MAINTAINING HIGH STANDARDS OF GOVERNANCE
How we act today impacts our business tomorrow.
Our values and Code of Conduct are embedded throughout Imperial Brands and drive our responsible approach. Our values reflect the behaviours we expect from everyone who works for us and our Code of Conduct is aligned with policies, internal controls and risk management processes that underpin our strategy.
How we conduct ourselves and our business can have wider impacts for society. Doing business in the right way, having integrity and not tolerating poor behaviour, fraud or bribery means we contribute positively.
We have a zero-tolerance approach to bribery and corruption. This commitment is detailed within our Code of Conduct, which also contains our process for approval and recording of gifts and entertainment.
As a responsible company we believe that how we fulfil our obligations to consumers is important. Whether this is through our rigorous product testing and analysis or through our commitment to only market our products to adult smokers. We set high standards to meet the evolving needs of consumers and regulators, and to enable the development of new, less harmful products. Further information on ‘Our Science’ can be found on our dedicated science website.
All our business partners including all third-party agents, contractors, consultants and distributors who are employed by us are expected to work within the standards and behaviours outlined in the Code of Conduct when conducting business on our behalf.
In 2018, we introduced our Supplier Code, which is aligned to our Code of Conduct and available in 19 languages. Through our procurement processes, suppliers are required to sign up to the spirit of our Supplier Code.
Our success depends on establishing open, honest and fair partnerships with trusted suppliers. We expect our suppliers to conduct their business in an ethical and responsible manner and comply with applicable laws and regulations. We only select and do business with suppliers who can demonstrate that they operate in a manner consistent with our standards and Code of Conduct. We also expect our suppliers to ensure that their own business partners meet similar standards.
We have a rolling training programme to ensure ongoing engagement with the Code of Conduct throughout the business, including e-learning courses and face-to-face sessions. Our Code of Conduct has been translated into 30 languages, it covers many topics including Bribery and Corruption, Gifts and Entertainment and Engagement with Governments and Political Bodies. See our Code of Conduct for more information. The training for the Code of Conduct covers the content of the Supplier Code.
We encourage employees and our business partners to raise any concerns they may have. We have mechanisms in place to enable this and a Group-wide Speaking Up (Whistleblowing) Policy, which has been translated into 40 languages. Any allegations of misconduct, fraud and irregularity are thoroughly investigated. We have processes to ensure that concerns are handled consistently across the business. All investigations are conducted in accordance with our legal obligations and where possible, we will protect confidentiality. See our Speaking Up Policy for more information.
We support reasonable, proportionate and evidence-based regulation that respects adult freedom of choice.
Our goal is to effectively operate in a rapidly evolving regulatory landscape and build trust in our products, not only with consumers, but also with regulators.
Regulation of tobacco products continues to increase and is largely driven by the World Health Organization (WHO) through; the Framework Convention on Tobacco Control (FCTC), the USA’s Food and Drug Administration (FDA) and the European Union, for instance through its Tobacco Products Directive (EUTPD).
We support reasonable, proportionate and evidence-based regulation that respects adult freedom of choice and recognises that tobacco products are enjoyed by more than a billion people worldwide.
We conduct thousands of analytical tests every year to make sure our products are compliant with regulatory requirements and our own high standards which are central to how we work.
We actively participate in international method standards bodies, such as the International Standards Organisation (ISO), the European Committee for standardisation (CEN), and CORESTA (Cooperation Centre for Scientific Research Relative to Tobacco). The robust, reproducible, and repeatable testing methodology that we achieve in these forums underpins our commitment to regulatory compliance for governments, and product quality for our consumers. Further information is available on our Science website.
We are proud to work in all areas of tobacco leaf research, aiming to improve resistance to plant disease and leaf quality amongst other areas. Samples of the tobacco that we purchase are tested regularly for residues of plant protection products to ensure that our tobacco blends meet regulatory requirements, our technical requirements and the standards expected by our consumers.
Regular ingredients submissions, including toxicological information, are made to Competent Authorities based on the jurisdictions where products are sold. We ensure all materials and products are fit for their intended purpose, meet relevant specifications and comply with legislation and voluntary agreements.
We do not commission or conduct research involving animals and would not undertake such research unless formally required to do so by governments or by recognised regulatory authorities. We are committed to our position and will engage with regulators when faced with such requirements as we believe that animal testing is no longer required. Our approach is based on a ground-breaking publication released by the National Research Council USA (NRC) in 2007. Further details are available on our Science website.
Next Generation Products
We have a growing Next Generation Products (NGP) business which is underpinned by leading-edge science. We support proportionate evidence-based regulation that encourages smokers to use alternative products that have the potential for reduced harm. As vapour products do not contain tobacco, they should be excluded from all existing and future tobacco legislation, including excise. For further information, see our ‘Creating Something Better for the World’s Smokers’ report.
The illegal market in tobacco undermines society’s efforts to ensure that tobacco products are sold responsibly, protecting children and government revenues.
Illicit trade is fuelled by excessive regulation and excise increases. We are totally opposed to illicit trade. It deprives retailers of legitimate sales and governments of taxes. Counterfeit products are not made to the same high standards as legitimate products.
Organised criminal gangs participate in illicit trade, using proceeds to fund other activities to the detriment of civilised society. Criminals are also unlikely to respect laws, such as those that prevent sales to minors.
We take a partnership approach to tackling illicit trade, working with dedicated security experts, to gather and share anti-criminal intelligence, partnering with law enforcement and border control agencies, using track and trace technology and conducting forensic analysis. We work collaboratively within industry working groups and with governments through Memoranda of Understanding and co-operation agreements.
Group Security initiatives continue to support the actions of Regulatory Authorities on a global basis. Our intelligence initiatives have seen marked success this year, directly contributing to law enforcement intervention in 11 different countries and resulting in the closure of illegal production facilities, the seizure of 360 million illicit cigarettes, all alongside the dismantling of criminal gangs and the recovery of cash.
Our policy is to only supply our products to approved customers and markets. We work with customers to ensure that they are aware of our policy and their responsibilities to have control in their supply chain. To address supply chain integrity, we strictly apply a ‘Know Your Customer and Contractor’ process.