POINT-BY-POINT RESPONSE TO QUESTIONS PUT TO PHILIP MORRIS INTERNATIONAL BY THE BUREAU OF INVESTIGATIVE JOURNALISM

ALLEGATION: PMI RESPONSE:

The key allegation is that Response from Dr. Moira Gilchrist BSc (Hons) ignoring the rights of hundreds of millions of Philip Morris International’s Pharmacy, PhD Pharmaceutical Sciences, adults who smoke; STOP ignoring science and “transformation” and “smoke- PMI’s Vice President. Strategic & Scientific evidence that doesn’t fit with their dogma; and free” campaign is disingenuous Communication: START having a real conversation. as the majority of its profits still This dangerous and misguided campaign come from and it is “You should develop a safer product”. For has provided grants to media for journalism aggressively marketing cigarettes decades, that is what governments and that many people believe is independent. in countries with lax regulations. the public health community have told the Ultimately, this undermines the goal of harm The campaign is simply a business industry. PMI has invested billions of reduction and confuses adults who smoke strategy designed to market dollars in science and technology to achieve about better choices. And ironically, the IQOS, increase the company’s that precise objective. campaign attacks the only company that has profits and rehabilitate its image publicly committed to eliminate cigarettes. so that it can regain a seat at the A campaign coordinated by American special policy table, influence regulations interest groups, all of whom are seemingly If people who smoke are denied accurate and ensure the sustainability of its funded by the same source—Bloomberg information—or worse yet, are deceived- business. Philanthropies—are dedicated to just one -about less harmful alternatives, the vast mission. Under the guise of promoting public majority will simply continue to smoke health, they are working to rob adults who cigarettes. smoke of their right to choose scientifically substantiated better alternatives to To set the record straight we have addressed continued smoking. We have a question all of the allegations made against us by this for them: Why are they using an elaborate global campaign on our website: PMI.com. We network of organizations to deceive adults invite everyone to learn the facts, study our who smoke, elected officials, and the public science and arrive at their own conclusions. health community? We can only conclude that We have nothing to hide.” they are pursuing a disastrous prohibition- only crusade. We urge these groups to: STOP

1 1) PHILIP MORRIS INTERNATIONAL’S CONTINUED SALES OF CIGARETTES AND CONTINUED LEGAL ACTION AGAINST TOBACCO CONTROL POLICIES:

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PMI claims it wants to phase out This information is out of date. Our source: https://philipmorrisinternational. cigarettes but it sold more than publicly available 2019 fourth-quarter gcs-web.com/static-files/a8eed5ab-aac5- 740m cigarettes in 2018 and is report shows that shipment 410b-94ea-fa98bf659b0d only reducing its production by volumes decreased by 33,606 million 1% a year worldwide. units in 2019, indicating a 4.5% decline (including the effect of deconsolidating RBH)

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Its revenues from alternative This is out of date. In 2019, Reduced-Risk who would otherwise continue to smoke 2 products shot up from 0.2% in Products accounted for almost one fifth away from cigarettes have increased from 2015 to 14% in 2018, but the of total PMI Net Revenues. practically zero to almost one fifth of our majority (86%) still came from total Net Revenues. cigarettes. This growth demonstrates the strength of our commitment to a smoke-free Surely, this should be regarded as future. In just a few short years since we concrete evidence of our sincerity rather announced our commitment to a smoke than cause for cynicism from the unnamed free future, revenues from products that critics you cite? are key to transitioning adult smokers

2 “Reduced-risk products,” or “RRPs,” is the term PMI uses to refer to products that present, are likely to present, or have the potential to present less risk of harm to smokers who switch to these products versus continuing smoking. PMI has a range of RRPs in various stages of development, scientific assessment and commercialization. PMI RRPs are smoke-free products that produce an aerosol that contains far lower quantities of harmful and potentially harmful constituents than found in cigarette smoke.

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Its 2019 investor presentation As PMI—and the world—transitions away cigarettes, the sooner we can stop making state it wants to remain a ‘leader’ from cigarettes towards smoke-free them. in cigarettes. products, PMI intends to maintain its market position. Our leadership position in the cigarette market gives us greater ability to convert Our vision is that one day smoke-free adult smokers to smoke-free products products will replace cigarettes. The and generates the revenues to fund our sooner the world transitions away from rapid transformation.

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Its executives have explicitly said As PMI—and the world—transitions away cigarettes, the sooner we can stop making it will not give up market share of from cigarettes towards smoke-free them. cigarettes to its competitors. products, PMI intends to maintain its market position. Our leadership position in the cigarette market gives us greater ability to convert Our vision is that one day smoke-free adult smokers to smoke-free products products will replace cigarettes. The and generates the revenues to fund our sooner the world transitions away from rapid transformation.

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PMI has acquired tobacco We are unlikely to be interested in any multiple international markets access to companies and launched acquisition that does not further our drive KT&G’s smoke free products for the first subsidiaries since 2016 when it towards a smoke-free future. While not time; accelerating the achievement of voiced ambitions to phase out an acquisition, our recently announced PMI’s vision of a smoke-free future while cigarettes global (ex- South Korea) collaboration enabling KT&G to benefit from PMI’s agreement with KT&G is a case in point. technical, scientific and international expertise in helping adult smokers switch Through that transaction we are able to better alternatives. This collaboration to bring PMI’s resources, knowledge will benefit adult smokers by providing and infrastructure as we launch greater choice and drive accelerated KT&G’s smoke-free products outside adoption of smoke-free products South Korea. Products sold under this worldwide. Further information can be agreement will give consumers across found here.

