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As we work to build a Better Tomorrowâ„¢, our Responsible Marketing Principles (RMP) guide our decisions in how we market our tobacco, nicotine and zero nicotine products and brands. We will uphold the same high standards in every market in which we operate, even when they are stricter than applicable local laws.

We believe tobacco and nicotine consumption is a choice for adults only. No one underage should ever smoke or use products containing tobacco or nicotine.

We understand the products we sell have different risk profiles, but that none of our products are risk-free. Marketing freedoms with respect to our new categories are critical for our ability to deliver on Tobacco Harm Reduction (THR). Through communicating and raising awareness around smoking alternatives that are scientifically substantiated, we can support the acceleration in reduction of smoking rates and in turn smoking related diseases. It is therefore essential we provide consumers with clear and meaningful information about our products.

All ÌÇÐÄ̽»¨companies, employees, and anyone working on our behalf, in any capacity, must adopt these Marketing Principles and seek to apply them in good faith at all times.

Our 7 guiding principles to Responsible Marketing are:

1. Our Products are intended for Adult Consumers
2. Our Marketing is targeted to Adult Consumers
3. We are committed to Underage Access Prevention
4. Our Marketing is honest and accurate
5. We inform Consumers that our Products are not risk free
6. We respect and comply with all applicable laws
7. We require our partners to market our products responsibly
   
   

Responsible Marketing Principles (0.3 mb)

Responsible Marketing Code

In coordination with RMP, our markets are also expected to adhere to our Responsible Marketing Code, a set of standards we hold ourselves accountable to, and what guides our decision-making process. The Responsible Marketing Code applies to our tobacco, nicotine and zero nicotine products and brands and covers all elements of marketing from product design through sales.

Responsible Marketing Code (0.3 mb)

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1. Products and Packaging

1.1Ìý Our Products and their Packaging are intended for Adult Consumers.

1.2Ìý Our Products and their Packaging will not be misleading or imply that our Products are without risk.

1.3Ìý Our Packaging will always contain appropriate warnings that are clearly visible and readable.

1.4Ìý We are committed to reducing the environmental impact of our Products and Packaging throughout their lifecycle.

2. Marketing

2.1Ìý Our Marketing is targeted to Adult Consumers.

2.2Ìý Our Marketing shall only feature Adults.

2.3Ìý Our Marketing shall be respectful to the diversity of our audience (including: race, religion, colour, ethnicity, national origin, ability, sexual orientation, and gender).

2.4Ìý Our Marketing shall be clear that it originates from ÌÇÐÄ̽»¨or our brands.

2.5Ìý Our Marketing will not suggest that our Products are without risks.

2.6Ìý Our Marketing will not suggest that our Products enhance social or professional success or sexual appeal.

2.7Ìý We will use appropriate, clearly visible, and readable warnings in our Marketing.

2.8Ìý We will not place any advertisement in printed publications unless we can reasonably establish that its audience is predominantly Adult.

2.9Ìý We will not place outdoor Marketing in close proximity to areas primarily occupied by the Underage (e.g. schools).

3. Digital Marketing and Social Media

3.1Ìý All Digital Marketing activities are intended for Adult Consumers.

3.2Ìý Our Digital Marketing will only be present where we can reasonably establish the channel’s audience is predominantly Adult.

3.3Ìý We will not use social media in our Marketing for combustible tobacco brands or products.

3.4Ìý Where we work with third parties to promote our Reduced-Risk Products*† or brands on social media we will ensure that they are Adult and their audience is predominantly Adult.

3.5Ìý Our websites and apps for our Products and brands are age restricted.

4. Sales

4.1Ìý Our Products and related branded items should only be sold to Adults.

4.2Ìý ÌÇÐÄ̽»¨has in place Underage access prevention programmes to prevent our Products being accessed by or sold to the Underage through ÌÇÐÄ̽»¨or its Trade Partners.

4.3Ìý We support laws and regulations prohibiting the sale of our Products to anyone under the legal minimum age.

4.4Ìý We will advocate to governments for minimum age laws of 18 where no age restrictions are in place.

5. Consumer Engagement (1:1 Marketing)

5.1Ìý ÌÇÐÄ̽»¨or its partners shall only conduct consumer engagement activities with Age Verified Adults.

5.2Ìý We will not engage non-smokers about our combustible Products.

5.3Ìý Employees or third-party engagement staff who engage with Adults for Marketing purposes must be transparent that they are working on behalf of BAT.

6. Training

6.1Ìý ÌÇÐÄ̽»¨employees and global marketing agency partners involved in the development, Marketing and sales of our Products will be required to complete an annual training on our Responsible Marketing Principles, Responsible Marketing Code and applicable policies, which for ÌÇÐÄ̽»¨employees will be as part of our Standards of Business Conduct.

6.2Ìý Third parties conducting ÌÇÐÄ̽»¨Marketing activities will be informed of our Responsible Marketing practices and must comply with them.

7. Governance & Ownership

7.1Ìý The Responsible Marketing Principles have been approved by the PLC Board and the Audit Committee maintains oversight over compliance across the Group.

7.2Ìý Our Responsible Marketing Principles and Responsible Marketing Code set out the minimum standard that applies to all of our Marketing activities.

7.3Ìý In addition, the Global Responsible Marketing Committee provides strategic guidance and oversight. Issues that require escalation or clarification are referred to the Responsible Marketing Committee.

7.4Ìý We publish as part of our Annual Reports and Accounts any incidences of non-compliance with marketing regulations that result in a fine, penalty or regulatory warning.

7.5Ìý As the function ultimately responsible for the Group’s Marketing activities, the Marketing function owns and is accountable for ensuring all Marketing activities are compliant with the Responsible Marketing Principles, Responsible Marketing Code and other applicable standards.