Copy Pi:;.
SECRET SF.ORr.-T
B.A.T. UUARD sylIATEGIES
SMOKING AND HEALTH : TRE PUBLIC AND T11L AUTUonITIES
STRATEGIUS AND CONSTRAINTS
A. RELATIONS WITH GOVERNMENT, MEDICAL
AUTHORITIES, INDUSTRY AND THE MEDIA
1. Social Awareness & Reseonsibility
1.1 Because there in general sensitivity in respect of
our products per se, we should at all times be
particularly vigilant in ensuring that we remain be-
yond reproach concerning the ordinary duties and
obligations we owe both our consumers and our workers.
Por example, we should be particularly sensitive to
industrial hygiene factors, environmental noise,
ordinary toxic hazards, etc.
1.2 Above all we must ensure that we never knowingly
mislead our consumers and we as manufacturers must
be able to demonstrate that we are acting responsibly
and have concern for their interests at all times.
1-3 _40b-@V_ - - __ -_!__ it in considered quite unde-
sirable to encourage children to smoke or to encourage
peoplo to smoke to excess.
2. Medical Controversy
2.1 Regardless of our wishes or our interpretation of
the nature or origins of our problems, Government
interest and action in respect of smoking is expected
to increase. We should continue to state quite
properly that millions of smokers throughout the world
derive ploasuro and satisfaction from smoking. But
because we would not wish to appear intransigent, and
recognizing the status of some of the medical research
on which the case against smoking is based, we would
not be wise to attempt to contest publicly the
validity or much of the medical evidence against
smoking. However, we must continue to reject claims
of causality based on statistical evidence alone.
Certainly, we should avoid any Company involvement in
medical controversy.
2.2 Nevertheless, in special cases we should challenge
interpretation where we are convinced that it is
wrong and certainly we should challenge inaccurate
and dishonest statements. We should not, however,.
initiate action which might load to ptiblic discussion
of issues in the smoking and health controversy which
had previously lain dormant. Wherever possible Millbank
must be consulted by Group Companies other than the
Companies which are repr*xonted at the Chairman's
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Advisory Conference, the C.A.C. CompanieS, before any
interpretation or statement is challenged.
2-3 To be effective it in desirable that B.A.T. Companies
and the Tobacco Industry as a whole must be seen to
be responsible and$ within our fieldt authoritative.
2.4 If possible, it is essential to speak as an Industry.
B.A.T. Companies should seek to induce the Industry
in any particular country to speak with one voice on
policy matters. They should also press for the
establishment of Industry representative associations
where these do not already exist.
2.5 A forum has now been established at which inter-
national companies can discuss issues of mutual
interest in the field of smoking and health, in order
to agree a common position where possible. This
should ensure uniformity of approach - and action
where necessary. Tobacco Division companies have
been advised and will continue to be advised of the
areas in which a common position has boon reached
by the forum and also of certain constraints that
the forum has accepted - and their company policies
should conform with this advice.
2.6 Companies should influence, as far as possible,
medical and official opinion against incautious
imposition of constraints and any unreasonable res-
triction on smoking. To do this it may be necessary
to talk to medical authorities and Government
agencies.
2.7 Our'primary objective must be to maintain, despite
the attacks on smoking on health grounds, a position
in which we are free to pursue our legitimate business
interests through the marketing of tobacco products.
Further objectives must be the protection of the
interests of our consumers, many of whom find smoking
beneficial in one way or another and the protection
of the interests of Industry employees, the retail
and wholesale trade and tobacco farmers, whose live.
lihoods all depend an smoking.
2.8 Each Company should ensure that its employees, the
tirade and the farmers are aware of its position in
relation to the issues of smoking and health.
Guidance on thin will be provided by Public Relations
Department, Millbank. Companies, other than C.A.C.
Companies, should not disseminate any documents on
these issues without prior clearance by Territorial
Directors.
2.9 Where the question of smoking and health is active
and where the Industry in sponsoring health research
it should keep madi air authorities informed and invite
their views.
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2.10 The Industry in one country might also publicise tile
research in other coitntries even where such research
I-% tint sponsored by health authorities, Intt the
company should rcror to Millbank berore such action
is taken.
2.11 B.A.T. research shovild be communicnted outside the
Group only where agreement by Millbank is obtained.
B. MARKETING AND ADVERTISING
1. Warninc Clauses
1.1 If to comply with legislation warning notices have
to be printed on packs, Companies must endeavour to
ensure their attribution to Government or some other
official body: similar attribution is equally
necessary even when there in no legal requirement
for It (e.g. concessions made by the Industry in the
interests or good relations). If Governments
suggest wordi g implying or stating smoking causes
erta
I- in named5diseases, Companies must strenuously
resist with all means at their disposal, until
legislation makes it inevitable. In this event it
is even more important that any such statement is
attributable.
