different tobacco and nicotine products, we subsequently introduced Snus Marketing Standards and Vapour Product Marketing Principles, and in 2017, we developed our new principles for tobacco heating products.
Alongside these, we have a digital marketing toolkit in place that includes in-depth guidance to help our markets apply our Marketing Principles online, covering content standards, use of social media and search engines, and ensuring robust age verification.
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 2017, no incidents of non-compliance were identified through our internal procedures. There were, however, two external allegations made about our marketing practices in relation to local tobacco control and advertising laws. In each case we conducted detailed investigations and found no evidence of any wrongdoing. 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. For example, following a report published by an NGO on the tobacco industry and alleged marketing around schools in Nigeria, we conducted our own investigations and commissioned an independent audit. The audit findings did not support the allegations in the report in respect of BAT’s activities, although it did identify minor improvements in the controls around our marketing practices which were immediately implemented.
In 2018, as part of the integration of Next Generation Products (NGPs) into our core business, we plan to develop a new set of consolidated Marketing Principles to cover all our product categories, including combustible cigarettes, smokeless tobacco and NGPs.
Please see www.bat.com for more information on our Marketing Principles.
To proactively support our strict requirement to only direct the marketing of our products at adult consumers, we have long expected our markets to work with retailers to prevent underage access, by supporting proof-of-age schemes, and providing training and awareness raising to shop staff. We also engage with governments to establish a minimum age law of 18 where none exist, or to enforce tougher penalties for those that breach existing laws.
In 2017, we revised and strengthened our approach with the launch of our new Youth Access Prevention (YAP) Guidelines, which now cover all our different product categories – from conventional cigarettes to vapour and tobacco heating products. We have also broadened the scope to include markets where our products are distributed through third parties, and strengthened the governance process for ensuring compliance.
We conducted youth smoking prevention activities in 2017, based on our previous guidelines, in all markets where we were able to do so. The YAP Guidelines came into effect in January 2018, and we will report our activities and adherence in our next report.
Please see www.bat.com for more information on our approach to Youth Access Prevention.