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PMI has launched new cigarette We have always been clear about our free products for adults who would brands, flavours and limited intention to maintain leadership in the otherwise continue smoking, PMI intends editions since 2016 combustible tobacco category until all to maintain its market position. adult smokers switch to smoke-free products. Our vision is that one day smoke-free products will replace cigarettes. The In addition, 92% of our research and sooner the world transitions away from development is focused on smoke-free cigarettes, the sooner we can stop making products, as is over 60% of our commercial them. expenditure .2 Our leadership position in the cigarette As PMI—and the world—transitions away market gives us greater ability to convert from cigarettes towards providing smoke- smokers to smoke-free products.

2 See our 2018 Sustainability report https://www.pmi.com/sustainability/sustainability-report

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Since PMI announced it wanted This is misleading. But it’s equally clear that millions of men to phase out cigarettes it has and women will continue to smoke, and fought legal action against PMI agrees that tobacco products should they should have the opportunity to tobacco control policies while be subject to strict rules and enforcement. switch to better alternatives. publicly claiming it wants to At times, we have objected forcefully phase out cigarettes, a position to measures that would do nothing to https://www.pmi.com/who-we-are/our- which critics have called dissuade people from starting to smoke or views/regulation hypocritical encourage cessation.

3 2) PHILIP MORRIS INTERNATIONAL’S CONTINUED YOUTH-FOCUSED ADVERTISING AND MARKETING OF CIGARETTES:

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PMI has introduced cigarettes A number of these brands—such as • PMI only places advertising in media in coloured packaging attractive Tropical Mix and Marlboro channels, venues or events that are not to children and young people. Pacific Breeze—are not part of PMI’ directed to minors and whose audience is It has introduced flavours like product portfolio. reasonably estimated to be at least 75% Marlboro Tropical Mix, Marlboro adults. Pacific Breeze, Marlboro The others are not intended for children Double Burst, Marlboro Fusion, or young people. PMI only markets • Advertising on television, in radio Marlboro Mega Blast, Marlboro cigarettes to legal-aged smokers. broadcasts, or in cinemas only appears in Ice Blast, Marlboro Splash Mega the later evening hours. Purple, Marlboro Bright Beyond, Marlboro Vibe Beyond etc which • PMI does not use images that have appeal to children and young particular appeal to minors, including • PMI does not place advertising on people. youth-oriented celebrities or cartoons. the front or back cover of a printed publication for general circulation or • PMI does not use models who are or general circulation to the trade. who appear to be under the age of 25.

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In some countries PMI cigarettes We are committed to doing our part to and to work with them to guard against appear at point of sale to prevent underage use of nicotine and sales to underage purchasers. We have chocolates and sweets which tobacco products. developed a set of tools for our affiliates appeal to children and young to use to work more closely with their people, which violates some PMI neither owns nor has any means of trade partners to guard against sales countries’ tobacco control laws control over the vast majority of the retail to underage purchasers, such as model points of sale around the world where clauses for contracts with trade partners, people buy our products. written communication to retailers reinforcing PMI’s commitment to not However, we recognize that when we sell its products to minors and PMI’s have the opportunity—for instance with expectation that all retailers who sell PMI our direct trade partners—we have a products will comply. responsibility to set robust standards

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PMI’s subsidiary Sampoerna has These are not “youth focused” statements. local regulation and PMI’s marketing created cigarette adverts that code. appeal to children, including youth “Go ahead people” and “tapi gue jadi” focused imagery and slogans like are both campaign executions for our In addition, when it comes to in-store “Go Ahead People” or “tapi gue brand AMild. The advertising is aimed at point-of-sale materials placement, jadi” (“but I did”) representing legal-aged smokers and placement of our Sampoerna includes the youth access teenage themes of freedom adverts across different channels follow prevention program campaign materials. and rebellion. These adverts play on television, are visible on billboards and signs on shops next to schools. Logos are displayed in bars, cafes and restaurants.

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Adverts for Sampoerna and PMI This is incorrect. Neither PMI nor Following your inquiry we checked cigarettes play on children’s Sampoerna advertises or has advertised whether any of Sampoerna’s agents or channels like Cartoon Network any tobacco products on Nickelodeon the broadcasters they work with had and Nickelodeon Junior or the Cartoon Network or any other failed to meet the standards set by the channel directed at minors. law. Unfortunately, we discovered a single instance in July 2019 where an advert for Sampoerna complies fully with the a Sampoerna product appeared before applicable Indonesian law which permits the watershed, during an animated movie. television advertising for tobacco products between 9.30pm and 5.00am. This was the result of a system error by the broadcaster for which they have accepted We require, by contract, that the agencies responsibility. We have informed the we work with to do the same and to broadcaster that we will no longer be ensure that the law is fully respected by using their services with immediate effect. the broadcasters they engage.

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PMI and Sampoerna sponsor Penthouse in which people could sit on sofas, watch television, youth-focused music events Sampoerna sponsors several music festivals, none of across including play PlayStation games, and buy cigarettes. There was a Marlboro which are targeted at youth. We go to great lengths Soundrenaline, the biggest to prevent youth attending, including requiring music festival in South East “Discover Room” with interactive attendees to register online and provide their date Asia, and Djakarta Warehouse red, blue and yellow booths, project, South East Asia’s biggest echoing cigarette-pack branding, of birth, and full ID checks at the entrance. PMI only dance music festival, which was and an arcade game where sponsors events that are not directed at minors headlined in 2019 by DJs Calvin people could win prizes. Young meaning that 75% or more of the audience need to Harris, Disclosure and Skillrex attractive salesgirls in Marlboro- be reasonably expected to be adults. favoured by young people. During branded dresses roamed around Djakarta Warehouse Project the site selling cigarettes. These 2019 there was a Marlboro activities promote cigarettes to young people.

