Toliaccri Straie2v Grovii) patter Stilliect: GrO1113 Additives and product Coninnitent Usnee Rackermind and Context The Group has to-date followed a consistent policy to ensure that products sold meet not only specific legal obligations. but that where external standards differ from one geographic region to another, it seeks to ensure that the highest reievant scientific standards are applied across all operations. fit the case of components of cigarette manufacture and additives used in the product. the regulations concerned with their use can vary considerably. TlWy range from the relatively clear position that exists in several European Countries (Germany. France and UK) to the requirement for disclosure to. but without specific control by government as in the case of the USA The position is further complicated. with some countries havine nit absence of any controls on components and additives used in cigarette niantifictufe leaving the ontis of responsibility ror the:r use to the manufacturer In recent years there has been increasing interest by governments and regulators to focus on the issues of product safety in many sectors of Industry but notably in the areas of food processing. pharmiCeLiticals. flavotirs. agrochernicals and tobacco and cigarette manufacitire It is proposed iliat the Gioup should establish a system to ensure that it is -,artistically positioned to be cable to respond rapidly and effectively to future government and regulatory demands and be able to defend' its use of specific components of ci girette manufacture and additives. both bv amount and if necessary at the level of the brand. In view of the fact hurt a single sourced Group product can be sold in an array of export markets, there is a requirement to be vigilant in ensuring that products. as a ininimurn. comply with local regrulations with responsibility for prodoct composition clearly identified lot addition. the responsibilities for product compliance and produce. composition for products manufactured by third parties and marketed by the Group need to be delineated A review of Group policy has been undertaken and a series of elements proposed that will allow the Group to continue to nicet its legal obligations and responsibilities and lie responsive to in evolving remilatoty framework which respects operating group autonomy and proprietary brand considerations. stitement or Policy 1. The Group confirms its position that all products should conform to the highest relevant and scicritificnily supportable standards. regardless of where manufactured and gold This includes the definition and control ofthe additives applied to the product and the components used in their manufacture. UNI (71% NJ BATCO document for Province of British Columbia 23 April 1999