2. Leasue Tables
2.1 We should discourage tile introduction of product
league tables since this leads to implied health
claims. But league tables are preferable to media
restrictions. In any event, if publication becomes
Inevitable, we should co-operate in setting up
measurement procedures which conform to inter-
nationally accepted standards, thus treating it as
a marketing opportunity but taking into account the
legal constraints. Published league tables should
preferably be compiled by an independent laboratory.
2.2 Irrespective of the likelihood of league table
publication in their host country, all Companies
should ensure that they arrange for own and compet-
itlon brands to be tested on a regular basis.
Priorities in this respect should be:-
(1) Own and competition international brands
(2) Significant own and competition domestic
brands
(3) Own and competition low delivery brands.
The tar test result should be expressed an Particulate
Matter Water and Nicotine Fros, (PMWNP), which conforms
with international standards, unless there is already
publication or league tables in the hoot country
using a different method.
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2.3 All companies should ensure that they have a brand
in the lowest delivery segment of the market and
that in the main segments of the market they have
brands favourably positioned in terms of delivery.
While it is accepted that consumer preference is of
paramount importance, companies should ensure that
the tar and nicotine deliveries in their brand
structure can be defended against criticism from
the local authorities and from international
opp-3nents of smoking and are not liable to be
unfavourably compared with the deliveries of
competitors' brands.
2.4 Filter versions of brands should always show lower
deliveries of tar and nicotine than plain versions.
Where possible, this should apply to carbon monoxide
delivery.
2.5 Various tactical moves are possible for achieving
low league table positions, e.g. decreasing the smoke
in later puffs, modifying filter plasticizer. The
considerable experience in the Group is available to
all associated companies.
2.6 Carbon Monoxide and the oxides of nitrogen are
already being increasingly regarded by certain
authorities as health hazards for smokers and non-
smokers and other constituents of the vapour phase
of smoke such as acetuldehyde, acrolain, hydrogen
cyanide, etc., are coming under suspicion. If
companies, other than C.A.C. companies, detect any
sign of the authorities in their host country becoming
concerned about constituents other than tar and
nicotine, they should immediately consult Millbank
regarding the need for additional analyses.
2.7 So far there is no valid scientific basis for combining
measurements of different chemical compounds in the
smoke of an individual cigarette brand into a single
index number so as to represent a measure of implied
hazard relative to other brands. Such aggregation
implies unjustifiable judgments of the strength of
association between chemical compounds and diseases.
Such arbitrary indices of hazard cannot receive any
serious scientific support and their introduction
should be resisted wherever possible.
2.8 Because it is believed that nicotine will be consid*red
by some leading doctors to be loss harmful than tar
or possibly carbon monoxide and because it is believed
that nicotine is the main attractive ingredient for
many smokers,@companies should encourage the separation
of nicotine from tar in the minds of those in authority
and of the. public.
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3. Maximum Tar and Nicotine Limits
3. 1 Where imposition of utaxitntim tar and nicotine yields
is likely this shovild be resisted, but if the
imposition of such limits becomes inevitable attempts
should be made to get levels fixed sufficiently high
to cover the majority of brands. It should be borne
in mind that once maximum levels are established, they
will n1most inevitnbly be reduced by Governments in
oubseq4ent years.
4. Declaration-of Constituents
4.1 We should resist for as long an possible any require-
ment to put figures for the yields of smoke constit-
uents or tar groups an packs or in our advertising,
but such requirements are preferable to restrictions
on advertising. In any case, before any concession
entailing the printing of figures or groups on packets
or advertising in made, Millbank should be consulted.
5. Taxation as a means to reduce cizarette consumption
or to induce smokers to switch to low tar brands
5.1 If Governments indicate their intention to employ
punitive taxation In order to increase prices and
reduce cigarette consumption, this should be strongly
resisted for the following reasons:-
(1) It would hit hardest those people with
low incomes.
(2) There in a real danger that p*oplev who
as a result of such measures would only,
be able to afford to buy fewer cigarettes,
would change their smoking habits and
smoke each cigarette to the shortest
possible butt length, which governments
are likely to regard as undesirable on
health grounds.
(3) A likely result would be that smokers
would switch to cheaper hand-rolled
cigarettes without filters or other
products, which governments may not regard
*a desirable. (The switch to hand-rolled
cigarettes without filters actually
occurred in Germany after a recent tax
increase and caused a lose in government
revenue).
(4) Punitive tax might lead to an overall
reduction in consumption, but this could
mean reduced Government revenue and
unemployment in the industry due to
contraction of the market.
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5.2 Graduated taxation based on tar yields, aimed at
inchicing smokers to switch to low tar brands should
also be strongly resisted on the following grounds:-
(1) It would he inequitable to penalize smokers
in one sector of the market and would be a
limitation of their freedom of choice when
the case for and against smoking is widely
known.
(2) Smokers of higher delivery cigarettes may
find that they need to smoke more low
delivery cigarettes to achieve the same
satisfaction.
