Imperial Tobacco

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Background

Imperial Tobacco is a transnational tobacco company that is headquartered in Bristol, United Kingdom (UK). It is the fourth largest tobacco company in the world, after Philip Morris (PMI), British American Tobacco (BAT), and Japan Tobacco International (JTI), and excluding the Chinese National Tobacco Corporation (CNTC).[1]

Its parent company, Imperial Tobacco Group was rebranded to Imperial Brands in February 2016, and consists of the following companies: Imperial Tobacco, ITG Brands, Logistic, Tabacalera, and Fontem Ventures (and within it e-liquids manufacturer Nerudia).[2][3]

The company has no relationship to Imperial Tobacco Canada, which is a subsidiary to BAT.

In 2016 Imperial Tobacco operated in 160 countries, selling cigarettes, Roll Your Own (RYO) tobacco, smokeless tobacco, cigarette paper, and cigars.[4] Its main brands are Davidoff, Gauloises Blondes, JPS, West, Fine, News, Winston, Bastos, Lambert & Butler and Parker & Simpson.

The company’s key markets are the Unites States (US), Germany, Australia, Spain and the UK.[5] Imperial used to be the UK’s cigarette market leader, but lost that position in 2015 to JTI.[6]

Employees or Board Members: Past and Present

A full list of the company’s leadership team can be accessed at Imperial’s website.

In February 2020, the company announced that Stefan Bomhard would be appointed as the Chief Executive of Imperial Brands on a five-year contract.[7] Bomhard previously held leadership roles at various multinational companies including Bacardi Europe, Cadbury and car dealership Inchape.[8] Two Imperial division directors, Dominic Brisby and Joerg Biebernick, were designated to share the interim chief executive duties until Bomhard took up his role on a date yet to be announced.[7]

Over the course of 2019, Imperial Tobacco underwent significant changes in leadership. On 3 October 2019, it was announced that Alison Cooper, Imperial Tobacco’s Chief Executive since May 2010, would step down “once a suitable successor is found”.[9] The announcement came after the company issued a profit warning that reduced the company’s anticipated revenue growth.[10]

At the start of the year, Imperial Tobacco had announced that it was seeking a new Chairman to replace Mark Williamson.[11] On 5 November 2019 the company announced that Williamson will be succeeded by Thérèse Esperdy, effective 1 January 2020.[12]

Other people that currently work for, or have previously been employed with, the company:

Roberto Ascoli | Drago Azinovic | Arthur van Benthem | Ken Burnett | Sue Clark | Helen Clatworthy | Fernando Domínguez | Robert Dyrbus | Gareth Davis | Louise Day | Kevin Freudenthal | Roberto Funari | David Haines | Michael Herlihy | Nikos Mertzanidis | Peter Middleton | Almos Molnar | Susan Murray | Iain Napier | Matthew Phillips | Walter Prinz | Michiel Reerink | Richard Ross | Berge Setrakian | Alessandro Tschirkov | Mark Williamson | Titus Wouda Kuipers | Colin Wragg | Malcolm Wyman | Waldemar Zegar

Affiliations

Memberships

In 2017, Imperial Tobacco was a member or supporter of the following organisations:

Asia Pacific Travel Retail Association (APTRA)[13][14] | Associate Parliamentary Corporate Responsibility Group | Association of Convenience Stores (ACS) | Confederation of European Community Cigarette Manufacturers | Euraffex/ European Affairs Expertise[15] | European Cigar Manufacturers Association (ECMA) | European Rolling Papers Association (ERPA)[15] | European Smoking Tobacco Association | European Travel Retail Confederation (ETRC) | Industry and Parliament Trust (see Rosemary Brook)[16] | Kangaroo Group | MARQUES | Public Affairs Council[15] | Tobacco Industry Platform | Tobacco Manufacturers' Association | Wirtschaftsrat[15]

The company was also a member of the Eliminating Child Labour in Tobacco-Growing Foundation (ECLT).[17] The ECLT has a partnership with the International Labour Organization (ILO), a United Nations (UN) agency, focussed on issues related to labour such as international labour standards, social protection and unemployment.[18]

Imperial is a member of the following e-cigarette trade associations, as Fontem Ventures and its e-cigarette brands]]: UK Vaping Industry Association (UKVIA), Vape Business Ireland, France Vapotage and VITA of Canada.

