To: Mr. M.F. Broulbton
bcc: Mrs. B. 11onour
Miss A. Johnson
ICC Marter
You asked for an update on where we stand with regard to the Operating
Companies' review of the ICC Charter.
So far we have received comments from Allied Dunbar, Brown & Williamson,
Farmers. Souza Cruz and Imasco.
Allied Dunbar and farmers indicate that adoption of the Charter by
B.A.T Industries would not cause problems for them.
As a company whose business direction is set by an Independent Board of
Directors. Imseco sees no implications for itself should B.A.T
Industries adopt the ICC Charter. However, Isasco has informed the
Canadian ICC Secretariat that it would not be appropriate for Isaac* to
sign the ICC Charter (on the grounds that Imasco has developed an
environmental policy specific to the needs of Isaac* and its various
businesses).
The Group Tobacco companies do not Ifeel able to si;;n the ICC Charter
without significant qualiiicatidus.-
- Brown & Williamson Is against our si,",nin, becausu of the
vagueness of sanv of the Mwrterlz principles and the resulting
risk o! them bein.: to tob;.ccj companies. Arown &
Williamson's prv.@.-rred aparoac!! -.:. sinil3r to that adopted by
Imasco, i.E. te man.' oy, our %-k:-1.'-cstab1ished- environmental
Policy lili&, is tallored to our bustiuss-
In the event that Industrlui -(cia.:b to support the
Charter. brown & ;@1111amsor. "eel tisat ch. scope a! tnat support
would need to L.: ciariied tv indicut-- that we do hot see the
Charter as addressim issues like mainstrear or secondary smoke.
In particular, tne 'v if-u! tint we woul-2 need to qualify our
support by notic; talat.-
we do not vic.-.; th.- aj applyin& to any of the
public controvcraics associate with tobacco products;
and
we view the ter-- Icnvirormcatall as relating to issues
associated with the loot-term ohysLcal destruction of the
environment.
Soun Cruz feel toat the Qsartrr woulu-' need to be mended to
indicate that the reference to safe products (principle 6) am$
safe considering, the hazards reasonably expected by the public,
bringing It into line with Brazilian Consumer Protection
legislation. They feel that such a change would be necessary to
prevent the situation whereby formal adoption of the Charter
results in an implicit guarantee that a cigarette la a 'safe'
product. Other than this. Souza Cruz sec no problem in adoption C:)
of the ICC Charter.
00
U4
BAT Industries document for Province of British Columbia 22 April 1999

2
Thus, as expected, It is the 1v1--al =plic3tions of the reference to 'safe,
products (principle 6) which is earn as the main di!!iculty.
As the ICC Charter has already been !ormolly adopted (at the WICEM II
Conference in Rotterdam) and is said to he supported by over 200 companies
and industry association (23 trom the. UK), formal amendment of the Charter
(as required by Souza Cruz) seems an unrealistic option. Even if it were
possible, it would draw adverse attention and risk undermining the
credibility of the whole Charter.
The possibility of B.A.T Tmdustrien adontin.- the Charter but qualifyJA&
that support in a coverine nott. whictt clarifies that we do not see the
principles In applying to 'publ-.c controversies associated with tobacco
products' would allow us to resnonu Positively to the ICC but could leave
us in a difficult position pub.'Lcly. 1@ 3sVed to publicly confirm our
support we would always havf- to
With this in mind, the most attractive oosition appears to be that adopted
by Tmasce and recommended by Brown L 11:111iamson'i.e. if asked, to express
support Zor the general thrust af tne C-larter but to emphasize that we
already have a demanding Croun Policy an environmectal protection and
responsibility uhich Is focusseL' on our particular activities. We might
also seek to incorporate sozi- of the ICC princ-';Irs into our existing
Environmental Policy Statement,(az nrevioujily su.-gcsted - draft attached).
There is also probably thc need tn Jcvcloj, @ nuhlic affairs strategy with
regard to environmental matter;,.
We understand that althou;h Phillip aorris &::ree with the broad concept of
the 1CC initiative, the7 @8%-z -10t YeZ 3utU'-tt-c;' i; forrial responsc to the
ICC- Not surprisingly, they !%ave '11Z.ficult.- -.I-tn ;ae requirement that
signatory companies would be a-,reein- "...to devalo7% and provide products
and services that havc no un-uc impact and arL bal-L in their
intended use.-
G.J. Bgrzess
GJB/DJA
2nd May 1991 Enclosure
CD
00
Xh.
BAT Industries document for Province of British Columbia 22 April 1999