BAT in its own wordssponsorship and viral marketing to subvert advertising laws. BAT has funded...

BAT basics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Corporate responsibility coalition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Message to the stakeholders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Corporate social responsibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5BAT’s big wheeze. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5BAT’s internal documents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Regulating the tobacco industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Model for a global treatyBAT on the back foot . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Driven to reputation management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Developing a strategy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Chinese case studyEthics and new colonialism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Health priorities and PRTactical move to split the United NationsUsing farmers for spadeworkGrowers’ association to block FCTCThe tobacco growers’ plight

Youth prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17FCTC weapon

Environmental questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19Same old greenwashCounter-productive public pressure

Charm in high places. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21BAT’s man in AfricaBAT’s inside manBAT’s man at the topDistorting scientific research

BAT’s self-regulation push . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Prevailing multinational trends

Public reporting and hidden agendas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Engaging the enemyNigerian case studyConsultants for repositioning

Undermining its own CSR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30South African contradictionSporting appealFormula OneTobacco smuggling and tax PRPaul Adams and Asian smuggling

Conclusion and recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34The UK government and the FCTCRegulation of corporations

BAT in its own words 01

BAT in its own words CO

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British American Tobacco (BAT) is theworld’s second-biggest tobacco firm.Up to 780 billion cigarettes soldacross 180 countries give BAT a 15per cent share of the world tobaccomarket. Its international brandsinclude State Express, 555, LuckyStrike, Kent, Benson & Hedges(outside of the UK), Dunhill and Pall Mall.

Paul Adams became BAT’s chiefexecutive in June 2004 after 13 years atthe company. During his eight years in ahigh-powered role in Asia, BAT’scomplicity with smuggling as an illicittrade strategy boosted the company’ssales in the region.

Concern for his children’s healthrecently prompted Adams actively tooppose a proposed mobile-phone mastnear his Buckinghamshire homebecause of the associated health risksand detriment to the environment. Onother occasions, as a BATspokesperson, Adams has spoken outagainst banning smoking in enclosedpublic spaces. He regards such bans asan unnecessary health precaution,despite evidence that secondhandsmoke can cause lung cancer, heartdisease and other health problems.

Rt Hon Kenneth Clarke QC is a leadingConservative politician and the non-executive chairman of BAT’s CorporateSocial Responsibility Committee, whichreviews the company’s social,environmental and corporate citizenshipperformance twice a year. Clarke is alsothe non-executive chairman of BritishAmerican Racing (Holdings) Limited(BAR). The Formula One team is ownedand sponsored by BAT. With the LuckyStrike brand plastered across them,BAR’s cars promote its sponsor’scigarettes on televisions around the world.

02 BAT in its own words

BAT basics

The Corporate Responsibility Coalition (CORE)This coalition represents more than 100 charities, faith-based groups,community organisations, unions, businesses and academic institutions.CORE works towards increasing the social and environmentalaccountability of UK companies. Christian Aid and Friends of the Earth aremembers of its steering group.

The UK government published a white paper in March 2005 which set out itsproposals for comprehensive reform of the UK’s company law framework.CORE is asking for the new framework to recommend:

transparency through mandatory social and environmental reportingdirectors to take environmental and social issues seriously by adopting a ‘dutyof care for the environment and local communities’accountability for affected stakeholders through foreign direct liability.

This would mean communities outside the UK who were suffering from thenegative impacts of a UK company or its overseas subsidiary would beprotected under UK law and able to seek compensation for any human rights orenvironmental abuses committed by the company.

Dear stakeholder

This is Action on Smoking and Health(ASH), Christian Aid and Friends ofthe Earth’s second joint reportexamining the performance of theUK-based multinational, BritishAmerican Tobacco (BAT).

BAT is the second-largest tobaccocompany in the world and makes profitsof more than £2.7 billion a year from a 15 per cent share of the world tobaccomarket. As about 5 million people diefrom tobacco-related diseases everyyear, BAT’s 300 brands of cigarettessold in 180 countries could be causingup to three-quarters of a million deaths.But in reports, speeches and on webpages, BAT assures us it has highstandards of behaviour and integrityacross its global operations.

Although genuine moves by UKcompanies to improve their social andenvironmental standards are welcome,the differences between the claims BATmakes in its reports and its true impactsare stark. Our 2004 report, BAT’s BigWheeze, showed that even as BAT winsawards for its social reports and gainshigh rankings in ethical andsustainability tables, the company is stillfailing to address the central health,human rights and environmentalimpacts of its business.

This year we reveal the documents thatBAT would rather you did not see. Inemails, memos and strategy papers,

BAT tells us – in its own words – how,behind the mask of social andenvironmental responsibility, many of itstop executives have been battling toblock the Framework Convention onTobacco Control (FCTC), an historicattempt to regulate the tobaccoindustry. This unprecedentedinternational convention is specificallydesigned to regulate corporations andaims to tackle the global healthproblems caused by tobacco, whichkills half of all long-term smokers. In2005 the convention became a robust,legally binding international treaty thatwill impose a comprehensive ban ontobacco advertising and promotion.

On top of the millions of pounds thecompany has already spent on high-profile corporate social responsibilitycentres, global marketing standards andyouth smoking prevention programmes,BAT’s directors, managers and lobbyistshave responded to the FCTC with anarray of tactics in an effort to prevent thisand other robust legislation taking effect.

BAT’s internal documents show how:BAT aimed to split the UnitedNations with strategic lobbying andhas tried to influence the World TradeOrganisation (WTO) to oppose theregulation of tobacco, dispatchingchief executive Martin Broughtonto lobby the then WTO director, Mike Moore.BAT campaigned to discreditresearch from the World HealthOrganisation (WHO). It used

scientific evidence from researchsupported by the tobacco industry toundermine WHO research intonicotine addiction and the healthimpacts of secondhand smoke. BAT circumvents laws. KennethClarke has publicly admitted that BATsupplies cigarettes knowing they arelikely to end up on the black market.The Royal Canadian Mounted Policerecently accused BAT of colluding in amulti-million pound smugglingoperation, and, along with itsCanadian subsidiary, exportingcigarettes to the US black market sothey could be smuggled back intoCanada where tobacco is heavilytaxed. BAT also uses sportsponsorship and viral marketing tosubvert advertising laws.BAT has funded lobby groups topersuade decision-makers not toregulate the tobacco industry.BAT promotes the voluntaryapproach in order to persuadegovernments not to regulate. BAThas explored using codes of conduct,self-regulatory bodies, publicreporting and coordinated corporate-giving programmes as tactics topre-empt higher taxes, tobaccoadvertising bans and restrictions onsmoking in public places.BAT attempted to divide andundermine critics by developingnon-governmental organisation(NGO) partnerships and promoting itsyouth smoking prevention policies, itsgood relations with tobacco farmersand its economic importance.

Message to the stakeholdersBAT in its own words 03

BAT’s directors, managers and lobbyists haveresponded to the FCTC with an array oftactics in an effort to prevent this and otherrobust legislation taking place


BAT constructs a false image ofelitist, Western, tobacco-controlcampaigners intent on destroyingpoorer Southern countries’economies.BAT tries to influence tobaccotaxation policies, using the fear of cigarette smuggling to persuadegovernments into lowering tobacco taxes.

This report shows how securingpolicymakers’ support for their voluntaryapproach to corporate regulation hasbeen a priority for BAT. It also exposesthe inherent weaknesses of thisapproach to corporate socialresponsibility (CSR). Companies –especially those operating in hazardousindustries – should not be left to regulatethemselves.

The UK government’s formal ratificationof the FCTC is welcome and its target ofreducing smoking in England to 21 percent of the population by 2010complements the aims of the globaltreaty. To achieve this it will need toimplement stronger measures, includinga complete ban on smoking in all publicand work places. We also urge thegovernment to use its tobacco taxationrevenue to help other governmentsimplement the FCTC, with specialregard to helping the world’s tobaccofarmers diversify away from the tobacco crop.

ASH, Christian Aid and Friends of theEarth call on the UK government toreform company law so that all UK-based companies are accountable fortheir social and environmental impactswherever in the world they operate. Ourgovernment must also work to securean international agreement ensuring allthe world’s corporations areaccountable for the damage they causeto people and the environment. Thiswould establish international standards

with which national laws would then bebrought into line. The United Nations’Norms on the Responsibilities ofTransnational Corporations and OtherBusiness Enterprises with Regard toHuman Rights represent an importantstarting point.

Deborah ArnottDirector, Action on Smoking and Health

Dr Daleep MukarjiDirector, Christian Aid

Tony JuniperDirector, Friends of the Earth

Message to the stakeholders (continued)

Corporate social responsibility (CSR)is an increasingly discredited catch-all phrase. It is used by some of theworld’s biggest companies todescribe their voluntary efforts tohonour their social and environmentalresponsibilities to the world, itspeople and future generations.

BAT is one of many FTSE 100companies engaged in a major CSRdrive. It is accumulating awards forsocial and environmental reporting fromthe accountancy firm ACCA, and for‘building public trust’ fromPricewaterhouseCoopers. In 2005 BATwas ranked fourth on the United NationsEnvironment Programme/SustainAbilitybest practice survey of ‘global reporters’and has been listed on the Dow JonesCorporate Sustainability Index for fouryears running.1, 2, 3, 4, 5

However, the World Health Organisation(WHO) predicts 10 million people coulddie from tobacco-related illnessesannually by 2030. If BAT continues to beresponsible for 15 per cent of alltobacco sales over the next 20 years,the company’s products could cause upto 1.5 million deaths a year.6 Given thisprojection, it is difficult to square thecompany’s awards and ‘sociallyresponsible’ rhetoric with its tobaccoprofits. But BAT is undeterred,promoting itself as ‘a responsiblecompany in a controversial industry’.


Corporate social responsibility

It is difficult to square the company’s awardsand ‘socially responsible’ rhetoric with itstobacco profits

BAT’s big wheezeIn 2004 ASH, Christian Aid and Friends of the Earth published BAT’s BigWheeze, a report comparing the company’s CSR claims to its impactsaround the world. The conclusions were not encouraging.7 The reportfound:

BAT says it is a socially responsible company, even though cigarettes and othertobacco products are among the most common, preventable causes of death inthe world.

BAT says it has a ‘unique relationship’ with a quarter of a million tobaccogrowers worldwide, but BAT’s Big Wheeze showed how the company chargesNigerian producers high prices for loaned materials and pays them low prices forthe tobacco they grow.

BAT says it opposes attempts to addict children to cigarettes. Yet BAT’s BigWheeze showed how they flooded Pakistan with advertising aimed at teenagersand ran promotions in Russia designed to appeal to young women.

BAT says environmental and health and safety issues are high priorities for thecompany. But in 2002 and 2004 Christian Aid revealed in its reports, Hooked onTobacco and Behind the Mask that small-scale Brazilian and Kenyan tobaccofarmers regularly apply a cocktail of pesticides recommended by BAT withoutproper protection.

Farmers are concerned about the symptoms they suffer when they usepesticides sold to them by BAT. Many complain of nausea, blurred vision,headaches, eye irritation and chest pains. Pesticides commonly used bytobacco farmers include Orthene, an organophosphate (OP) insecticide, andDithane, an ethylene (bis) dithio carbamate fungicide. OPs have been linked withneurological damage and are based on nerve agents. Ethylene (bis)dithiocarbamates, although low in acute toxicity, have been linked withsymptoms similar to Parkinson’s Disease.8,9

BAT says it is planting managed renewable woodlands. But BAT’s Big Wheezerevealed how in Uganda and other countries, the tobacco-curing process is stillresulting in forest destruction. BAT’s plantations are an agricultural crop bearingno resemblance to the indigenous woodland habitat they replace.

Multinational companies usually keeptheir ambitions and desires wellhidden from civil society, consumersand regulators. Their websites andaudited social reports only disclosewhat they want us to read. Forexample, BAT’s annual social reportsfrom 34 of its subsidiaries around theworld contain a stream of sociallyresponsible rhetoric. ‘Guidingprinciples’ supported by ‘core beliefs’commit to ‘strength from diversity’ and‘open minded freedom throughresponsibility’. Showers of bulletpoints on relentless green web pagespromise a wide range of benefits,from ‘inspiring work environments’ to‘value to communities’ which‘collectively express the culture ofBritish American Tobacco’.

But because ASH, Christian Aid andFriends of the Earth have been able tocompare BAT’s public statements tomany of its internal documents we can expose some of the motives andtactics behind the company’s extensiveCSR drive.

This is thanks to the 1998 State ofMinnesota legal settlement with thetobacco industry that required BAT andother tobacco companies to providepublic access to their documentarchives for a period of ten years.10

However, the vast majority of thecompany’s documents are onlyavailable at its Guildford depository inSurrey, where conditions of access canbe highly restrictive for researchers. For

this reason, ASH, Christian Aid andFriends of the Earth are indebted to theLondon School of Hygiene and TropicalMedicine and other researchers whohave allowed us access to thedocuments through a searchable onlinedatabase and published research.11,12

Throughout the report, quotes from BAT’sprivate, internal documents appear initalics like this from Shabanji Opukah,BAT’s corporate social accountabilitymanager, in a 1999 memo:13

‘Put in another context and in order torelate the project on the TFI [TobaccoFree Initiative] threat, I would analogiseas follows. If Brent Spar and the NigerianOgoni issue were the major spark thatpushed Shell to where they are todaywith social accountability, then the WHOTFI threat is our spark...’

Quotes from BAT’s public documents,reports and speeches appear in romantext like this from Martin Broughton,chief executive, in 2000:14

‘A word of warning. The necessaryestablishment of international rules andregulations is becoming a vehicle forthose whose real interest is what I thinkcan properly be called the “NewColonialism”.’

Our access to BAT’s internal documentsallows us to reveal that alongside themillions of pounds BAT has spent onhigh-profile CSR initiatives,programmes and publicity drives, manyof BAT’s top people have engaged in acalculated effort to avoid regulation.


BAT’s internal documents

For BAT as for many multinationals, CSR is at best largely rhetorical and at worst anessential weapon in an ongoing battle againstfurther legislation


Regulating the tobacco industry

By 2030, tobacco could be causing up to 7 million deaths a year in the world’spoorest countries

This report focuses on BAT’s use ofCSR to block and avoid an historicattempt to regulate the tobaccoindustry on a global level.

The Framework Convention on TobaccoControl (FCTC) is the result of aninternational effort to regulate the tobaccoindustry dating back to the 1970s.

But it took until 1999 for formalnegotiations to be endorsed at theannual World Health Assembly, when191 WHO member states pledgedfinancial and political support, and arecord 50 nations spoke in favour of theFCTC. This included the five permanentmembers of the UN Security Council, aswell as many tobacco-growing andexporting countries. The EuropeanUnion and civil-society groups alsomade statements supporting theconvention.15 The WHO finallyimplemented the treaty in February 2005,by which time 168 countries had signedup, of which more than 50 had ratified.

The FCTC was devised to tackle theglobal health problems caused bytobacco, which kills almost 5 millionpeople every year. This epidemic isprojected to mushroom in the next 25years. By 2030, tobacco could becausing up to 7 million deaths a year inthe world’s poorest countries, where it isalready responsible for enormoushealthcare costs and lost productivity.16

Even today, most tobacco-relateddeaths occur in countries lacking

sufficient resources to develop policiesand programmes to reduce smokingeffectively and treat smoking-relateddiseases. As a tool to reduce thenumber of smokers worldwide, theFCTC has the unique potential to reduceboth these healthcare costs and thepain and suffering of smokers, theirfamilies and people exposed tosecondhand smoke. It is also the firstattempt by a global body to regulatecorporate activity.