Imperial Tobacco used to be a member of:

British Chamber of Commerce in Belgium (in 2013/14) | BusinessEurope (in 2013/14) | European Smokeless Tobacco Council (appears defunct in March 2017) | Institute of Business Ethics (in 2011)[19]

Consultancies

Imperial Brands has worked with the following public relations companies:

  • Aspect Consulting lobbied for Fontem Ventures in the UK in 2017[20]
  • Bell Pottinger lobbied for Imperial in the UK and Brussels from 2010 to 2016[21][22][23][24][25][26]
  • FTI Consulting named Imperial Brands on its client list in 2016[27]
  • In 2019, Fontem Ventures was listed on the UK lobbying register as a client of David Alexander, Director of UK Sports PR agency Calacus.[28]

Think Tanks

In May 2012, the Tobacco Control Research Group (TCRG) at the University of Bath asked Imperial Tobacco to disclose which think tanks the company was funding, and had funded over the last few years. The company replied that it did "not wish to participate in your research".[29]

In response to a specific query made in 2014 in regards to Imperial Tobacco’s engagement with the Institute of Economic Affairs (IEA), a UK-based right-wing think tank, Imperial's Head of Regulatory Science, Steve Stotesbury, replied: “We [Imperial Tobacco] have been supporters of the IEA for many years, stretching back well over a decade”.[30]

Imperial Tobacco also held historical links with the Democracy Institute, a think tank based in the UK and US. In 2006 the company funded a book published by the Democracy Institute, which argued there was no evidence that graphic health warnings on tobacco, food, and alcohol packaging would work.[31]

Controversial Marketing Strategies

Targeting Women and Girls

In 2011, the tobacco industry introduced cigarette packs to the market that were specifically designed to attract female consumers.

Imperial Tobacco launched its Richmond SuperSlims, promoted as “the first superslim brand in the value-price cigarette sector”.[32] At the time, The Grocer retail magazine reported that the pack was embossed with a "stylish pink design", and that it was "clearly designed to appeal to female smokers".[32]

It is worth noting that plain packaging legislation introduced in Australia in late 2012, and in the UK in May 2016, does not address the size of the cigarette stick and its use as a marketing vehicle to target specific consumer demographics. The legislation bans slim cigarette packs, but not slim individual cigarette sticks.[33][34]

  • For more information on tobacco companies' efforts to market its product to female consumers, go to Targeting Women and Girls.
Image 1. Screen grab of Peter Stuyvesant packaging Australia September 2012. Screengrab from the Telegraph, http://www.webcitation.org/6Afiop1PT (archived webpage)

Pre-empting Plain Packaging Legislation in Australia

In September 2012, a few months before plain packaging legislation was introduced in Australia, Imperial Tobacco Australia changed the packaging of its Peter Stuyvesant cigarette pack to show a ripped pack exposing plain packaging underneath (see image 1).[35][36] The accompanying slogan said “it’s what’s on the inside that counts”.

The Australian Health Minister criticised Imperial’s marketing campaign, saying that “diseased lungs, hearts, and arteries are the reality of what is happening on the inside to a smoker”.[35]

Complicity in Tobacco Smuggling

Imperial Tobacco has claimed that tobacco control legislation, in particular plain packaging, might lead to unprecedented levels of illicit tobacco trade. The company has made these claims in its Submission to the 2012 UK Consultation on standardised packaging and its Submission to the 2014 UK Consultation on standardised packaging. In 2016, ahead of the introduction of plain packaging in the UK, Imperial Brands launched a ‘Suspect it? Report it!’ anti-illicit trade campaign.

In January 2017, Imperial Tobacco collaborated with the National Federation of Retail Newsagents (NFRN) to “educate independent retailers and UK smokers about the growing trade in illegal tobacco”.[37] The collaboration saw 50,000 packs branded with Imperial’s ‘Suspect it? Report it!’ campaign distributed to retailers, containing infographics, posters and stickers.