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In Argentina Marlboro cigarettes During 2019 Massalin Particulares was Even though Regulations do not prohibit were being promoted at festivals present at events such as Lollapalooza minors accessing POS where tobacco primarily targeted at young and Rock in Baradero (Events). On both products are sold, Massalin Particulares people including Lollapalloza occasions, a point of sale (POS) of tobacco implemented an age verification gate so and Rock at Baradero festivals products was implemented in strict only adults over 18 could access the POS in Buenos Aires. PMI cigarettes compliance with national law 26,687 inside the Events. Those who were under are promoted at beachfront “Regulation of advertising, promotion the legal age were not admitted. nightclubs where PMI runs and consumption of tobacco products” promotions for combinations of and with its Implementing Decree N° Regards marketing executions inside cigarettes and alcoholic drinks, eg a reduced price for a drink and a 602/2013 (Regulations). the POS located at the Events, Massalin cigarette compared to just a drink Particulares only displayed tobacco Regulations prohibit the advertising of products and engaged with legal aged tobacco products except: inside POS or smokers according to the Regulations. outlets of tobacco products or through In addition Massalin Particulares placed direct communications addressed to a hospitality spot inside its POS for its individuals over eighteen (18) years adult guests, but no purchase of tobacco old, provided their prior consent had products was required to access to been obtained and their age had been it. Lastly, Massalin Particulares never verified. Tobacco products’ display is not promoted its tobacco products associating prohibited nor regulated. them with alcoholic beverages.

5 3) PHILIP MORRIS INTERNATIONAL’S “NORMALIZATION PLAN”

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- Internal Philip Morris We are transitioning our Company, Governments make their own decisions. International (PMI) documents our industry, and the world away from 2014 obtained by Reuters cigarettes. Our communications and Just because we interact with in 2017 reveal a 10-year regulatory engagement strategy is governments, does not mean that “normalization” plan. Its completely and transparently aligned governments cannot act independently. objective was to “Establish PMI with this aim. Silencing those who disagree never as a trusted and indispensable makes sense and simply does not work. partner, leadings its sector and We understand the scepticism Open dialogue is the only way to solve a bringing solutions to the table” towards our industry and have complex problem. - The strategies and actions become accustomed to vocal involved being “for something”, mischaracterizations of how we make our Decisions on the future of public health establishing a “forward looking, views known. are often made behind closed doors motivational and credible” without any public accountability or purpose statement. To be clear, we do not “interfere” scrutiny. Where we are excluded, we with governments, we interact with work hard to ensure that our views - PMI strategized to “balance governments. are heard and we offer our opinions the debate” around nicotine by proactively. exposing “double standards” Like every other business, governments of anti-tobacco opponents and amplifying the voices of people meet with PMI to discuss a wide range To move forward in the best interests supporting harm reduction of issues, such as taxation, international of public health and adult smokers, we rather than “prohibitionists” trade and product regulation. It’s a believe that tobacco policies should element of policy making to allow continue to focus on keeping people - PMI strategized to build multiple points of view. For example, from starting to smoke and on helping on existing and foster future, when working on the FCTC, the people quit. An essential third element stakeholder relations with WHO had open hearings and received is to ensure that adults who continue to international organizations, hundreds of submissions. There wasn’t smoke have access to, and information politicians, NGOs, academics, a rule that said, “All opinions welcome so about, smoke-free products that are a scientists, researchers and the media, etc. to further long as you agree with us.” much better choice. expand communications and engagement opportunities.

- PMI strategized to make this “normalization” strategy a priority. Changing the company’s reputation should be a key objective for senior staff and communications managers.

- PMI planned to hire company ambassadors to spread this narrative and represent Philip Morris International on issues beyond tobacco.

6 4) EVIDENCE OF “NORMALIZATION” IN ACTION

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PMI has increased its media PMI is committed to a smoke-free future problem that smoking prevalence is high appearances with executives in the UK and around the world. Not within the LGBTQ+ community, a fact appearing on prominent surprisingly we communicate to media highlighted in the Government’s Tobacco television and radio shows, about our vision, mission and purpose. Control Plan for England. advertising campaigns in major newspapers, funding In 2019, we sponsored a page on the We had no editorial control of the of content with Vice (Change Gay Star News website to cover a range content created. Incorporated) and Gay Star of health issues which included the News and sponsorship of articles, videos and events with other publications.

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PMI has sought relationships with For many years the Conservative Party such a space, in order to share our ideas politicians. From 2017 - 2019 has a Conference where organisations, for achieving a smoke-free UK. For there was a PMI stand at the companies, charities can book space transparency, this stand was clearly Conservative party conference, in an exhibition hall. For the past three attributed to Philip Morris. allowing the company to promote Conferences, Philip Morris has booked its messages to British politicians and their teams.

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In July 2018 PMI held an event In 2019, Mr Ross Thomson MP sponsored The purpose of the event was to highlight in Westminster, sponsored by a room booking in , which the inequality in smoking prevalence Scottish MP Ross Thompson, to enabled us to hold a drop-in event for across constituencies in Great Britain. present how it could work with MPs. The data are available on our public MPs to “deliver a smoke-free website: https://www.smokefreefuture. future” and to provide new data For transparency, the event was clearly co.uk/smokingmapofbritain/ it had analysed on the number of attributed to Philip Morris Limited (PML). smokers in each constituency.