If implemented properly, and notinfluenced by the tobacco industry, theFCTC will help governments reach theUN’s millennium development goals ofreducing poverty and improvinghealth.17 Key provisions in the treatyencourage countries to:

ban tobacco advertising, promotionand sponsorship as far as theirconstitutions permit. Tobaccoproducts are currently advertisedthrough sports and music events,films, fashion – in fact, almostanywhere the tobacco industrybelieves it can target potential new smokers. adopt and implement large, clear,visible, legible and rotating healthwarnings on tobacco products andtheir packaging, occupying at least 30per cent of the principal display areas.As advertising restrictions areimplemented, tobacco packagingplays an increasingly important role inencouraging tobacco consumptionprotect people from exposure totobacco smoke in indoor work and

public places by adopting andimplementing (in areas of existingnational jurisdiction as determined bynational law), or promoting (at otherjurisdictional levels) effectiveprohibition. Secondhand smoke is areal and significant threat to publichealth. Children are at particular risk –exposure to tobacco smoke cancause respiratory disease, middle-eardisease, asthma attacks and suddeninfant death syndrome (SIDS)ban the use of misleading anddeceptive terms such as ‘light’ and‘mild’. Smokers automaticallycompensate for lower levels of tar bybreathing in more smoke. They theninhale higher levels of tar than usualand breathe nicotine more deeply intotheir lungs18

implement effective measures toeliminate the illicit trade, illicitmanufacturing and counterfeitingof tobacco products. Cigarettes aresmuggled widely throughout theworld. In addition to makinginternational brands more affordableand accessible, illegal cigarettesevade restrictions and healthregulations19

promote economically viablealternatives for tobacco workers,growers and individual sellers. Cropsubstitution can be a useful strategyto aid tobacco farmers’ transition toother livelihoods as part of a broaderdiversification programmeprotect the environment from theharmful effects of tobacco cultivationand manufacture. In many tobacco-

growing countries, evidence indicatesthat tobacco agriculture has anegative impact on the environment,particularly when associated with thedeforestation required to increasefarmland and cure tobacco leaves.20

In addition to specific obligationscontained within the FCTC, the processof negotiating the treaty has alreadystrengthened tobacco-control efforts inscores of countries by:

giving governments greater access toscientific research and examples ofbest practicemotivating national leaders to rethinkpriorities as they respond to anongoing international process engaging powerful ministries, such asfinance and foreign affairs, moredeeply in tobacco control raising public awareness about thestrategies and tactics employed bymultinational tobacco companies mobilising technical and financialsupport for tobacco control at bothnational and international levels making it politically easier for poorercountries to resist the tobaccoindustry mobilising civil society in support ofstronger tobacco control.21

Model for a global treatyASH, Christian Aid and Friends of theEarth ask: if an international conventionto regulate the tobacco industry ispossible, why is it not also possible toadopt a similar measure to hold allcorporations accountable? We call onthe UK government to reform companylaw so that all UK-based companies areaccountable for their social andenvironmental impacts wherever in theworld they operate.

Our government must also work tosecure an international agreementensuring all the world’s corporations areaccountable for the damage they cause

people and the environment. The UNNorms on the Responsibilities ofTransnational Corporations and OtherBusiness Enterprises with Regard toHuman Rights could be the startingpoint for the negotiation of a frameworkof international standards by the world’sgovernments. It would then be theresponsibility of individual nations toimplement the code in their owncountries.


Regulating the tobacco industry (continued)BAT in its own words 08


BAT on the back foot

‘The WHO’s proposed Framework Conventionon Tobacco Control (FCTC) represents anunprecedented challenge to the tobaccoindustry’s freedom to continue doing business.’The FCTC is a potent means of savingmillions from disease and reducingthe strain on health services. But BATand the rest of the tobacco industryregard the treaty’s goals to reduce thenumber of smokers around the worldas an unprecedented threat to theirprofit margins.

BAT voiced its concerns about the treatyfrom its inception, both in public andprivate.

Publicly, Ooi Wei-Ming, managingdirector of BAT China, made the followingcomments in a 1999 keynote speech atthe World Tobacco Symposium andTrade Fair in Hong Kong:

‘The WHO in its Framework Conventionon Tobacco Control, is attempting todevelop a comprehensive and legallybinding international treaty that seeks todeny access to a legal product enjoyedby hundreds of millions of adult smokersaround the world… Forcing farmers toreplace crops, creating a complete banon any in-store product, and to cap it all,classification of the cigarette as apharmaceutical product!... In short, theimplication is that we, as an industry,don’t take our social and economicresponsibility seriously, that we aren’tcapable of pro-active self-regulation,and that we need to be nannied bygovernments. We know that this is notthe case and it is now up to us to correctthese misconstrued views of our industry.It is time to push back – and we need tomake our case in a compelling way.’ 22

In an interview with the BBC in 2000,Martin Broughton, then chief executiveof BAT, dismissed the FCTC as a‘developed world obsession beingfoisted on the developing world’.23 (sic)

However, BAT’s real concern about theFCTC was that it would impinge onbusiness, as BAT’s strategy document,British American Tobacco ProposedWHO Tobacco Free Initiative Strategy,reveals:

‘The WHO’s proposed FrameworkConvention on Tobacco Control (FCTC)represents an unprecedented challengeto the tobacco industry’s freedom tocontinue doing business.’24

An internal memo from a BAT executive,Andreas Vecchiet, to his colleagues in2000 summarises the company’sconcern that the WHO was respondingto pressure from health ministers andtobacco-control groups:

‘We affirmed that the seriousness ofregulatory threats against BAT areincreasing on the back of the FCTCprocess.’25

To this day, on its website, in speechesby its executives and in its promotionalliterature, BAT asks us to believe that thecompany isn’t ‘promoting smoking’, butsimply wants to capture the largest shareof the existing market. According to PaulAdams, BAT’s current chief executive:‘Our business is about offering a choiceof quality brands to adult smokers, not

promoting smoking.’26

If, as Mr Adams has suggested, BAT isn’tinterested in ‘promoting smoking’ andonly wants to command a significantshare of whatever market exists fortobacco, it should support the FCTC.This is because it does not target anyparticular brand, but it does have thepotential to reduce the number ofpeople taking up smoking, the numberof people suffering from tobacco-relateddiseases and tobacco-relatedhealthcare costs worldwide.

But BAT didn’t welcome the FCTC.Instead, the convention sent shockwavesthrough the organisation and managersbegan devising means to stop theproposed legislation being passed.


‘If Brent Spar and the Nigerian Ogoni issuewere the major spark that pushed Shell towhere they are today with social accountability,then the WHO TFI threat is our spark...’‘The question we need to ask is: Can thetobacco industry move itself ahead – fastenough and far enough – of the WHOagenda to negate the need for theconvention and enhance its reputation inthe process?’ 27 (sic) BAT strategydocument British American TobaccoProposed WHO Tobacco Free InitiativeStrategy

This is what BAT privately asked itself inthe face of what it saw as the FCTCthreat. In another internal documenttitled Why look at setting up a regulatorybody?, company executives exploredstrategies to change the companyimage, ‘crucially in the eyes of generalpublic and in how politicians perceivepublic attitudes’.28

Consequently, BAT took the radical ifparadoxical step of using CSR toconvince governments not to enact lawsthat would force the company to behavein a socially responsible manner.

One internal company strategydocument reveals BAT’s thoughtprocess, expressing both its concernabout the FCTC and illustrating how thecompany adopted CSR as a necessarystrategic response to the initiative:

‘Assuming that a FCTC – in whateverform – is a certainty, British AmericanTobacco’s strategy now needs to adopta two tier approach: lobbying andreputation management.’29

Internally, BAT’s self-assessment wasthat:

‘The most elusive part of the campaign...reputation management will require somesearching discussion, solid research andhard business decisions.’30

‘We need to consider a set of policychanges we consider necessary toconvince our priority stakeholders thatsensible economic, political and publichealth goals can best be achieved via aco-operative tobacco industry, ratherthan one that is in permanent conflictwith the WHO.’31

A 1999 memo from Shabanji Opukah,BAT’s corporate social accountabilitymanager, to Simon Millson, thecompany’s international governmentaffairs manager, shows how Opukahbelieved BAT had no alternative but toengage with ‘CORPORATEREPUTATION Management’ (sic) inresponse to the WHO’s TFI.

‘Put in another context and in order torelate the project on the TFI threat, Iwould analogise as follows. If Brent Sparand the Nigerian Ogoni issue were themajor spark that pushed Shell to wherethey are today with social accountability,then the WHO TFI threat is our spark...

‘Time comes when organizations mayhave to be shocked out of their comfortzones and shells and some of thisunfortunately may come from externallydriven rather than internally inspired and

value driven sources. Then for us WHOTFI presents the best opportunity to takeforward the big agenda on CORPORATEREPUTATION Management.’32 (sic)

Opukah’s memo exposes the extent towhich BAT only became concerned withthe impact of tobacco on health andsocial welfare when health authoritiesresorted to regulation to tackle it. This‘shock[s]’ BAT out of its ‘comfort zones’because it affects its brand and profits.

In its internal documents, BATrepeatedly refers to ‘the antis’ to denoteanyone trying to reduce the impact oftobacco on health.

‘During the past two to three decades,the fortunes of the tobacco industry inthe public affairs and public relationsarena have waxed and waned...

‘To use a boxing analogy, round one(60’s) was won by the industry; roundtwo (two) (sic) was a draw; round three(80’s) saw a win by the anti’s. (sic)

‘Round four (90’s) is now underway andup for grabs. It is by no means lost bythe industry, however, we must learnfrom the experiences of the past threerounds and apply these lessons…

‘In this context, BATCo public affairsdepartment must clearly establish apublic affairs leadership position...’33

Driven to reputation management


Developing a strategy

‘The whole [CSR] programme is commerciallydriven and recognises that BAT’s primary roleis to be economically successful.’

To develop its public-affairsleadership position, BAT put somestrategic muscle into its CSRprogramme.

BAT’s CSR approach was designed tocombat the threat of more robustnational and international legislation onmarketing restrictions, environmentalregulations and increased taxation. Thisnew approach was to be coordinatedand overseen centrally.

BAT explored opportunities for strategicgiving to enhance its ‘image andreputation as a good corporate citizen’.A 1998 note from BAT executive JulianOliver to his colleague Heather Honourproposed that Ken Clarke MP shouldoversee the policy and budget of asystemised corporate responsibilitiesprogramme.34

Potentially offering a swathe of externalopportunities, Oliver promised that theprogramme:

‘enhances BAT’s ‘licence to operate’with local communities and the media;responds to the growing demands forsuccessful companies to demonstratetheir social commitment;improves image and reputation as a‘good corporate citizen’;extends access and influence withregulators and politicians.’35 (sic)

The system would also address keyissues such as:

‘access and influence re exciseregimes

access and influence re the WorldBankdemonstrate leading edge corporatesocial responsibilities in Central andEastern Europe, Central Asia,emerging markets generally.’36 (sic)

This broader strategy resulted in high-profile CSR initiatives to promote ‘apositive reputation in order to improveour ability to shape the future businessenvironment’. In another 1998 internaldocument entitled Multinationals andSocial Accountability, BAT noted:

‘The recent award to B.A.T’s ManagingDirector in Hungary demonstrates thegroup’s sympathetic handling of localaspirations. Among the projects are aclinic for the diagnosis of disease;accommodation for the homeless, aswell as arts and educational projects.For B.A.T, such programmes not onlywin allies in local markets but open thedoors of politicians and regulators.’37

In 2000 BAT spent £3.8 million fundingthe new International Centre forCorporate Social Responsibility at theUniversity of Nottingham as part of itsefforts to play a central role in the voguefor CSR.38 Other attempts to buyacademic credibility included efforts tooffer a London School of Hygiene andTropical Medicine student a £1,500grant and work experience at thecompany.39

Chinese case studyBAT’s recent strategy in China reflectsthe corporate responsibility programmeset out by Oliver in 1998 when heemphasised, ‘The whole programme iscommercially driven and recognises thatBAT’s primary role is to be economicallysuccessful.’40

BAT had been making friendly corporategestures in China for more than tenyears. In 1992 it donated HK$300,000(£20,000) to repair the Haizhou Bridge inGuangzhou province which BAT hopedwas ‘the sort of gesture to whichofficialdom will be obligated, and (that)can benefit 555 and BAT more waysthan advertising alone’.41 (555 is one ofBAT’s leading cigarette brands in China.)

Such gestures were running alongsideother plans to influence Chineseofficialdom in BAT’s favour. In 1992 thecompany’s Chinese plans aimed to:

‘Influence the drafting of thesupplemental tobacco advertisinglaws’ and‘Lobby the ministry of Public health toreprioritise health issues. Hepatitis isthe number 1 killer disease in China’.42

A measure of success would be if:‘he [sic] liver disease preventionprogram is endorsed by and goodwill isgenerated among the Ministry of Publichealth and senior government leaders’.43

By the millennium, the one-off gifts andscatter gun approach had evolved into afar more strategic programme. BAT’s

internal 2000-2002 proposals for HongKong and China were calculated toemphasise BAT’s contribution to China’ssustainable development and to‘continue to lobby for marketingfreedom’ in the Republic.44

The endowment of a Chair of Marketingat a Shanghai business school,sponsorship of the Beijing Orchestraand a youth smoking preventionprogramme were all strategicallydesigned to improve BAT’s image in theworld’s largest cigarette market. Thesponsorships could also profit BAT ifthey influenced China’s young womento smoke the company’s cigarettes. Asonly ten per cent of China’s currentsmokers are female, women represent amassive potential market.45

BAT has also begun investing in China’stobacco infrastructure. In 2001 thecompany contributed funding to afactory in Sichuan province, and in 2004it announced it was financing another£800-million Chinese factory designedto produce 100 billion cigarettes a year.This would dwarf the output of BAT’s180 other plants worldwide and give thecompany a five-per-cent share ofChina’s tobacco sales.46,47

As recently as July 2004, BAT chiefexecutive Paul Adams said: ‘We arecommitted to China for the long term.’ 48

His company’s PR strategy reflectsChina’s key role in its expansion plans ina country where 350 million smokersaccount for a third of all cigarettessmoked around the world.49,50


Developing a strategy (continued)


Ethics and new colonialism

BAT portrays itself in a very ethical lightcompared with health workers, whom formerchief executive Martin Broughton rarelymissed an opportunity to denounceIn an effort to persuade tobacco-farming countries that the FCTC isnot for them, a tranche of BAT’s CSRinitiatives have promoted thecompany as a friend of the tobaccofarmer. BAT shifts the terms of thedebate away from the protection ofpublic health and towards theperceived damage that tobacco-control policies will have on tobaccogrowers and their communities. BAT’spublic statements and farmer-friendlyCSR initiatives are strategicallydesigned to dazzle policymakers intobelieving scaremongering about‘metropolitan liberals’, and the WHO’s‘export of attitudes’ and ‘insensitivity’.

An internal company documentproposing a self-regulatory body showsthat BAT believed it had found a weakspot in the FCTC.51

‘One aspect of the World HealthOrganisation’s programme is theeffective export of attitudes to tobaccouse amongst metropolitan liberals in theFirst World to the regulatory process ofdeveloping countries... The insensitivityto the differing circumstances aroundthe world is a key weakness in the WorldHealth Organisation’s position.’ 52

Exposing this perceived weaknessmotivated publicity:

promoting a ‘unique relationship withsome 250,000 tobacco farmersworldwide’emphasising how the ‘industrycontributes substantially to the

economies of more than 150countries’highlighting how BAT is ‘adding valueto the communities in which weoperate’.53,54

BAT continues to complain about what itsees as the one-size-fits-all approach ofthe FCTC.

