Expectation

• Use plain speaking when expressing company positions on harm reduction.

 Response

We do our best to communicate in a simple and clear fashion. This is not always easy or possible when dealing with complex issues of a highly scientific and technical nature. We strive to use the right level of language depending on the audience when communicating on the issue of harm and harm reduction. We would also ask our stakeholders to help us ensure our external communications on harm and harm reduction are in plain English and express the content clearly.

 Commitments

	Following stakeholders' feedback we may consider also liaison with The Plain English Society organisation and will seek their advice on how to make the communication of our position on harm reduction more accessible and simple.
	Our "glossary of terms" on harm and harm reduction will be included on the EU social reporting website - www.batresponsibility.eu. We will report substantive comments made by stakeholders.
	Through the feedback form, we will seek stakeholders’ feedback on our social report – whether our responses and positions are clearly articulated and our commitments are formulated in a simple and understandable manner.

 Expectation

• Use the company's expertise on a long-term basis to develop harm reduction solutions.
• Collaborate with other tobacco companies on harm reduction and engage collectively where possible with other stakeholders.
• Engage not only with those working directly in the tobacco area but also with a wider range of interested parties.

 Response

Harm reduction is a key element of our product strategy. We firmly believe that we can contribute to reducing the harm of tobacco use through the development of novel products, while also supporting the long term sustainability of our business. While there are encouraging signs of increased stakeholder engagement on harm reduction, we remain committed to enlarging the scope and depth of our engagement.

British American Tobacco recognises the magnitude of the challenge of developing products that are recognised by the scientific and public health community as reducing the risks of smoking (see British American Tobacco report and accounts 2005). We will seek to engage with all interested parties from four primary areas: the scientific community, regulators, the public health community and across the tobacco industry, in order to find common ground.

British American Tobacco is an active member of all major EU based tobacco associations (CECCM, ESTA, ECMA and ESTOC). In these fora, British American Tobaccofocuses on achieving optimal results by balancing the various members' objectives with the expectations of the public and of regulators. An example of good co-operation is the debate on harmonized EU standards for ingredients reporting. The tobacco industry members of CECCM worked closely with the European Commission and proactively contributed to the development of reporting formats that provide the authorities and the consumers with appropriate and relevant information, but also protect industry trade secrets.

An additional platform for wider engagement is also through the membership of the European Smokeless Tobacco Council (ESTOC). British American Tobacco, together with other ESTOC members, is supporting the proposal of a new regulatory framework for smokeless tobacco products (including snus), which is science-based, addresses consumer protection and has food regulation as one of its guiding principles.

 Commitments

	We will report our key scientific publications on our EU social reporting website including a commentary on findings and the rationale for the work. We have a long history of scientific publications but for reasons of clarity moving forward we will list our recent publications as a starting point for scientific dialogue with stakeholders. As a matter of course we will list all of our future scientific publications.
	In Q1 2008 we will invite EU stakeholders involved in public health issues to visit our scientific facilities and will organise a panel discussion on the key scientific and regulatory challenges for harm and harm reduction. Despite the difficulties in gaining the confidence of the public health community we will not be deterred from pursuing engagement with all working in the tobacco area.
	Before the end of 2007 we will develop and share, initially with the European Commission, our views on a research agenda for Europe designed to underpin public health policy developments on tobacco regulation and comprising our proposed contribution to this process.

 Expectation

• British American Tobacco should support smoking cessation projects.

 Response

British American Tobacco believes that it is the responsibility of the public health community to lead on smoking cessation projects and programmes.

In this context, it should also be mentioned that the Tobacco Product Directive (2001/37) requires tobacco manufacturers to ensure the regular appearance of the following additional health warning (out of 14) on the back of their cigarette packs: "Get help to stop smoking: (telephone/ postal address/ Internet address/ consult your doctor/pharmacist)". British American Tobacco applies this Directive in all EU member states accordingly and in line with local legal and technical requirements.

 Commitments

	By the end of Q1 2008 we will ensure that our European Operating Companies have clear links from their websites to local sources of information on smoking cessation and quitting advice.
	By the end of 2007 we will put on the EU social reporting website all the national telephone numbers (quit lines) printed on cigarette packs as part of EU health warnings.