In contrast to Imperial's campaign, which portrays the tobacco company as the victim of illicit trade, there is strong historical evidence of Imperial Tobacco’s complicity in facilitating the smuggling of their own cigarettes. For example, genuine Imperial Tobacco brands accounted for more than half of the 17 billion cigarettes smuggled into the UK in 2002.[38] The company claimed ignorance when it was questioned about over-supplying countries notorious for smuggling at the Commons Public Accounts Committee, to which Imperial Tobacco’s chief executive was told: “One comes to the conclusion that you are either crooks or you are stupid, and you do not look very stupid.”[39]

Internal documents from Gallaher (now part of JTI), released through litigation, refer to Imperial Tobacco's “highly aggressive" smuggling activities in the 1990s, blaming Imperial’s smuggling for Gallaher's weakening position in the UK market.[40]

Tactics to Subvert Tobacco Control Campaigns and Policies

Imperial Tobacco has strongly opposed tobacco control legislation and regulations, including plain packaging in Australia and the UK, and the Tobacco Products Directive (TPD) in the European Union (EU). The company has used a variety of strategies and tactics to influence tobacco control policies, and subvert existing regulations.

Discrediting Science and Scientists

The tobacco industry has long tried to undermine science and legitimate anti-tobacco messages from scientists to get around, weaken, or discredit tobacco control legislation. According to one tobacco executive, "doubt" was the best means "to compete with a body of fact and establish controversy”.[41]

In 2011, Imperial Tobacco strongly criticised a study commissioned by the UK Department of Health,[42] which concluded that England’s smoke-free 2007 legislation had positive benefits for public health. The study also concluded that the legislation had no obvious negative impacts on the hospitality industry, contrary to claims made by the tobacco industry.[43]

Imperial Tobacco criticised the three-year review as being "lazy and deliberately selective", and furthermore accused the study’s author, Professor Linda Bauld, of having a conflict of interest due to her links to the charity Action for Smoking and Health (ASH).[44]

  • For further information on Imperial Tobacco’s attempts to discredit Professor Bauld, and the subsequent hate campaign by others that followed, visit our page on Professor Linda Bauld.

Using Freedom of Information Requests to Counter Health Campaigns

In February and March 2011, acting on behalf of Imperial Tobacco, Bell Pottinger, persistently requested access to research data that supported an anti-RYO tobacco health campaign run by a regional charity.[45][46]

  • For more information on Imperial's vexacious Freedom of Information (FOI) requests, go to the FOI: SmokeFree South West page.

Fabricating Support through Front Groups

Imperial Tobacco has used front groups to oppose tobacco control legislation. Front Groups are organisations that purport to serve a public cause while actually serving the interests of a third party, and obscuring or concealing the connection between them.[41]

For example, Imperial Tobacco Australia (in collaboration with PMI and BAT) financed the Alliance of Australian Retailers (AAR) to oppose the introduction of plain packaging in Australia.[47] The AAR claimed to represent the owners of local corner stores, milk bars, newsagents and service stations, but did not reveal that it was financed by tobacco companies and run by tobacco company executives and a public relations company.[48] The purpose of the AAR was to argue that plain packaging would cause economic damage to small Australian retailers.

Image 2. Imperial Tobacco cover of The House magazine in plain packaging, June 2012

Corporate Political Advertising

In June 2012, Imperial Tobacco attempted to influence UK Members of Parliaments’ (MPs) views on the plain packaging debate by running an anti-plain packaging advertising campaign in The House magazine, a magazine designed for MPs (see image 2).[49] The company did not reveal itself as the funder anywhere on the front page advertisement.

Hospitality for UK Politicians

In 2014, Imperial Tobacco gifted Wimbledon tennis tickets to Members of Parliament (MPs) Aidan Burley, Mark Field, and Mark Pritchard.[50]

Imperial Tobacco also gifted Wimbledon tickets to Lord Pendry in 2005, 2008 and 2012.[51][52][53]

In the 1990s, the tobacco company provided the following hospitality to MPs:[54]

  • Jacqui Lait MP and her husband attended the 1999 Scotland v England rugby match courtesy of Imperial Tobacco
  • MPs attended a 1998 and 1999 Lords v Commons Clay Pigeon Shoot at Highclere Castle sponsored by Imperial Tobacco
  • Conservative MPs Ian Taylor and John Townsend attended the 1997 rugby international England v New Zealand at Twickenham, courtesy of Imperial.
  • In 1995, Imperial gifted a lunch and two tickets for the Men’s Singles final at Wimbledon to Liam Fox, at the time the MP for North Somerset

Our page on Tobacco Industry Hospitality for UK Politicians provides more detail on gifts and hospitality provided to MPs and peers by Imperial Tobacco and other tobacco companies.

