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    =BhT BRITISH-AMERICAN TOBACCO COMPANY LIMITED
    TO: Mr M Broughton
    Mr U V Hefter
    Mr S P Chalren
    Mr M Prideaux 15 FEb 1994
    Mr D Bacon&/' ill 
    Pan  ..
    CC. copy 
    FROM: Philipps Casingens,
    ...............
    DATE: 14 February 1"4
    SUWECT: BATCo Policy on Advertising and Marketing
    1 attach an extract from BATCo's Operating Procedures Manual which clearly states in
    Section 9 (iv), BATCo's policy in direction of ad of its marketing and sales programmes
    to adult consumers, 18 years of age or older.
    The principal purpose of the Manual is to provide BATCo stafl~ particularly those in the
    Regional Business Units, with a ready reference guide to the operational control
    procedures to be followed.
    The international brand managers are responsible for ensuring the integrity of the
    marketing elements relating to the brand proposition for BATCo's international brands.
    Responsibility for the preparation and execution of the Regional Marketing Programme
    lies with the Regional Business Units- National brands are subject to the control
    procedures as indicated in the guidelines by approval through the Regional Director.
    0
    Philippa Casingena.
    C-D
    IMILLB&NK KNOWLE GREEN STALNIS MEDDLESEX TWIS IDY N)
    U1
    BATCo document for Legal Services : Health Canada 21 October 1999

    




    2. ACCOUXnNG PR.ACnCES
    A. Books and records
    it is important that &H the Company's books and records are properly kept and
    that the prescribed accounting procedures are foDowed. Employees must provide
    information to management or internal/external audit when asked.
    B. Invoicing
    Requests by customen;Lnd/or agents to provide an invoke showing a price or an
    amount different from the contracted price must be refused and reported to the
    0 C', Company Secretary.
    3. USE OF AGENTS AND NON EMPLOYEES
    A. Agents or other third parties must not be used to bre2k the law.
    B. BATCo and BATLIKE prefer all contracts to be in writing. In particular all
    agreements with relevant distributors or sales agents most be in writing and be
    approved by the Company Secretary before signature.
    4. ADVERTISING AND MARKETING
    BATCo is committed to the principle that smoking is an adult custom and thus
    directs a1l of its marketing and sales efforts toadult consumers, IS years of age or
    older. The Company adheres strictly to this policy in designing and implementing
    advertising, marketing, sampling and promotionai programmes for its cigarette
    products. Company Policy strictly prohibits the use of any programme directed
    to those under 18, and in particular it is forbidden to employ models who are, or
    appear to be, less than 2S Years of age in brand advertising.
    N;
    G-N
    IZZ)
    Operating ?rocedures December 1992 Section 9iv) Page 4 IN-)
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    BATCo document for Legal Services : Health Canada 21 October 1999

    




    BATCo is also committed to the principle that tobacco advertising and marketing
    programmes are used to cause existing adult consumers to switch From one brand
    to another (preferably to a BATCo brand) and are not used to get people to start
    smoking. As such, it is Company policy that all tobacco advertising and
    marketing programmes be directed to existing tobacco products consumers over
    Is Years of age.
    RBU staff should ensure that they are at all times 6wilia with the requirements
    of the currently applicable voluntary code signed between members of the
    industry and tl~e United Kingdom Government and shall ensure that regard is had
    to the provisions of that code when commissioning advertising world-wide.
    Experience has shown that agencies, despite their familiarity with BATCo
    products, do not adhere to the provisions of that code and therefore Marketing
    staff have a first responsibility to emure that draft advertising materials do so
    comply.
    5. COMP=ON
    BATCo requires strict compliance with all applicable UK and EC competition
    legislation, as well as the competition and anti-trust legislation of all countries in
    which the Company operates. These laws are designed to foster competition not
    only for the ultimate benefit of consumers but also to protect the rights of the
    companies such as BATCo to compete effectively and fairly without being
    adversely affected b the anti-competitive conduct of others in the market.
    I  Y
    These laws govern BATCo's conduct as a participant in the market place and
    prohibit BATCo from engaging in anti-competitive practices by itself or in
    conjunction with competitors. in compliance with these laws, it is BATCo's strict
    policy that decisions made on behalf of the Company are to be reached
    independendy and without collusion with competitors. Any meetings with
    competitors which could be taken by any external regulatory authority to be
    evidence of collusion, however innocent, must be reported to the relevant
    Director and to the Company Secretary immediately.
    ~_r-
    cz:
    NJ
    10-1\
    Operating Procedures December 1992 Section 9iv) Page 5
    I-D
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    BATCo document for Legal Services : Health Canada 21 October 1999