Compliance & Business Conduct

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Introduction

The JTI Group of Companies, its management and its employees are fully committed to achieving business results which are driven and supported by the highest level of integrity and in full compliance with the laws and regulations of all jurisdictions where we do business.

To support the achievement of these objectives, the JTI Corporate Compliance Function, led by the Chief Compliance Officer works hand in hand with Executive Management to identify and implement key compliance related programs and activities in accordance with JTI Corporate Governance.

Code of Conduct

The JTI Code of Conduct represents the company’s statement to its employees and to the world regarding JTI’s values and responsibilities, against which we will be measured. Although the company’s employees are from different backgrounds and cultures, they share the same values and aspirations.

Click to download the full text of the JTI Code of Conduct .

Compliance & Business Conduct Training

Training efforts are led by the JTI Corporate Compliance Function and expound on and reinforce the company’s Code of Conduct and key elements within. On a periodic basis all employees worldwide are required to take part in training provided in native languages and in a variety of formats including web based and instructor led. Additionally and on an ongoing basis the Chief Compliance Officer and his team, meet regularly with Senior Management across our worldwide operations to provide training as well as to reinforce key aspects of compliance and responsible business conduct.

Responsible Trading

JTI employs a holistic approach by strengthening and reinforcing its business practices, manufacturing and sales processes as well as internal policies and procedures relating directly or indirectly to the trade and supply of its products. At the same time, and in full alignment with its parent company, Japan Tobacco Inc, JTI fully cooperates with governments worldwide, as evidenced by the Cooperation Agreement with the European Commission and 26 Member States of the European Union, to fight against illicit tobacco product trade.

Sales Integrity Programs

JTI and its operating companies around the world are required to comply with stringent requirements surrounding the supply and sale of tobacco products. Such requirements include those that legally apply within the jurisdictions governing JTI's businesses as well as others which are mandated by JTI’s Sales Integrity Programs.

Click to download the full text of the Sales Integrity Programs

Collaboration with Governments

JT International believes that contraband and related counterfeit trade is an issue that needs to be addressed through constructive partnerships with Governments and public authorities. JTI believes cooperation is critical in that neither the tobacco industry nor governments can solve the problems associated with illicit trade of tobacco products on their own. JTI has always offered its full cooperation to government agencies in the battle against smuggling, and participated in a number of public and industry programs aimed at preventing all types of contraband and counterfeit. JTI works on a technical and an executive level with government authorities to fight contraband and counterfeit. JTI is committed to further establishing mutually beneficial cooperation arrangements with governments across the world.

As part of the aforementioned efforts, JTI signed a 15-year agreement with the European Commission and 26 Member States of the European Union on December 14, 2007. The agreement defines our cooperation to combat the illegal trade of cigarettes in the European territory. Although not one of the original signatories, in 2009, the UK Government decided to join this agreement.

The Agreement builds upon and reconfirms a number of initiatives underway at JTI and include but are not limited to the following:

A Know-your-Customer policy designed to ensure that JTI sells products to customers only who have integrity, fully comply with all local laws - as well as JTI's own stringent standards.
A Code of Conduct setting forth high standards of business conduct.
Compliance programs that address the manufacture, sale, distribution and storage of cigarettes.
Transparent payment procedures for all transactions.

Additionally JTI, and in full compliance with the Agreement will

Implement various programs which will further facilitate investigations, reporting of breaches of internal and external regulations and suspicious transactions.
Work with the authorities to establish clear processes around seizures, including measures aimed at getting to the root cause of such.
Implement a state-of-the-art Track and Trace system over the next few years. The system will allow for the tracking of products via Master Cases and Cartons and if appropriate, and in the longer term cigarette packs.

Overall, the track and trace system coupled with other efforts as noted above, will allow JTI and the authorities to tackle illicit trade at its sources of origin.

Click to download the full text of the agreement