 Expectation

• Continue to publicise the reduced health risks of snus compared with smoking and the experience of countries where snus is used.

 Response

Our objective is to provide competent bodies and the scientific community in general with the scientific evidence available to us on the role of snus in the context of tobacco harm reduction. Currently the European Commission, aided by the Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR), is conducting a review of snus. This is in the context of the report due by end December 2007 in accordance with the Commission’s obligations set out in Directive 2001/37/EC known as the Tobacco Products Directive (TPD).

Submissions have been made to the SCENIHR committee by public stakeholders. British American Tobacco and the European Smokeless Tobacco Council (ESTOC, a trade association of which we are a member) have also submitted scientific documentation and product specific information. A preliminary SCENIHR report has been published in June 2007
(report available here) and following a consultation process the final report is expected by end of 2007.

British American Tobacco will continue to take an open and active part in Global Scientific and Public Health meetings where the topic of tobacco harm reduction is addressed. In March 2007, we presented a poster on our initial South African snus insights at the SRNT’s (Society for Research on Nicotine and Tobacco) annual meeting in Austin, Texas. As a follow up we are preparing for future participation in similar events during 2007 and 2008.

 Commitments

	We will continue to communicate to competent bodies and the scientific community the reduced health risks of snus when compared with smoking.
	We will work with others to organise a European seminar on snus and harm reduction by the end of 2007 to include a review of the findings and recommendations of the SCENIHR Committee.
	By the end of 2007 we will provide, through our EU social reporting website, access to those internet sources of information and fora which follow the scientific debate on snus.

 Expectation

• Pursue the development and promotion of non-combustible tobacco products such as snus - for some participants in the EU social reporting process, this is the harm reduction priority.
• Create new markets for snus products outside the EU.
• Expand the range of smokeless tobacco products to appeal to more smokers.

 Response

We believe we can contribute to reducing the harm inherent in tobacco consumption by, for example, extending some of our cigarette brands to Swedish style snus. As our experience with this type of product gradually increases, we also believe we may be able in the future to provide other consumer relevant cigarette alternatives with reduced risk profiles through product innovation.

Our own research and engagement with third parties has informed us, that cigarette smokers are looking for less harmful products, of which snus is an example. Therefore we are committed to look beyond snus in terms of providing cigarette smokers with relevant alternatives to choose from if they wish to reduce or stop smoking without stopping tobacco consumption entirely. We are marketing snus in Sweden, and have started sales in Norway. British American Tobacco is also continuing and gradually expanding consumer trials in South Africa and has started a limited consumer test in Tokyo, Japan. We plan to extend these initiatives elsewhere in due course.

 Commitments

	Within the next 12 months we will initiate a pilot test of Swedish snus in Canada. All new introductions of snus will be carefully monitored and we seek to develop these potential opportunities through engagement and co-operation with regulators and public health stakeholders.
	We will continue to share relevant consumer insights and information - generated from such initiatives as launching snus in Canada and potentially other markets - with authorities and competent scientific bodies in an open and transparent manner.
	Depending on our evolving learning, we will consider the potential to expand our snus portfolio not only geographically but also using additional brands and product variants.

 Expectation

• Support further research into the impact of snus on smokers' behaviour patterns and on public health.

 Response

It is our objective to reduce the public health impact of tobacco use. We believe that replication of the Swedish experience with snus in other markets has the potential to reduce substantially the health risks for smokers that switch to snus. We have a programme for introducing snus style products into other markets and are conducting consumer research to understand its acceptability for smokers and the impact it has on consumer behaviour and ultimately public health.
It clearly takes time to establish a critical and thus meaningful mass of data regarding the use of snus.

 Commitments

	We would be pleased to share with interested parties the design of our consumer research. We will publish an outline of the consumer research design on our EU social reporting website by the end of 2007.
	We will share our research findings with the Commission and its advisors no later than one year after publication of this social report. Subsequently we will share the findings of our research with other interested parties as may be appropriate.

