[Intl-tobacco] UK: Select Committee on Health Second Report: IV EXPANDING INTO NEW MARKETS (fwd)

[Robert Weissman]

Select Committee on Health Second Report: IV EXPANDING INTO NEW MARKETS
Source: House of Commons, Wednesday, 6/14/00

201. The main focus of the Committee's inquiry has been the health effects
of smoking on consumers in the United Kingdom who buy their cigarettes
through the legal channels provided by tobacco companies and legitimate
retailers. However, during the course of the inquiry evidence was also
taken concerning the alleged activities of the tobacco companies in
seeking to expand their markets through two methods: by manipulating the
market in smuggled tobacco goods, both in the United Kingdom and
internationally; and by increasing cigarette consumption in the developing
world. Both issues are complex and require further investigation. They
raise issues outside the remit of this Committee; however, both activities
lead to increased cigarette consumption, especially amongst groups of
consumers who otherwise would not have access to cigarettes. The increased
incidence of death and illness, domestically and internationally, caused
by such consumption is of direct interest to us and is why we proceed to
outline the evidence presented to us and our concerns.

Smuggling

202. BAT told us that 25 per cent or more of the tobacco products consumed
in this country are smuggled into it.[352] Imperial's evidence stated that
"Cross-border trading now comprises at least 80 per cent of handrolling
tobaccos smoked in the UK, and at least 20 per cent of cigarettes".[353]
As well as the millions of pounds worth of revenue lost to the Government,
we were told that the tobacco companies were damaged by this trade, and
that they thought it was caused by differential duty rates, with the
United Kingdom having higher rates than France and other continental
countries. Mr Wilson, of Gallaher told us: "I deplore smuggling and we
will do whatever we can in order to bring it to an end. It is not in our
interests; it is not in the interests of government; it is certainly not
in the interests of the Department of Health. It is making more and more
low price cigarettes available in this country. It provides no control
over the access of children to cigarettes and it is a direct consequence
of the enormous disparity of duty rates".[354] This approach was echoed by
the representatives of Philip Morris, BAT, Imperial and R J Reynolds
giving evidence alongside Mr Wilson.[355]

Andorra

203. It had been claimed that one route used to smuggle cigarettes into
the United Kingdom was through Andorra. In March 1999, a Sunday Times
article alleged that "Andorra.... is the hub of Europe's burgeoning
smuggling trade ...  with no tax, no VAT and almost no excise it is...a
smuggler's paradise. Between 1993 and 1997, the number of British-made
cigarettes sent to Andorra ...  increased 117-fold. The tiny country
imported 3.1 billion cigarettes in 1997 - equivalent to every Andorran
smoking seven packets a day ... [Smugglers] operate by setting up front
companies in the principality or in the neighbouring countries that buy
cigarettes from British manufacturers, which are exempt from duty because
of their destination. They are then legally exported from Britain, stored
in warehouses in Andorra and then smuggled back to the United
Kingdom".[356] HM Customs and Excise subsequently told the Home Affairs
Committee that in 1996 cigarette exports from the United Kingdom to
Andorra had risen very rapidly, but by late 1997 they had "tailed off just
as quickly", following work undertaken with the Andorran and Spanish
authorities by the European Commission's anti-fraud organization.[357]

204. When it was put to Mr Wilson of Gallaher that his company's annual
report had noted the increase in sales to Andorra and that he must have
been aware that illegal smuggling had been occurring, he said that "of
course" he was aware of that, but that he was "delighted when the
authorities.... [stopped] it, but they stopped the smuggling, not us, as
we were not doing anything illegal. I was very unhappy about it. I deplore
smuggling." He also said that his company had helped the authorities'
investigations.[358]

The Amber Leaf Briefing

205. Mr Wilson's robust stance against smuggling is to be welcomed, but it
is undermined by the fact that the advertising agency employed on
Gallaher's behalf was basing part of its strategy for one product - Amber
Leaf hand rolling tobacco - on sales to bootleggers. The "Amber Leaf
Briefing" prepared by M&C Saatchi and obtained by the Committee discusses
"Trial through bootleggers" and describes "Adoption by bootleggers" as a
key issue.[359] In oral evidence Mr Moray MacLennan of M&C Saatchi, told
us that "Everyone is concerned about smuggling because it is the chief
reason for more young smoking in the last two years".[360] He went on to
say that the briefing document suggested that "what is being forced to
happen in certain instances, because of the lack of control of smuggling
in this country ... is that the tobacco companies, yes, are targeting
legal distribution methods, some of which are on the continent. They sell
it through legal distribution. Because of the lack of enforcement here in
terms of smuggling, a lot of that finds its way back into this country
through illegal distribution ... I think that really the onus is on the
Government not the tobacco manufacturers".[361]

