Standards of Business Conduct

Tobacco and nicotine products should be marketed responsibly to adult-only consumers and not designed to appeal to youth.

All companies selling these products should have consistent marketing principles and youth access prevention activities, as we do at BAT.

Through a globally responsible approach to marketing, we help raise standards and prevent underage access, while growing our market share and encouraging adult consumers to choose our products over those of our competitors.

Our International Marketing Principles (IMP) govern our approach to marketing for all our products. They include five key principles for our marketing:

•  Responsible;
•  Accurate and not misleading;
•  Targeted at adult-only consumers;
•  Transparent; and
•  Compliant with all applicable laws.

Our IMP are applied consistently, even when they are stricter than applicable local laws. Our Supplier Code of Conduct also includes a requirement for our suppliers, agents and third parties to comply with the IMP.

Our markets are also expected to adhere to our global Youth Access Prevention (YAP) Guidelines. These apply to all markets where our products are sold, including where they are distributed through third parties. Unless there are legal restrictions in place, our YAP Guidelines include mandatory requirements to:

•  Work directly with retailers to uphold minimum-age laws and our own internal standards;
•  Support distributors in providing training and point-of-sale materials for use by retailers; and
•  Engage with governments in markets where there is no minimum-age law of 18 to see one introduced.

IMP and YAP compliance is monitored by our Regional Audit and CSR Committees and by the Audit Committee annually.

International Marketing Principles (0.1 mb)

A well-established approach
 

Our IMP were first introduced in 2001 and have been regularly updated to reflect developments in marketing, our product portfolio, technology, changing regulations and stakeholder expectations.

The result is that responsible marketing is embedded in our culture and the way we operate. Our current IMP came into effect in January 2020 and covers all aspects of marketing – from print and billboards to electronic and social media. All marketing materials are subject to review by our Legal and External Affairs function. We have detailed compliance procedures, guidance and toolkits to help our IMP to be applied consistently and effectively.
 

Responsible Marketing in a Digital Age
 

Our new e-commerce and social media channels play an important role in accelerating our transformation, driving growth in New Categories, building strong brands of the future and digitising our business.

We continue to provide our people and partners with the right tools and capabilities to ensure compliance with our IMP and Youth Access Prevention (YAP) Guidelines. Our digital marketing toolkit includes in-depth guidance on topics including content standards, social media and search engines. In 2021, we introduced additional toolkits and guidance, such as applying our YAP Guidelines and age verification standards on our own and third-party e-commerce sites.

Additionally, our digital marketing hub continues to provide guidance on how to achieve long-term consumer satisfaction and product awareness in a responsible way.

We never use open social media to promote our cigarette brands. However, where legally allowed, we use social media to communicate information about our New Category products. This is important in supporting adult smokers who are looking for reduced-risk*† alternatives to cigarettes.

Where we use social media partnerships to promote New Category products, we select third-party partners who have at least an 85% adult following. When conducting social listening, we only use platforms where the vast majority of users are adult. And, through the use of language-analysis algorithms, we are rapidly enhancing our ability to identify and exclude posts made by anyone underage, whatever the platform.

In 2021, we established our new Digital Confidence Unit. This is a centralised social audit and reputation management team covering all brand-related digital communications and marketing across the Group. Utilising cutting-edge technology, the unit conducts 24/7 monitoring of:

•  All BAT digital channels globally for compliance with our IMP and YAP Guidelines;
•  Social media channels for user-generated content, such as social media users tagging our products and brands; and
•  Brand reputation monitoring of any news and digital content related to our brands and products. This approach enables any potentially non-compliant content to be identified and flagged in real-time, enabling swift remediation.

Over the course of 2022, the DCU reviewed 100% of our own content on social media and found that 99.4% of our own content was IMP/YAP compliant. In relation to the 226 potential compliance issues identified in 2022, 99.8% have been resolved, with the remainder in the process of being resolved.
 

iCommit
 

In 2021, we launched a new training programme, iCommit, covering measures for ensuring IMP and YAP compliance across our digital channels.

The training includes a mix of theory and practical training. A detailed ‘expert’ module is mandatory for all our marketing, commercial and marketing legal teams. And our senior leaders for each of our business units worldwide are required to complete the leadership module and confirm compliance for their area. All other employees (except for those who work in factories) are required to undergo the basic induction module.

The iCommit training was rolled-out in November 2021, accompanied by a global communications campaign across our internal channels, including videos, articles, and webcasts.

In 2022, we achieved 100%** completion of iCommit training across our regions for BAT employees and over 5,000 agency employees across 598 agencies, as well as one million retailers across 93 markets.

During 2022, iCommit was enhanced and implemented as a digitally enabled training programme for all our Marketing colleagues and external agencies across all channels and markets. Looking forward, we plan to include the training as part of our onboarding process for new joiners. We also plan to incorporate training on responsible marketing as part of the annual SoBC sign-off process for all employees.

For more and to see how we are driving compliance, read our  BAT Combined Annual and ESG Report 2022 (8.7 mb) 

* 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.

** excluding factory employees.