‘We accept that tobacco should beregulated but are in favor of sensibleregulation, and feel that FCTC is a one-size-fits-all approach and needs to belooked at more nationally… What maywork in one country may not work inanother country,’55 Jeannie Cameron,BAT’s international regulatory affairsmanager, told the Center for PublicIntegrity in 2003.

BAT portrays itself in a very ethical lightcompared with health workers whomformer chief executive Martin Broughtonrarely missed an opportunity todenounce.

‘A word of warning. The necessaryestablishment of international rules andregulations is becoming a vehicle forthose whose real interest is what I thinkcan properly be called the “NewColonialism”,’ pronounced Broughton in2000.56

However, BAT’s internal discussions onthe benefits of a self-regulatory body didpredict the company could be scoringan own-goal by drawing attention to itsown bad practice. Some staff

anticipated allegations that the tobaccoindustry was exploiting ‘developingcountries’ could follow in the wake of itsanti-WHO stance.

‘…the more the industry draws attentionto this weakness, the more it isperceived as wishing to exploit theopportunities presented by theeconomic deprivation of many of thesedeveloping countries.’ 57 (sic)

Health priorities and PRIn an attempt to expose WHOweaknesses and shift the terms ofdebate, BAT has publicly emphasisedthe impact of HIV/AIDS, hepatitis, liverdisease and other illnesses to distractfrom the effects of smoking.Unsurprisingly, it fails to point out thatthe 5 million tobacco-related deaths peryear outnumber global annual hepatitisand HIV-related deaths combined.58,59

Even though tobacco will kill up to halfof the world’s long-term smokers –approximately 650 million people – BATtried to persuade the WHO to prioritiseHIV/AIDS over the tobacco epidemic.For this reason, the company was keento support an HIV/AIDS conference inZambia and has supported other HIVinitiatives.60

However, BAT’s UK headquarters didn’tfind it easy to ensure consistency ofconduct in the ‘operational territories’.Training sessions, policy documentsand action plans are all employed in aneffort to streamline the messages. In

1996 Shabanji Opukah instructed BATrepresentatives in India and Bangladeshto send him plans of action for theforthcoming ‘World No Tobacco Day’.

The India plan of action for the day asksOpukah to approve plans to emphasisethat ‘the health issues (like tobacco) ofthe First World are dwarfed by moreimmediate health problems in thiscountry,’ and determines to ‘Highlightinstances or cases of neglect in theareas of health. An example could be astory on the urban slums, which aregrowing at an alarming rate, bereft ofsanitation etc. Or the malaise of pollutionand the diseases induced by it. Or thegrowing, but inadequately challengedmenace of AIDS.’61

Nevertheless, BAT’s committment toHIV/AIDS relief is only intermittent.Opukah once turned down a request forAIDS-programme funding in Kenya,stating that:

‘As for the aids [sic] programme, it wouldappear it is too global and there arealready too many sponsors on board.Impact and recognition would be ratherdifficult to come by.’62

Tactical move to split the UnitedNationsBAT’s internal correspondence alsoindicates that its purported concern fortobacco farmers and tobacco-producing countries was a tactical movein its campaign to prevent regulation.Aiming to divide opinion within the UN,BAT intensively lobbied the UN’s Foodand Agriculture Organisation (FAO) topersuade it to criticise the WHO.

‘In 1989, intensive lobbying in Romecaused the FAO to publish, despite theWHO’s vigorous objection, importantreports on the economic significance oftobacco and on tobacco tradeprojections.’

Letter from M Oldman to D Baconregarding ‘Agro-Tobacco services (ATS),Proposal for a Consultancy Agreement’,BAT Guildford depository 1992.63

The tobacco industry’s efforts toachieve this split were coordinated byan international consortium of tobaccoindustry officials, initially called ICOSI,later renamed INFOTAB. BAT was afounding member of the consortium andpaid regular dues from 1978 to1987.64,65

An INFOTAB document outlines how to‘Attack WHO’ and ‘Split FAO/WHO’. Thetactics it suggests include thefollowing:66

‘3.1 PROGRAMME GOALS3.1.1 Criticise budget management3.1.2 Address health priorities3.1.3 Expose resource blackmail3.1.4 Highlight regional failures3.1.5 Attack ‘behaviourism’. 3.1.6 Counter on public issues, 3.1.7 Discredit activists’ credentials, 3.1.8 Engage in statistical warfare, 3.1.9 Invest in press relations, 3.1.10 Show impact of ‘cuckoo’organisations.’67

Using farmers for spadeworkBAT and the rest of the tobacco industrygave tobacco growers in developingcountries funding to help them brief UNofficials on the economic importance of tobacco.

‘…support of the Growers will beinvaluable in our continued battle withcritics of the Industry. Indeed, we havealready used them to help us brief bothdelegates to the WHA [World HealthAssembly] and to the FAO. The onlyhope of them being able to operateeffectively is with funding help.’ 68

In the past, BAT and other cigarettemultinationals have encouraged leaf

buyers’ lobbying activities on theassumption that ‘people whothemselves belong to the Third World’would have more credibility withpolicymakers than ‘an industry alreadyunder attack, by multinationalenterprises who only care for theirexcessive profits’.69

And by the 1980s the industry-backedInternational Tobacco Growers’Association (ITGA) had emerged as a‘“front” for our third world [sic] lobbyactivities at WHO’.70

BAT’s plan was for the ITGA to lobbyboth the WHO and FAO. BAT hoped thetobacco growers would capture the‘moral high ground’ by convincingpolicymakers of the developmental andeconomic benefits of tobacco farmingto producing countries.

‘By providing the resources necessaryto transform the ITGA from anintrospective and largely ineffectualtrade association to a pro-active,politically effective organization, theindustry created the opportunity tocapture the moral high ground in relationto a number of fundamental tobacco-related issues.’ 71

Growers’ association to block FCTCBAT has continued to use these tacticsinto the new millennium. In 2001, it wassupplementing the lobbying andpublicity generated by the ITGA with itsown ‘Grower Public RelationsProgrammes’, targeting the FCTC anddesigned to demonstrate the importanceof the tobacco crop to poor farmers:72

‘MAIN STRATEGIES1 FCTC

Assist grower countries in respondingto further rounds of FCTC decisionand the INB [IntergovernmentalNegotiating Body] negotiationsdevelop a more targeted approach to


Ethics and new colonialism (continued)

the co-ordination of grower countryactions, especially in Africa, SouthAsia and Latin Americabuild relations with other UN bodiessuch as FAO, ILO and UNCTAD torevive studies on economicimportance of the crop’.73

BAT aimed to: ‘Target WHO’s blind spotson key primary health priorities, such asHIV/AIDS prevention and malaria.Working through African and LatinAmerican members, [ITGA] will buildactions with their governments to putpressure on WHO.’74

This was consistent with the tobaccoindustry’s strategy to ‘challenge andridicule’ the WHO and FCTC by drawingattention to the HIV/AIDS crisis. Opukahlooked forward to getting some returnfor the money BAT had spent supportingtobacco growers at a Pan AfricaHIV/AIDS conference:

‘On FCTC the ITGA Africa region agreedthat these countries’ priority is nottobacco and health issues rather AIDs[sic] is the big issue.’

‘The ITGA agreed to support fully aproposal for a pan African aids [sic]conference to be held in Zambia inSeptember hosted by the health ministryat which they will discuss the aids [sic]scourge in Africa. The ITGA is going topresent what their grower associationshave been doing to support governmentand NGO efforts in combating AIDs [sic]in Africa and through that highlight theimportance of tobacco to the economywhilst relegating it as an issues [sic] inthe health priorities of these countries.Then [sic] idea is to use the forum tochallenge and ridicule the WHOconvention. I suggest that we supportfully the ITGA’s efforts in this regard.…Needless to repeat this is one way ofus getting value from our subs to ITGA –a natural ally.’75

But to carry out these sophisticatedlobbying strategies, the ITGA neededmore cash from the tobacco industry:‘At this time of great threat to the industry,ITGA needs financial support for itsimportant activity beyond that which itsfarmer members can provide.’76

In order for the ITGA to ‘take a moreprogressive, attacking position, not justrespond to WHO’ it would ‘needconsiderable additional support’.

BAT was keen to fund the ITGA, but itwas also vital to make this sort oflobbying appear independent of thetobacco manufacturers. Simon Millson,the company’s international governmentaffairs manager, makes this clear in amemo to BAT colleagues asking them tohelp ITGA member organisations ‘whipup some opposition to the FrameworkConvention on Tobacco Control’.

Millson stressed: ‘You also need toremember that this is an ITGA/farmersinitiative and they should be doing thewriting to governments.’77

The tobacco growers’ plightAlthough BAT has persistently positioneditself as the tobacco growers’ friend, thegrowers themselves are not unanimousin their endorsement of the industry.However, they are reluctant to publiclycriticise corporate practice becausecigarette companies and leaf dealers arethe only buyers of tobacco leaf.78

Two Christian Aid reports, Hooked onTobacco and Behind the Mask, raisedserious concerns about the health andsafety of small-scale tobacco farmers.They revealed how contract tobaccofarmers, working for BAT in Brazil andKenya, reported chronic ill-heath relatedto tobacco cultivation.79,80

Christian Aid and Friends of the Earth

were recently invited to take part inBAT’s social dialogue in Kenya, butdeclined on the grounds that they hadalready voiced their concerns about thesocial and environmental impact oftobacco cultivation to the company. ButSocialNEEDS Network, a Kenyanorganisation with which Christian Aidhas collaborated on research amongtobacco-farming communities inwestern Kenya, did take part.

The Reverend Joe Asila, who has spentmany years working with tobaccofarmers, led the SocialNEEDSdelegation, which included a farmers’union leader and a doctor. Together,they put it to Jan du Plessis, BAT’schairman, that the company paidfarmers a low income and discouragedunion representation, and that tobaccocultivation had damaged theenvironment and the health of farmers.

In his report of the dialogue, the Rev Asilaobserves that: ‘The team [from BAT] thatwas in Nairobi has the power, the abilityand the instruments [to deal with theproblems faced by farmers]; what theyneed to muster to act is the will.’

Many farmers are also concerned that byencouraging more and more countriesto grow tobacco, BAT and othertobacco companies have succeeded indriving down the world price. This hasreduced farmers’ revenues and profits,making them increasingly vulnerable tothe vagaries of the global tobaccomarket. And tobacco farmers must nowcompete not only with growers in theirown country but with producers on theother side of the world. No wonder thetobacco industry had to finance the ITGA– many farmers can barely afford to lookafter themselves.

BAT’s efforts to scare governments intobelieving the FCTC will be economicallyruinous are also unconvincing. In a


BAT STAYING ‘INDEPENDENT’

‘You also need to remember

that this is an ITGA/farmers

initiative and they would

be doing the writing to

governments’

landmark report, Curbing the Epidemic:Governments and the Economics ofTobacco Control, the World Bank notedthat: ‘...the negative effects of tobaccocontrol on employment have beengreatly overstated. Tobacco productionis a small part of most economies. Forall but a very few agrarian countriesheavily dependent on tobacco farmingthere would be no net loss of jobs, andthere might even be job gains if globaltobacco consumption fell. This isbecause money once spent on tobaccowould be spent on other goods andservices, thereby generating more jobs.’81

The report does conclude that there area small number of countries, notably insub-Saharan Africa, for which a global fallin tobacco demand would result in joblosses. But such a decline will not takeplace for decades, giving governmentsample time to plan a trouble-freetransition away from tobacco.


Ethics and new colonialism (continued)


‘Early progress [on underage smoking] wouldbe measured via end-market activities andcampaigns, rather than by any reduction [in]underage smoking’As a supplement to its farmer-friendlytactics, BAT has increasingly painteditself as a protector of young people’shealth. Promoting cigarettes as anissue of ‘adult choice’, BAT has usedmarketing pledges and youth CSRprogrammes as another major thrustin its ongoing fight against the FCTC.

Although BAT appears philanthropic,over the years internal documents haveindicated the extent to which suchinitiatives are motivated by PR: ‘Weneed to ask ourselves whether as anindustry we could be turning ourdeclared belief that we have no interestin recruiting children and by that I meansub-teenagers to more practicalaccount.’ (sic)

The tobacco industry’s initiatives toprevent young people smoking areknown to be counter-productivebecause they encourage children to seeit as an adult activity and thereforesomething to aspire to. They also givethe impression that addiction is a youthissue and not relevant to the populationas a whole.

Critics view the tobacco industry’spurported stance on youth smoking asdisingenuous; because so many long-term smokers die in middle age, thetobacco industry is perpetually in needof new young customers. TheUndermining its own CSR section onpage 30 describes how BAT is runningyouth-marketing initiatives alongsideyouth-prevention programmes.

However, for BAT and others in theindustry, youth-smoking preventionprogrammes also have a special appealbecause of their potential to preventregulation. Even as early as 1982, thetobacco industry was aware of howyouth-smoking prevention schemescould serve to block regulation: ‘…aprogram to discourage teens fromsmoking (an adult decision) mightprevent or delay further regulation of thetobacco industry.’82

A few years later, BAT met withcompetitors Philip Morris and Rothmansto discuss emerging threats to theirability to do business in Pakistan. In theface of ‘unprecedented opposition’ tocigarette advertising and the threat ofsecondhand smoke, they turned to a‘minors’ programme’ as a rescueremedy: ...it was proposed that we lookat developing a minors’ programme thatwould show the industry to be willing towork cooperatively with the authorities inat least one area in which we have amutual objective.’83

FCTC weaponIt comes as no surprise that BAT hasemployed youth-smoking preventionprogrammes as a weapon against theFCTC. As the company that reluctantlyconceded ‘an FCTC will come forwardin some shape or form’, it focused itsattention on persuading legislators toadopt a less robust treaty.

Instead of a total ban on advertising,BAT hoped for ‘a sensible convention

that addresses the issues of youthsmoking, raising awareness of risk andpreserving an orderly market’.

To this end, BAT was keen to ‘Undertakea long-term initiative to counteract theWHO’s aggressive global antismokingcampaign and to introduce a publicdebate with respect to a redefinition ofthe WHO’s mandate’.84

An undated BAT strategy document onthe Proposed WHO tobacco freeinitiative strategy states that ‘Actionsthat could reposition the tobaccoindustry might include’ marketingpractices such as ‘the withdrawal of allTV advertising before a 9.00pmwatershed and the voluntary removal ofall billboards from the vicinity of schools’as ‘meaningful concessions to the WHOagenda’.85

An internal BAT document entitled KeyEfforts by British American TobaccoCORA [Corporate and RegulatoryAffairs] Departments on Tackling theWHO Tobacco Free Initiative contains adetailed analysis of how youthprogrammes were used for lobbyingpurposes around the world.86

BAT Spain was ‘concentrating itsefforts on underage smokingcampaigns, winning the support of theHealth Ministry.’87

BAT Ukraine had ‘maderepresentation to WHOrepresentatives outlining its positionon youth smoking.’