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PMI is a founding member PML is one of many members of UK of stakeholders on policy issues, and we of an industry group, the UK Vaping Industry Association (UKVIA). We support their work with the wider vaping Vaping Industry Association support their work to engage with a range community (UKVIA), which funds an All Party Parliamentary Group on Vaping, giving PMI access to British politicians. UKVIA has called for a relaxation of the cap on nicotine strength after Brexit among other things.

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Some British researchers have The Bureau of Investigative Journalism they have received requests to appear at reported an increase in requests would not reveal the number of PMI-affiliated events. Nor, has there been to collaborate with PMI and researchers or their identities and would a timescale over which this allegation has appear at PMI-affiliated events not provide any facts relating to the alleged to happen. This is conjecture and increase (e.g. number of occasions) that not based on facts

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Critics say the above points We are working to provide better of “normalization” misses the key point represent the normalization alternatives to smoking, which is a that the many people who will otherwise strategy in action well-recognized element of tobacco keep smoking should have access to such control. The negative characterization alternatives.

8 5) FOUNDATION FOR A SMOKEFREE WORLD

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Critics call the Foundation a According to the WHO and other health impacts from smoking. While “front group” for PMI, working to sources, a “front group” is one that masks PMI has provided initial funding, the further its interests or doesn’t properly disclose tobacco- Foundation is seeking and expects to company source. PMI’s financial support receive funding from other sources as of the Foundation is crystal clear. well. PMI and the are precluded from having any influence over So this is simply untrue. how the foundation spends its funds or focuses its activities. All inquiries about The Foundation for a Smoke-Free the Foundation’s activities should be World is an independent, non-profit directed to the Foundation. organization dedicated to reducing the

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The World Health Organization This misrepresents both the Foundation spends its funds or focuses its activities. says the Framework Convention and the Framework Convention on All inquiries about the Foundation’s for Tobacco Control guidelines Tobacco Control. activities should be directed to the are explicit that governments Foundation. should not accept financial The Foundation for a Smoke-Free or other contributions from World is an independent, non-profit It is absolutely incorrect to suggest that the tobacco industry or those organization dedicated to fund research the FCTC prohibits “contributions from working to further its interests, and encourage innovative measures to the tobacco industry”. This is a frequent such as the Foundation. reduce the harm caused by smoking, mischaracterization. Such a prohibition is to evaluate the impact that smoke-free not supported by the letter, nor the spirit, alternatives can have on smokers and of the Treaty. Treaty guidelines, such as public health, to assess the effect of those referred to here, are non-binding, reduced cigarette consumption on the as the FCTC Secretariat has made clear: industry value chain, and to measure overall progress towards a smoke-free “Guidelines constitute a non-binding world. While PMI has provided initial instrument adopted by an international funding, the Foundation is seeking and body to provide assistance to countries in expects to receive funding from other addressing specific issues at the national sources as well. PMI and the tobacco or international level.” - FCTC Secretariat, industry are precluded from having January 2006 (link) any influence over how the Foundation

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Academics say Moira Gilchrist, The Bureau of Investigative journalism which academics they refer to here and PMI’s VP of Strategic and was unable or unwilling to specify to has withdrawn this allegation. Scientific Communications approached them to sit on the Foundation’s board, calling into question its independence from PMI

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An analysis of the Foundation’s The Foundation for a Smoke-Free World any influence over how the Foundation tax returns reveals it has is an independent, non-profit organization spends its funds or focuses its activities. All spent more on hiring PR and dedicated to reducing the health impacts inquiries about the Foundation’s activities communications agencies than from smoking. While PMI has provided should be directed to the Foundation. scientific research, leading to initial funding, the Foundation is seeking critics to say it performs a key and expects to receive funding from other PMI’s funding of the Foundation is well communications function for PMI sources as well. PMI and the tobacco known and a matter of public record. industry are precluded from having

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Critics say the Foundation is The premise of the question is wrong. An to assess the effect of reduced cigarette promoting PMI’s rhetoric on element of tobacco control – including consumption on the industry value chain, harm reduction, “reduced risk” as the FCTC defines it – is that tobacco and to measure overall progress towards products and what the industry’s companies should develop less harmful a smoke-free world. While PMI has role should be in science and alternatives. provided initial funding, the Foundation policymaking without the is seeking and expects to receive funding listener/reader being aware that The Foundation for a Smoke-Free World from other sources as well. PMI and message is funded by PMI is an independent, non-profit organization the tobacco industry are precluded dedicated to fund research and from having any influence over how the encourage innovative measures to reduce foundation spends its funds or focuses the harm caused by smoking, to evaluate its activities. All inquiries about the the impact that smoke-free alternatives Foundation’s activities should be directed can have on smokers and public health, to the Foundation.

10 6) HEALTH CLAIMS AND POLICY AROUND IQOS

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Critics question why, if PMI’s Tobacco control aims to reduce the well and are more similar to e-cigarettes. stated desire to be part of the documented health effects of smoking. The ideas is to maximize the number of solution to smoking is genuine, its Many public health authorities have current adult smokers that completely flagship product Iqos is a heated acknowledged that it is the burning of stop smoking, and therefore need tobacco product, which offers tobacco that produces/releases that products that are less harmful and satisfy less harm reduction than an majority of the toxicants that cause adult smokers enough so that they e-cigarette. smoking-related diseases. complete abandon cigarettes.

