Advocacy helps shape public policy and provides decision makers with valuable insights and data. But it can also lead to undue influence on regulations or unfair competition, to the detriment of the public interest.


Topic description

For PMI, responsible advocacy means acting in a fair, honest, accountable, and transparent manner when advocating our position in stakeholder engagements.

Why it is important to us and our stakeholders

Responsible and transparent advocacy is relevant to stakeholders because public policies are intended to be in the public interest. Society expects openness in policy-making and transparency on financial or other support provided to industry associations, trade groups, and political parties and their representatives. A sound framework for transparency in advocacy is therefore crucial to safeguarding the integrity of the public decision-making process. An organization’s participation in such processes, directly or through industry associations, must be transparent and consistent with its established public positions on the areas of public policy in question.

To PMI, the business case for advocacy and stakeholder engagement is clear and goes beyond the social license to operate. It focuses on finding solutions to current and future global challenges, raising awareness, and working hand-in-hand with major stakeholder groups while making a significant positive societal impact. Advocating our positions responsibly is important since the legislative, regulatory, and political landscapes in which we operate may affect our ability to achieve our objectives. These landscapes are shaped by the advocacy efforts of multiple types of stakeholders, including those of other businesses and civil society. A process of advocacy has the potential to create trust or erode it. Advocating responsibly carries advantages for partnership building, supports risk and reputation management, and protects our social license to operate.

Achieving our aims

Our ongoing goal is to ensure a responsible approach to advocating our positions in accordance with best practice such as the Guidelines for Multinational Enterprises and the 10 Principles for Transparency and Integrity in Lobbying, both published by the Organization for Economic Cooperation and Development (OECD). The body of knowledge on which we draw also includes the Stakeholder Engagement Manual, jointly published by the UN Environment Programme, AcountAbility, and SRA.

PMI regards stakeholder engagement as fundamental to the creation of shared and sustainable value. As such, we seek to consider not just our needs but also those of society when formulating our positions. In all cases, our advocacy work is expected to align with our Guidebook for Success and is directed by specific policies regarding anti-bribery and anti-corruption. We train our staff and third parties acting on behalf of PMI on relevant policies.

We make very few political contributions and disclose them all on our website. Those we do make are governed by strict rules concerning what contributions are appropriate, what due diligence must be conducted before making them, what disclosures are required, and, as needed, how to ensure the independence of recipients.

Our engagement principles are available on our website. We also use the site to provide clarity on our views regarding public health and other central issues. We are transparent about memberships and disclose information about our level of involvement in business and trade associations around the world. We participate in policy discussions on issues on which we have an interest or objective. We regularly interact with governmental bodies, and we work with a wide range of governmental and nongovernmental stakeholders.

Our management processes on external engagement are systematic and include audit protocols monitored using bespoke software.

The success of our business, especially as we continue to work toward a smoke-free future, depends largely on our ability to interact with others, including government officials, within the boundaries of the law and to avoid interactions that might be perceived as having an improper or corrupt intent. Hence, PMI has a very strict anti-corruption policy, which unequivocally sets the principles on how to lobby, including reporting and registration requirements. In this regard, PMI defines lobbying as direct or indirect communications with government officials to influence policies, laws, programs, positions, or policy-related actions or other official acts.

Many countries and their subdivisions have laws relating to lobbying activities as a way to promote transparency in the policy-making process and/or to regulate outside influence. PMI is committed to ensuring that all lobbying activities undertaken on behalf of the company are conducted in accordance with our standards and comply with applicable laws, including registration and reporting requirements. Any employee who may be engaged in lobbying activities or oversees the work of third parties who may be engaged in lobbying activities must comply with all applicable requirements.

This online supplement to our integrated report should be read in conjunction with PMI’s Integrated Report 2019. The information and data presented in this online supplement cover the 2019 calendar year or reflect status at December 31, 2019, worldwide, unless otherwise indicated. Where not specified, data come from PMI estimates. See About this online supplement for more information. Aspirational targets and goals do not constitute financial projections, and achievement of future results is subject to risks, uncertainties and inaccurate assumptions, as outlined in our forward-looking and cautionary statements.


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