Youth prevention

BAT Russia had helped ‘launch a pilotcampaign to stop youth smoking in StPetersburg. BAT Russia [was] alsoleading the industry in its efforts totackle the WHO Tobacco FreeInitiative.’88

In Zimbabwe, ‘Although the WHOchief Dr Brundtland, showed a “zerotolerance” attitude toward the industry,the Minister of Health and ChildWelfare was supportive of the principleof dialogue with manufacturers wherethere are common interests such asprevention/reduction of under-agesmoking.’89

BAT’s US subsidiary Brown &Williamson was ‘instrumental ingetting the International AdvertisingAssociation to come on board andvoice opposition to the WHO TobaccoFree Initiative. B&W led the campaignaround the Washington conferenceissuing a press release and taking partin many media interviews advancingthe company’s position on combatingyouth smoking.’90

BAT India, Bangladesh, Pakistan,Nepal and Sri Lanka were‘coordinating efforts across SouthAsia, focusing on the economicimpact and under age smoking.’91

BAT Taiwan was ‘focusing on winningthe support of the Department ofHealth through juvenile preventionsmoking campaigns in cooperationwith the Government.’92

In Hong Kong and China, BAT’s 2000-02 plan raised the concern that ‘theissue of youth smoking is a highpriority on the agenda of WHO andantis’. Taking this as a starting point,BAT is keen to ‘proactively promotejuvenile smoking prevention programsto demonstrate BAT is a responsiblecompany that produces qualityproducts for informed adults.’ Alsokey for BAT is to ‘Gain endorsement ofthe programme by regulators andgenerate recognition among them ofBAT’s contribution.’93

In order to preempt the ‘increased levelsof restrictions and bans’ BAT anticipatesthe FCTC will bring, the company PRplan aims to ‘continue work with theHong Kong Junior Chamber ofCommerce to generate awareness ofthe issue among Hong Kong studentsthrough “The Right Decision”programme.’94,95

But in his 2000 paper entitled Meetingreasonable public expectations of areasonable tobacco company, BAT’scorporate and regulatory affairs director,Michael Prideaux, was keen to point outthat on the topic of underage smoking,‘early progress would be measured viaend-market activities and campaignsrather than by any reduction on underage smoking’.


Youth prevention (continued)


In addition to promoting its ‘uniquerelationship with some 250,000 tobaccofarmers worldwide’ and its strategy to‘proactively promote juvenile smokingprevention programs to demonstrateBAT is a responsible company’, thecompany has also considered the PRpotential of environmental and humanrights initiatives.97,98 A strategy todevelop ‘NGO partnerships’ aimed atdrowning out calls for regulation andimproving BAT’s brand image.

When BAT’s Corporate and RegulatoryAffairs steering group met in 2000 todiscuss a 200-page presentation andstrategy document, it dedicated asection to ‘NGO Partnerships’. It hopedthese would help tackle a list of issuesunder the heading ‘The challenge fortobacco’. These were:

‘LitigationRegulation- More of it- More extreme- Spreading faster- International/multi-lateralDemonisation of- The industry- The product- Employees- The consumer’99

BAT’s ‘roadmap’ included the‘development of NGO partnerships’because:

‘Being responsible is one thing, beingrecognised for it is key:

Who will do the recognising?’

In order to address the question of ‘Whowill do the recognising’ BAT decided tocourt the endorsement of two particulartypes of NGOs. It was thought that,‘much pressure emanates fromlabour/human rights and environmentNGOs’ so BAT decided to concentrateon these two types of organisation – oras it put it: ‘NGO engagement will startin these clusters’.

Environmental groups such asEarthwatch, the UK Food Group, Fauna& Flora International, Wildcru, RoyalBotanical Gardens Kew, and theTropical Biological Association were allconsidered targets for partnership, whilein its strategy document BAT decided toconcentrate its energies on ‘substantiveengagement with well-respected andreasonable NGOs, centrally and at endmarket level – and to brand andcommunicate it.’100

Finally, BAT aimed to ‘grow partnershipswith NGOs and get their third partyverification/support for BAT’sachievements and standards ofbusiness integrity.’101

Same old greenwash?Once again, the idea was not a new one.In 1996, top BAT executive HeatherHonour told her colleague David Read:

‘…you asked me to set out the benefitsfor the Group of a higher profile on ourenvironmental policy and practise [sic].102

‘There is growing pressure fromGovernments and internationalorganizations for companies to becomemore transparent and accountable fortheir environmental managementsystems.103

‘The facts about our environmentalpractise [sic] in many countries will helpto counter some of the accusationsmade about tobacco, e.g. deforestation;land use and pollution and emphasisethe economic contribution of tobacco.These issues tend to rise in relation todeveloping countries often fromWestern Governments or pressuregroups or international organisations.’104

In defining the audience for a report onenvironmental practice, Honour writes:‘Martin Broughton [then chief executive]is keen that on these issues which dealwith the Group’s reputation, we shouldcarry our employees with us. Externallywe need to consider first of all theregulators and then civil service, MPs;…the press industry bodies; othercompanies; international organisations;scientific organizations, etc.’105

BAT’s Public Affairs Department wasgiven a central role in formulatingenvironmental policy. The departmentwas asked to ‘recommend companypolicy and strategy on responding toenvironmental issues with particularregard to proposals for legislation or theactivities of pressure groups.’

Environmental questions

Although there were considered ‘clear publicrelations benefits to be gained from adoptinga proactive stance [on the environment]’these were balanced against the cost of such a stance.

Counter-productive public pressure Corporations often maintain regulationis unnecessary because in a consumer-driven marketplace public pressure willforce standards up. For example,consumer pressure for fewer pesticides,less waste, fairer trade and action onclimate change has resulted in growingmarkets for organic and fair-tradeproduce, more corporate recycling and anincrease in the use of renewable energy.

But in BAT’s case, according to onedocument, the public’s environmentalconcerns did not persuade the companyto be as proactive as it could have been.

BAT’s Environmental Review in 1989suggested an environmental policystatement could be useful in ‘signallingto external audiences the company’scommitment on such issues’.

The document considered taking threepossible positions:

a ‘minimalist position, which simplycommits the individual operations tocomply with the relevant nationalregulations’a ‘compliance plus’ position whichwould seek to minimise environmentaldamage in areas not covered bynational legislationa ‘crusading attitude’.

Although there were considered ‘clearpublic relations benefits to be gainedfrom adopting a pro-active stance’,these were balanced against the cost ofsuch a stance. BAT also feared that a‘high-profile position’ could be counter-productive; if any aspects of itsoperations were ‘singled out as failing tomeet the highest internationalstandards, the Group will be particularlyvulnerable to public criticism’. In view ofthis potential vulnerability the internalBAT document recommended‘compliance plus’ in preference to amore crusading stance.106


Environmental questions (continued)


In public, BAT says it:believes in good governmentdoes not think companies are morepowerful than governmentsdoes not believe business shouldinfluence government decision-making.

‘However large and successful they are,companies have neither the ability northe mandate to step into areas ofauthority or decision making that arerightly for governments orcommunities,’ says BAT’s website.107

But behind the scenes, one of the majorthrusts of BAT’s campaign to preventregulation has been a charm offensivetargeting key politicians and businesspeople, aimed at persuading them of thecompany’s responsible nature.

BAT considers health ministers to be‘key stakeholders’ and has privatelylamented that: ‘In all but a few cases, itis politically impossible for a healthminister to oppose tobacco control.’BAT thought there were ways ofinfluencing these ministers, however,noting that ‘many health ministers aresusceptible to pressure from theircounterparts in the finance ministry.’107

BAT’s man in Africa Zimbabwe is an example of the ‘frontman’ approach in action. In an undatedletter found in BAT’s Guildford archives,Tom Watson, a consultant from the PRcompany Hallmark, working on behalf ofthe ITGA, updated BAT’s Simon Millson

about discussions he was having withDr Tim Stamps, the Zimbabweanminister of health. The letter contains anurgent request from Millson for evidencefrom other countries’ consultationprocesses which he hoped wouldpersuade Zimbabwe to widen itsconsultation on the FCTC to includegrowers and tobacco-industry boards.

Watson wrote: ‘Dr Stamps is on linealready about this wider approach, butwe need to give him evidence that othercountries have already made thatdecision. (That is, put lead in thegovernment’s pencil!).

‘Tomorrow we are meeting the DeputyMinister for Foreign Affairs, the Ministerfor Lands and Forests and the editor ofthe government newspaper, The Herald.We’ll take the same message to them.’109

BAT’s inside manUsing consultants for lobbying work is atried, tested and well-documentedapproach for BAT. Back in the early1990s, US lawyer Paul Dietrich was aconsultant for BAT while sitting on theDevelopment Committee of the PanAmerican Health Organisation (PAHO),the regional arm of the WHO in theAmericas.

He used his position to have tobaccodowngraded in PAHO’s list of healthpriorities and to divert attention from theEighth World Conference on Tobacco inArgentina. He used the media topromote the position that health

spending in Latin America should not gotowards controlling tobacco but to otherpressing public health issues.110

BAT’s man at the topBut BAT doesn’t leave all its lobbying tofront organisations, PR companies andconsultants. Targeted lobbying isfrequently undertaken by the chiefexecutive himself. A 1999 memo to thenchief executive Martin Broughton fromin-house lobbyist Nicola Shearsdiscussed a forthcoming meeting shewas setting up between Broughton andMike Moore, who recently had beenappointed director general of the WorldTrade Organisation (WTO). For BAT themeeting was an opportunity to supportthe new round of trade talks, emphasiseBAT’s interest in China’s accession tothe WTO, and, crucially, to ‘create aplatform for dialogue on the WHOTobacco Free Initiative’s (TFI) impact onWTO principles’.111

The memo said:

‘You have agreed to meet Mike Moore,newly appointed Director General of theWTO, at the Rugby World Cup Finals inCardiff on Saturday 6th November. BATNZ has received a verbal commitmentfrom Mr Moore to attend (along with hiswife). We now need to formalize theinvitation and a draft letter for you tosend to Mr Moore is attached.

The aim of the meeting will be to:a. create a platform for dialogue on the

WHO Tobacco Free Initiative’s impact

Charm in high places

One of the major thrusts of BAT’s campaign toprevent regulation has been a charm offensivetargeting key politicians and business people.

on WTO principles.b.discuss BAT support for a new round

of multilateral trade talks, Moore’sambition to take account of the needsof Least Developed Country membersof the WTO, and China’s accession toWTO.

c. establish our interest in WTO issues inadvance of the Millennium round andput down a marker for more formaldiscussions between BAT and theWTO in future.

BackgroundA smoker and former NZ ally, Moore mayprove key in helping to resist calls for theWHO’s TFI proposals to be built into theWTO system.’

BAT was particularly anxious to ensurethe WHO’s tobacco-control initiativeswould not impinge on WTO tradefreedoms:

‘Pressure is mounting for inclusion ofpublic health issues in the next round.We believe the WHO is considering howto amend WTO rules to ensure that theTFI is compatible. Our concern is thattobacco products could be

subject to exclusions from WTOfreedoms through changes to, or newinterpretations of, a [sic] existing WTOAgreements…excluded from the benefits affordedby tariff reductions.’112

BAT has also sought to bring pressure tobear on UK politicians’ moves to probethe tobacco industry.

In early March 2000, Stephen Byers,then trade secretary, had signalled thathe planned to set up an inquiry intoallegations that BAT was colluding incigarette smuggling. The minister plannedto use section 432 of the Companies Act,allowing files to be seized, employees tobe questioned on oath, and permittingthe outcome to be published.

The company’s initial attempts toinfluence Byers and the Department ofTrade and Industry (DTI) seemed to fallon deaf ears, but this changed whenBroughton gained access to PrimeMinister Tony Blair as a member of theMultinational Chairmens’ Group, whosemembers also include BP, Shell, Diageo,Unilever and Vodafone.

Avoiding parliamentary and publicscrutiny, and in spite of the seriousnessof the allegations against BAT,Broughton was invited on 14 March2000 to breakfast with Blair at DowningStreet. Byers was also at the breakfastand agreed to meet Broughton in aprivate one-to-one. Simon Millson wasdelighted with this result:

‘It was said we have been verysuccessful in getting the one-to-onemeeting with Byers… There are fewcompanies that have achieved this.’113

Soon after this meeting, Byers’ plans foran official Whitehall inquiry into BAT werechanged. Instead of using section 432of the Companies’ Act, the DTI pursuedtheir enquiry under section 447, which,critically, prohibits publication. Theinquiry was subsequently conducted insecret. Its outcome – that there wasinsufficient evidence for legal actionagainst BAT – was only made public aftersustained criticism from campaigners.Details of how the inquiry reached thisconclusion have not been published.

BAT used its private links to Mr Byers’officials to get some backgroundinformation. Ray Mingay, recent formerhead of export promotion at the DTI,also talked to officials on BAT’s behalf,according to the documents.114

BAT’s notes on the meeting betweenBroughton and Byers also reveal howthe company missed no opportunity tolobby for an independent, industry-led,

cigarette-marketing body. Having heardthat the government was committed toan advertising ban, Broughton thensuggested the DTI could develop anindependent forum for ‘the principles ofresponsible marketing of controversialproducts’. Broughton proposed thiscould be ‘organised either through theCentre for Disputes Resolution orInstitute for Marketing, to distanceGovernment’.115

The BAT minutes note: ‘Byers was verymuch taken with the fact that Martin wasthe Chairman of a tobacco company,non-executive director of an alcoholcompany – at the time – and head of theBritish Horseracing Board. (A uniqueselling point for Martin perhaps.) “I cansee where you are coming from,” Byerssaid. Byers seemed to enjoy the point hewas making.’116

Distorting scientific researchUnmoved that secondhand smoke cancause lung-cancer, heart disease andother health problems, BAT has beenpart of a long-running, multi-million-dollar campaign to discredit scientificresearch into its effects.117

BAT has a long history of denying linksbetween passive smoking and cancer,asserting in 1988 that:

‘All allegations that passive smoking isinjurous to the health of non-smokers, inrespect of the social cost of smoking aswell as unreasonable demands for nosmoking areas in public places, shouldbe countered strongly.’118

In the 1990s, BAT and the wider tobaccoindustry mobilised to misrepresent astudy by WHO offshoot, theInternational Agency for Research onCancers (IARC) into secondhandsmoke, which, when published someyears later, revealed: ‘The evidence issufficient to conclude that involuntary


Charm in high places (continued)

smoking is a cause of lung cancer innever smokers.’119

BAT’s minutes from a 1998 meetingreveal that the cigarette company PhilipMorris wanted financial help from BATfor Project Whitecoat, which aimed touse scientists as front men to producetobacco industry sanctioned researchand to stimulate controversy about thesecondhand smoke issue:120

‘The consultants should, ideally,according to Philip Morris, be Europeanscientists who have had no previousconnection with tobacco companies…121

‘Their idea is that the groups of scientistsshould be able to produce research orstimulate controversy in such a way thatpublic affairs people in the relevantcountries would be able to make use of,or market, the information.’122

Before the IARC study was complete,BAT led industry efforts to ensure mediacoverage was misrepresentative of itsoutcome. A 1997 internal documententitled IARC response plan outlinesBAT’s premeditated communicationsstrategy to preempt the publishing ofthe study:123

‘Please remember that British AmericanTobacco is likely to be the onlyinternational tobacco companycommenting on this study. The onus ison our company to state the industry’scase and, if appropriate in your market,you should ensure that you exploit allopportunities to do so.’124

Two key communications objectiveswere:

‘To communicate that the science doesnot establish ETS [environmentaltobacco smoke] as a cause, or riskfactor, for lung-cancer in non-smokers

‘To limit the opportunity for this study tobe taken out of context to justify publicsmoking restrictions.’

