Our role in preventing youth access to our products
We believe our products are only suitable for adults and we do not want people who are underage to use them.
We fully support laws and regulations prohibiting the sale of our products to anyone under the legal minimum age in their country. 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.
It’s essential that any tobacco or nicotine products are not marketed to youth. Given the nature of our products, we take seriously our commitment to market them responsibly and only to adults.
That’s why our operations in our markets worldwide are required to follow marketing principles which are globally consistent and demonstrate our commitment to marketing appropriately.
Our International Marketing Principles (IMP), revised in 2019, provide detailed guidance on all aspects of our marketing of our conventional combustible tobacco products and our reduced-risk*† products portfolio. Central to the principles is our commitment that our marketing is aimed only at adult consumers and is not designed to engage or appeal to youth.
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. Our commitment to only market our combustible tobacco products to adult smokers has long been supported by our global Youth Smoking Prevention (YSP) Guidance and activities for our operations worldwide. Our revised YAP Guidelines that now cover all our product categories (including all RRPs), 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.
Our global approach requires all our operations in our markets, wherever possible, to:
The support we provide to our operations in our markets and to distributors includes training and point-of-sale materials for retailers to help them uphold minimum age laws.
With the growth of digital marketing and social media, the way consumers want to engage with us and learn about new category products has changed. Online channels are increasingly important, and we use them to engage with adult consumers. In the digital age, our IMP continue to be at the centre of the way we market. We never use open social media to promote our cigarette brands; however, where legally allowed, we use social media to communicate regarding our new category products to support adult smokers who are looking for alternatives to smoking. Where we use social media partnerships to promote new category products, we use analytical tools to help us select partnerships with third-party promoters who have majority-adult following. Since digital marketing is rapidly evolving, it is key we build capability with our business and support employees to apply the IMP effectively and consistently. To meet that challenge, we established a digital marketing hub in 2019. Based at our headquarters, the hub supports all markets where new category products are sold. Comprised of responsible marketing and consumer engagement experts, the hub’s team helps markets achieve long term consumer satisfaction and product awareness in a responsible way.
We report our Youth smoking prevention performance in our 2020 ESG Report (14.1 mb) . In 2020, we continued to focus on achieving 100% adherence to our IMP and YAP Guidelines. We are therefore pleased that 100% of our markets reported adherence to our YAP Guidelines in both 2019 and 2020. Examples of their activities include supporting proof-of-age schemes, training retailers to better understand minimum age laws and their responsibilities in upholding them, and providing point-of-sale materials to display in retail stores with YAP messaging. We always endeavour to ensure our IMP is consistently applied, including through mandatory training, launched in early 2020, for all Marketing and relevant LEX employees across the Group. However, in 2019, five cases of IMP non-compliance were identified through our internal procedures, as well as external reports and allegations. In addition, our subsidiaries reported a total of approximately £1.37 million in fines or settlements associated with incidents of non-compliance with laws relating to marketing, labelling or advertising. As of the end of the year, some of these were still ongoing and subject to appeal. We believe the increase in IMP non-compliance cases, compared to previous years when none were identified, reflects the strengthening of our compliance procedures and controls. We conduct detailed investigations of all cases and, where a breach is found, implement immediate measures to address them.
* Based on the weight of evidence and assuming a complete switch from cigarette smoking. These products are not risk free and are addictive.
† Our products as sold in the US, 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.