OVERVIEW

Our values and Code of Conduct are embedded throughout Imperial Brands and drive our responsible approach. Our values reflect the behaviours we expect from everyone who works for us and our Code of Conduct is aligned with policies, internal controls and risk management processes that underpin our strategy.

 

WHY IS IT IMPORTANT?

How we conduct ourselves and our business can have wider impacts for society. Doing business in the right way, having integrity and not tolerating poor behaviour, fraud or bribery means we contribute positively.

We have a zero-tolerance approach to bribery and corruption.  This commitment is given in our Code of Conduct, which also contains our process for approval and recording of gifts and entertainment.

As a responsible company we believe that how we fulfil our obligations to consumers is important. Whether this is through our rigorous product testing and analysis or through our commitment to only market our products to adult smokers. We set high standards to meet the ever evolving needs of consumers and regulators, and to enable the development of new less harmful products. Further information on ‘Our Science’ can be found on our dedicated science website.

All our business partners including all third-party agents, contractors, consultants and distributors who are employed by us are expected to work within the standards and behaviours outlined in the Code of Conduct when conducting business on our behalf.

In April 2018, we introduced our Supplier Code, which is aligned to our Code of Conduct and available in 19 languages. Through our procurement processes, suppliers are required to sign up to the spirit of our Supplier Code.

Our success depends on establishing open, honest and fair partnerships with trusted suppliers. We expect our suppliers to conduct their business in an ethical and responsible manner and comply with applicable laws and regulations. We only select and do business with suppliers who can demonstrate that they operate in a manner consistent with our standards and Code of Conduct. We also expect our suppliers to ensure that their own business partners meet similar standards.

 

WHAT ARE WE DOING ABOUT IT?

We have a rolling training programme to ensure ongoing engagement with the Code of Conduct throughout the business, including e-learning courses and face-to-face sessions. Our Code of Conduct has been translated into 30 languages, it covers many topics including Bribery and Corruption, Gifts and Entertainment and Engagement with Governments and Political Bodies. See our Code of Conduct for more information. The training for the Code of Conduct covers the content of the Supplier Code.

We encourage employees and our business partners to raise any concerns they may have. We have mechanisms in place to enable this and a Group-wide Speaking Up (Whistleblowing) Policy, which has been translated into 40 languages. Any allegations of misconduct, fraud and irregularity are thoroughly investigated. We have processes to ensure that concerns are handled consistently across the business. All investigations are conducted in accordance with our legal obligations and where possible we will protect confidentiality. See our Speaking Up Policy for more information.

 

WHAT ARE THE KEY ISSUES?

REGULATION

We support reasonable, proportionate and evidence-based regulation that respects adult freedom of choice.

ADULT CHOICE AND YOUTH ACCESS PREVENTION

Our products are for adults and should never be sold to minors.

ILLICIT TRADE

We are totally opposed to illicit trade and actively take steps to combat smuggling and counterfeiting.

REGULATION

We support proportionate evidence-based regulation that encourages smokers to use alternative products that have the potential for reduced harm.  We believe there should be a clear distinction between tobacco and non-tobacco products.

Our goal is to effectively operate in a rapidly evolving regulatory landscape and build trust in our products, not only with consumers, but also with regulators.

Tobacco Products

Regulation of tobacco products continues to increase and is largely driven by the World Health Organization (WHO) through; the Framework Convention on Tobacco Control (FCTC), the USA’s Food and Drug Administration (FDA) and the European Union, for instance through its Tobacco Products Directive (EUTPD).

The visible aspects of tobacco product regulation are well known, such as the requirement for health warnings, bans on smoking in public places and advertising restrictions, whereas the complexity of technical product regulation is less commonly understood. It is likely that technical product regulation will increase further in the future, which is something that we understand and are preparing for.

The WHO continues to expand guidelines on tobacco product regulation and the three main areas covered by the FCTC are:

Ingredients Restrictions

Applying restrictions to (e.g. maximum levels) or prohibiting the use of ingredients in tobacco products.

Technical Compliance

Applying restrictions on technical design features or product performance (emissions) from the tobacco products, for example: applying maximum levels of tar, nicotine and carbon monoxide.

Product Information Reporting

The confidential disclosure to authorities of information related to ingredients and tobacco composition, technical design features and performance (emissions data).

We conduct thousands of analytical tests every year to make sure our products are compliant with regulatory requirements and our own high standards which are central to how we work.

We actively participate in international method standards bodies, such as the International Standards Organisation (ISO), the European Committee for standardisation (CEN), and CORESTA (Cooperation Centre for Scientific Research Relative to Tobacco). The robust, reproducible, and repeatable testing methodology that we achieve in these forums underpins our commitment to regulatory compliance for governments, and product quality for our consumers.  Further information is available on our Science website.

We are proud to work in all areas of tobacco leaf research, aiming to improve resistance to plant disease and leaf quality amongst other areas.  Samples of the tobacco that we purchase are tested regularly for residues of plant protection products to ensure that our tobacco blends meet regulatory requirements, our technical requirements and the standards expected by our consumers.

Regular ingredients submissions, including toxicological information, are made to Competent Authorities based on the jurisdictions where products are sold. We ensure all materials and products are fit for their intended purpose, meet relevant specifications and comply with legislation and voluntary agreements.

We do not commission or conduct research involving animals, and would not undertake such research unless formally required to do so by governments or by recognised regulatory authorities. We are committed to our position and will engage with regulators when faced with such requirements as we believe that animal testing is no longer required.  Our approach is based on a ground-breaking publication released by the National Research Council USA (NRC) in 2007.  Further details are available on our Science website.