Direct Lobbying of Decision Makers: Access to Confidential Information

Political lobbying is legal in most countries, and an acknowledged part of the democratic process. In the financial year 2014-2015, Imperial Tobacco reported to have spent €400,000 - €499,000 lobbying EU institutions, employing five fulltime equivalent staff in its Brussels office.[15]

Lobbying disclosure records by Conservative Members of European Parliament (MEPs) show, that in 2011 and 2013 Imperial Tobacco met with UK MEPs Giles Chichester, Ashley Fox, Emma McClarkin, and Anthea McIntyre to discuss the revision of the TPD.[55][56][57]

Imperial Tobacco and other tobacco companies were given several opportunities to share their views on the TPD review with the European Commission’s Health directorate, DG SANCO, and Health Commissioner John Dalli.[58][59] But Imperial Tobacco also lobbied other directorates on the TPD. In 2011, Bell Pottinger tried to broker access to officials in DG Trade and the Secretariat General on its behalf (for more details see Bell Pottinger and Tobias Ghersetti pages). In July and September 2012, Imperial Tobacco attended meetings with DG ENTR (Enterprise and Industry) as part of a delegation with CECCM,[60][61] and in October 2012 the company directly met with DG Trade.[62]

With the exception of DG SANCO, EU officials were not systematically transparent about their contact with Imperial Tobacco and other tobacco companies.[63] Some meetings only became public knowledge due to FOI requests. For more information on the lack of transparency around the TPD review process, go to our page on EU Tobacco Products Directive Revision.

Documents released by the UK Department of Health reveal that Imperial Tobacco had access to confidential information from the European Council concerning the TPD.[64] Despite the Department of Health asking the company to explain how it came into possession of this confidential information, Imperial refused to disclose its source.

Corporate Social Responsibility Initiatives

Image 3. Love Where You Live website, April 2012

To help rehabilitate its image as a responsible business that "acts with integrity and lives its values"[65], Imperial Tobacco ran a number of Corporate Social Responsibility (CSR) initiatives. These initiatives not only attempt to rehabilitate the company's image, but also make it easier for the company to gain access to decision makers.

To make it easier for smokers to smoke whilst travelling, yet be seen to comply with smoke-free legislation, Imperial Tobacco launched its Smoking Allowed campaign in 2011, aimed at providing smoking shelters across UK airports.[66] Apart from supporting smokers, Simon Clark, the director of Forest, suggested that the campaign also “challenges the Orwellian ‘denormalisation’ of smoking”.[67]

In 2013, Imperial Tobacco co-founded the Love Where You Live campaign in the UK, aimed at encouraging individuals, companies and local groups to clean up after themselves (image 3).[68] The campaign gave Imperial Tobacco the opportunity to partner with government, who supported the project. More information on this CSR initiative can be found on the page CSR: Imperial and Love Where You Live.

Intimidating Governments with Litigation or Threat of Litigation

Imperial Tobacco has legally challenged tobacco control regulations in the UK, EU and Australia, including:

  • The Tobacco and Primary Medical Services (Scotland) ACT 2010. The company argued that the ban on tobacco display and cigarette vending machines falls outside the legislative scope of the Scottish Parliament.[69] This challenge was dismissed by the Supreme Court in December 2012, but delayed the introduction of the display ban by 2 years.
  • The Tobacco Plain Packaging Act 2011 (Australia). Imperial Tobacco unsuccessfully challenged the legality of standardised packaging legislation in Australia. For more information, go to Australia: Challenging Legislation.
  • The Standardised Packaging of Tobacco Products Regulations 2015 (UK). Imperial first threatened with litigation against the UK Government in 2012, if the Government were to implement plain packaging legislation.[70] Following the passage of the legislation in March 2015, Imperial Tobacco and others launched a legal action, which it lost in May 2016 (the day before the legislation was due to come into force).[71][72]
  • The 2014 EU Tobacco Products Directive (TPD). Imperial Tobacco formally supported a legal challenge brought by PMI and BAT to invalidate the TPD as a whole, or various provisions within it. This legal challenge was dismissed in the European Court of Justice in May 2016.[73] More details can be found on the page TPD: Legal Challenges.

