Uganda- BAT Marketing Strategies

Tobacco Regulation in Uganda

There are a handful of Ugandan laws relating to various aspects of tobacco control. Primarily, these laws include: Tobacco (Control and Marketing) Act (1967), Public Health Act (1964), Constitution of the Republic of Uganda (1995), National Environment Act (1996), and the National Environment Regulations (2004). There is no comprehensive ban on tobacco advertising, sponsorship and promotion. Although there are bans on smoking in hospitals, universities, and government buildings, there is no adequate regulation in public places, restaurants, and clubs. Therefore, these regulations are limited in both scope and reach as many of them are outdated and fail to address tobacco control measures in any depth. Consequently, they are widely unenforced and much of the public is unaware that such laws even exist.

Uganda signed the WHO’s first global public health treaty, the Framework Convention on Tobacco Control (FCTC) in 2005, yet there has been no further implementation of tobacco regulation since the country ratified the Framework in 2007. After efforts to pass a Tobacco Control Bill stalled in 2012, current efforts are now focused on implementing an adequate, up-to-date tobacco control law, the Uganda Tobacco Control Bill 2014 (UTCB). If passed, the bill would “regulate the manufacture, sale, labelling, promotion, advertising, distribution, public use of tobacco products, and sponsoring of tobacco products”.

British American Tobacco Uganda (BATU) has made many efforts to stall this legislation. At present BATU widely advertise, market, and promote its products in through media, print, and sponsorships, in direct conflict with existing legislation, voluntary agreements on direct advertising with the Ugandan Government, its own International Marketing Principles and the FCTC.

This page explores the marketing techniques utilised by BATU, particularly those which target youth.

BATU and Children

A 2013 Uganda National Tobacco Control Association (UNTCA) report monitoring FCTC implementation in Uganda concluded that BATU actively sought to increase demand for their products within the underage population of Uganda, making youth the focus of their advertising and marketing at promotional events known to appeal to them.

The findings of the 2011 Global Youth Tobacco Survey, a school-based survey focusing on 13-15 year-olds, support the conclusions of UNTCA, concluding that:

• One in ten students had been offered free cigarettes by a representative of a tobacco company and the same proportion had been given merchandise with tobacco company logos on it;
• Over half had seen pro-cigarette advertising on billboards in the 30 days preceding the survey and nearly half had seen pro-cigarette advertising in magazines and newspapers.

Another monitoring report also revealed that the tobacco industry produces cigarette-shaped sweets and sells them individually by schools. By doing so, the industry markets the appeal of its product to children as studies show that children who consume candy cigarettes are more likely to become smokers. Knowing that many children in Africa who start smoking will purchase single stick cigarettes as they are cheapest, this activity also mimics the routine of buying and smoking single stick cigarettes, which can nourish an attitude of acceptance and preference toward smoking.

BATU: Forms of Marketing and Advertising

BATU has engaged in many different marketing activities to increase demand for their products. Such activities include: point-of-sale advertising, sponsorship of events, Corporate Social Responsibility as brand promotion, self-promotion disguised as consumer notices, and campaigns against illicit trade. Some of these tactics are discussed below.

Point of Sale Advertising

Point of sale advertising of BATU products is widespread across Uganda, especially in cities such as Kampala. Various brands can be seen advertised at the entryways to restaurants, clubs, and supermarkets; displayed along the roadside of busy streets; and presented in catchy displays in vendor shops and kiosks. See images below of BATU’s recent advertising in Uganda, collected as evidence for a 2013 Uganda tobacco monitoring report.

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  1. Dunhill sign at a Ugandan bar

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  2. Cigarette display at a Ugandan supermarket

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  3. Counter cigarette display at a store in Uganda

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  4. Advertising on a vehicle

Advertisement Disguised as “Consumer Notices”

Image 7. June 2014 consumer notice advertisement

Image 8. BATU consumer notice advertisement

In East Africa, BAT has recently been accused of advertising its products in places where advertising bans are implemented under the guise that they are not advertisements but communications to consumers regarding changes to their tobacco products. In June 2014, this ‘Notice to Consumers’ appeared in a Kenyan newspaper informing consumers of changes it was making to the appearance of its Embassy cigarettes (see Image 7). In a country where a display ban is in existence, this can be interpreted as advertising BAT’s cigarettes. Moreover, the advertisement is promoting single stick cigarettes, which is prohibited, as the changes being made to the product’s appearance are on the individual cigarettes (see Image 7), making the single cigarette the focus.

A similar notice to consumers in Uganda is also pictured (Image 8). In this case, the company is informing its consumers of the cost of its available brands. However, the layout and presentation of the information illustrates that BAT is maximising the opportunity to attract prospective and current consumers to its products.

Sponsorship

BAT has an established track record of sponsoring a variety of popular events. Such sponsorships have included:

Image 1. Poster for BATU’s “Think and Win” competition

• Sponsoring and chairing the Commonwealth Business Forum.

• Launching its ‘Dunhill’ brand of cigarettes at an event at a luxury resort in Uganda.

Image 2. Children at a BATU “Think and Win” promotion

• Spending $70,000 to sponsor a 10-day Jua Kali exhibition inclusive of publicity, media coverage, souvenirs, security, and hospitality.

Sponsorship at Youth Orientated Events

Examples of BATU's sponsorship of youth-oriented events include:

• BATU’s ‘Think and Win’ competition allowed any tobacco consumer of any age (children included) to enter into a raffle drawing if they purchased five single Embassy cigarettes (Image 1). The grand prize was a luxury holiday to South Africa. A promotional event for this campaign was hosted at a prime football event in Kampala, widely attended by children (see Image 2).