Scott Gottlieb, M.D., then Commissioner The two principal categories of smoke of Food and Drug Administration (July free alternatives are heated tobacco, 28, 2017) said: “Nicotine is by no means which makes up around 70% of the a completely safe and benign compound. total international retail value of $23 But a family and population-focused billion, and e-vapor at 30%, all based approach to reducing tobacco-caused on our latest estimates. We also note disease and death must start from that heated tobacco is growing faster the premise that, as far as nicotine is than e-vapor, helped by the quality of concerned, the problem isn’t just the consumer experience and consequent nicotine. The bigger problem is the better rates of conversion away from delivery mechanism -- how the nicotine cigarettes. gets delivered. Attach it to smoke particles created by burning cigarettes In keeping with this portfolio approach, and the mechanism is deadly (emphasis we have commercialized e-cigarettes added). But attach the very same in parallel with IQOS for several years. nicotine to a medicinal product without We have recently announced that later the other chemicals found in tobacco this year we plan to launch the latest products and these therapeutic products generation of e-cigarette products, IQOS have been found to be safe and effective Veev at scale in Europe. by FDA in helping smokers quit. In fact, for nicotine replacement products Many adult smokers have used such as gum, lozenges and patches, e-cigarettes to successfully stop smoking FDA doesn’t even require a doctor’s cigarettes, but many have not. For these prescription for them.” smokers a product that more closely mimics the smoking experience (sensory, PMI also recognizes that combustion taste, ritual, etc.), may be an alternative and the production of smoke is the that can help. What is most important primary cause of smoking related disease, is that adult smokers have access to a therefore is developing a portfolio of product that they are able to switch to products that deliver nicotine without and completely quit smoking cigarettes. burning tobacco. Some of these products use heated tobacco and others do not

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PMI’s studies and independent PMI conducted targeted assessments potential toxicological concern. Based studies agree that levels of 56 of the IQOS aerosol which specifically upon published inhalation toxicology harmful and potentially harmful looked at the US FDA’s list of HPHCs. In literature, we determined that the level constituents (HPHCs) were addition, PMI performed and submitted of exposure to these compounds through lower in Iqos’ emissions than in to the US FDA the results from a non- IQOS are below the level of toxicological cigarette smoke. However an targeted differential screening of the concern. analysis by Neal Benowitz and IQOS aerosol. In this assessment over colleagues published by the 80% of the compounds were confirmed The U.S. FDA reviewed all of this data, BMJ in 2018 shows levels of 56 by reference standards resulting in as well as performing its own tests on other constituents which are not included in PMI’s or the US FDA’s 99.7% of the total mass of IQOS aerosol the product and in their technical review list of HPHCs were higher in Iqos’ being of known composition. of the Premarket Tobacco Application emissions than cigarette smoke. (PMTA) for IQOS, they stated that The authors say the impact of In the assessment 51 compounds were the “aerosol contain some chemicals these substances on the overall identified that were present at higher which are different from those found toxicity or harm of Iqos is not levels and 3 compounds that were unique in combusted cigarettes”. “Although known. Other studies also show in the aerosol of IQOS compared to some of the chemicals are genotoxic or the presence of other chemicals the smoke of the reference cigarette. cytotoxic, these chemicals are present in in Iqos emissions whose long An evaluation for the likely origins very low levels and potential effects are term health risks are unknown. of the constituents more abundant outweighed by the substantial decrease demonstrated that the majority are in the number and levels of HPHCs found either: 1) flavors that are naturally found in CC [conventional cigarettes]”. (link) in cured tobacco or added to the tobacco, or 2) plant metabolites or 3) compounds Further information can be found at: that are the result of sugar (naturally present in tobacco) transformation upon https://www.fda.gov/tobacco-products/ heating. These results were expected advertising-and-promotion/philip- since the IQOS variants are flavored, morris-products-sa-modified-risk- while the reference cigarette used for tobacco-product-mrtp-applications testing is not. https://www.pmiscience.com/ Of the compounds found that were resources/docs/default-source/news- unique to or in higher quantities than documents/pmi-tpsac_final-sponsor- the smoke of the reference cigarette, we presentation.pdf?sfvrsn=15dcce06_4 identified and reported 4 compounds of

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The World Health Organization The WHO recently withdrew this reviewed published literature and other also maintains that there is no statement. sources, the agency found that the evidence to demonstrate that aerosol produced by the IQOS Tobacco heated tobacco products or IQOS is not a cessation product, Heating System contains fewer toxic e-cigarettes are less harmful than and therefore not intended for, or chemicals than cigarette smoke, and conventional tobacco products marketed to, smokers who would like many of the toxins identified are present and conclusions cannot yet be to quit nicotine and tobacco products at lower levels than in cigarette smoke. drawn about their ability to assist all together. IQOS is designed for, and For example, the carbon monoxide in quitting smoking marketed to, adult smokers who would exposure from IQOS aerosol is otherwise continue to smoke cigarettes. comparable to environmental exposure, Based on the data up to the end of 2019, and levels of acrolein and formaldehyde we estimate that there are approximately are 89% to 95% and 66% to 91% lower 14 million IQOS users, of which over than from combustible cigarettes, 70%--close to 10 million people—have respectively.” stopped smoking cigarettes all together. This is in line with the World Health The totality of evidence available on Organization’s (WHO) “Tobacco Product IQOS supports that it presents less risk Regulation – Basic Handbook” published of harm compared to continued smoking. in August 2018, where it is recognized This evidence was submitted in support on page 7, “If overall exposure to tobacco of our applications for authorization to product toxicants is reliably lowered, commercialize the products in the US as population harm may be reduced even modified risk tobacco products. Those if large numbers continue to use these applications remain pending with the products”. FDA. This decision from the U.S. FDA to However, the U.S. FDA authorized the authorize the marketing of IQOS in the commercialization of IQOS in the US US does not mean that IQOS is safe, under the premarket tobacco product risk-free or “FDA approved.” All tobacco application pathway in April 2019 products are potentially harmful and and in its decision made the following addictive and those who do not use statements relevant to your inquiry: tobacco products should continue not to. “Through the FDA’s scientific evaluation of the company’s applications, peer-