Interfering with Democratic Processes

As Next Generation Products: Imperial Tobacco have come onto the market, new tobacco industry tactics are emerging to challenge current tobacco control regulations around the world. In February 2019, a campaign was launched under the European Union Commission’s “Citizen’s Initiative” with the name “Let's demand smarter vaping regulation!”[74] This campaign, part-funded by Imperial, proposed revoking article 20 of the Tobacco Products Directive (TPD) , which “requires EU Member States to introduce restrictions on the advertising of electronic cigarettes”.[75]

The European Citizens’ Initiative is a democratic tool meant to benefit individuals, or groups of individuals, by bringing to the Commission’s attention proposals for legal acts. There are rules in place which prohibit companies or organisations from proposing this process. However, there are no specific rules against company employees using the initiative as individuals.[76]Organisers of the ‘smarter vaping regulations’ initiative include Valerio Forconi, head of EU corporate affairs and registered lobbyist for Imperial Brands, and it was set up with EURO€10,000 from Imperial’s Brussels office.[74]

Two of the other organisers were representatives of e-cigarette trade associations (Vape Business Ireland and France Vapotage) of which Imperial was a member.[74] For details see E-Cigarettes: Imperial Tobacco

This is a clear example of ‘astroturfing’, a well-known tactic used by the tobacco industry to interfere with tobacco control legislation.[77] Corporate watchdog Corporate Europe Observatory has condemned Imperial’s activities, stating that the tobacco company “has vested commercial interests in getting vaping products excluded from the Tobacco Products Directive and is abusing a democratic tool for citizenship participation”.[76] For more information see E-Cigarettes: Imperial Tobacco

The main representative of the “Let's demand smarter vaping regulation!” organising committee is listed as Dustin Dahlmann, from German e-cigarette-business association Bündnis für Tabakfreien Genuss (BfTG), which donated EURO€8,000 to the campaign. BfTG states that it is “tobacco-free” and has no tobacco industry members.[74][78][79] Another organiser is Mosè Giacomello, from Vapitaly, which organises an annual trade event in Italy, and provided EURO€16,000 in funding to the campaign.[74]

The initiative was launched in April 2019 with the intention of gathering one million signatures in one year, from at least 7 EU countries. This would then require the European Commission to consider the request to revoke article 20.[74][76] The accompanying website, promoted by Imperial Brands, portrayed it as a “grassroots” campaign to support a change in regulation, by differentiating e-cigarettes from traditional tobacco products.[80]

Circumventing EU Menthol Ban With New Products

The 2014 EU Tobacco Products Directive Revision, passed into UK law in 2016, banned the sale of menthol cigarettes and rolling tobacco, as menthol was deemed a ‘characterising’ flavour.[81] Pipe tobacco, cigars and smokeless products such as e-cigarettes and snus were exempted from this flavour ban. After lobbying from tobacco companies, and a legal case brought by the Polish Government, a 4 year delay was granted.[82][83] The sales ban was due to come into force in May 2020.[84]

In December 2019, Imperial announced that it was launching a new Rizla product in the UK in January 2020; a cardboard insert which could be put into a packet of cigarettes or rolling tobacco, to infuse the product with one of two flavours - “Menthol Chill”or “Fresh Mint”. The company argued that this product was an “accessory” and therefore not covered by the tobacco product regulations.[85] The regulations state that the ban includes “tobacco products containing flavourings in any of their components such as filters, papers, packages, capsules or any technical features allowing modification of the smell or taste of the tobacco products concerned”.[86]

In January 2018, Imperial had relaunched one of its cigarette brands, JPS Green, with a menthol-infused packet liner, which it claimed would be “more effective at transferring flavour to the cigarettes than traditional menthol tips”.[87]

Next Generation Products

For an overview of Imperial Tobacco's investment in Next Generation Products, including snus and e-cigarettes, go to Next Generation Products: Imperial Tobacco.

