We are committed to aiming for 100% compliance with our global International Marketing Principles worldwide, as well as ensuring all our product marketing complies with local legislation.
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, we updated our International Marketing Principles in October 2018 to apply across all our products, not just conventional combustible tobacco products as they had done previously. The new principles replace our previous International Marketing Principles, Vapour Products Marketing Principles and Snus Marketing Standards.
Our three key marketing principles are:
All marketing materials also need to be formally reviewed and approved by the local Legal and External Affairs function. Our marketing and trade representatives and external agencies receive regular training to effectively apply our approach.
In addition, with digital channels now being much more accessible and widely used, it’s essential that social media is only used for activities that do not involve the advertising of any of our cigarette brands. Where we use social media partnerships to promote our PRRPs, we use advanced analytical tools to select partnerships with influencers who have a majority-adult following.
This work is complemented by a digital marketing toolkit that includes in-depth guidance on topics such as content standards, social media and search engines, and ensuring robust age verification where we have online sales of our products.
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. For example, in the UK, promotional claims used for one of our vapour products was reported to the Advertising Standards Authority (ASA) by a third-party as an alleged breach of the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (“CAP Code”). Following this, an immediate action plan was put in place by our local subsidiary to remove the claims and we are further reviewing future promotional descriptors. The matter was subsequently closed by the ASA and no fines were issued.
In another example, following a report published by an NGO on alleged cigarette marketing around schools, we immediately conducted a detailed internal investigation. We found that of all the allegations made, only one was in breach of our IMPs and none breached local law. The IMP breach was in relation to materials put in place by a marketing agency, used by our local subsidiary in Indonesia. Corrective steps were taken both by our local subsidiary and the agency, including immediate removal of the material, as well as actions to prevent future breaches, such as strengthened sanctions in the local agency contracts and additional spot checks by our field team to review alignment with IMPs.
Please see www.bat.com/imp 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 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.
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.
Please see www.bat.com/yap for more information on our approach to Youth Access Prevention.