Next Generation Products

We have a thriving and expanding Next Generation Products (NGP) business which is underpinned by leading-edge science. With the rapid growth of NGP, in particular vapour products, more and more governments seek to regulate these products. As vapour products do not contain tobacco, they should be excluded from all existing and future tobacco legislation, including excise.

We are able to draw upon our extensive experience and expertise to engage with key stakeholders and to inform governments for their development of fair and effective legislation. We believe evidence-based and proportionate regulation for NGPs is essential for the development of this category as a reduced-risk alternative to smoking and to support adult consumer choice. For further information, see our ‘Creating Something Better for the World’s Smokers’ report.

ADULT CHOICE AND YOUTH ACCESS PREVENTION

Our products are for adults and should never be sold to children. Preventing children from using tobacco products is an issue for society as a whole to resolve. We play our part by not directing the marketing of our products to anyone under the age of 18, or higher minimum age where specified locally, or to non-smokers.

We market and sell our products responsibly and adhere to regulation at all times, wherever we do business. Our International Marketing Standard (IMS) sets out clear rules and principles to ensure our advertising and marketing are only ever aimed at adult smokers. We insist that all Imperial Brands companies and employees, as well as the agencies who work with us, stringently adhere to our IMS and local legislation. Where local legislation is stricter than our IMS, this takes precedence, and where local legislation may be less stringent, then our own high standards set out in the IMS take precedence.  The IMS has been translated into 14 specific languages to cover markets where the IMS standard was a higher standard than local legal or voluntary market restrictions.

We work with retailers to reinforce the message that tobacco products are for adults only and encourage responsible selling. In the majority of markets, legislation exists to prevent the sale of tobacco products to minors.

Youth access prevention initiatives, such as retailer engagement programmes, are designed to discourage the sale of tobacco products to minors, which helps to ensure retailers remain aware of the issue and our position to only support adult sales. Our preferred involvement is through government approved identity programmes, such as proof of age schemes, working in conjunction with independent bodies and trade associations. 

Vaping products are for adult smokers, and current vapers. We fully support and advocate for legislation prohibiting sales of vaping products to children and voluntarily implement a number of youth protection initiatives, including online age-verification mechanisms and clear product labelling that states “not for sale to minors”.

Fontem Ventures has its own stringent Marketing Standard for e-vapour products and ensures that all marketing activity is only ever aimed at adults.

The core principles of this standard include:

  1. We believe that alternatives to Conventional Tobacco Products such as E-Vapour Products can make a significant contribution to tobacco harm reduction and we recognise that as such, they should only be marketed responsibly.
  2. We are committed to the marketing, advertising and sale of our E-Vapour Products responsibly within the local laws, codes of practice and voluntary agreements which govern the advertising and promotion of E- Vapour Products.
  3. We have adopted a number of standards which govern our advertising, promotion and marketing activities, and corresponding sales of our E-Vapour Products.
    These standards are set out in our E- Vapour Products Marketing Standard and apply to all our Adult Consumer marketing activities.
  4. We fully support Youth access prevention and minimum age restrictions for the lawful sale and purchase of E-Vapour Products.
  5. We believe that E-Vapour Products should only be sold to and used by Adult Consumers and we communicate in a responsible manner with Adults about our E-Vapour Products.
  6. Our E-Vapour Marketing Standard shall not apply to any E-Vapour Products that are licensed by any medicines authority nor any heated tobacco products (HTPs).

Our IMS and E-Vapour Products Marketing Standard can be accessed from the download library.

We adhere to marketing and advertising standards that ensure all communications are intended for, and presented to, adult audiences only. We also take proactive measures to ensure responsible sales practices, both on our own online storefront and through third-party online and brick-and-mortar retail locations:

  1. We conduct a thorough online age verification process via third party vendors Veratad and Experian, in addition to mandatory manual ID checks for anyone with a date of birth that shows them to be under 27.
  2. We monitor all transactions for evidence of fraudulent activity, unauthorized wholesaling, or sales by proxy where products could potentially reach non-adult users.
  3. We require a commitment from vape store partners to prohibit underage access.
  4. We require retail partners’ compliance with all applicable local, state, and federal laws.
  5. We conduct post-market surveillance to flag any concerning demographic trends.

ILLICIT TRADE

The illegal market in tobacco undermines society’s efforts to ensure that tobacco products are sold responsibly, protecting children and government revenues.

Illicit trade is fuelled by excessive regulation and excise increases. We are totally opposed to illicit trade. It deprives retailers of legitimate sales and governments of taxes. Counterfeit products are not made to the same high standards as legitimate products.

Organised criminal gangs participate in illicit trade, using proceeds to fund other activities to the detriment of civilised society. Criminals are also unlikely to respect laws, such as those that prevent sales to minors.

We take a partnership approach to tackling illicit trade, working with dedicated security experts, to gather and share anti-criminal intelligence, partnering with law enforcement and border control agencies, using track and trace technology and conducting forensic analysis. We work collaboratively within industry working groups and with governments through Memoranda of Understanding and co-operation agreements.

Group Security initiatives continue to support the actions of Regulatory Authorities on a global basis. In 2018 we provided information that lead to the closure of four illicit production facilities and the seizure of over 200 million illicit cigarettes, across 13 countries, protecting legitimate business and state revenues.

Our policy is to only supply our products to approved customers and markets. We work with customers to ensure that they are aware of our policy and their responsibilities to have control in their supply chain. To address supply chain integrity we strictly apply a ‘Know Your Customer and Contractor’ process.

OUR VIEWS

What we say on the most important issues facing our business and our stakeholders.

GOVERNANCE

Colleagues at business meeting in conference room

High standards of governance are critical to our sustainability.

NEXT GENERATION PRODUCTS

Our aim is to increasingly transition smokers to our thriving and expanding Next Generation Product (NGP) portfolio.