TobaccoTactics Resources

Relevant Link

TCRG Research

Notes

  1. ↑ Euromonitor International, Company Shares (Global-Historical Owner) Retail Volume % Breakdown, World 2010-2015. Available from www.euromonitor.com (by subscription), accessed February 2017
  2. ↑ C. Guibourg, Imperial Tobacco is rebranding to Imperial Brands, City A.M., 5 February 2016, accessed February 2017
  3. ↑ Nerudia, Who we are, undated, accessed February 2018
  4. ↑ Imperial Brands, Annual Report and Accounts 2016. Delivering Against Our Strategy, Imperial Brands website, accessed February 2017
  5. ↑ A. Cooper, Introduction Slides, Imperial Brands Investor Day 8 June 2016, Imperial Brands website, accessed February 2017
  6. ↑ Euromonitor International, Company Shares (Global-Historical Owner) Retail Volume % Breakdown, United Kingdom 2010-2015. Available from www.euromonitor.com (by subscription), accessed February 2017
  7. ↑ 7.0 7.1 A. Hancock, Imperial Brands names new chief executive, Financial Times, 3 February 2020, accessed February 2020
  8. ↑ Inchape plc, Our Leadership Team, Inchape website, 11 January 2018, accessed February 2020
  9. ↑ Imperial Brands, Imperial Brands Chief Executive Officer to Step Down, Imperials Brands website, 3 October 2019, accessed October 2019
  10. ↑ Imperial Brands, Pre-close Trading Update, Imperials Brands website, 26 September 2019, accessed October 2019
  11. ↑ Imperial Brands, Imperial Brands Chairman, Imperials Brands website, 11 February 2019, accessed October 2019
  12. ↑ Imperial Brands, Imperial Brands Announces New Chairman, 5 November 2019, accessed November 2019
  13. ↑ L. Barras-Hill, Imperial Tobacco’s Cords joins APTRA board, Frontier Magazine, 24 November 2014, accessed February 2017
  14. ↑ Asia Pacific Travel Retail Association, Board Members, 2017, accessed February 2017
  15. ↑ 15.0 15.1 15.2 15.3 15.4 European Commission Transparency Register, Transparency Register: Imperial Brands PLC, last updated 19 April 2016, accessed February 2017
  16. ↑ Industry and Parliament Trust, Supporting organisations, Industry and Parliament Trust website, undated, accessed January 2012 & February 2017
  17. ↑ The Eliminating Child Labour in Tobacco-Growing Foundation, ECLT Foundation Governance, 2017, accessed November 2017
  18. ↑ International Labour Organization, Mission and impact of the ILO, 2017, accessed November 2017
  19. ↑ Institute of Business Ethics, Email reply to TobaccoTactics editor 21 February 2017 10:00, subject: RE: Query about IBE membership Imperial Brands
  20. ↑ S. Millicheap, Leaked email to MSP dated 10 January 2017 16:19, subject: E-Cigarettes, accessed January 2017
  21. ↑ PRCA Public Affairs Register June to August 2010, PRCA website, accessed February 2017
  22. ↑ PRCA Public Affairs Register March - May 2011 (Agency), PRCA website, accessed February 2017
  23. ↑ PRCA Public Affairs Agency Register March - May 2012, PRCA website, accessed February 2017
  24. ↑ PRCA Public Affairs Agency Register March - May 2013, PRCA website, accessed February 2017
  25. ↑ PRCA Public Affairs Agency Register March - May 2014, PRCA website, accessed February 2017
  26. ↑ PRCA Public Affairs Agency and In-House Register March - May 2015, PRCA website, accessed February 2017
  27. ↑ PRCA Public Affairs Agency and In-House Register December to February 2016, PRCA website, accessed February 2017
  28. ↑ UK Lobbying Register, David Alexander, register entry, undated, accessed 7 January 2020
  29. ↑ A. Parsons, Imperial Tobacco, Email to Tobacco Control Research Group, University of Bath, 25 May 2012
  30. ↑ S. Stotesbury, Head of Regulatory Science, Imperial Tobacco, Email to Tobacco Control Research Group, University of Bath, 25 March 2014
  31. ↑ J. Luik, A Picture of Health? Why Graphic Warnings Don’t Work, The Democracy Institute, 2006, accessed March 2017