206. Mr Wilson told us that "The tragedy and the extraordinary thing about
this whole situation is that we are here faced in the United Kingdom with
the fact that four out of every five packets of hand rolling tobacco that
are consumed in this country are sourced from outside this country. That
is 80 per cent of the market sourced from outside the United Kingdom,
predominantly Belgium and Holland. This is a direct consequence of the
enormously high duty attaching to hand rolling tobacco here compared with
Belgium. I think it is five times higher in this country than it is in
Belgium. As a consequence, a pouch of hand rolling tobacco in this country
which costs close to eight pounds will be available in Belgium for two
pounds. That has led to a situation where 80 per cent of the market is
sourced from outside this country and it leads to the ridiculous situation
where the only way that you can develop distribution for a brand in this
country is by making it available in Belgium".[362]

207. It seems that although Mr Wilson thinks it is a "tragedy" that hand
rolling tobacco is smuggled into the country, his company works on the
basis that it is prepared to sell to markets on the continent, aware of
the knowledge that the goods will be smuggled back into this country;
indeed not only are they aware, but their advertisers appear to
deliberately frame their strategy to appeal to the criminals undertaking
the smuggling. Gallaher's stance that they deplore smuggling appears to be
contradicted by their advertising which seems to want to court those doing
the smuggling. Gallaher noted in its evidence to us that smuggled tobacco
gives children access to tobacco. If they genuinely believe that this and
the other problems associated with smuggled tobacco are a "tragedy", they
should make sure that all their business practices and those of their
advertisers work against the illegal trade rather than encourage it.

Allegations regarding BAT and smuggling

208. During our inquiry serious allegations concerning BAT's involvement
in international smuggling operations were made in the Guardian newspaper.
While it was not claimed that BAT carried out the smuggling itself, it
stated that "British American Tobacco condoned tax evasion and exploited
the smuggling of billions of cigarettes in a global effort to boost sales
and lure generations of new smokers".[363]

209. The article was based on research undertaken by the International
Consortium of Investigative

Journalists, based in Washington DC. This research focused on the papers
made public as a result of BAT's legal settlement of 1998, and which are
now kept at BAT's depository in Guildford, which the Committee visited.
The papers concerning smuggling are mainly from the early 1990s. The
documents end in 1995. An additional memorandum received from ASH outlined
the background to the smuggling claims, and gave examples of the original
BAT documents on which the claims were founded. It stated that, against a
"pitched battle" with Philip Morris for control of the worldwide cigarette
market, evidence in the depository suggested that "manipulation and
control of cigarette smuggling is an integral part of company business and
expansion. The documents provide compelling evidence to suggest illegal
trade is co-ordinated and promoted at the very highest level of the
company".[364]

210. ASH's evidence further stated that a third of all internationally
traded cigarettes (335 billion in 1996) are smuggled, thereby evading
taxes and lowering the black market price. This stimulated demand, with
knock-on health effects. They alleged that "cigarettes legitimately move
through the 'in-transit' regime without bearing tax until they reach the
final end market at which point tax is payable. Most smuggling involves
the cigarettes moving out of the untaxed distribution chain and entering
the final end market illegally - often through a third country. This can
happen by legal export followed by illegal re-import or cigarettes in
transit may be diverted from the legal to the illegal distribution
chain".[365]

211. ASH claimed that while BAT's internal documents did not refer
directly to smuggled goods, the following terms were used as euphemisms:
DNP (Duty Not Paid); Transit; or GT (General Trade).[366] A background
piece in the Guardian, also published on 31 January, quoted Lee Thompson,
an RJR senior sales manager who pleaded guilty in 1999 to money-laundering
charges, as saying that DNP is "an industry-wide term... It's essentially
a long-winded term used by senior folks when they're talking around the
topic of smuggling." Thompson was quoted as saying that "re-entry",
"parallel market" and "transit" were similar euphemisms.[367] ASH's
evidence quoted a number of BAT documents which it claimed showed the ways
in which these euphemisms were used, for example:

