Confederation of British Industry

The Confederation of British Industry (CBI) is the UK’s most prominent business lobbying organisation.¹ In its own words, it aims to be the “collective voice of business”, speaking for “businesses of all sizes and sectors across the whole economy, in every UK region and nation”.² It has 190,000 members, mostly via trade bodies, though this includes 1,500 direct members.¹ It has established offices across the UK and in Brussels.³

Benefits associated with CBI membership includes access to decision makers.⁴

Relationship with the Tobacco Industry

As of September 2024, both British American Tobacco (BAT) and Imperial Brands were listed as members of the CBI President’s Committee.⁵ This committee, which is comprised of business leaders, chairs and CEOs from the UK’s leading companies, advises the CBI President and executive “on all issues of national importance.”⁶

Internal tobacco company documents published in 2010 also show that during the 1990s BAT was a paying member of the CBI and that BAT staff held key CBI posts, such as sitting on and chairing various CBI committees.⁷

Between 1995 and 1999, Martin Broughton simultaneously held the position of CEO of BAT and Chairman of the Companies Committee at the CBI. He later went on to become the President of the CBI between 2007 and 2009.⁸

Minutes from a BAT board meeting in 1996 revealed how closely BAT was working with the CBI:

“Mr Broughton reported that on Thursday, 31st October, the Confederation of British Industry would publish its report on Unitary Boards and Stakeholders, which report had been prepared by the Companies Committee of the CBI, of which Mr Broughton was the Chairman. Mr Broughton would be launching the report at a press conference.”⁹

Lobbying for EU Better Regulation with British American Tobacco

Internal tobacco industry documents have also revealed that the CBI and other large business lobby organisations worked with BAT to lobby for regulatory reform in the EU, now known as Better Regulation (BR).

In the early 2010s BR was described as a way to strengthen the effectiveness, efficiency, coherence, accountability and transparency of EU policies, whilst ensuring greater engagement of stakeholders and citizens in their development.¹⁰ BR has been interpreted in a number of ways, but it is most commonly thought of as a way of simplifying regulation, with an emphasis on ‘self-regulation’ rather than formal intervention. This commitment was formalised by the EU goal to reduce regulatory costs to business by 25%.¹¹ More recently, its has been framed as a way to help “the EU deliver evidence-based policies and laws that achieve their objectives in the most efficient way, while being tailormade to the needs of EU citizens, businesses, and civil society.¹²

BAT’s influence occurred in three stages. The CBI worked with BAT in the second stage, on an 18-month lobbying campaign to change the Treaty of Amsterdam, alongside other business lobby groups such as the Union of Industrial and Employers’ Confederations of Europe (UNICE – now BusinessEurope), as well as the European Policy Centre think tank.

1. Recruited allies and created front groups – BAT approached the European Policy Centre (EPC) to lobby for regulatory reform and recruit other corporations subject to regulation (i.e. those part of the pharmaceutical, chemical and petroleum industries). Using the EPC as a third party successfully concealed BAT’s involvement in the campaign. The number of organisations involved gave the impression to EU member states that there was great and diverse pressure for regulatory reform in the EU.
2. Secured changes to the Treaty of Amsterdam – Working with the EPC, the CBI, and other business lobby groups including UNICE, BAT established an 18-month lobbying campaign which led to changes to the Treaty of Amsterdam. These changes meant that the European Commission was obliged to consult widely on all future policy proposals and to reduce the burden of policy changes on “economic operators”, i.e. businesses.¹¹¹³
3. Nurtured a supportive policy network – BAT also collaborated with the EPC to recruit more companies and create the EPC Risk Assessment Forum. In turn, this created another business pressure group called the Fair Regulation Campaign.¹¹Both groups successfully targeted policy makers promoting Business Impact Assessment and Risk Assessment.

Despite its fundamental role in bringing about changes in how regulation is made, BAT was so successful in obfuscating its involvement that European Commission staff had no awareness that the tobacco industry was involved in the reforms, not even after they came into effect.⁷ David Byrne, Commissioner for Health and Consumer Protection 1999-2004, said in an August 2008 interview:

“I would be absolutely astonished and would find it very difficult to believe if there was any information available which tended to indicate that the European Policy Centre was advocating on behalf of the tobacco industry – that would be shocking.”⁷

Using Better Regulation Principles to Counter Regulation

BAT was very concerned about the draft European Tobacco Advertising Directive, and how tobacco companies had been excluded from assessing the impact of the Directive until after legislation had already been agreed. The company used the BR initiative to improve the industry’s position in the policy making process, and appealed to the CBI for help.

On 28 January 1998, BAT CEO Martin Broughton wrote a letter to the Director General of the CBI, Adair Turner, laying out his concerns (see Image below):¹⁴

Letter from BAT CEO to CBI Director General, 28 January 1998

Broughton asked Turner to write to the government’s Cabinet Secretary Sir Richard Wilson, suggesting:

“The letter could make it clear that business expects a full appraisal to be produced for all regulatory proposals, that the assessment should be carried out with a full and open discussion with business, and that all risk and compliance cost assessments should be made public before Ministers agree to impose or support legislation.”¹⁴

CBI Cited in Imperial’s Submission to the UK Consultation on Standardised Packaging

In its submission to the UK’s public consultation on plain packaging, Imperial Tobacco (now Imperial Brands) argued that the policy was anti-business, anti-competitive and anti-consumer. It also argued that plain packaging would have an adverse impact on the UK economy in terms of consumer choice, competition and innovation, as well as increasing the size of the illicit market.¹⁵

Imperial cited the support of “leading business groups such as the Confederation of British Industry (CBI), the International Chamber of Commerce UK (ICC), the British Brands Group (BBG) and many others” who “have expressed significant concerns about the precedent that standardised packaging would set, its potential impact on markets and the message it would send to companies looking to invest in the UK”.¹⁵

For more information on these industry arguments and the efficacy of them, see:

• Industry Arguments Against Plain Packaging
• Countering Industry Arguments against Plain Packaging

Identified as a Potential Third Party Lobby Group for PMI

In mid-2013, leaked Philip Morris International (PMI) documents revealed that the company planned a multi-faceted campaign to oppose the British government’s plans to introduce plain packaging.¹⁶¹⁷

Image from leaked PMI presentation showing potential influencers of government

The documents included a model centred around UK Prime Minister David Cameron, the “decision maker” (see Image). Cameron, depicted at the centre, is surrounded by nine “formal/informal advisors” who in turn are surrounded by a large number of “influencers” including MPs, Lords, Government departments and a series of non-governmental organisations, charities and lobby groups (see Image). Included amongst the lobby groups identified as influencers is the CBI.

For more information, see:

• PMI’s Anti-Plain Packaging Lobbying Campaign
• PMI’s Anti-PP Media Campaign

CBI Lobbies MPs Prior to House of Commons Vote

On 11 March 2015, the CBI Director General John Cridland urged MPs to vote against plain packaging in the UK. “There is a sound business case for voting against the proposals in parliament,” he wrote, adding: “We have concerns about the impact of introducing a plain packaging policy for cigarettes on the UK’s global reputation for IP [intellectual property].”¹⁸

Tobacco Tactics Resources

• EU Better Regulation
• Lobby Groups
• Lobbying Decision Makers
• Plain Packaging in the UK
• Plain Packaging in the UK: Opposition Following January 2015 Announcement
• Members of UK Parliament Opposed to Plain Packaging
• Countering Industry Arguments against Plain Packaging