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PMI says it is only targeting the Based on the data up to the end of Despite the conclusion the results of world’s 1.1 billion adult smokers 2019, we estimate that there are the study suggest that IQOS is, in fact, with Iqos, but an Italian study approximately 14 million IQOS users, more appealing to current adult smokers found nearly half of people who of which over 70%—close to 10 than to ex- and never smokers and these had tried the product had never million people—have stopped smoking results are in line with PMI studies in the smoked. cigarettes all together. According to the US that PMI submitted to the US FDA FDA’s PMTA authorization of IQOS for as part of their application. From which commercialization in the US: “available the US FDA concluded that the “available data, while limited, also indicate that data, while limited, also indicate that few non-tobacco users would be likely few non-tobacco users would be likely to choose to start using IQOS, including to choose to start using IQOS, including youth.” youth”

The research looked at a 3086-person Other Studies you should take into sample of the Italian population aged consideration to balance the reference to ≥15 years, and then extrapolates the the study you cite include the following: results from the sample (2009 never PMI: presented the first 2 years of data smokers, of which 20 had tried IQOS) from their cross-sectional survey … The to the entire population of 52.4 million survey shows a fairly stable tobacco use despite the fact that the authors stated prevalence, with the majority (~98.7%) that one limitation of the study is “the of IQOS users transitioning from other relative small size that does not allow us tobacco products, primarily cigarettes. to obtain stable prevalence estimates in (link) subgroups”. Sutanto et al. data showed that the This is further conflated by the fact majority of HTP users are current and that the study looked at ever-triers and former cigarette smokers, with only 1.0% intention to try, without considering how of HTP users who have never smoked many will actually start using the product cigarettes. (Int. J. Environ. Res. Public on a regular basis. Health 2019, 16, 4630) (link).

To minimize potential biases and TP (IQOS) store customers are misinterpretations of the results from predominantly current and former a study like this, it would be more smokers, with the majority having quit appropriate to express the results as a smoking. A small minority are never percentage of the total sample size and smokers who do not subsequently initiate indicate the level of precision by including smoking. (Chest Volume 155, Issue 6, confidence intervals for the various point Supplement, June 2019, Page A387) estimates. And to continue to monitor the (link) population overtime.

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Critics say PMI’s promise For PMI, the long-term business to 10 million of these fully converted not to target non-smokers or opportunity is to convert adult smokers and another 4 million in various stages teenagers is disingenuous. They who would otherwise continue to of conversion. For e-cigarettes, there are argue if PMI’s stated aim was smoke cigarettes to better alternatives. around 40 million global users, of which achieved, and it convinced its There are over 1 billion adult smokers we estimate fewer than 10 million are customers to switch to Iqos worldwide. As of December 2019, we converted. The approximate total of 20 without attracting any news ones, estimate IQOS is being used by close to million converted users represents only the company would go out of 14 million legal-age smokers, with close 2% of the world’s smokers. business once that generation of former smokers had died out. They say PMI’s business model relies on young people beginning to use Iqos to create a new market. It also functions to prevent smokers from quitting but to continue consuming PMI products instead

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Independent studies and PMI’s This is inaccurate. The FDA, commenting on PMI’s data, own data shows that rather said: “The toxicological and clinical than completely switching from Based on data up to the end of 2019, we studies do not show an increase in cigarettes to Iqos most people estimate that there are approximately HPHC exposures when consumers become “dual users” - both 14 million IQOS users, of which over are using both IQOS and [cigarettes] smoking and using Iqos. Experts 70% have stopped smoking cigarettes all and, although the decreases are not say it is likely that these users do together. statistically significant, some HPHC not receive any health benefits exposures appear to be decreased”, but PMI is clear that adult smokers who do the “available evidence shows no increase not quit and would otherwise continue in HPHC exposures for those who dual to smoke should fully switch to these use”. products.

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Dr Reto Auer and colleagues External authorities have reviewed at 330 °C in the IQOS system with set up a study to characterize the paper and concluded that the data Heatsticks and in mainstream cigarette Iqos emissions, and found many published were not considered adequate smoke at 684 °C. Although the results of the same chemicals found in for this comparison. indicated significantly elevated levels of regular cigarette smoke, and acenaphthene and formaldehyde in the higher levels of other chemicals According to the FDA: IQOS product, the chemists concluded which may be harmful to health. the data published by Auer et al. are He maintains that a process “The chemistry reviewers conducted not considered adequate for comparing of pyrolysis, producing smoke, a search of peer-reviewed literature occurs during use of Iqos. He the levels of HPHCs between the and his team maintain Iqos emits and identified eight additional studies IQOS products and CC [conventional smoke, not vapour. He says PMI reporting results of chemical analyses of cigarettes] due to analytical issues – is “dancing around” the definition “heat-not-burn” tobacco products. The specifically lack of testing reference of smoke to avoid indoor smoking individual studies are described in the samples, low number of replicates, and bans. chemistry PMTA review. Auer et al.27 a lack of sensitivity on some analytical compared the concentrations of eight methods.” (Premarket Tobacco Product volatile organic compounds (VOCs), 16 Marketing Order, Technical Project PAHs, three inorganic compounds, and Lead Review (TPL) April 30, 2019, p.21, nicotine in mainstream aerosol generated emphasis added).