- "In 1993, it is estimated that nearly 6% of the total world cigarette
sales of 5.4 trillion were DNP sales ... A key issue for BAT is to ensure
that the Group's system-wide objectives and performance are given the
necessary priority through the active and effective management of such
business".[368]

- "We will be consulting here on the ethical side of whether we should
encourage or ignore the DNP segment. You know my view is that it is part
of your market and to have it exploited by others is just not
acceptable".[369]

- "I am advised by Souza Cruz [BAT subsidiary] that the BAT Industries
Chairman has endorsed the approach that the Brazilian operating Group
increase its share of the Argentinian market via DNP".[370]

The claims that the terms 'DNP' 'Transit' and 'GT' were euphemisms for
smuggling were vigorously denied by BAT (see below, paragraph 219).

212. ASH also claimed that BAT engaged in 'umbrella operations' whereby a
small trade in legitimate, duty paid exports could justify a large-scale
marketing campaign to bolster sales in the much larger DNP sector. They
claimed that the following extract provided evidence of such operations:

- "It is recommended that BAT operate under "umbrella" operations. A small
volume of Duty Paid exports would permit advertising and merchandising
support in order to establish the brands for the medium/long term with the
market being supplied initially primarily through the DNP channel".[371]

The author of the three documents quoted above, Keith Dunt, was at that
time BAT's regional director for Latin America. He now sits on BAT's board
as finance director.

213. ASH claimed that the evidence demonstrated that BAT did not merely
acknowledge the existence of smuggled cigarettes, but that it deliberately
stimulated the market, not just by 'umbrella operations', but by:

- treating smuggling routes as near-normal distribution channels;

- establishing relations with intermediaries that directly or indirectly
supplied smugglers;

- controlling the price and supply of smuggled cigarettes;

- placing warehouses and marketing personnel near borders;

- organising complicated movements of goods to create difficulties in
tracing the products;

- targeting routes with weak or corrupt official controls.[372]

214. Some of the most serious allegations made concerned Colombia. The
Guardian reported that "BAT records show that billions of cigarettes were
shipped from BAT subsidiaries in the US, Venezuela and Brazil to
distributors in the free trade zone of Aruba, an island in the Caribbean
just off the coast of Colombia".[373] It was claimed that they were then
moved to Maicao or to Turbo - two special customs zones - and from there
that they were smuggled into the country's black market. Two BAT
subsidiaries supply Colombia - Souza Cruz and Cigarrera Bigott. A fax from
Keith Dunt to Laux, of Cigarerra Bigott in April 1992 stated that "I do
need to clearly understand the answers to the following:

- can we pursue the approach noted in your last strategy submission, ie
continuing with DP and DNP in parallel and be seen as a clean and ethical
company at the same time

- This "ethical correctness" would be achieved via letters to
Government...etc - can we really do this and continue DNP...

A final point I must stress to you is that it is a key, key objective for
you to achieve your company plan quoted total SOM [Share of Market] of
70.3%. This is an absolute focus for you."[374]

215. The Guardian stated that "in 1993 corporate records show that BAT
subsidiaries imported a total of 3.98bn cigarettes into Colombia. However,
3.89bn of those cigarettes entered as duty not paid goods." However, it
further stated that "since the mid 1990s legal imports of cigarettes have
risen exponentially in Colombia. Official figures show that while only
$4.6m in cigarette imports were registered in 1994, that number had leapt
to $39.9m by November 1999. In August 1999 BAT signed a letter of
commitment with the customs and tax department promising "....that if they
have any evidence that distributors to whom they sell their products are,
in turn, selling to smugglers, they will stop selling to those
distributors." It also stated that "21 state governors and the mayor of
Bogota have engaged American lawyers to prepare lawsuits in the US against
British American Tobacco and Phillip Morris". It quoted Jose Manuel Arias
Carrizosa, executive director of the federation of Colombian governors as
saying that they were seeking "an indemnification for damages caused
through contraband of cigarettes into the country ... We think there are
two markets, one legitimate that pays its duties and taxes, and the other
much bigger, illegal. That cannot be happening without the knowledge of
the producing companies".[375]