• Spending $70,000 to sponsor an East African trade fair in Tanzania, widely attended by Ugandans and children under the age of 18, including many school groups. The event included a BAT-sponsored VIP hospitality area.

• Sponsoring the education of over 200 students in fields including medicine, law, commerce, and engineering. .

Corporate Social Responsibility and Youth Smoking Prevention Programmes

BAT has also used Corporate Social Responsibility (CSR) events as opportunities to market its products and enhance its reputation. Despite what the company’s representatives may say in public, internal documents outline BAT’s use of CSR as a means of self-promotion. An internal document, the company’s Corporate and Regional Affairs (CORA) plan for the African region in 2001-2002, states that the aim of CSR-related activities is to:

“reassure those stakeholders who directly or indirectly influence British American Tobacco’s license to operate that the Company is meeting its commercial objectives in a manner which is consistent with reasonable public expectations of a responsible tobacco company in the 21st century.”

Image 3. BAT efforts to maintain “marketing freedoms”

The plan also calls for the identification of “suitable activity that we may undertake, outside of our own business, in order to enhance our corporate reputation.” One of these activities involves a “high profile” Youth Smoking Prevention programme.

Another internal document detailing the company’s strategy in the African region explains some of the activities intended to manage its reputation and enhance its influence in Africa:

“There are increasing challenges targeting the reputation of the industry and the company and it is crucial that the company’s reputation be managed extremely well…

“We will enhance our corporate image and influence to achieve the status of the authoritative voice on tobacco issues through:

• Building and enhancing strong relations with authorities, regulators and the communities.
• Demonstrating our positive corporate citizenship via community and other sponsorships.”

An excerpt (see Image 3) from a regional review of BAT’s Consumer and Regulatory Affairs in Africa reveals some of the actual ways the company extended its influence under the ruse of corporate relations and community engagement. For example, by seeking “government relations” and “effective community involvement programmes”, BAT was able to avoid a proposed ad ban in Sierra Leone, re-start television advertising in Kenya and Uganda, and stall a tobacco control bill in Kenya in exchange for a softer bill. The same document also suggested that BAT used its relationship with an organisation active in the community, the International Tobacco Growers Association (ITGA), to draw public attention to the value of tobacco growing on its behalf. ITGA is a known front-group of the tobacco industry, financed by multinational tobacco companies to lobby against tobacco control legislation. Although it presents itself as independently representing tobacco growers worldwide, it is intricately linked to the objectives of the tobacco industry.

Image 4. BAT Congratulatory Message as self-promotion. Source: Newvision.co.ug archives

BAT Uganda has also used media attention focused on civic engagement to promote their brand. For example, a publicised congratulatory message (see Image 4) which commends the Uganda Revenue Authority on a new Authorised Economic Operator scheme it has implemented is a cynical attempt by BATU to improve its reputation, advertising to the public that it is “one of only 10 companies in the country” selected to be part of the scheme.

Image 5. BAT’s need for evolution

A Responsible Company in a Controversial Industry

Internal documents show that in 2000 BAT hired brand promotion consultancy firm Red 14 to help BAT become a “responsible company in a controversial industry”. In slides presented to BAT, Red 14 underlined the need for the company to evolve its reputation in an attempt to shed the “highly destructive” effects of “inappropriate brand promotion” of the company in Africa, especially since “Africa is under the microscope” and such actions were under great scrutiny (see Image 5). Among other things, the slides show that highlighted benefits of this “evolution” included an “effective and sustainable Best Practice brand promotion” and “a clear demonstration of BAT’s commitment to absolute responsibility in a highly sensitive region”.

Research published by the Tobacco Control Research Group supports these findings. A paper published in November 2013 on the tobacco industry and corporate philanthropy concluded that tobacco companies primarily use CSR-related activities to secure political gains, particularly to gain access to policy makers, build community support for policy positions, constituency fragmentation, reputation and credibility enhancement, and agenda setting.” A similar paper on political CSR also details the tobacco industry’s established use of CSR to further their self-interested aims. These findings and the evidence presented here sheds significant doubt on whether BAT’s acts of CSR in Africa, including its Youth Smoking Prevention Programmes, can be considered genuine forms of giving back to the community when the evidence suggests the ultimate aim is to advance their corporate objectives.

The Bottom Line

Although BAT insists it strives to act responsibly and transparently, the above practices raise concerns of questionable business ethics and standards. In addition to this, many of these tactics are prohibited in many of the countries BAT sells its products in, are discouraged by the Framework Convention on Tobacco Control, and are in violation of the company’s own business mandates. Given the current way this evidence shows the company conducts business in Uganda, it is perhaps not surprising they have taken many extreme measures to fight current efforts to implement tobacco control legislation in Uganda.

More About BAT in Africa

For more information on BAT in Uganda and Africa, see:

• British American Tobacco Uganda.
• Uganda- BAT's Tactics to Undermine the Tobacco Control Bill
• British American Tobacco in Africa: A Past and Present of Double Standards
• A list of all TobaccoTactics pages on Africa

TCRG Resources

• Corporate Philanthropy, Political Influence, and Health Policy - G. J. Fooks and A. B. Gilmore, PLOS ONE, November 2013
• The Limits of Corporate Social Responsibility: Techniques of Neutralization, Stakeholder Management and Political CSR - G. Fooks, A. Gilmore, J.Collin, C.Holden, and K. Lee, Journal of Business Ethics, March 2012