A multilevel analysis of cross-sectional data from a survey involving 1941 pupils (in grades 10 and 11) and policy indicators developed from interviews with staff from 45 secondary schools in Wales examined the hypotheses that pupil smoking prevalence would be associated with: restrictive staff and pupil smoking policies; dissemination of school smoking policies; and implementation of smoking policies in the context of a health promoting whole school environment. The only statistically significant association found was that pupils attending schools that did not disseminate pupil smoking policy in a written document had a greater tendency (OR = 2.16, 95% CI 1.13-4.10) to smoke daily on school premises than those who attended schools that disseminated policy through a written document. This association was not significant (p less than 0.05) when pupil level covariates were included. Further research is required to identify the effectiveness and optimal content, enforcement and support of school smoking policies. (Contains 2 tables.)