216. The Guardian published a response to the allegations by Kenneth
Clarke MP, BAT's deputy chairman, on 3 February. It stated that "BAT is a
good corporate citizen which maintains high ethical standards. We reject
allegations that we have 'condoned tax evasion and exploited smuggling'.
We seek to work with governments around the world to find solutions to the
problem of smuggling ...  It is caused by high tax levels, different
levels of tax on two sides of a border and the imposition of notional
trade barriers to legal imports." It went on to state that "where
governments are not prepared to address the underlying causes of the
problem, businesses such as ours who are engaged in international trade
are faced with a dilemma. If the demand for our brands is not met,
consumers will either switch to our competitors' brands or there will be
the kind of dramatic growth in counterfeit products that we have recently
seen in our Asian markets. Where any government is unwilling to act or
their efforts are unsuccessful, we act, completely within the law, on the
basis that our brands will be available alongside those of our competitors
in the smuggled as well as the legitimate market". The article concluded
by stating that "When governments and health campaigners are prepared to
accept policies to reduce and control smuggling, we will always welcome
such policies and co-operate with them".[376]

217. We thought that the allegations made against BAT were serious enough
to merit further questioning of the company, and so we invited Mr
Broughton and Mr Clarke to give evidence on its behalf, alongside ASH and
Mr Duncan Campbell, one of the authors of the Guardian articles.
Dismissing the general allegations about BAT's involvement with smuggling,
Mr Broughton said that the documents cited demonstrated that BAT was aware
that smuggling went on, but that it was not involved with that smuggling
in the way suggested by ASH and Mr Campbell.  He told the Committee that
"an assumption seems to be being made by Mr Campbell that knowledge of
what happens in a market is a criminal offence. I would say to you that we
do understand pretty well what happens in various markets ...  You would
expect that of a consumer goods company like British American Tobacco. So
knowing what happens in a market....and knowing [that there are] some
smuggled goods in there is hardly a surprise ... Knowledge of what is
happening in a market is not, as far as I have understood, a criminal
offence".[377] Mr Broughton also made the point that in some markets the
distribution chain was extremely complex, the inference being that it was
difficult to trace the movement of goods from beginning to end of that
chain.[378]

218. Mr Kenneth Clarke MP, the Deputy Chairman of British American
Tobacco, supported Mr Broughton's assertion that, while it was widely
known that smuggling occurred, no evidence had been produced which proved
that BAT was the "originator, the organiser, [or] a participant in that
smuggling". Indeed, he went on to say that BAT was "the victim of
smuggling ... We seek to minimise smuggling".[379] Mr Clarke later said
that "I satisfied myself that [BAT] is a company of integrity. It is an
extremely good corporate citizen".[380]

219. Relating to terminology , Mr Broughton denied that terms such as
'DNP', 'general trade', or 'transit' were "specifically euphemisms for
'smuggled'.  That is not to say that there are not times where DNP would
be the same as smuggled in one market".[381] Mr Broughton said that to
look at individual documents, or to quote small parts of individual
documents was to risk taking them out of context.[382] Mr Clarke went
further: he told the Committee that "any case which depends on taking
sentences out of eight million pages ... is absurd".[383]

220. Given the severity of the charges made against them, and their
robustness in denying them, the Committee asked whether BAT were intending
to take legal action against the Guardian. Mr Clarke said that "we did not
contemplate legal action, there has been no question of legal action"[384]
and that to bring such action would give the investigative journalists
involved credibility.[385]

221. Mr Bates of ASH said that the concerns raised merited an
investigation into BAT's conduct by the Department of Trade and Industry
(DTI). Asked whether he would welcome such an inquiry, Mr Broughton said
he would not, but that the appropriate thing would be to have BAT's own
audit committee, chaired by Mr Rupert Pennant-Rea, a non-executive
director, to look into the allegations and to "review all of our current
trading practices and ensure they are all entirely legal and that we are
entirely comfortable with those practices and that there are no
conspiracies going on between people within the company, the company, our
distributors and other people".[386] Mr Bates subsequently called this an
"important and welcome development".[387]

222. The allegations made against BAT in regard to smuggling are extremely
serious and merit careful investigation. This Committee is not the
appropriate body to conduct such investigations and would be going beyond
its remit were it to do so. We welcome the fact that BAT's audit committee
will look into this matter and we will be calling for its findings when
they are available. But this is not enough. The allegations need to be
looked at independently and we therefore call on the DTI to investigate
them. If they prove to be substantiated, the case for criminal proceedings
against BAT should be considered; if they prove to be false, then those
perpetrating them should publicly apologise to BAT for what will have
amounted to a malicious slur on the company's name.