15 7) IQOS MARKETING

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PMI has launched “try it for We are committed to helping those who the opportunity to ‘try before you buy.’ free” promotions across many would otherwise continue to smoke, to Under this programme, consumers pay countries. In the UK customers convert to smoke-free alternatives. For for HEETS (tobacco sticks) and they are can try the device for just £10. many smokers, switching to smoke-free given the opportunity to use the device alternatives represents a significant for a 14-day period. If they don’t return change in ritual, and to help overcome the the device, they are charged the sales barriers to switching, we provide them price.

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Dr Robert Jackler, of Stanford Experts say it is clear from the You have admitted that this report has not been contents of this report that University, has released a report published although it seems you have a copy. You documenting marketing of Iqos Iqos is not being targeted at non-smoking adults, and is have refused to provide us with a copy of the report. all over the world. The report It is not the practice of reasonable journalism to ask documents Iqos’ use of brand being targeted at the general PMI to comment on your representation of this ambassadors called coaches, population. They fear this means models, influencers, events, non-smokers could become report’s contents when we have not been able to see parties, brand affiliations and addicted to a heated tobacco the basis of these allegations, or any supporting facts stores to market the product. product, increasing their risk of or evidence. smoking-related diseases. Unnamed “experts” may make unsubstantiated comments on unpublished reports and responsible independent journalists should challenge this.

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It was revealed in May 2019 that campaign. Yet Stanford The @iqostyle.arm account is independent of PMI. researchers uncovered an PMI was using models under PMI has nothing to do with it. the age of 25 - which it against Armenian account - @iqostyle. its internal guidelines - and so it arm - which appears to be linked suspended its influencer to PMI which has continued to use attractive young influencers posting about Iqos.

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Gabriele Gzimailaite, a London- Gabriele Gzimailaite is a blogger. She was a smoker. No fee or payment was given. based blogger and Instagrammer invited to several events, between 2017 Gabriele maintained full editorial control with a following of more than and 2018. At this time, she identified as over any content she chose to publish. 120,000, was paid and/or given travel and hospitality from PMI to promote Iqos. In her blog she says she is a social smoker. Experts said PMI should not be targeting social smokers as they may become more addicted by regularly using Iqos.

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Some of the Iqos advertising, lipstick, appearing to target This “fear” is unfounded and is clearly teenagers and young women. in countries including Ukraine, scaremongering. Armenia, Italy and Japan, features Experts fear young people who may not have smoked could begin young-looking models or posts According to a study conducted under a Japanese featuring pastel-coloured Iqos’ on using Iqos, raising their risk of Ministry of Health research grant from 2017-2019, a backdrop of cupcakes and smoking-related diseases and other health effects of nicotine on 0.1% of high-school students were daily users of the developing brain. heated tobacco products.

Children should not use our product or any other tobacco or nicotine and we do not market or sell the product to them.

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Some advertising shows Iqos This is a ridiculous assertion. Adult We make clear in our communications with surfers and runners, smokers run too. Adult smokers surf too. that IQOS is not risk free and addictive. implying it is a product to suit Adult smokers are “outdoorsy”. In fact, IQOS is not a product for non-smokers. healthy, outdoors-y lifestyles adult smokers do all the things non- when in fact it has health risks for smokers do. non-smokers.

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PMI adapts its message for each Spot: a place where you can use The post you refer to is not connected with PMI or Iqos while quitting”. A post from country’s culture and regulations. its affiliates. We did not make this claim. While in the US PMI is forbidden Iqos’ Instagram page in Japan from claiming Iqos is a smoking promotes Iqos as a way to avoid cessation device, in Japan Iqos lung cancer, emphysema and adverts make explicit health myocardial infarction. Public claims things like “Iqos health experts said PMI does not have the evidence to make this claim

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PMI has already faced regulatory The Department of Health (DoH) wrote featured in the posters. action due to its marketing of to us regarding some of our posters In 2017 Moscow division of the Federal Iqos. In 2018 the UK Department displayed in shop windows. This was Antimonopoly Agency fined the local of Health wrote to the company on the back of a Telegraph article in affiliate for using Internet banner ads ordering it to take down posters which our activities were described leading to the IQOS website where in shop windows describing Iqos as, “marketing [IQOS] as a healthier heated tobacco sticks were sold. PM as “healthier” than cigarettes and alternative to cigarettes.” This is not Russia is no longer using such banners. hosting pop up displays at public language used by PML and neither events. In 2017 Russia’s Moscow Federal Agency fined PMI for promotion of Iqos