The document concludes ‘Stay close.And Good luck.’(sic)125

In line with this plan Chris Proctor, headof research at BAT, publicly told theGuardian that the IARC study ‘confirmswhat we and other scientists have longbelieved – that while smoking in publicmay be annoying to some non-smokers,the science does not show that beingaround a smoker is a lung-cancer risk.’126

And BAT issued a press release headed‘Europe’s largest ever passive smokingstudy has failed to establish ameaningful risk of lung cancer to nonsmokers.’127

In fact, the IARC report, published inOctober 1998 in The Journal of theNational Cancer Institute, clearlydemonstrated the opposite. The WHOissued its own press release inresponse, saying unequivocally that:‘Passive smoking does cause lungcancer, do not let them fool you.’128

A 2004 British Medical Journal studyhas recently suggested thatsecondhand smoke’s role in increasingthe risk of heart disease may even havebeen underestimated.129 But in 2005 astatement on BAT’s website dismissessecondhand smoke as merely anannoyance and a concern. Thecompany still does not admitsecondhand smoke kills.

BAT says: ‘We recognise EnvironmentalTobacco Smoke (ETS) can be a realannoyance and may be a concern tosome non-smokers and smokers.’130

But the BAT group ‘do not believeregulations banning smoking in publicplaces are necessary’.

BAT chief executive Paul Adamsdenounced the UK and Ireland’s policiesto ban smoking in enclosed public placesshortly after taking the helm in 2004.

He told The Times: ‘I think it’sunnecessary and I think it’s legislatinghow people should behave.

‘Yes, smoke in the (enclosed)atmosphere is a nuisance but there areways of handling it….’131

Incongruously, concern for his children’shealth has previously prompted Adamsto join a campaign to stop the localgovernment approving a mobile-phonemast near his home.

‘I would like to strongly oppose any suchplanning application being granted onthe grounds of:

its detrimental impact on thegreenbelt and the environmentgenerallythe possible health risk from theelectromagnetic radiation, particularlywhere it is sited close to threeschools.

As a very concerned parent of twochildren, I would ask that you turn downthis application,’ Adams wrote toChiltern District Council in 2002.132


BAT ON TARGETED LOBBYING

‘Many health ministers are

susceptible to pressure from

their counterparts in the

finance ministry’


Alongside the various thrusts of BAT’sCSR strategy, there were alsoproposals within the company for thetobacco industry to set up its ownalternative regulatory body inresponse to the FCTC threat. Crucially,BAT intended such a body to operatewithin a frame of reference dictatedby the tobacco industry itself. Beingseen to be self-regulatory would pre-empt potential future initiatives forglobal regulation, higher taxes, moreeffective environmental standards ormore rigorous advertising controls.Special consideration was given toensuring ‘developing countries’concerns’ were integral to theproposals so that further calls forregulation would be seen as both an‘impertinence’ and an ‘irrelevance’.133

‘The negotiations around theestablishment of a global regulatoryregime would provide a day-to-dayframework in which these developingcountries’ concerns could be expressedand accommodated… From there, it isbut a short step to pointing out to thegovernments of the First Worldcountries that continuing to haveadditional campaigns on the issue oftobacco use is both an impertinence andan irrelevance, because the issue isalready dealt with within the frameworkof the new body or charter asadministered by that body.’134

To work effectively for BAT’s business,such a proposal needed two keyelements:

‘Firstly, the entire process must beinitiated by the tobacco industry itself.Secondly, it must involve the settingup of an independent body to monitorthe operations of the tobacco industryglobally.’135

BAT reasoned that by kick-starting theprocess itself, the industry could controlthe agenda. It could set an acceptableremit regarding the areas in which it wasprepared to alter behaviour, such asrunning youth anti-smoking schemesand adopting codes of marketingbehaviour. And it could keep unpalatablecontrols at bay, such as advertising bansand laws to ban smoking in enclosedpublic spaces. BAT wanted the processto be monitored independently so itwould be perceived as credibly separatefrom the tobacco industry. As BAT itselfconcluded, this would be a difficulttightrope to negotiate.

Prevailing multinational trendsBAT’s plans were consistent with thegrowing fashion for self-regulationamong multinationals. According toBAT, one of the most ‘radical’expressions of this approach is theMarine Stewardship Council (MSC). Thisis a charitable, not-for-profit, non-governmental, international organisationset up to promote sustainable fisheriesand responsible fishing practicesworldwide through long-term, market-based solutions that meet the needsand objectives of both the environmentand commerce.136 Unilever, the world’slargest buyer of seafood, established

the MSC in 1997 in partnership withWWF – the global conservationorganisation.137

BAT saw the MSC as an attempt byUnilever to ‘maintain public confidencein the industry’ for which ‘the critical andilluminating point’ was that ‘no amountof work on this issue will be seen ascredible if it comes entirely from theindustry itself’.138 BAT was particularlyimpressed that the MSC ‘changedmedia attitudes, on this issue, in a matterof weeks’, and that:

‘To be perceived as being solutionseeking rather than solely self-interestpreserving might well be a major step torepositioning the tobacco industry...139

‘However, by seizing the initiative andconstructing a declared set of aims thatare likely to meet with the informedpublic’s approval, we change the natureof the game.’140

BAT also reasoned: ‘The other clear andobvious reason for this being a tobaccoindustry initiative is that it allows us todraw up what we believe the objectivesof the new body actually are.141

‘Be it noted, the constitution wouldspecifically preclude the regulatory bodyfrom considering or monitoring aspectsof the industry’s operations that werenot part of an agreed and achievableprogramme.’142

BAT’s self-regulation push

‘The other clear and obvious reason for thisbeing a tobacco industry initiative is that itallows us to draw up what we believe theobjectives of the new body actually are.’

This would ‘increase pressure on theindustry’s critics to justify theiralternative goals and mechanisms – adiscussion that would be almost entirelytheoretical since there would be nomechanism for their effectiveimplementation.143

‘If the organization is going to achievethe strategic aims of the industry, itsactivities need to be very visible to thepublic. It needs an attendant campaignof information about its proposed roleand the scope of its activities. Thecredibility of the body lies crucially in theeyes of general public and in howpoliticians perceive public attitudes asevolving towards it, and by implicationtowards the industry.’144

BAT reveals that a strong motive forsetting up an alternative regulatory bodywas to put critics in a difficult position.BAT hoped health workers would haveto accept such a body as ‘the only viablemeans of achieving the agreedobjective.145

‘No doubt, many reservations can beexpressed about providing a platform forthe industry’s critics. It should beremembered, however, that such criticsare going to find themselves in anincreasingly difficult position. To take theMarine Stewardship Council exampleyet again, it became increasingly difficultfor Greenpeace and other environmentalorganizations to criticize the initiative asit became clear that it was the onlyviable means of achieving the agreedobjective. Journalists can be madeacutely aware of this dilemma.146

‘The industry is attempting todemonstrate that where the aims andobjectives of the WHO are desirable,they are achievable by better methodsthan those currently underconsideration. Furthermore that many ofthe aims and objectives of the WHO are

ill conceived or intrinsically undesirable.However a careful balance of theapparent paradox between legitimatecommercial interests and public healthconsiderations is required.’147

BAT’s plans for self-regulation have notmaterialised in the form BAT envisaged inits strategy document. However, in 2002a consortium of tobacco companiesincluding BAT did launch a new set ofglobal tobacco-marketing standards.

According to a BAT news release, thesenew ‘globally consistent internationalmarketing standards’ represented a‘raising of the bar’ and established ‘abenchmark for the industry world-wide’.Simultaneously, however, globalfinancial market analysts responsible forassessing corporate-profit prospectsreassured investors that the newguidelines wouldn’t adversely affectBAT’s sales volumes.

Bonnie Herzog, Wall Street analyst forCredit Suisse Group and a tobacco-stock analyst, privately believed that themarketing code was designed toimprove the tobacco industry’s imageand head off legislation, but did notinclude any meaningful restraint ontobacco marketing. In a private researchnote, she assured tobacco investorsthat the marketing code could‘proactively’ counter a number of WHOproposals to ‘curb’ cigaretteconsumption, and that reducedadvertising in some areas could beeffectively redirected elsewhere.148 Shetold them:

‘We have analyzed the 9-pageagreement and believe that themultinationals’ strategy is proactive andis a way to improve their image. Theseinternational marketing standards partlycame as a result of increasing pressurefrom governments worldwide and anti-smoking activists. Also, by proactively

setting new international tobaccomarketing standards, the multinationalscould be trying to counter a number ofproposals that the WHO has beenworking on to curb the amount ofcigarettes that are consumed on aninternational level.

One would think that the elimination ofcertain marketing practices wouldeffectively decrease advertisingspending and hence increase margins,however we believe the modest amountthe multinationals actually spend onthese types of practices will beredirected into other types of marketingpromotions i.e., point of sale activity.’149

BAT thrust itself into new realms of PRcontortions. ‘Public discussion ofsomething that you are doing and wishto be seen to be doing, as distinct fromthe process of being continually on thedefensive, is a whole new ball game,’150

the company concluded whenconsidering how proposals to self-regulate might impact on publicperception and credibility.


BAT ON REGULATION

‘...the entire ‘process’ must be

initiated by the tobacco

industry itself.’


Public reporting and hidden agendas

[Solid reporting] ‘will provide an opportunityand forum for communicating positively aboutthe things BAT does well’.

Just as BAT considered setting up anindependent body as an alternative tothe FCTC, so it has developed a socialreporting process to protect itsreputation, deflect criticism, andcontrol the scope and framing of itspublic consultation exercises.

BAT advertises itself as an‘Organisational Stakeholder of the GRI(Global Reporting Initiative)’, which is aUnited Nations EnvironmentProgramme (UNEP) voluntary reportingprogramme for businesses. Chiefexecutive Paul Adams says BAT’s socialreporting is based on ‘a direct approachto dialogue with stakeholders’. BAT’ssocial report for 2003/4 notes thatmeetings were held with stakeholdersfrom the political, investment, scientificand health communities along withNGOs, business organisations,commercial partners and governmentand multilateral organisations.

‘Adopting social reporting based ondialogue has helped us to engage withstakeholders in a more fresh and directway. In working to embed the principlesof corporate social responsibilitythroughout the Group, my message isthat CSR is for all our companies,whether or not they are producing SocialReports,’ declares Adams on thecompany’s website.151

But behind the smokescreen, BAT haskept firm control of the reportingprocess. It takes full advantage of thevoluntary nature of the Global Reporting

Initiative – and the absence of anymandatory social reporting standards –which allows companies to pick andchoose those standards against whichthey wish to be measured.

Audits performed on BAT’s socialreports – what it refers to as an‘independent assurance statement’ –are conducted by a consultancy firmcalled Bureau Veritas. The firm isemployed by BAT and the scope of itswork is also determined by BAT. For its2003/2004 social report the statementconsists of a couple of pages ofassurances that the information withinthe report is accurate. An ‘advancedassurance’ is given that BAT did meetwith stakeholders as described.152

An internal discussion paper presentedto the board in 2000 introduced BAT’sown summary of social reporting.153 Inthis document, corporate and regulatoryaffairs director, Michael Prideaux outlinedwhat BAT’s Corporate and RegulatoryAffairs department believed to be thebenefits to the company of adopting theInstitute of Social and EthicalAccountability (ISEA) social reportingprocess known as AA1000. Accordingto Prideaux, the process will provide‘credibility’, ‘demonstrate’ its globallyconsistent approach to CSR and providea ‘robust platform on which to build areputation communications campaign’.154

Prideaux stresses some importantpoints for BAT to consider:

‘It is important to note that such

indicators would be set by BAT andnot imposed by external groups.’Social reporting would ‘validateenvironmental and communityprogrammes through stakeholderengagement’. Independent verification is ‘critical inoffsetting external accusations ofsecrecy or malfeasance’ and to ‘helpBAT to be recognised among its peergroup companies as a responsiblecompany and thereby limit further“demonisation” of the industry’.‘This will ensure that all businessactivity is aligned with reasonablestakeholder expectation and that itcontributes to the recognition of BATas a responsible company.’155

Reporting could also relieve BAT of thepressure to be ethical, asserts Prideaux,by protecting it from criticism andproviding a ‘publicly endorsed amnesty’.

‘The process will not only help BATachieve a position of recognizedresponsibility but also provide “aircover” from criticism whileimprovements are being made.Essentially it provides a degree ofpublicly endorsed amnesty.156

‘[Social reporting] will improve thecompany’s risk management capabilityand reduce the amount of timeabsorbed in day-to-day fire fighting. Andwill provide an opportunity and forum forcommunicating positively about thethings BAT does well.

‘Ultimately it will underpin the company’scredibility as a responsible industryleader and enhance its corporatereputation,’ concludes Prideaux.157

Engaging the enemyIn 2005, Michael Prideaux’s vision for asocial reporting process has takenshape in the form of BAT’s 34 socialreports from around the world, as wellas its detailed Annual Group SocialReport, which takes pride of place onthe BAT website. These reports areincreasingly based around an extensiveseries of ‘stakeholder dialogues’, citedby BAT as an example of best practicewhich Adams is quick to endorse:

‘Stakeholder dialogue is giving us newand better ways to engage and listen,and our stakeholders internationally tellus we’re on the right path.’158

But the introduction to social reportingPrideaux gave the board also revealedthat stakeholder dialogues can be usedto ‘provide access to importantstakeholders and opinion-formers that,until now, have proved difficult toengage…’159

In this he echoes Brendan Brady,director of BAT’s corporate andregulatory affairs in Australasia, whoonce made the following statement on aDVD entitled The Challenge of Change,which was distributed to BAT’sAustralian staff in late 2001:

‘If we find people who don’t want to talkto us, then I believe over a period of timewe can effectively embarrass them intotalking to us. We can ensure they cometo the table eventually with theirproblems about the industry or theirproblems about tobacco or whatever.’160

In 2004, Christian Aid and Friends of theEarth were invited to participate instakeholder dialogues in Kenya, led by

BAT’s company chairman Jan DuPlessis. Both declined. Christian Aid didnot feel it necessary to enter into furtherdialogue with BAT, as it believed its tworeports explained its position clearly.

Action on Smoking and Health (ASH)has also been invited to BAT dialoguesessions. However, ASH feels thatbecause the company sets the agendaand does not accept that it shoulddesist from promoting a product that willcause the deaths of half its long-termusers or acknowledge that secondhandsmoke can kill, the dialogues are anexercise in time wasting.

The SocialNEEDS Network, a Kenyanorganisation with which Christian Aidhas collaborated on research amongtobacco-farming communities inwestern Kenya, did take part. See Thetobacco growers’ plight on page 15 for asynopsis of the outcome.

Nigerian case studyInternal documents recording BATNigeria’s social reporting dialoguesessions show how the exercise worksfor BAT in practice. In an internaldocument entitled Social ReportingOverview, BAT Nigeria outlined itsproposals for a series of stakeholderdialogue sessions that began in 2002.

‘Benefits to stakeholders’ werepurportedly:

‘a unique opportunity to communicatewith and influence British AmericanTobacco within a framework of mutualtrust and respect’.

But being influenced was not on the listof ‘Benefits to British AmericanTobacco’, which were mainlyreputational and consisted of:

‘Improved long-term clarity of visionhence opportunities to achieve long-term survival/success

Enhanced corporate trust, respectand integrity from external partiesStrengthened trust, loyalty andcommitment from employees andbusiness partnersReduced reputational risk.’

A few paragraphs further on, BAT madeits priorities clear. According to thisdocument the company did notenvisage changing its behaviour as aresult of these dialogues. It simplywanted to hear what stakeholders haveto say, and then wanted to present itsview of itself to stakeholders:

‘The dialogue process will enable BritishAmerican Tobacco to understand itsstakeholders and, equally importantlywill provide an environment wherebystakeholders can fully understand BritishAmerican Tobacco.’

BAT, however, did envisage the processexposing divisions among stakeholdersand predicted a conflict of interestbetween tobacco-control workers andtobacco growers:

‘An example of this could be the desireby the health authorities that tobaccogrowing should be restricted to curbsmoking – this action would have aneffect on the welfare of tobacco farmerswho earn a living from growing tobacco.’