  32. ↑ 32.0 32.1 H. Gilbert, "Now Imperial offers the ladies a stylish new cigarette brand", The Grocer, 6 August 2011, p25
  33. ↑ Department of Health, Tobacco Packaging Guidance, March 2017, accessed March 2017
  34. ↑ J Hoek, P. Gendall, C. Eckert, J. Louviere, Dissuasive cigarette sticks: the next step in standardised (‘plain’) packaging?, Tobacco Control 2016; 699-705
  35. ↑ 35.0 35.1 S. Gardiner, Plain package row: tobacco company resorts to ‘sick joke’, 12 September 2012, accessed September 2012
  36. ↑ J. Pearlman, Australian tobacco accused of ‘sick joke’, 12 September 2012, accessed September 2012
  37. ↑ National Federation of Retail Newsagents, NFRN and Imperial Tobacco team up to fight illicit tobacco, 13 January 2017, NFRN website, accessed March 2017
  38. ↑ K. Evans-Reeves, A. Rowell, Tobacco industry rallies against illicit trade- but have we forgotten its complicity, The Conversation, 16 March 2015, accessed March 2017
  39. ↑ Select Committee on Public Accounts, Minutes of Evidence Examination of Witnesses (Questions 540-559), 19 June 2002, http://www.parliament.uk, accessed March 2017
  40. ↑ Unknown, International Trading – opportunities for Gallaher, undated, Truth Tobacco Industry Documents, Bates no: GA00025, accessed March 2017
  41. ↑ 41.0 41.1 World Health Organization, Tobacco Industry Interference A Global Brief, 2012, accessed March 2017
  42. ↑ L. Bauld, Impact of smokefree legislation: evidence review, Department of Health, March 2011, accessed March 2017
  43. ↑ Tobacco Manufacturers’ Association, Three Years on – industry calls time on a complete smoking ban, 1 July 2010, TMA website, accessed March 2017
  44. ↑ Imperial Tobacco, The Bauld truth - The Impact of Smokefree Legislation in England: A critique of the evidence review using publicly available information, June 2011, accessed March 2017
  45. ↑ D. Petrie, Email to Lorenza Fernandez, 14 February 2011
  46. ↑ D. Petrie, Email to Lorenza Fernandez, 1 March 2011
  47. ↑ ABC News, Leaks reveal $9m tobacco blitz, 11 September 2010, accessed March 2017
  48. ↑ A. Davies, Big Tobacco hired public relations firm to lobby government, The Sydney Morning Herald, 11 September 2010, accessed March 2017
  49. ↑ The House, Parliament’s Magazine, Dods, No.1419, Vol 36, 14 June 2012
  50. ↑ House of Commons Publications, Register of Members’ Financial Interests – 9 February 2015 report, 9 February 2015, accessed February 2017
  51. ↑ House of Lords Publications, Register of Lords’ Interests as Amended to Show Position on 16 July 2007, 16 July 2007, accessed November 2017
  52. ↑ Peer’s tobacco Wimbledon tickets, Manchester Evening News, 20 April 2010, accessed November 2017
  53. ↑ House of Lords Publications, Register of Lords’ Interests as Amended to Show Position on 23 July 2009, 23 July 2009, accessed November 2017
  54. ↑ Unknown, The UK Tobacco Industry and the Register of Members’ Interests of the House of Commons: Health Committee, 5 May 2000, Truth Tobacco Industry Documents, Bates no: 325118382-325118400, accessed February 2017
  55. ↑ Conservative Europe, Lobbying Contacts Report 1st January-30th June 2011
  56. ↑ Conservative Europe, Lobbying Contacts Report 1st July-31th December 2011
  57. ↑ Conservative Europe, Lobbying Contacts Report 1st January-30th June 2013
  58. ↑ DG SANCO, Minutes of Meeting Between Commissioner Dalli and Representatives of the economic stakeholders active in tobacco products on 7 March 2012, accessed March 2017
  59. ↑ DG SANCO, Minutes of Meeting on the revision of the Tobacco Products Directive (TPD) with cigarette manufacturers 27 November 2013, accessed March 2017
  60. ↑ DG ENTR, Email to DG ENTR colleagues, 12 July 2012 6:45PM, Subject: Réunion CECCM 12/07 9h30-10h30, released under freedom of information request 2013-5964