 Expectation

• Explore the potential to reduce TSNAs in snus.
• Explore the potential health risks of nicotine in snus.

 Response

Whilst snus does not generate combustion products like cigarettes it does contain a small number of constituents of public health concern notably nicotine and TSNA's. All tobacco products and therapeutic quitting aids contain nicotine and clearly snus is no exception. There have been numerous public health reviews and publications examining its biological properties, which are well documented.

The nicotine in snus is the same as nicotine in other smoking products. Nicotine has known biological properties and at this stage no further research is envisaged. Nicotine is an inherent part of smoking pleasure and its removal from snus would render it unacceptable to consumers.

Snus, like other tobacco products contains TSNAs. These are compounds that have the potential to be formed during harvest, curing, processing and storage of tobacco and in general the industry adopts best practices to minimise their formation. In the case of snus the procedures are even more stringent in two respects, the use of a "sterilisation" process during manufacture and the setting of a manufacturing standard to ensure snus does not exceed set TSNA limits. A number of independent scientists have concluded that the current low levels of TSNAs in snus contribute to the fact that snus presents little or no oral cancer risk compared to other smokeless products with higher levels of TSNAs. It is generally accepted that the levels of TSNAs in snus are so low as to have no biological significant risk for neck, head and oesophageal cancers.

 Commitments

We will continue to track the scientific literature and the public health concerns on TSNA and nicotine content in snus and will respond accordingly. If our position changes on this matter we will report our change of view.

 Expectation

• Explore potential of techniques such as filter analysis, smoker panels, epidemiological studies and whole smoke analysis for harm reduction purposes.
• Continue to offer co-operation with independent researchers on shared harm reduction objectives.
• Develop tobacco industry proposals for future, sustainable research funding.

 Response

British American Tobacco has a comprehensive programme of research to address the issue of harm and its potential for reduction. The programme of research can be broadly divided into three categories for purposes of discussions:

1. Filter study research and programmes to estimate product yields under human smoking conditions as a contribution both to the development of methods on measuring and regulating product emissions and to the public health debate. In support of that objective, we are planning a study to monitor the smoking behaviour of Russian consumers over time and the influence of their smoking history on current product use.
2. A programme of research into the identification, development and validation of biomarkers of exposure which included clinical trials.
3. A programme of research into the development, assessment and potential validation of biomarkers of harm.

We are committed to sharing our research on these subjects through scientific publication and directly with relevant stakeholders and independent third parties. In the latter case, the tobacco control community exerts influence on independent researchers which makes it difficult if not impossible for them to work with the tobacco industry. For instance, one leading UK charity has a policy of rejecting or removing research funding for university departments that accept financial support from the tobacco industry. Scientific understanding and progress is always enhanced through debate and challenge by the scientific community and tobacco product science is no exception. We believe also that industry scientists can make a valuable contribution to the issue of product modification and harm reduction.

It is our view that research into harm and harm reduction should be part of an EU wide research agenda in order to shape public health policy on this issue.

 Commitments

We will include the issue of independent research and future funding of research and any proposals on this matter into the agenda of the "panel discussion" planned under commitment No. 5.

We will investigate possibilities for our involvement in the EU Community framework programmes for research and technological development in Europe and in the Sinapse research network*, where, if appropriate, we will contribute research know-how and scientific expertise. Information on the progress in this area will be posted on the EU social reporting website within a year after the social report publication.

* Sinapse - Scientific INformAtion for Policy Support in Europe – is a web-based communication platform established by the European Commission. It offers a set of tools to promote and encourage the effective exchange of information between all stakeholders concerned by the use of science in European governance (more information here).

 Expectation

• Include an examination of consumer behaviour in research when developing conventional, modified or reduced risk products.

 Response

Any harm reduction programme must be evidence based if it is to reduce the potential risk of tobacco product use. British American Tobacco would agree therefore that consumer behaviour must form a critical part of research in order to determine changes in smoke or constituent dose from conventional or future modified products.

