JTI's Internal Code and Procedures to Fight Contraband

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The Company Code of Conduct clearly sets standards for all employees covering all aspects related to contraband activities on smuggling, on money laundering and on customer knowledge.

JTI has set up procedures of customer review with an independent third party checking for accuracy.

Internal Audit

An independent team conducts regular internal audits throughout JTI's markets to check compliance with all policies and the code of conduct. Its reports are transmitted to JT company headquarters in Tokyo.

Worldwide duty-free sales policy & procedures

An updated worldwide duty-free sales policy and procedure was established setting out rules covering the whole process from customer selection and approval to the execution of sales orders. This policy is regularly monitored for compliance. Key measures include:

Client categories

The policy limits duty-free sales to only two categories of clients:
license-holding retailers (i.e. retailers duly authorized by relevant authorities to carry on business in the duty-free retail sector);
long-standing, reputable, regional or local duty-free distributors, who in turn sell to license-holding duty-free retailers or to government appointed purchasing authorities.

As a consequence of this policy and a customer review process, there has been a substantial consolidation and reduction of duty-free customers. Consequently the remaining customers consist of traditional duty-free retail operators, such as airports, cruise boats and border shops.

All duty-free sales orders are made through a centralized computer controlled system

Once approved, the details of each duty-free customer are entered into a centralized database. This computerized system controls all orders and shipments of duty-free product and is specifically designed to make any sale of goods to unregistered customers impossible.

Cigarette sales are under strict control

JTI's Customer Approval form must be completed and the original of any prospective customers' official documentation must be sent to the company before any sales can be made. An independent third party investigative firm then checks all information for accuracy.

A review committee consisting of the Regional President, the Chief Legal Officer, the Chief Compliance Officer and other Vice-Presidents then review prospective customers' files for final approval. This committee may approve, reject, revisit or even terminate existing customers who fail to satisfy the company's compliance requirements.