  61. ↑ DG ENTR, Email to DG ENTR colleagues, 5 September 2012, Subject: Meeting report- Tobacco industry 05/09 10h00-10h30, released under freedom of information request 2013-5964
  62. ↑ F. Bernandini, Email to DG Trade colleagues, 15 October 2012 15:03, Subject: Flash report meeting Imperial Tobacco 12 October 2012, released under freedom of information request 2013-3874
  63. ↑ S. Peeters, H. Costa, D Stuckler, M. McKee, A. Gilmore, The revision of the 2014 European tobacco products directive: an analysis of the tobacco industry's attempts to ‘break the health silo’, Tobacco Control, 2016,25(1):108-117
  64. ↑ R. Ross, Subject: European Tobacco Products Directive & Plain Pack, 9 April 2013, accessed March 2017
  65. ↑ A. Cooper, message from our CEO: Our values, our responsibility, Imperial Brands website, undated, accessed February 2017
  66. ↑ Tobacco Journal International, Smoking allowed – at an airport in the UK!, 2 January 2012, accessed February 2017
  67. ↑ S. Clark, Welcome to ‘Smoking Allowed’, Taking Liberties blog, 12 November 2011, accessed February 2017
  68. ↑ Staff writer, Keep Britain Tidy launches 'Love Where You Live' ads, The Drum, 20 September 2011, accessed February 2017
  69. ↑ ASH Scotland, Timeline of legal challenges against tobacco legislation in Scotland, updated December 2012, accessed March 2017
  70. ↑ City & Finance Reporter, Imperial Tobacco will take legal action against the Government if it implements plain packaging for cigarettes, The Daily Mail: This is Money website, 15 July 2012, accessed March 2017
  71. ↑ A. Ram, Tobacco giants launch UK packaging challenge, Financial Times (by subscription),8 December 2015, accessed April 2016
  72. ↑ Imperial Tobacco v Secretary State for Health Judgement, Royal Courts of Justice, Case no: CO/2601/2015, Mr Justice Green, 19 May 2016, accessed March 2017
  73. ↑ A. Glahn, ENSP welcomes the European Court of Justice’s decision to reject challenges against the Tobacco Products Directive, 2 December 2016, European Network for Smoking and Tobacco Prevention website, accessed March 2017
  74. ↑ 74.0 74.1 74.2 74.3 74.4 74.5 European Union Commission,EU Commission Citizens Initiative, 20 February 2019, accessed April 2019
  75. ↑ European Parliament, Revision of the Tobacco Products Directive 2014/40/EU, 3 April 2014, accessed May 2019
  76. ↑ 76.0 76.1 76.2 K. Jennings, Big Tobacco’s push for Big Vape, Politico, 26 February 2019, updated 27 February 2019, accessed December 2019
  77. ↑ S. Ulucanlar, G.J. Fooks, A.B. Gilmore, The Policy Dystopia Model: An Interpretive Analysis of Tobacco Industry Political Activity, PLoS Med, 2016; 13(9): e1002125
  78. ↑ BfTG vaping association, Bündnis für Tabakfreien Genuss (Alliance for tobacco fee enjoyment), archived July 2019, accessed December 2019
  79. ↑ S. Rosel, A Call For Common Sense, Tobacco Reporter, December 2019, accessed December 2019 (paywall)
  80. ↑ Sign the European Citizens’ Initiative], Vapingisnottobaccco.eu, undated, archived 1 May 2019, accessed May 2019
  81. ↑ UK Government, The Tobacco and Related Products Regulations 2016, Statutory Instrument, 20 May 2016
  82. ↑ P. Oppel, M. Geller, EU's highest court upholds restrictive new law on cigarettes, Reuters, 2 May 2016, accessed January 2020
  83. ↑ W. Szary, Poland to Challenge EU Ban on Menthol Cigarettes, Reuters 21 July 2014, accessed January 2020
  84. ↑ Association of Convenience Stores, Menthol Cigarettes Ban, ACS website, 2019, accessed January 2020
  85. ↑ R. Hegarty, Imperial Tobacco to launch Rizla Flavour Infusions to offset 2020 menthol ban, The Grocer, 11 December 2019, accessed January 2020 (paywall)
  86. ↑ European Commission, Directive 2014/40/EU Of The European Parliament And Of The Council, 3 April 2014, accessed January 2020
  87. ↑ E. Cronin, Imperial Tobacco Unveils New Innovations, Talking Retail, 24 November 2017, accessed January 2020
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