 Commitments

	We believe that we have scientific knowledge and expertise in this area and will seek to publish our findings as appropriate and share these findings with the public health community and their scientific advisors.
	We will seek to drive and contribute to the design of a specific research method, to study consumer perception and potential behaviour in respect of reduced risk products, and to establish their likely acceptability and use. We would intend to discuss our approach with the scientific community and to seek recognition for the method as part of a public health impact assessment. Once such a method is available we are committed to use it and report our research findings appropriately. This approach would become an element of our proposal for an EU research agenda (see previous commitments).
	We will provide periodic updates on the progress or otherwise we achieve in communicating with stakeholders on these issues on the EU social reporting website and specific commitments that may arise through continued dialogue.

 Expectation

• Explore further the harm reduction potential of lower delivery products and smoking methods such as hookahs and products with an independent heat source.
• Take the lead in advocating the reduction of hazardous substances in all cigarettes rather than for brand differentiation.
• Focus on conventional, modified or reduced risk products most likely to appeal to consumers.

 Response

There have been in principle two major research approaches to address the issue of cigarette harm reduction to date, the general reduction approach or "low tar" programme and the selective reduction approach whereby attempts are made to reduce individual smoke constituents. Most in the public health community support the principle of the former approach but do not believe it has been achieved in practice. In the case of the latter approach there is no agreement currently on which constituents should be targeted or on the health consequences for the consumer. These concerns are critically important issues in the harm reduction debate that is needed between industry, the public health community and independent scientists.

We have a scientific and technical contribution to make on these key issues and will seek every opportunity to engage widely on these matters. We have views and technologies that could be important. However we believe that with regard to conventional products and their modification as well as the use of novel products, we should share these views and technologies with the public health community before generating products, and agree how to position and potentially communicate their properties to consumers.

 Commitments

We shall seek to develop a protocol which can demonstrate whether modified products result in reduced exposure to specific smoke constituents when used by consumers. As part of this commitment we shall: seek independent recognition of this protocol by the scientific and public health community, share the protocol as appropriate with external stakeholders and seek their feedback, apply the protocol in the development, assessment and validation of future modified products presuming acceptance by the scientific and public health community, provide information on progress in this area on the EU social reporting website no later than one year from publication of this social report.

 Expectation

• Continue to show leadership in the public disclosure of information.
• Encourage the meaningful disclosure of research findings to consumers.

 Response

It is our view that national authorities have the right to request and receive full product information disclosure whilst ensuring that such information is held in confidence. We also support the view that the consumers have the right to be informed in a meaningful way about the composition of the product they purchase and use. It is important to find a basis whereby consumers can be provided with all relevant information whilst protecting a company's trade secrets. British American Tobacco, as a member of a wide range of industry associations representing different tobacco sectors has taken a lead position in seeking an appropriate balance on product information disclosure to the European Union relevant bodies and its member states authorities, that can be communicated to consumers and believe significant progress has been made in this area.

A lot has already been done by British American Tobacco in the area of ingredients disclosure. We have launched a global website - www.bat-ingredients.com. This site provides information for consumers and governments about our Group companies' products, such as cigarettes, cigars, roll-your-own tobacco and pipe tobacco, which are sold all over the world. We have information there for brands in 121 countries (including all 27 EU member states), giving details of all ingredients added to the tobacco during manufacturing, along with other materials such as filters, paper and adhesives.

Countries such as the UK, Germany, Belgium, Switzerland and France have legislation or voluntary agreements that govern the ingredients that may or may not be used in tobacco products. For countries without published legislation, uniform standards are set for the Group based on the regulations and scientific standards typically applied to foodstuffs.

In respect of product research and disclosure to consumers there is a balance to be struck between providing meaningful information that guides consumer choice versus potentially misleading a consumer. We believe that it is most appropriate to work with the public heath community and their advisors in deciding what research information is both relevant and appropriate for consumers.

 Commitments

We will seek engagement with regulators, scientific and health community in order to identify the ways of providing consumers with meaningful information about the risks associated with tobacco consumption and potential ways to reduce them. The results of this engagement, being one of the elements of EU research agenda proposal (see commitment No. 6), will be reported on EU social reporting website on annual basis.