(3) Experience has shown that such taxation
results in loss of revenues illegal
introduction of cigaretteir from other
markets and fierce criticism of the
authorities imposing the tax. (All
these occurred when New York City intro-
duced graduated taxation in 1971).
(4) Smokers who like higher tar yield cig-
arettes can still obtain them - and
avoid tax - by buying lower tar brands
and removing the filter tip.
6. Adv*rtisinx
6.1 We should resist restrictions on media advertising
on the basic ground that advertising does not affect
total cigarette consumption. Now and effective
evidence of this will shortly be circulated to all
Companies. However, we should recognise that a
totally intransigent attitude could lead to a ban an
advertising. The Industry, working together, should
therefore keep under constant review limited conces-
sions, which it might have to make in order to avoid
more effective restriction on advertising.
6.2 We should try to obtain the support of other industries
in resistance to advertising restrictions, particularly
those industries which might themselves be threatened
later - e.g. alcohol. We should also onlIst the help
of the media and of the advertlaing agencLes whose
revenue would be adversely affected by such restrictions.
6.3 In Third World countries Companion should be aware or
advertising and promotional standards current in the
Western world. They should roaliss that certain
practices may Invite Governments to Impose restrictions.
6.4 Wherever possible Companion should attempt to reach
joint agreement with their competitors that tboy will
mutually refrain from Oromoting brands in terms of
explicit health claims.
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6.5 Where our product development has resulted in a
reduction in deliveries or smoke constituents which
others consider harairul, reCerenco is permitted in
advertising providilkg there nre good competitive
reasons for so doing and competent legal advice has
been taken. Companies other than C.A.C. companies
must, however, refer to Millbank before they embark
upon advertising of this nature.
7. Sponsors ip
7.1 We should resist attempts to restrict our right to
sponsor sporting, cultural and other events. Benefi-
ciaries of any such sponsorship should be used an
pressure groups to oppose any attempt to restrict
sponsorship. There in no evidence whatever that
sponsorships increase the total consumption of
cigarettes. Our reason for undertaking sponsoring
activities are to create company goodwill, endorse
brand loyalty and encourage brand switching.
Restrictions on Smoking in Public Places
8.1 WhIlst recognising the need for restrictions in
certain special cases, Companies should make every
effort to resist unreasonable restrictions. They
should influence whenever possible the sithorities
responsible for imposing them by pointing out that
the bulk of the evidence shows that the allegations
about "passive smoking" are grossly exaggerated and
that 9 expert witnesses bsfore the Tobacco Sub-
Committee of the Committee on Agriculture of the
U.S.A. Hous:r of Representatives testified on the
7th Septemb 1978, that tobacco smoke has not been
shown to cause disease in people who do not smoke.
(Documentation on this testimony has been sent to
all Companies or their local industry associations).
C. RESEARCH AND DEVELOPME14T
1. Research and Development plays a key role in car
reaction to the attacks on smoking. Responsibility
in this area lies wIth R. & D. Millbank and the
Companies particularly involved in R. & V. activities,
to whom a paper entitled "Smoking and Health : Research
and Development" has been circulated. Nevertheless
all companies should understand the allegations against
smoking products and acquire on a continuing basis
an much knowledge as possible of their products and
those of their competitors and thetr interaction with
consumers.
2. Companies should examine diligently all suggestions
made to them, from any source, which are claimed to
enhance the safety or ftminLsh the hatzards of smoking.
Such suggestions should be referred to R. & D. Killbank.
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1 We should have as much knowledge as is available on
the compoxition of our products..
2. In particular this ineans companies should not use
additive materials tinless the composition is known
to them. Further, they should take such steps as
are appropriate for a responsible manufacturer to
ensure they do not use additive materials against
which allegations of harm may be reasonably sustained.
For this assessment the Additive Guidance panel is
available.
3. In all respects we shall demonstrate a responsible
attitude to product modifications. We shall not
adopt product modifications unless we are satisfied
it is not against the interests of our consumers to
do so. Further, while the addition of nicotine would
give more freedom of cigarette design in some circum-
stances, because of the legal and public relations
problems and the possibility of production errors,
nicotine, as an isolated identifiable chemical mater-
ial, should not be added In our products. However.
these objections do not refer to tobaccos or tobacco
extracts which contain nicotine.
4. Tobacco substitute materials will not be sold by
companies in their products without prior consultation
with Territorial Directors well in advance.
5. We should not attempt to exploit the position of cigars
'a
via-'* -via cigarettes an in the long run this will be
self-defeating.
6. Companies should, therefore, ensure that nothing done
in promoting cigars should prejudice the position of
cigarettes.
7. We should try to discourage the publication of cigar
league tables, When publication is unavoidablet we
should co-operate with others in establishing con-
ditions of testing by which our cigar products are
riot shown in an unfavourable light compared with
competitors' cigar products. We should, therefore,
try to get smoking conditions for cigar league tables
which conform to human smoking of cigars rather than
of cigarettes.
November 1978
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