BAT’s first social reporting dialoguesession in the South was attended by 18stakeholders from civil societyorganisations, the Nigerian governmentand the private sector. BAT set theagenda, deciding on the issues fordiscussion. The minutes show thatsome stakeholder expectationsmatched parts of BAT’s CSR strategy,such as suggestions that BAT shouldaward scholarships to the giftedchildren of tobacco growers andcoordinate talks on HIV/AIDS inuniversities.161


BAT ON ENGAGMENT

‘If we find people who don’t

want to talk to us, then I

believe over a period of time

we can effectively embarass

them into talking to us’

Other expectations were morefundamental and touched on issueswhich are not part of BAT’s usual CSRterritory:

‘NGOs to fashion out regulatoryprocedures that would be faithfullyimplemented by BATBAT to liaise with other Stakeholdersi.e. consumers, government healthagencies, and NGOs to fashion outregulatory procedures that would befaithfully implemented information on the dangers of passivesmoking/ETS.’

At a later date, stakeholders alsorequested that:

‘BAT should modify cigarettes in orderto remove harmful substancesBAT should institute an insurancescheme for smokers.’ 162

A second dialogue session was held afew months later and the minutes notethat BAT took the opportunity to give apresentation outlining: ‘what BAT haddone, what it can deliver and what itcannot deliver.’163

BAT reiterated its standard position onvoluntary marketing standards, socialreporting, community giving, under-agesmoking programmes and contributionto the economy. On other substantiveissues, the company was unable to givea positive response, saying:

‘BAT did not believe it was itsresponsibility to institute an insurancescheme for smokers.’

And on removing harmful substances:

‘BAT believed that although there wasno such thing as a “safe” cigarette, thereality was that a large number of peoplewould still choose smoking, even thoughit was risky.’

BAT’s notes do not mention addressingstakeholder concerns about secondhandsmoke. Nor do they record any responsegiven to stakeholders’ requests for thecompany to implement regulatoryprocedures fashioned by NGOs.

Following the presentation,stakeholders were given furtheropportunity to feed back and wereasked:

‘How can you (or any other stakeholder)support/work with BAT Nigeria tosuccessfully implement thesecommitments?’164

The focus of this final feedback –designed to take BAT’s relationship withthe stakeholder to a new level – thennarrowed. The emphasis was put onissues such as:

‘using drama and other means to drivehome the point on under-age smokingwork on BEST BEFORE dates oncigarette packsthe training of local communityrepresentatives to take up theresponsibility of disseminatinginformation on AIDS.’165

BAT followed up the dialogue with amarketing touch, sending thestakeholders corporate 2004 diaries anddesk calendars for the New Year.166

Finally, BAT Nigeria based its 2003social report on the sessions, andaccording to managing director NickHales:

‘The Social Report is an account of thefirst formal process of stakeholderengagement that we commenced in2002.’167

However, the report did not discussmany of the important issues raised bystakeholders. Stakeholders’ requests

that BAT remove harmful substancesfrom cigarettes and that it set up aninsurance scheme for smokers were notmentioned. There was no reference tothe request for BAT to implementregulation designed by NGOs or to theissue of secondhand smoke.

Consultants for repositioningTo help design such reporting andstakeholder dialogue processes, BAThad considered using corporateconsultancy firm KPMG in 1999.

In an initial meeting held between BATand KPMG the topic of whether KPMGrecommended BAT adopt a strategy toabandon the tobacco business wasdiscussed. In a post-meeting write up,Shabanji Opukah, BAT’s corporatesociability manager, reassured hiscolleagues such a strategy was not whatKPMG had been suggesting. He didnote, though, that KPMG hadrecommended BAT address thecontroversy regarding its core productand its health impacts.

Opukah explained that David Coles ofKPMG had reassured him that:

‘[KPMG] was not referring to the needfor [BAT] to adopt a strategy to get out ofthe tobacco business, rather the need toaddress the controversy regarding ourproduct. [David’s] view was that to hangour flag on the mast of corporateresponsibility without dealing with thisissue would be a futile effort.’

It was agreed that: ‘there is need to ensure that [BAT’s]Board… appreciate and understand theneed for addressing the health issue as akey plank in the whole area of seeking tobe a responsible company in acontroversial industry...‘the Board should be made tounderstand the implications for thecompany in terms of the long term


Public reporting and hidden agendas (continued)

strategy and resources of embarking onthe CSR journey…’

KPMG then submitted a proposal toBAT entitled British American Tobacco –KPMG’s involvement in the WHO projectin which it analyses BAT’s need for‘repositioning’ in the light of the FCTC:168

‘For the purpose of the current terms ofreference, BAT has invited KPMG tohelp address these requirements initiallyin relation to the World HealthOrganisation’s (WHO) FrameworkConvention on tobacco control. Inparticular, BAT wishes to lead the rest ofthe industry in repositioning tobaccomanufacturers as socially responsible.BAT wishes to achieve this byestablishing an industry wide code ofconduct in consultation with relevantstakeholders.’169

In its proposal, KPMG sets out a table of‘concerns’ and ‘approaches’.

Top of the list of concerns is that:

‘The general perception is that BAT’sproposal does not go far enough,BAT’s proposal is seen as a spoilingtactic which backfires on BAT.’170

KPMG also asks whether it would bepossible to find:

‘a position which leaves organizationslike ASH and Tobacco Free Kidssatisfied that it is NOT ‘just a brilliantpublic relations gesture’.’

KPMG concluded that within BAT’s CSRplan there are ‘areas of the proposalswhich may damage credibility’, revealingit still had concerns about how BAT wasgoing to tackle fundamental healthissues in a way that would satisfyhealth-control workers.171 Nevertheless,the consultancy firm thought it couldhelp. KPMG revealed it was ‘keen to

work with BAT’ to ‘act as advisors onstakeholder inclusion and dialogue’.

BAT had hit its usual paradoxicalobstacles. Because it uses socialreporting to improve its reputation anddeflect criticism, it needs to control itspublic consultation exercises. But untilthe company is willing to tackle corehealth issues meaningfully, health-control workers will remain unconvincedthat BAT’s CSR is much more than PR. Many NGOs, such as ASH, TobaccoFree Kids, Christian Aid and Friends ofthe Earth lack faith in BAT’s socialreporting and stakeholder dialogues.International UN agencies, such as theWHO, and many health ministers intobacco-growing and consumingcountries around the world are alsounwilling to be involved in BAT’sstakeholder dialogue sessions.


BAT ON CUSTOMER CARE

‘BAT did not believe it was its

responsibility to institute an

insurance scheme for smokers’


BAT’s CSR initiatives, although ofquestionable value to society and the environment, are effective in thatthey have propelled the company toa position of leadership in the rapidlyburgeoning CSR movement.

However, an image of social andenvironmental responsibility can help multinationals build an argument against further regulation and influencelegislators in their favour.

South African contradictionIn its 2002 social report, BAT SouthAfrica was publicly ‘taking a firm stand’against youth smoking with a publiccommitment to raise the legal age ofpurchase for tobacco products from 16 to 18.172 The report emphasised that BAT South Africa would ‘undertakeexhaustive efforts to ensure that ourcommunication is directed only at adultsover that age’. The South Africangovernment also imposed a ban oncigarette advertising, sponsorship andpromotion in April 2001.

Despite its stated youth policy, BATdecided to circumvent South Africa’stough new advertising laws for therelaunch of its Lucky Strike cigarettebrand. It used a new marketing strategydeveloped by advertising agency,Bates/141, which circumvented theneed for posters and TV advertising,concentrating instead on a ‘customer-get-customer’ approach.

The strategy consisted of using ‘word of

mouth to encourage “friend get friend”.’Chosen retailers ‘could enter and win atrip to the Brazilian Grand Prix if theymaintained stock levels and displayquality’, while stylish young people BATcalled ‘Brand Amplifiers’ were recruitedto front the campaign. These ‘BrandAmplifiers’ were employed to ‘representthe embodiment of the brand in all thatthey do or say’. They were given LuckyStrike Volkswagens and ‘encouraged to“live” the brand lifestyle’ as they workedto establish relationships with potentialconsumers.

The campaign also featured a series ofevents focusing on internationallyfamous DJs and rock bands:

‘Rumours were generated through acombination of Brand Amplifiers“leaking out” information to a carefullyselected few contacts and through pre-event communication materials.’173

The campaign not only circumventedSouth Africa’s advertising ban, it wasalso calculated to appeal to youngpeople – marketing BAT claimed to be‘taking a firm stand’ against. Themarketing strategy’s objective was to‘penetrate [the] 18-24 sector’ using theinternationally famous DJ, PaulOakenfold, and rock bands Bush andViolent Femmes. All three of these actsappeal to the youth market.

On their official website, the ViolentFemmes rock band declare that:

‘…for the most part the audienceremains the same high school andcollege kids who have always been thecore of the Femmes crowd.’174

Commenting on the viral marketingventure, BAT’s Simon Millson told theFinancial Times: ‘It’s nothing new.Tupperware have been doing it foryears.’ Millson failed to mention that,unlike tobacco, Tupperware does not killhalf its long-term users. Nor did hemention that BAT had made a strongcommitment against youth advertising,or that cigarette advertising was bannedin South Africa.

Sporting appealFollowing BAT’s sponsorship of the1996 Cricket World Cup in India, aBritish Medical Journal study revealedcricket sponsorship by tobaccocompanies increased the likelihood ofchildren smoking. In light of this studyand in accordance with the ‘Preventionof Underage Smoking’, a key BATobjective in Asia, the company wasexpected to end all suchsponsorship.175,176

Instead, BAT’s Indian subsidiary, theIndia Tobacco Company, continued itslong-standing tradition of sponsoringIndia’s national cricket team throughoutthe televised 1999 Cricket World Cup.The Wills cigarette logo adorned theshirts of the whole Indian team andchild-size replica T-shirts were sold atthe MCC shop at Lord’s, in high streetsports shops and by international mail

Undermining its own CSR

‘Brand Amplifiers’ were employed to representthe embodiment of the brand in all that they door say.

order from the official Cricket World Cupwebsite.177 BAT did not end itssponsorship of the cricket team foranother two years.178

Formula OneIn China, BAT’s strategic plan includesthe aim to:

‘proactively promote juvenile smokingprevention programs to demonstrateBAT is a responsible company thatproduces quality products for informedadults.’179

Yet, in a parallel marketing initiative, BATis also establishing Formula One racesin countries with fewer advertisingrestrictions, such as China. Formula Oneis another sport that appeals to childrenand young people – particularly boysand young men – projecting a dynamic,young and cosmopolitan image.180

‘Research confirms that it has a youngerimage than before, is more dynamic,more human and credible and quiteclearly international.’181

A survey in 1996 found that around two-thirds of 11-16-year-olds could identifyat least one sport connected to cigaretteadvertising through sponsorship.182

Another study found that boys whosefavourite sport was motorracing weretwice as likely to become regularsmokers than those who did not have aninterest in it.183 But in his outline ofBAT’s CSR programme in 1998, thecompany’s executive, Julian Oliver,suggests ‘Arts and Motor Sportssponsorship’ as possible contributionsto ‘community activities’.184

Considering BAT’s youth-preventioncommitment, it is difficult to understandhow Oliver could conceive of such a link.

As far back as 1985, BAT consideredFormula One racing cars as a good way

of using young and dynamic imagery topromote its cigarettes around the world.Teams and organisers received moneyfrom tobacco companies while the roleof BAT as a race host could ‘assist indeveloping relationships with keydecision makers, otherwise known as“tickling the soft underbelly of thedecision makers”’.185

BAT’s Lucky Tribe campaign, whichaccompanied its entry into FormulaOne, had an estimated direct advertisingvalue of US$20m and a PR value ofUS$60m during the first financial quarterfollowing the team’s launch in 1998.According to SLAM, a company thatreviewed the campaign for BAT, the aimwas to build awareness of the LuckyStrike cigarette brand by ‘targetingyoung people on an international scale’through ‘cable, digital and new mediabroadcasting’. SLAM also advised that‘Young people are traditionally earlyadopters of new media capabilities andconsequently a very receptiveaudience.’186

BAT also explored merchandisingproducts targeting children and youngpeople such as racing car models andplay stations.

Another company, The MerchandiseGroup Ltd, advised BAT’s head of globalsponsorship, Tom Moser. In a 1998memo to Moser, a Merchandise Groupemployee advises:

‘We feel strongly (and have also beenadvised by professional animators) thatwe should not follow the “cuddly/funnyanimal” character concept as in the NFL[National Football League] pre-gameshow, Disney theme parks or events likethe World Cup. We feel this concept hasrun its course and is probably morepopular with very young children ratherthan “kids”. Our direction will becomputers. For example a computer

rendered character as in the charactersfrom the play station game Tomb Raideror Tekken.’187

Partly because of the influence oftobacco companies, more Formula Oneraces are being held in emergingmarkets throughout Asia that haveminimal regulation or negotiatedexemptions, as races in more regulatedcountries such as Austria, Belgium andCanada have been threatened orwithdrawn.188, 189

The following note to the ChiefExecutive’s Commitee in 1997summarises why the Asian marketswere so crucial to BAT as it facedincreasing curbs on its advertising inEurope:

‘Tobacco legislation is not new, but hasexperienced an escalation in activity inrecent years. This has impactedsponsorship. However, due to theconsumer and economic appeal ofFormula One and the content of tobaccosupport it has been successful in gainingspecial exceptions. Further, the drawingpower of Formula One has opened newopportunities in the Far East with longterm guarantees of no restrictions,putting less dependence on Europewhich should result in little impact in theforeseeable future.’190

China’s recent signing of the FCTC islikely to prevent the deaths of millions ofsmokers in the future. The inaugurationof the Chinese Grand Prix is not sopromising and the ‘long term guaranteesof no restrictions’ that BAT anticipatedfor new races in Asia probably meansmore young Chinese people will betaking up the addictive smoking habit,many of whom will not reach old age.


BAT ON F1 SPONSORSHIP

[Formula One could] ‘assist in

developing relationships...

otherwise known as “tickling

the soft underbelly of the

decision makers”’

Tobacco smuggling and tax PRFor years, BAT has used the fear ofcigarette smuggling to scaregovernments into not raising tobaccotaxes.

Yet internal documents reveal BAT’sambition ‘to achieve excise structures,which provide competitive advantage toBritish American Tobacco’s brands.’191

On its website, BAT complains:

‘Smuggling is caused by taxdifferentials, weak border controls, andimport restrictions and bans – often toprotect state monopolies – on goodswhich are in high consumer demand.Where governments are not prepared toaddress the causes of smuggling, it canrapidly spiral to overwhelm an orderlymarket and will frequently be penetrated byorganised crime.’192

But recent court cases have revealedthat tobacco smuggling is madepossible by actions taken by thetobacco industry itself.193

Cigarette smuggling is undertaken by criminal gangs in order to evade taxin countries where levies on tobacco are high. But BAT has flooded low-taxmarkets with cigarettes and could nothave been blind to the likelihood of themthen being smuggled into neighbouringhigh-tax countries.194

One BAT document discussing ‘Q&As’on smuggling – or ‘transit trade’ – asks: ‘Q: What is Transit Trade?A: Transit trade is the movement ofgoods from one country to anotherwithout payment of taxes and tariffs. It is more commonly known assmuggling.’195

In 2000, Kenneth Clarke publiclyadmitted to the Guardian that BAT

supplies cigarettes knowing they arelikely to end up on the black market.

