british american tobacco p.l.c. sustainability report 2009 - Response to the assurance statement

radley yeldar
"Helpfully the company addresses controversial issues with a high degree of transparency. . . Limits are clearly established, but within these British American Tobacco openly discusses issues: like where stakeholders hold differing opinions or where they see opportunity to improve the impacts of their product."

Radley Yeldar,
How does it stack up? CR reports in 2009

British American Tobacco’s response to the 2009 assurance statement

An independent review of our approach is essential to support our commitment to continuous improvement. Ernst & Young LLP carried out an independent review of our Sustainability Report and of how it is aligned with the AA1000 Assurance Standard (2008). This highlighted a number of strengths in our reporting process, as well as where improvements could be made.


In 2007, we carried out a three-stage materiality test to identify which issues we should include in our Sustainability Reports. In 2009 we reviewed the Group Risk Register, along with minutes from the 2009 regional audit and CSR committee meetings and from stakeholder dialogue held during 2008–2009, in order to identify any additional issues that should be included in view of ceasing local sustainability reporting. We used the services of the member organisation Business for Social Responsibility to assess the validity of our conclusions. As a result, we now cover HIV/AIDS and Broad-Based Black Economic Empowerment in this Report, with links throughout to other areas of interest such as public place smoking and corporate social investment.

Although not raised by our own internal materiality test, we accept that our reporting of economic impacts is not as detailed as we would like. In some of our companies, research has been carried out to quantify the economic impact of tobacco growing in particular areas. While providing useful information at a local level, we have found that varying methodologies have meant that this information cannot be aggregated to provide a meaningful global picture of economic impact.

Ernst and Young LLP concluded that we could provide a more detailed explanation of the reasons why the target on full adherence to our IMS had not been met. The 15 non-adherences all related to the size of voluntary health warnings applied to:

  • Certain point of sale materials in a small number of markets;
  • In two instances, to outer packaging on cartons of 200; and
  • In one instance to brand promotional materials.

In all cases, action plans have been put in place to address these issues.

Actions for us
  • Engage with stakeholders to ensure the continued relevance of our sustainability agenda;
  • Continue to ensure that the process for identifying risk within the Group allows for adequate consideration of sustainability-related risks; and
  • Consider how we can better report on the economic impact of the business.


Ernst & Young LLP attended our London-based stakeholder dialogue event described in the Supply chain section of this Report. This meeting was independently facilitated and was attended by senior management from British American Tobacco and Ernst & Young LLP. Ernst & Young LLP concluded that there were no issues raised at dialogue that are not covered in this Report.

During 2009, we have developed our approach to dialogue to involve stakeholders more directly in the development of sustainability plans and initiatives and we reviewed and updated our stakeholder mapping process. In addition to our London based dialogue, we also provide a summary of dialogue that has been undertaken by our companies globally.

Actions for us
  • Focus our stakeholder engagement programme on developing plans to address our most material issues; and
  • Make better use of the outputs from dialogue across the Group.


Ernst & Young LLP concluded that we have been inclusive in our engagement with stakeholders across the business. However, they also shared our observation that some stakeholders often refuse point-blank to engage with us because of the nature of our products. We hope that the changes we are making to our approach to dialogue will encourage wider participation.

Actions for us
  • Continue to try to engage with our critics; and
  • Develop our approach to dialogue to include wider participation from different stakeholder groups.