17 8) PHILIP MORRIS INTERNATIONAL’S LOBBYING OUTSIDE THE UK

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PMI has embarked on a global We are vocal and transparent: We are stakeholders with significant lobbying campaign to prevent Products like e-cigarettes and heated expertise and will continue to actively Iqos from being banned and to tobacco products should not be banned. partake in democratic processes so our ensure Iqos is taxed at a lower They should be regulated in a way that voice is heard. rate than cigarettes, including will allow adult smokers to have access launching legal action in order to, and accurate information about them We are just one stakeholder and can only to sell Iqos in Mexico. It lobbied so they are encouraged to switch to hope that our arguments are heard and senators of the Ways and Means them rather than continuing to smoke. fairly and objectively assessed by those committee in the Philippines In some countries, laws never really who make decisions. for a tax band for Iqos that was 95% lower than cigarettes, contemplated these innovative smoke- which it claims is proportionate free alternatives, and this is the reason Please take note that we do not claim that to the reduced risk. It has they can unintentionally constrain better our products reduce risk by 95%, the new conducted meetings with consumer choice. tax law in the Philippines differentiates government officials in Vietnam tobacco products based on combustion, and also lobbied the Argentinian We advocate for appropriate, non- or the lack of it, and we commercialized government (which has banned discriminatory and risk-proportional IQOS in Mexico under existing applicable heated tobacco products) to regulation in all product spheres laws. lower the taxes on the Iqos including where taxation is concerned. device.

18 PHILIP MORRIS INTERNATIONAL’S LOBBYING IN THE UK

PMI supports the Government’s framework that ensures adult smokers commitment to make England smoke- have the facts about alternatives and that free by 2030. To realise this ambition, tobacco companies are pushed to phase millions of current adult smokers need to out cigarettes. We have made this point be persuaded to quit altogether or switch time and time again to MPs, civil servants, to less harmful alternatives. Critical to local councilors, journalists and the this will be putting in place a regulatory broader public.

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In the UK PMI has offered to PML made a clear commitment in a three national newspapers. We followed fund local authority smoking 2018 New Year advertisement (available up on this commitment by contacting the cessation services, which was here) to offer support to Local Authority local authorities with high prevalence rebuffed by then-health minister cessation services where smoking rates rates. Steve Brine, who said he did are highest. This advert was placed in not believe such a partnership would be “ethical” and deemed any further meeting with PMI as “inappropriate”. Despite this, PMI has since contacted local authorities directly with its proposal.

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During a meeting with A PML representative went to a meeting prioritized. They told us what mattered to public health officials at the with officials from Windsor Council to get them and we relayed other experiences Royal Borough of Windsor their perspective on the smoking issues that other Councils are going through. and Maidenhead, PMI in their community which need to be representatives discussed the possibility of doing some work around smoking cessation in schools. A PMI representative explained that having had “a couple of initial conservations with other councils’, it was still ‘in the development stage of how a partnership could work.”

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In email exchanges with officials Burnley Council reached out to PML in reports, our science (publically available) at Burnley council, PMI shared response to our letter after our New Year and reports we commissioned from images of a “quit/switch mobile advertisement. There was a meeting and Frontier Economics. We also included cabin” and a PMI report on as part of the follow up to this, a number an early stage mock-up of a ‘Quit/Switch’ the role of heated tobacco in of documents were requested, so we cabin. reducing smoking rates. shared links to Public Health England

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In 2018, PMI claimed to have had “partnering to end smoking Yes. This was communicated in correspondence locally”. more than 40 approaches at the to Burnley Council. We are happy to share this Local Government Association It has also contracted C|T information. Conference, during some of Group, a lobbying firm run by Sir Yes, we tasked C|T Group to write to some local which it was discussed potentially Lynton Crosby, to contact local authorities on its behalf. authorities reiterating PML’s offer to engage.

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In one letter, a C|T Group responsibility for public health Yes. As above, this was reiterating the offer PML had and smoking cessation services consultant said: “PML [Philip already made publicly. Morris Limited] are looking to to explain what they are seeking meet with representatives from to do and in what ways they can Local Authorities with the help to reduce smoking rates in local areas.”

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Leaked internal emails show Philip Morris supports the Government’s framework that ensures smokers have Philip Morris attempting to use commitment to make England smoke- the facts about alternatives and that this offer of local funding as a free by 2030. To realise this ambition, tobacco companies are pushed to phase way to leverage weaker rules millions of current smokers need to be out cigarettes. We have made this point on advertising heated tobacco persuaded to quit altogether or switch time and time again to MPs, civil servants, products. to less harmful alternatives. Critical to local councilors, journalists and the this will be putting in place a regulatory broader public.

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PMI funded a Westminster and attended by its lobbyist The event was organized by Public Policy Projects James Barrow. By not disclosing reception in September 2019 (PPP). They have told us that Philip Morris’ hosted by Public Policy Project, PMI’s sponsorship of the event, public health officials attending sponsorship of the reception was made clear to an advisory firm run by former anyone interested in attending, ahead of the event. Conservative health minister unwittingly breached article 5.3 of Stephen Dorrell. It was not the World Health Organisation’s disclosed to attendees, which Framework Convention on included local authority public Tobacco Control, which ensures health chiefs, stop smoking policies are protected from officials and NHS staff, that the commercial and other vested event was sponsored by PMI interests of the tobacco industry.

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Philip Morris has been accused internal Philip Morris document, It is absurd to call our campaigning for a smoke-free previously reported on by of running a secretive campaign future “secretive”. We are open about our science, around the world to block or Reuters in 2017, the company sees it as a “regulatory runaway our communications and our ambition to replace weaken provisions in the treaty, cigarettes with better smoke-free alternatives. which is designed ultimately to train” driven by “anti-tobacco protect public health and save extremists”. lives. According to a 2014 Regarding the treaty, we believe that open dialogue is the only way to solve a complex problem. Decisions on the future of public health are often made behind closed doors without any public accountability or scrutiny. Where we are excluded, we work hard to ensure that our views are heard and we offer our opinions proactively.

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