‘Where any government is unwilling toact or their efforts are unsuccessful, weact, completely within the law, on thebasis that our brands will be availablealongside those of our competitors inthe smuggled as well as the legitimatemarket,’ said Mr Clarke.196

Paul Adams and Asian smugglingBAT’s top brass are very much aware of smuggling. Internal documents reveal that even the company’s recentlyappointed chief executive, Paul Adams,had accepted the role smuggledcigarettes play in the marketplace – and in building BAT’s brands in newmarkets – in Asia while he was a regionalmanager. The extent of BAT’s complicitywith smuggling by criminal gangs isexposed in hundreds of confidentialinternal documents revealed through US litigation. Many of these documentsshow Adams could not have beenunaware of the likelihood that BAT’scigarettes would be smuggled.

In Vietnam and other nations, whereBAT’s documents note all privatecigarette imports were illegal in the early 1990s, files held by Adams in hiscapacity as BAT Asia-Pacific regionaldirector show that the companymonitored and encouraged ‘GT’(general trade – sometimes also called‘transit’ trade), which is used as a termthat appears distinct from normal orduty paid cigarettes – although BATdenies this. It is clear from thedocuments that the senior directors andstaff who handled such sales wereunlikely not to have understood whatthey were doing.197, 198, 199

The highest offices of BAT’s subsidiariesalso appear to have known about andunderstood BAT’s complicity insmuggling into China. In November

1993, a memo from a Brown &Williamson executive to Adams said:

‘... not more than 30 % of importedcigarettes in China reach the marketthrough the CNTC [Chinese NationalTobacco Company]. The best prospectsfor growth in the Chinese marketcontinues [sic] to be unofficial channelsfor the foreseeable future.’ 200

Another note found in Adams’ file fromBAT employee Paul McPhail describedthe creation of a Vietnamese jointventure and sets out BAT’s position inthe Vietnamese market. Legal BATproducts made by the joint venturewould now be competing against illegalBAT products which continue to besmuggled into Vietnam. The note states:

‘We must accept the continuedpresence of G.T. [versions of StateExpress 555 in Vietnam] (unless acomplete government clampdown takesplace). Both [legal joint venture madeand smuggled G.T.] versions will have arole to play in the further building of thebrand, and the ‘system’ profitability...’201

And in a 1994 memo Adams clarified that‘general trade’ was to be the primaryresponsibility of his own RegionalBusiness Unit (RBU) in future rather thanBAT’s main South East Asia distributors,Singapura United Tobacco Ltd (SUTL).

‘All GT business in Asia Pacific shouldnow be handled by the RBU. Can we please check with [B&W vicepresident] Tom Whitehair that we arenow handling all GT and that thereforethey are not using SUTL for any GTbusiness.’202

(Translated into English, this memosuggests G.T. (general trade) is used torefer to cigarettes destined for marketsfrom which there was a high probabilitythat they would be smuggled.)


Undermining its own CSR (continued)

In January 2005, BAT was hit by freshallegations that it had colluded in amulti-million pound smugglingoperation. The revelations werepublished by the Royal CanadianMounted Police who raided the officesof a BAT subsidiary shortly beforeChristmas 2004 following a clandestinesix-year investigation. The policeaffidavit quotes from internal BATdocuments and alleges the companyand its Canadian subsidiary, ImperialTobacco Limited, exported cigarettes tothe US black market so they could besmuggled back into Canada, wheretobacco is heavily taxed.203



Internal correspondence written byBAT’s top executives shows how thecompany has employed a plethora oftactics to resist the FrameworkConvention on Tobacco Control(FCTC). CSR has formed a core partof this strategy. Youth-smokingprevention programmes, Farmers’Associations, codes of conduct andenvironmental partnerships have allbeen deployed as part of a grand planto convince policymakers to allowtobacco companies to continue on aself-regulating basis.

However, allowing multinationalcompanies such as BAT to regulatethemselves will not result in far-reachingor long-lasting improvements to theirhealth, human rights and environmentperformance.

As BAT’s cigarettes continue to kill halfits long-term customers, the company’sCSR positioning has allowed it to:

secure a strong presence at a UNDP-led CSR conference in Kuwait, whilein Nigeria, BAT tobacco farmers arestill concerned about the high pricesthe company charges for loanedmaterials and the low prices it paysfor their tobacco crops a high ranking on the UNEP/SustainAbility social reporting index,despite having used face-to-face viralmarketing techniques and FormulaOne racing to reach potential newyoung smokers in emerging markets be regarded by the Dow Jones

Sustainability Index as ‘leading itsindustry in terms of sustainability’,even though the companyrecommends Brazilian and Kenyantobacco farmers use risky pesticideswhich they routinely apply withoutproper protection develop its role in a ‘biodiversitypartnership’ with a group ofconservation NGOs, despite the factthat the tobacco-curing process is still resulting in forest destruction.Furthermore BAT’s replacementplantations bear no resemblance to the indigenous woodland habitatthey replace.204

The UK government and the FCTCThe UK government’s formal ratificationof the FCTC is welcome and its PublicService Agreement target of reducingthe number of people smoking inEngland to 21 per cent of the adultpopulation by 2010 complements theambitions of the global treaty.205 Toreach this target the UK government willneed to implement stronger measures,including a complete ban on smoking inall public and work places. We also urgeit to use UK tobacco taxation revenue tohelp the world’s tobacco farmersdiversify away from the tobacco crop.

Regulation of corporationsThe voluntary approach to corporatesocial responsibility is insufficient inholding companies to account and forthis reason the FCTC’s significancecannot be overstated. As aninternational approach to tackling the

tobacco epidemic and its costs to theworld’s health services, it is unique. Richand poor governments that workedtogether to negotiate the treaty will nowimplement the FCTC with special regardto helping the world’s tobacco farmersdiversify away from the tobacco crop.

ASH, Christian Aid and Friends of theEarth ask: if an international conventionto regulate the tobacco industry ispossible, why is it not also possible toadopt a similar measure to hold allcorporations accountable? We call onthe UK government to reform itscompany law so that all UK-basedcompanies are accountable for theirsocial and environmental impactswherever in the world they operate.

Our government must also work tosecure an international agreementensuring all the world’s corporations areaccountable for the damage they causepeople and the environment. In this way,countries would implement nationallaws that meet international standards.The UN Norms on the Responsibilities ofTransnational Corporations and OtherBusiness Enterprises with Regard toHuman Rights could be the startingpoint for the negotiation of a frameworkof international standards by the world’sgovernments. It would then be theresponsibility of individual nations toimplement the code in their owncountries.

Conclusion and recommendations

Allowing multinational companies such asBAT to regulate themselves will not result infar-reaching or long-lasting improvements intheir impact on people and the environment.


The Corporate ResponsibilityCoalition (CORE)This civil society umbrella organisationworks towards the social andenvironmental accountability of UKcompanies. Christian Aid and Friends of the Earth are members of the steeringgroup.

The government has promised tointroduce new legislation as a follow-upto the company law review. In particular,CORE is asking for:

transparency through mandatorysocial and environmental reportingdirectors to take environmental andsocial issues seriously by adopting a ‘duty of care for the environmentand local communities’accountability to affectedstakeholders through foreign direct liability.

This would mean communities outsidethe UK who were suffering from thenegative impacts of a UK company or its overseas subsidiary would beprotected under UK law and able toseek compensation for any humanrights or environmental abusescommitted by the company.

26-28 Underwood Street London N1 7JQUnited KingdomTel: 020 7566 1665 Fax: 020 7490 0881 Email: [email protected] Website: www.corporate-responsibility.org/

Framework Convention AllianceThis is a heterogeneous alliance ofNGOs from around the world who areworking jointly and separately tosupport the development andimplementation of the FrameworkConvention on Tobacco Control (FCTC)and related protocols.

The alliance includes individual NGOsand organisations working at local andnational levels, as well as existingcoalitions and alliances working atnational, regional and international levels.

7, Place du MolardCH 1204Geneva, SwitzerlandEmail:[email protected]

Action on Smoking and Health (ASH)102 Clifton StreetLondon EC2A 4HWWebsite: www.ash.org.uk

Christian Aid35 Lower Marsh, London SE1 7RLWebsite: www.christianaid.org.uk

www.christian-aid.ie

Friends of the Earth26-28 Underwood StreetLondon N1 7JQTel: 020 7490 1555Fax: 020 7490 0881Email: [email protected]: www.foe.co.uk

The London School of Hygiene and Tropical MedicineKeppel StreetLondon WC1E 7HTTel: 020 7636 8636Website: www.lshtm.ac.uk

British American Tobacco Documents Archivebat.library.ucsf.edu

British American Tobacco plcGlobe House 4 Temple Place London WC2R 2PG United Kingdom Tel: 020 7845 1000Fax: 020 7240 0555Website: www.bat.com

Links

1. www.acca.co.uk/sustainability/awards/susra/case_studies/BAT,www.ukmediacentre.pwc.com/Content/detail.asp?NewsAreaID=2&ReleaseID=1013, www.sustainability-index.com

2. www.acca.co.uk/sustainability/awards/susra/case_studies/BAT

3. www.ukmediacentre.pwc.com/Content/detail.asp?NewsAreaID=2&ReleaseID=1013, www.sustainability-index.com

4. Dow Jones Sustainability Index www.sustainability-index.com/htmle/sustainability/corpsustainability.html

5. Standard & Poors, SustainAbility, UNEP Risk & Opportunity, BestPractice in Sustainability Reporting.www.sustainability.com/publications/engaging/Risk-Opportunity2004.pdf

6. World Health Organisation, Making a Difference, World HealthReport, Geneva, Switzerland, 1999.

7. ASH, Christian Aid, Friends of the Earth, BAT’s Big Wheeze, 2004.www.ash.org.uk

8. J Melby, Hooked on Tobacco, a report on British American Tobaccosubsidiary Souza Cruz, Christian Aid/DESER, 2002.www.christianaid.org.uk/indepth/0201bat

9. A Pendleton, Behind the Mask, The real face of corporate socialresponsibility, Christian Aid, 2004.www.christianaid.org.uk/indepth/0401csr/index.htm

10. MN Consent Judgement. Second Judicial District. Court File No C1-94-8565. 18 May 1998.

11. London School of Hygiene and Tropical Medicine, GuildfordArchiving Project, www.lshtm.ac.uk/cgch/tobacco/guildford.htm

12. M Muggli et al. ‘Big Tobacco is Watching: British AmericanTobacco’s Surveillance and Information Concealment at theGuildford Depository’.www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=pubmed&dopt=Abstract&list_uids=15172782

13. Email from Shabanji Opukah, 19 October 1999, Re: KPMG terms ofReference. Bates number 321310087www.publicintegrity.org/docs/fctc/KPMG.pdf

14. Speech by BAT chief executive Martin Broughton, ‘The newcompetitive stakes for global companies: Doing business in aborderless world’, 5 May 2000.www.bat.com/oneweb/sites/uk__3mnfen.nsf/0/947248b0c005d41bc1256e8600524494?Op

15. WHO and TFI, The Framework Convention on Tobacco Control: APrimer, 2003.http://fctc.org/about_FCTC/WHO_NCD_TFI_99.8_Rev.7.pdf

16. World Health Organisation, Making a Difference, World HealthReport, Geneva, Switzerland, 1999.

17. www.un.org/millenniumgoals

18. ‘Tobacco Industry Deceit on Low Tar Cigarettes Exposed’, ASHpress release, 2003, www.ash.org.uk

19. www.who.int/tobacco/tobacco_economics/en

20. www.who.int/tobacco/tobacco_economics/en

21. www.fctc.org/about_FCTC

22. Speech for Mr Ooi Wei Ming on behalf of BAT at the World TobaccoSymposium and Trade Fair, 1999, www.globallink.org/gt/ap-docs/9911yu/2.htm

23. Martin Broughton, quoted in the article ‘BAT Profits Nearly Double’on BBC Online, 7 March 2000.

24. British American Tobacco documents archive, ‘British AmericanTobacco Proposed WHO Tobacco Free Initiative Strategy’,bat.library.ucsf.edu/pageview?a=img&tid=imk60a99&total=10,Bates number 322016374-322016383.

25. www.publicintegrity.org/docs/fctc/box/FCTC_strategy_regional.pdf

26. www.bat.com/OneWeb/sites/uk__3mnfen.nsf/vwPagesWebLive/

DO52ADR2?opendocument&SID=CD3989948BC622B55AFE74E50E2EB079&DTC=20050124&TMP=

27. British American Tobacco Documents Archive, ‘British AmericanTobacco Proposed WHO Tobacco Free Initiative Strategy’,bat.library.ucsf.edu/pageview?a=img&tid=imk60a99&total=10,Bates number 322016374-322016383.

28. www.publicintegrity.org/docs/fctc/Why_look_at_setting_up_regulatory_body.pdf

29. British American Tobacco Documents Archive, ‘British AmericanTobacco Proposed WHO Tobacco Free Initiative Strategy’,bat.library.ucsf.edu/pageview?a=img&tid=imk60a99&total=10,Bates number 322016374-322016383.

30. ibid.

31. ibid.

32. Email from Shabanji Opukah, op cit.

33. Business Management Seminar-Chelwood BATCo Public AffairsProject, 1991,bat.library.ucsf.edu/data/z/x/x/zxx01a99/zxx01a99.pdf

34. Note to Heather Honour from Julian Oliver, re corporateresponsibilities programme, 1998. Bates number 322121448.

35. ibid.

36. ibid.

37. BAT internal document. Bates number 322121564, Multinationalsand Social Accountability, 1998.

38. WHO, ‘Tobacco industry and corporate responsibility… an inherentcontradiction’, 2004, www.who.int/tobacco/media/en/tob-industry.pdf

39. ibid.

40. Note to Heather Honour from Julian Oliver re corporateresponsibilities programme, 1998, Bates number 322121448.

41. BATCo China Briefing Document, UK Brand Strategies - China1992, Guildford Depository, Bates number 301591556.

42. ibid.

43. ibid.

44. Asia Pacific North 2000-2002 company plan,bat.library.ucsf.edu/data/q/v/g/qvg61a99/qvg61a99.pdf

45. WHO, Tobacco or Health: A global status report, 1997

46. M Broughton, speech at the BAT annual general meeting, 2 May2001, www.bat.com

47. Anon, Financial Times, 17 July 2004.

48. news.bbc.co.uk/1/hi/business/3900559.stm

49. Asia Pacific North 2000-2002 company plan op cit.

50. J Mackay, M Eirksen ‘The Tobacco Atlas’, WHO, Geneva,Switzerland, 2002.

51. Why_look_at_setting_up_regulatory_body.pdf op cit.

52. ibid.

53. www.bat.com/oneweb/sites/uk__3mnfen.nsf/vwPagesWebLive/4ADD7183EC3B6AF780256BF40003315D?opendocument&SID=F4B8601E88BE5CC66984F2509C8BFFF6&DTC=20050124

54. www.bat.com/OneWeb/sites/uk__3mnfen.nsf/vwPagesWebLive/0CFCFE19CFBFEC7EC1256E97003429F2?opendocument&SID=F4B8601E88BE5CC66984F2509C8BFFF6&DTC=20050124 BATInternational Issues map.

55. B Coates, ‘Cigarette company documents outline strategy to derailglobal tobacco treaty’, The Center For Public Integrity.www.publicintegrity.org/report.aspx?aid=85&sid=200

56. Speech by Martin Broughton, ‘The new competitive stakes forglobal companies: Doing business in a borderless world’, 5 May2000.


