Position paper

Context

In many cultures around the world, alcoholic beverages have, since the earliest times, played an important role in social life and community celebrations.

There is also an expanding body of evidence to show that the responsible consumption of alcoholic beverages by those not at risk can be compatible with a healthy and balanced lifestyle. At the same time however, excessive or irresponsible consumption of alcohol can result in negative personal, social or health consequences.

We acknowledge that the vast majority of consumers drink responsibly, but we are concerned by the potentially negative consequences of irresponsible consumption and are committed to addressing misuse and abuse. In this regard we believe we have an important role to play in partnership with governments, NGOs and the public health community.

Advocating and encouraging responsible consumption and facilitating targeted interventions that reduce misuse and abuse are at the heart of our commitment.

Helping to create a consumer environment where moderate, responsible attitudes to consumption prevail, is a way we can contribute to addressing misuse and abuse.

In our view, no single action is likely to reduce alcohol problems and a mix of self-regulation, enforcement of existing laws governing sale and consumption, and targeted interventions, combined with individuals taking personal responsibility for their drinking choices, is the most appropriate response.
Alcohol consumption is associated with a broad range of outcomes, both positive and negative. Some are related to health, others to the social aspects of drinking. The consequences individuals are likely to experience from their drinking are a direct result of their so-called “drinking patterns”. There is growing recognition that drinking patterns are a more reliable predictor of outcomes than just the quantity of alcohol consumed, i.e. how people drink is at least as important as how much they drink.

It is necessary however to address both chronic patterns of abuse as well as the harm that may result from occasional over-consumption by those whose total consumption may not be excessive.

As a demonstration of our commitment to responsible drinking, we launched our Alcohol Manifesto with a clear set of objectives and ten policy provisions, including a stringent Code of Commercial Communication.

The Manifesto sets a consistent worldwide standard that all group companies must meet or exceed, and is integral to how we do business.

Objectives

The objectives of this position paper are:

• To provide a shared vision of SABMiller plc’s views, commitment and future outlook in relation to discouraging irresponsible drinking and to demonstrate that SABMiller understands its responsibilities in this regard as a manufacturer of alcoholic beverages.
• To provide an overview of SABMiller’s Alcohol Manifesto, which contains our principles, policies and a detailed code of commercial communications. This Manifesto applies to all companies in the SABMiller group.
• To provide a link with the SABMiller Sustainable Development strategy and overall Corporate strategy.

SABMiller commitment to responsible alcohol consumption

SABMiller is committed to promoting responsibility in the use of beverage alcohol, as part of a healthy lifestyle, while at the same time endeavouring to prevent alcohol misuse and abuse.

Our commercial communications to promote our own brands are targeted at legal drinking age consumers who have already made the decision to consume alcoholic beverages.

Our commitment to responsibility remains seamless across the SABMiller group, however we acknowledge the cultural differences that exist in the different  countries in which we operate and the differences in market structures.

Our policy commitments

In order to accomplish our commitment to responsible alcohol consumption, the following policy has been adopted by all SABMiller companies:

• In addition to complying with existing national legislation, statutory regulations and industry self-regulatory codes, group companies adhere to the SABMiller plc Code of practice for commercial communication.
• Internal compliance committees monitor and review commercial communications and ensure that these comply with the letter and the spirit of the Code.
• Wherever appropriate, SABMiller plc group companies include responsible messages in commercial communication.
• SABMiller plc group companies have an employee alcohol policy in place, which provides guidelines on responsible behaviour.
• SABMiller plc group companies take steps to educate the retail trade on the responsible use of the company's products and, in particular, to prevent the serving of underage or intoxicated patrons.
• SABMiller plc group companies take steps to educate consumers on the responsible use of the company's products and in particular on such issues as under-age drinking, and drinking and driving.
• SABMiller plc group companies encourage, where possible, efforts to collect data on patterns of alcohol consumption and associated problems, and encourage research projects that will provide data to direct efforts to combat misuse.
• SABMiller plc group companies cooperate with, and positively influence, the alcohol industry nationally and internationally to promote the responsible use of alcohol.
• SABMiller plc group companies collaborate with relevant national and international authorities, and non-governmental organisations, to develop effective controls and programmes to promote responsible alcohol use.
• SABMiller plc group companies formally report on progress made in terms of the policy. 

Our Code of Commercial Communication

Strict internal communication guidelines are fundamental to our efforts to promote responsible drinking. Our Code of Commercial Communication (CCC) regulates the way we market alcoholic beverages. It is our own internal set of standards, which means we act consistently and responsibly wherever we operate – often above the requirements of local laws and legislation.

The Code covers advertising in all media (including the internet and text messaging), packaging, promotions, product placement, merchandising, research and sponsorship.

Its guidelines support our company efforts to combat under-age drinking; for example, commercial communication may not be directed at persons under the legal drinking age (or in countries without a legal drinking age to persons under the age of 18) and the use of characters or icons with unique appeal to children is not allowed.

The Code was introduced in 2004 and has been systematically adopted throughout the company: all of our subsidiaries worldwide adhere to its rules. In addition our advertising agencies, events organisers and other related suppliers are subject to the provisions of the Code and all have to acknowledge in writing that they are aware of the Code and that they are contractually bound to follow the Code in any business which they conduct for, and/or on behalf of SABMiller.

We conduct regular training on the Code for all employees and suppliers.

In accordance with policy, robust internal compliance mechanisms are established and maintained to ensure that all commercial communication emanating from the company comports with the letter and spirit of the Code.

Managing Directors are responsible for ensuring compliance and, while the actual mechanisms might vary from market to market, a minimum standard is applied.

In several countries, SABMiller subsidiaries have also been active in developing self-regulatory codes of commercial communication for the entire industry in that specific country.

Implementation

The SABMiller Alcohol Manifesto was introduced at the beginning of calendar year 2005. All group companies are required to comply with the code and companies must produce an update, twice yearly, on their progress. New companies which join the SABMiller group as a result of mergers or acquisitions are given support and training to enable them to implement the Manifesto at the earliest opportunity.

Accountability and responsibility

• The SABMiller Executive Committee (Excom) is responsible for ensuring that effective internal controls are in place and functioning and that there is an effective risk management process in operation throughout the group.  As such, Excom is responsible for ratifying policies, strategies and position papers relating to SD.
• Supporting Excom, from a risk management perspective, is the Corporate Accountability and Risk Assurance Committee (CARAC).  This group assists the Board in the discharge of its responsibilities in relation to corporate accountability, which includes sustainable development.
• Country managing directors are responsible for ensuring compliance with the Alcohol Manifesto. They are supported by the local corporate affairs directors and marketing directors.
• Country/operation corporate affairs directors are responsible for leading the process of communicating policy through the business, collecting key performance indicators required to manage their stairway position and keeping hub corporate affairs director(s) informed about their operation’s stairway positions.
• The SABMiller plc Head of Alcohol Policy will support both the hub and country/operational teams in facilitating the above processes.