Expanding markets in developing countries

223. The Government's tobacco White Paper notes that there are over a
billion smokers across the world, with nearly one third of those in China.
It states that worldwide deaths from smoking - currently standing at 3
million annually - will rise to 10 million in about 30 years' time. It
further notes that "smoking is fast increasing in third world countries
and in Eastern Europe ... Many of the countries in which smoking is
increasing fast have limited regulation of tobacco or health education and
health care systems which are ill-equipped to handle the consequences. In
parts of Africa tobacco companies are using advertising and marketing
campaigns, sponsorship of events and price wars to promote cut-priced
cigarettes".[388]

224. The World Health Organisation (WHO) told us that "we cannot simply
stand by and count the dead. Internationally, the WHO is taking the lead
in the United Nations in heading the development of the Framework
Convention on Tobacco Control. The Convention would address transnational
aspects of tobacco control",[389] although the WHO makes it clear that
there will still be a need for national and regional action. Dr Derek Yach
told us that while the incidence of smoking in western countries was
declining, smoking prevalence was rapidly increasing elsewhere. He said
that over the past 20 years there had been a decline of "about 1.6 per
cent of adult consumption per capita per year - compared to increases ...
of 8 per cent per year for 20 years in China, 6.8 per cent in Indonesia,
almost 5 per cent in Syria ... By the 2020s we estimate that there will be
around 10 million deaths [caused by smoking] and 70 per cent of those will
occur in developing countries ...which means we are going to face one of
the largest, if not the largest, public health challenges in the 2020s and
2030s ... This eclipses the sum total of deaths from malaria and
tuberculosis and many other causes of deaths worldwide".[390]

225. The Framework Convention on Tobacco Control mentioned by Dr Yach is a
new legal instrument that will circumscribe the global spread of tobacco
and tobacco products. The Framework Convention will establish legal
parameters;  separate protocols will make up the substantive part of the
agreement. It is expected that the Convention and possible related
protocols should be adopted by the World Health Assembly no later than May
2003. The Government has welcomed the Framework Convention and its White
Paper states that "we will do everything we can to help, drawing on our
experience of tackling tobacco, and will be discussing with the WHO how we
can most effectively be involved in this landmark initiative".[391]

226. Given the huge scale of the problem, it is alarming to note the
reaction of some tobacco companies to the WHO's actions. Mr Broughton of
BAT told his company's AGM on 29 April 1999 that "driven by the western
agenda, [WHO's] priorities are different from those of health ministers in
the developing world, for whom issues like malnutrition, lack of
sanitation, infant mortality and AIDS loom much larger ... Regrettably,
the WHO has got the smoking issue completely out of proportion with its
Tobacco Free Initiative ... Indeed the WHO seems to have been hijacked by
zealots in its desire to set itself up as some sort of
'super-nanny'."[392] This approach seems to belie the claim made in BAT's
written evidence to the Committee that it seeks "to co-operate with the
Government and public health authorities to the fullest extent reasonably
possible. The reason for this is simple. We take the view that the most
effective way of developing rational smoking and health policies is for
the industry, the Government and public health bodies to work with each
other and to engage in a free and frank exchange of views".[393]

227. The idea that developing countries were uninterested in tobacco
control was rebutted by Dr Yach. He said that the WHO represented the will
of its 192 member states and that "there is virtually no other area of
public health where there has been so much international consensus." He
went on to state that, although it was sometimes said that African
ministers accorded tobacco control a low priority, at a conference of
African health ministers held in October 1999, a range of tobacco control
options were discussed and that "in their discussions on tobacco they
acknowledged the need for action on all the areas being discussed in
western countries ... This was a relatively short meeting with a massive
public health agenda. They selected to highlight the importance of tobacco
as a public health problem because they know that somewhere down the line
they are going to face the problem and addressing it early and vigorously
is going to save enormous public resources. The truth is that wherever we
go there is not a single country where increasingly the ministries of
health and the ministries of finance are not beginning to recognise that
tobacco control makes sound public health sense and sound economic
sense".[394]

228. Mr Broughton's comments were further undermined by Zhang Wenkang,
Minister for Public Health, People's Republic of China, who stated in
correspondence to the Committee that "The Ministry of Health of China has
recognized that the effect of tobacco on health is an important public
health issue. In order to protect the health of the public, Chinese
governments at all levels have been actively facilitating the tobacco
control programme in the last twenty years .. We think that tobacco
control ... [requires the] joint efforts of all countries in the world.
Therefore, we support the Framework Convention on Tobacco Control of the
World Health Organisation".[395]