Footnotes

www.bat.com/oneweb/sites/uk__3mnfen.nsf/0/947248b0c005d41bc1256e8600524494?OpenDocument

57. Why_look_at_setting_up_regulatory_body.pdf op cit.

58. www.biomerieux.com/servlet/srt/bio/portail/dynPage?open=PRT_PRD_CLN_VIR

59. www.avert.org/worldstats.htm

60. Opukah email op cit.

61. bat.library.ucsf.edu/data/y/d/h/ydh00a99/ydh00a99.pdf

62. Shabanji Opukah, Amref, BAT Guildford Depository, 20 April 1993.BB0303 Box No XMA0025, Bates number 500024349-4350.

63. M Oldman, letter to D Bacon regarding ‘Agro-Tobacco Services(ATS), Proposal for a Consultancy Agreement’, 7 January 1992, BATGuildford Depository, Bates number 502552644-50.

64. Tobacco Free Kids, ‘Expert Panel Details ‘Decades-long Effort’ byTobacco Industry to Subvert World Health Organization: SecretIndustry Documents Reveal Industry Plans To Discredit WHO, FightTobacco Control Measures, Undated,tobaccofreekids.org/campaign/global/pdf/infiltration.pdf

65. A general briefing on INFOTAB,bat.library.ucsf.edu/data/j/x/a/jxa30a99/jxa30a99.pdf

66. INFOTAB, Appendix I, January 1989 discussion paper, 30 January1989, www.pmdocs.com/PDF/2501045258_5268.PDF, Batesnumber 100433043-47.

67. ibid.

68. B Ely, letter to B Bramley, 19 October 1988, BAT GuildfordDepository, Bates number 502555415.

69. J M Hartogh, letter to all members of the ICOSI working group,enclosing a memorandum by Dr E Bruckner, BAT GuildfordDepository, 26 June 1979, Bates number 100433043-47.

70. J Bloxicage, fax to board members, Bat Guildford Depository, 11October 1988, Bates number 502555416-7.

71. M Oldman, letter to G Pedlow regarding the Agro-TobaccoProgramme, BAT Guildford Depository, 13 March 1991, Batesnumber 502555357-63.

72. BAT Grower Public Relations Programme, draft proposals for 2001.www.publicintegrity.org/docs/fctc/box/grower_pr_programme.pdf

73. op cit.

74. http://publicintegrity.org/docs/fctc/ITGA.pdf

75. Email Shabanji Opukah op cit.

76. International Tobacco Growers’ Association, ‘The Case forAdditional Industry Support’, publicintegrity.org/docs/fctc/ITGA.pdf

77. www.publicintegrity.org/docs/fctc/box/Millson_email.pdf

78. B Christopher, ‘Adversaries Now’, Tobacco International, March2000.

79. Hooked on Tobacco op cit.

80. Behind the Mask op cit.

81. www1.worldbank.org/tobacco/reports.htm

82. Tobacco Institute, ‘The Development of the Tobacco IndustryStrategy’, 16 April 1982,www.lorillarddocs.com/PDF/03673753_3762.PDF

83. Philip Morris memo from Colin Goddard, ‘Pakistan meeting inLondon’, 19 October 1994,www.pmdocs.com/getallimg.asp?DOCID=2504024765/4767

84. World Watch, ‘Protecting our Global ‘Next Generation’ – A Proposed Conference on Children’s Health Issues’, BAT GuildfordDepository, October 1989, Bates number 300516227-85.

85. British American Tobacco documents archive, ‘British AmericanTobacco Proposed WHO Tobacco Free Initiative Strategy’ op cit.

86. BAT archive document, ‘Key Efforts by British American Tobacco

CORA Departments on Tackling the WHO Tobacco Free Initiative’.www.publicintegrity.org/docs/fctc/CORA.pdf

87. ibid.

88. ibid.

89. ibid.

90. ibid.

91. ibid.

92. ibid.

93. Asia Pacific North 2000-2002, Company Plan,bat.library.ucsf.edu/data/q/v/g/qvg61a99/qvg61a99.pdf

94. ibid.

95. ibid.

96. ‘Meeting Responsible Public Expectations of a ResponsibleTobacco Company’, Paper for discussion at Castle Combe, Section2 - Introduction to Social, 29/30 June 2000,bat.library.ucsf.edu/data/h/w/g/hwg61a99/hwg61a99.pdf

97. www.bat.com/oneweb/sites/uk__3mnfen.nsf/0/bc11d5ba5017090d80256bf4000331e2?OpenDocument

98. Asia Pacific North, company plan, op cit,bat.library.ucsf.edu/data/q/v/g/qvg61a99/qvg61a99.pdf

99. The CORA roadmap, CORA Strategic Steering Group, Cora Plan2001, 16 May 2000,bat.library.ucsf.edu/data/d/e/w/dew70a99/dew70a99.pdf

100. ibid.

101. ibid.

102. Heather Honour, note to David Read, 1996,bat.library.ucsf.edu/data/u/o/m/uom71a99/uom71a99.pdf

103. ibid.

104. ibid.

105. ibid.

106. BAT, Industries Environmental Review, October 1989,bat.library.ucsf.edu/data/f/t/n/ftn10a99/ftn10a99.pdf

107. www.bat.com/OneWeb/sites/uk__3mnfen.nsf/vwPagesWebLive/DO52AQH8?opendocument&SID=100230249015FD447F17DB4594957297&DTC=20050120&TMP=1

108. www.publicintegrity.org/docs

109. www.publicintegrity.org/docs/fctc/box/watson_letter.pdf

110. S Boyse, letter to P Dietrich, BAT Guildford Depository, 7 August1991, Bates number 300516113.

111. Nicola Shears, memo to Martin Broughton,www.publicintegrity.org/docs/fctc/box/Broughton_letter.pdf

112. ibid.

113. politics.guardian.co.uk/foi/images/0,9069,1336499,00.html

114. R Evans et al, ‘Tobacco Firm Gained Secret Access to Blair’ theGuardian, 27 October 2004,www.guardian.co.uk/uk_news/story/0,3604,1336810,00.html See also Reputation Future,bat.library.ucsf.edu/data/z/v/h/zvh70a99/zvh70a99.pdf

115. politics.guardian.co.uk/foi/images/0,9069,1336499,00.html

116. ibid.

117. ASH and Tobacco Free Kids ‘Trust us We’re the Tobacco Industry’.www.ash.org.uk/

118. BAT, ‘Note on a special meeting of the UK Industry on EnvironmentalTobacco Smoke,’ 17 February 1988, 301150179 - 184.

119. ‘Tobacco Smoke and Involuntary Smoking’, IARC Monographs onthe Evaluation of Carcinogenic Risks to Humans, Vol 83, Lyon,France, 2004.

120. Tobacco Company Strategies to Undermine the Tobacco Control


Footnotes

Activities at the World Health Organisation, Report of the Committeeof Experts on Tobacco Industry Documents, 2000,www.who.int/tobacco/media/en/who_inquiry.pdf

121. BAT, ‘Note on a special meeting of the UK Industry on EnvironmentalTobacco Smoke’, 17 February 1988, 301150179 - 184.

122. S Boseley, ‘“Foul Play” by Tobacco Firm’, the Guardian, 9 March1998.

123. Keith Gretton, IARC response plan, 1997,http://bat.library.ucsf.edu/data/m/f/c/mfc60a99/mfc60a99.pdf

124. ibid.

125. ibid.

126. S Boseley, ‘“Foul Play” by Tobacco Firm’, the Guardian, 9 March1998.

127. BAT press release, 1998,tobaccodocuments.org/pm/2063594018.html

128. WHO press release, ‘Passive Smoking does Cause Cancer, do notLet them Fool You’, 1998, www.who.int/inf-pr-1998/en/pr98-29.html

129. P Whincup, et al, ‘Passive Smoking and Risk of Coronary HeartDisease and Stroke: Prospective Study with CotinineMeasurement’, BMJ Online First, June 2004,

130. www.bat.com/OneWeb/sites/uk__3mnfen.nsf/vwPagesWebLive/20F40100FB3BC23B80256BF400033172?opendocument&SID=1C8B96EEC337F0BA4732299CC9DD94F1&DTC=20050131

131. P Klinger, ‘BAT Man Lives (and Breathes) Tobacco Business’, TheSaturday Profile, Interview, Paul Adams, 2004,www.bat.com/OneWeb/sites/uk__3mnfen.nsf/vwPagesWebLive/DO52AEMG?opendocument&SID=E5C9946DA6985F566581C8CFE83A326A&DTC=20050224&TMP=1

132. BAT document Bates number 500015732, April 2002.

133. Why_look_at_setting_up_regulatory_body.pdf op cit

134. ibid.

135. ibid.

136. ibid.

137. www.msc.org/html/content_462.htm

138. Why_look_at_setting_up_regulatory_body.pdf

139. ibid.

140. ibid.

141. ibid.

142. ibid.

143. ibid.

144. ibid.

145. ibid.

146. ibid.

147. ibid.

148. International Tobacco Marketing Standards, ‘New Standards CreateConsistent, Responsible International Marketing Practices’,www.ash.org.uk/html/advspo/pdfs/csfb.pdf

149. ibid.

150. www.publicintegrity.org/docs/fctc/Why_look_at_setting_up_regulatory_body.pdf

151. www.bat.com/OneWeb/sites/uk__3mnfen.nsf/vwPagesWebLive/DO52ADBZ?opendocument&SID=100230249015FD447F17DB4594957297&DTC=20050120&TMP=

152. www.bureauveritas.com/homepage_frameset.html

153. ‘Meeting Responsible Public Expectations of a ResponsibleTobacco Company’, Paper for discussion at Castle Combe, Section2 – Introduction to Social Reporting, 29/30 June 2000,

http://bat.library.ucsf.edu/data/h/w/g/hwg61a99/hwg61a99.pdf

154. ibid.

155. ibid.

156. ibid.

157. ibid.

158. www.bat.com/OneWeb/sites/uk__3mnfen.nsf/vwPagesWebLive/DO52ADBZ?opendocument&SID=100230249015FD447F17DB4594957297&DTC=20050120&TMP=

159. ‘Meeting Responsible Public Expectations of a ResponsibleTobacco Company’, op cit.

160. B Burton and A Rowell, ‘British American Tobacco’s SociallyResponsible Smoke Screen’, PR Watch 2002,www.prwatch.org/node/278/trackback

161. Minutes of the social reporting dialogue one session of BritishAmerican Tobacco, Sheraton Hotel and Towers Ikeja, Lagos, 7November 2002.

162. List of stakeholder expectations after dialogue one.

163. Minutes of second stakeholder dialogue session.

164. BAT Nigeria stakeholder dialogue session two feedback form.

165. Minutes of second stakeholder dialogue session.

166. Letter to stakeholder.

167. BAT Nigeria social report 2003,www.bat.com/oneweb/sites/uk__3mnfen.nsf/vwPagesWebLive/DO5Z5AUR?opendocument&SID=31074141536F3BD7B6806F5C28DA4749&DTC=20050301&TMP=1

168. publicintegrity.org/docs/fctc/KPMG.pdf

169. ibid.

170. ibid.

171. ibid.

172. www.bat.com/oneweb/sites/uk__3mnfen.nsf/vwPagesWebLive/DO5Z5AUR?opendocument&SID=F279E32091B964FD2244A81E8AB7C2D6&DTC=20050128&TMP=1

173. E Terazono, ‘Sociable Smoking’, www.ft.com, 26 January 2004.search.ft.com/s03/search/article.html?id=040126005310

174. www.vfemmes.com/bio-1.htm

175. Amesca regional plan, 1999- 2000.

176. S Vaidya et al, ‘Effects of Sports Sponsorship by TobaccoCompanies on Children’s Experimentation with Tobacco’, BMJ 313,17 August 1996.

177. ASH press release, May 1999. www.ash.org.uk

178. www.rediff.com/cricket/2001/feb/23itc.htm

179. Asia Pacific North 2000-2002 company plan,bat.library.ucsf.edu/data/q/v/g/qvg61a99/qvg61a99.pdf

180. A Charlton et al, ‘Boy’s Smoking and Cigarette-brand SponsoredMotor Racing’, Lancet, 199; 350:1474.

181. J-C Chebat, ‘Effects of F1 Grand Prix Sponsorship by CigaretteBrands on Adolescents’ Cognitive and Behavioural Responses’, IntJ Sports Marketing Sponsorship, 105-28, June/July 2003.

182. ASH News Release, MORI Schools Omnibus Survey, 31 May 1996.

183. A Charlton et al, ‘Boy’s Smoking and Cigarette-brand SponsoredMotor Racing’, Lancet, 199; 350:1474.

184. Julian Oliver, note to Heather Honour re corporate responsibilitiesprogramme, 1998. Bates number 322121448.

185. Z Kmietowicz, ‘UK Exempts Motor Racing from Advertising Ban’,British Medical Journal, 1997. 315:1251-4.

186. www.wpro.who.int/tfi/docs/news/07-10-04_1.htm

187. Memo from The Merchandise Group Ltd to Tom Moser from BAT.Bates number 321229072 1998,


Footnotes

www.library.ucsf.edu/tobacco/batco/html/17300/17396

188. BBC sport Canadian GP back for 2004,news.bbc.co.uk/sport1/hi/motorsport/formula_one/3195158.stm

189. F1 fights to delay tobacco ban,news.bbc.co.uk/sport1/hi/motorsport/formula_one/2910663.stm

190. British American Tobacco, note to chief executive’s committee,British American Tobacco, Minnesota Document Depository, 1997.Bates number 321713308/3328.

191. British-American Tobacco Consumer & Regulatory AffairsTransitional Plan, 30 July 1996,bat.library.ucsf.edu/data/t/n/m/tnm71a99/tnm71a99.pdf

192. BAT, ‘Smuggling: Our View’,www.bat.com/oneweb/sites/uk__3mnfen.nsf/vwPagesWebLive/DO52AEDL?opendocument&SID=E02DE288B5D489E50DF87EAF2ED4CE28&DTC=20050217&TMP=1

193. ‘Trust us We’re the Tobacco Industry’, op cit.

194. ibid.

195. B Brady, letter re Q&A overseas trade, to K Hardman and T Bates,BAT Guildford Depository, 25 May 1993,www.publici.org/download/BAT_Q&A.pdf

196. Kevin Maguire, ‘Clarke admits BAT Link to Smuggling’, 3 February2000, www.guardian.co.uk/bat/article/0,,191286,00.html

197. A March, Adams memo to O’Keefe and Bramley, 1994, BAT filenumber BB0159.

198. Handwritten list from Paul Adams, file number BB0151.

199. ‘Secret’ memo from Adams to P C Godby, January 1994, filenumber BB0159.

200. Memo from Peeples, Brown & Williamson to Adams, November1993, file number BB0149.

201. Paul McPhail note to O’Keefe from Adams file, Notes from Vietnam,1993, file number HJ0393.

202. P Adams, Duty free and GT Sales, British American Tobacco,Available from Guildford depository,14 March 1994, Bates number500017237.

203. Physicians for a Smoke Free Canada, ‘RCMP raid on ImperialTobacco’, www.smoke-free.ca/eng_home/news_special_RCMP_Search_Warrant_Jan_05.htm

204. www.batbiodiversity.org/index.asp

205. www.dh.gov.uk/AboutUs/HeadsOfProfession/ChiefMedicalOfficer/CMOArticle/fs/en?CONTENT_ID=4081803&chk=3O5ZET


Footnotes

This report was written for Action on Smoking and Health (ASH), Christian Aidand Friends of the Earth by Lisa Rimmer. Comments were provided by DeborahArnott, Ian Willmore, Simon McRae and Andrew Pendleton.

ASH, Christian Aid and Friends of the Earth would like to thank Jeff Collin andthe London School of Hygiene and Tropical Medicine for their help andcomments.

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