229. There are also concerns that the tobacco industry's negative attitude
towards the WHO's tobacco control objectives might go beyond words to
deeds. Dr Yach quoted a senior Philip Morris official speaking at a Philip
Morris sponsored conference in 1988, where there were also representatives
from other tobacco companies, as saying that the WHO "'has an
extraordinary influence on government and consumers and we must find a way
to defuse this and reorientate the activities to their prescribed
mandate'". Dr Yach also said that a document emerging from the conference
"discussed 'countermeasures designed to contain, neutralise, reorientate
=2E.. WHO' and stated 'the necessary resources should be allocated to stop
WHO in their tracks'".[396] Such was the level of concern felt by the WHO
at the activities of the tobacco industry, that it established an inquiry
into "the way in which WHO and the UN systems have had their policies
thwarted by the industry ... This is unprecedented ..." The World Bank has
also joined the inquiry and has nominated a top anti-corruption expert to
assist the inquiry.[397]

230. We welcome the Framework Convention proposed by the World Health
Organisation and the Government's support for it. However, any success
will be dependent on a responsible approach being taken by the tobacco
companies.  Depressingly, there is little sign of that in the cheap jibes
made at the WHO's expense by BAT. To call an organisation committed to
improving global health 'zealots' and a 'super-nanny' because of its
concern about the 10 million deaths which will be caused by tobacco each
year by the late 2020s seems to us bizarre. We hope that the other
companies - and, belatedly, BAT - will work constructively with the WHO.
On a national level, we recommend that the Government requires the British
tobacco companies to provide an annual summary of the action they have
taken to co-operate with the WHO, to which the WHO should be invited to
respond. If the action taken by the companies is not satisfactory, further
action, including legislative and fiscal approaches, should be considered.
It would be a hollow victory if, as a result of more stringent action
taken on tobacco control in the developed world, smoking related deaths
were merely exported to the world's poorer nations.

352 Q1376. Back

353 Ev., p.223. Back

354 Q1064. Back

355 QQ1065-66. Back

356 Sunday Times, 'Bootleg Britain', 7.3.99, p.12. Back

357 Home Affairs Committee, Minutes of Evidence, 25 May 1999, The Work of
HM Customs & Excise: Matters Relating to Crime, HC478, QQ131- 32. Back

358 QQ1059-1060. Back

359 Ev. p.309. Back

360 Q775. Back

361 QQ776-77. Back

362 Q1054. Back

363 The Guardian, 31.1.2000, p.1. Back

364 Ev., pp.429-30. Back

365 Ev., pp.430-31. Back

366 Ev., pp.431-32. Back

367 The Guardian, 31.1.2000, p2. Back

368 BAT Co Global Five-year Plan 1994-1998, quoted in Ev., p.433. Back

369 Letter from Keith Dunt (now BAT's Finance Director), to 'Grant' [of
Nobleza Piccardo, a BAT subsidiary], 24 June 1992, quoted in Ev., p.432.
Back

370 Memo from Keith Dunt to Ulrich Hester, Barry Bramley [Chairman, BAT Co
Industries], Pilbeam, Castro, quoted in Ev., p.432. Back

371 Note from Keith Dunt to Barry Bramley (BAT), 6 September 1992, quoted
in Ev., p.436. Back

372 Ev., p.429. Back

373 The Guardian, 31.1.2000, p2. Back

374 TB 18A, p.6, not published. Back

375 The Guardian, 31.1.2000, p2. Back

376 The Guardian, 3.2.2000, p.12. Back

377 Q1361. Back

378 Q1361. Back

379 Q1369. Back

380 Q1384. Back

381 Q1361. Back

382 Q1387. Back

383 Q1400. Back

384 Q1367. Back

385 Q1372. Back

386 Q1509. Back

387 Ev., p.483. Back

388 Smoking Kills, p.75. Back

389 Ev., p.97. Back

390 Q283. Back

391 Smoking Kills, p.79. Back

392 Speech by Mr Broughton at the BAT Annual General Meeting on 29 April
1999 (TB 28G, not published). Back

393 Ev., p.130. Back

394 Q286. Back

395 Amongst the measures adopted by the Chinese Government are: bans and
restrictions on advertising; restrictions on smoking in public places; and
a Tobacco Free Schools initiative.  See Ev., p.631. Back

396 Q269. Back

397 Q269. Back

=A9 Parliamentary copyright 2000

Prepared 14 June 2000