Allen William Andrew Gallagher

Background Following overwhelming evidence of transnational tobacco company (TTC) complicity in smuggling, TTCs claimed to be working actively to address illicit tobacco trade (ITT), establishing internal programmes and partnerships with governments to achieve this. Until now, however, little has been known about these internal programmes. Methods A systematic search and analysis of approximately 15 000 internal British American Tobacco (BAT) documents, focused primarily on East and Central Africa, along with other parts of Africa and the Middle East, covering the period 2000–2014, identified 92 relevant documents, triangulated via additional resources including from governments, parliaments, IGOs, NGOs and other tobacco company documents, websites and statements. Results The primary focus of BAT’s Anti-Illicit Trade (AIT) programme, established in 2004, was to increase the company’s revenue and policy influence rather than prevent the diversion of its own products to illicit supply chains or effectively reduce all ITT. (I). Contracting external companies to “act as a buffer”, BAT deployed tactics against competitors to disrupt their legal and illegal supply chains, including using informants and undercover agents. Meanwhile, BAT sought to conceal illicit activities along its own supply chains, aiming to resolve them internally before authorities could intervene. Conclusions The primary purpose of BAT’s AIT programme was not to reduce smuggling. Our findings provide clear evidence that governments should cease all partnerships with BAT and other TTCs, reinforce protections against industry interference and launch official investigations into BAT’s activities.

Background Internal documents released in the 1990s and 2000s demonstrated that illicit tobacco trade (ITT) was central to transnational tobacco companies’ (TTCs) business strategies between the 1960 and 1990s. TTC products have continued to make up the majority of global ITT since then. This paper uses a set of internal British American Tobacco (BAT) documents to examine the company’s involvement in ITT from 2000 to 2014. Methods Keyword searches on a dataset of approximately 15 000 BAT documents dating from 2000 to 2014, primarily focusing on East and Central Africa and the Middle East, identified 210 relevant documents which were analysed thematically, drawing on a hermeneutic approach to company document analysis. Results Documents suggest BAT remained involved in ITT in parts of Africa and the Middle East throughout 2000–2014, appearing to rely on some of the same strategies for which TTCs were subject to legal action in the 1990s, including continuing to work with distributors linked to smuggling and supplying products to poorly regulated areas, leading to further smuggling. In addition, despite entering into partnerships with authorities to curb smuggling, documents indicate BAT concealed illicit activities. Conclusion Governments in the affected regions should consider if legal action is necessary, and the UK (where BAT is headquartered) government should reopen investigations into BAT’s conduct. Our findings demonstrate that greater transparency in the tobacco supply chain is needed, including via independent data and research, track and trace systems, electronic cargo tracking and audits. All governments should refrain from partnering with TTCs to control illicit trade.

Background: In 2023, the UK government proposed a Bill introducing a generational ban on the sale of tobacco products and measures targeting youth nicotine product (NP) use. Industries’ responses remain unexplored. Methods: We analysed 43 consultation and evidence submissions from tobacco and nicotine industry-linked actors, assessing their connections to transnational tobacco companies (TTCs) and using an evidence-based taxonomy to examine framing strategies. Results: TTCs and actors with known current TTC links accounted for 42% of submissions. Other actors—some with historic TTC ties—were other tobacco products (OTPs) specialists, NP specialists and retailers. Tobacco and nicotine industries were generally portrayed as ‘good’ with TTCs framing themselves as public health champions, while policymakers, the public health community and non-compliant sellers were depicted as ‘bad’ actors. TTCs, linked groups and additional OTP actors opposed the generational ban, arguing it lacked evidence and would harm the economy and increase violence against retailers. Proposed alternative approaches included exempting heated tobacco products (HTPs) and OTPs, and raising the age of sale to 21. TTCs, linked actors and NP actors opposed restrictions on NP flavours, packaging and display, arguing these would infringe on rights, harm retailers, stifle innovation, and increase smoking and illicit trade. They framed youth NP use as resulting from irresponsible individuals and advocated for education, stricter penalties and self-regulation. Conclusion: When faced with tobacco endgame and nicotine control policies in the UK, tobacco and nicotine industries pushed back using framing strategies common to health-harming industries. Despite contradicting their ‘transformation’ narratives, TTCs still sought to position themselves as public health actors deserving policy access. Advocates, researchers and policymakers can anticipate opposition to endgame policies—such as a generational sales ban—and NP restrictions, proactively preparing to counter this opposition in order to safeguard public health policy from vested interests.

South Africa (SA) used to be recognized as a committed leader in tobacco control (TC) having passed effective TC policies in the 1990s, but in recent years, it has been overtaken by other countries. While research suggests that the tobacco industry (TI) predominantly uses economic arguments to shape TC policy discussions in SA, TI tactics to influence policy formulation have not been examined in the peer-reviewed literature. In this study, we draw on three frameworks (health policy triangle, ‘bit in the middle’, and Policy Dystopia Model) and 20 interviews, supplemented with academic and ‘grey’ literature, to explore TC policy formulation in SA. We focus on SA’s 2018 draft TC Bill, which as of January 2025 has not been adopted. We found that despite SA’s commitment to protect TC policies from the TI’s vested interests, as set out in Article 5.3 of the World Health Organization Framework Convention on Tobacco Control, TI actors interfered throughout the policy formulation process. Participants reported efforts to shape policy alternatives by influencing the impact assessment and generating favourable evidence. To influence deliberation, they lobbied policymakers. To advocate for their preferred outcome, they sought to shape public opinion through campaigns and built alliances, for example, with the non-tobacco business community. The identified strategies were consistent with those observed elsewhere. Some were tailored to the SA context characterised by political corruption, and sensitivity around race and the legacy of Apartheid, as well as rivalry between transnational corporations and local producers. Industry actors also sought to redirect attention to TC areas (illicit trade and taxation) not led by the health sector, likely more susceptible to TI influence. The study demonstrates to policymakers, advocates, and researchers, the importance of not looking at a TC policy in isolation and of being mindful of industry efforts to exploit inherent policy-making complexities.

Objective: Previous research has identified that transnational tobacco companies lack transparency and that they hide their harms to health and nature behind environmental, social and governance (ESG) reporting. Our objective was to find whether independent tobacco supply chain companies similarly lack transparency on tobacco-related activities while prominently displaying ESG. Methods: In this cross-sectional study, mentions of tobacco supply chain activities and ESG company official documentation and websites were explored for independent tobacco supply chain companies (n=80) with identified annual reports included in the Tobacco Supply Chain Database. Bivariable statistical analysis tested for differences in the visibility of tobacco supply chain contribution and ESG within official documents and websites. In depth exploration was undertaken for seven case study companies. Results: Independent tobacco supply chain companies were significantly less likely to mention their tobacco supply chain contribution than ESG (31% and 80%, respectively p<0.001) in annual reporting. Tobacco supply chain contribution was also less prominent than ESG on websites (29% and 79%, respectively, mentioned on the home page or a home page menu p<0.001). The companies were making median annual profits of over US$2 million (n=76), with a large variation of revenue from tobacco activity (5–100%) where it was reported (n=9). Conclusions: Independent tobacco supply chain companies undertake ESG activities that they prominently display in official reporting and on websites while often being less transparent about their tobacco supply chain contribution. Potential investors and customers may thus be misled about the companies’ true nature. More rigorous reporting requirements are needed.

Previous evidence suggests the tobacco industry uses media to disseminate misleading narratives relating to illicit tobacco trade (ITT) as part of efforts to influence policy outcomes. Such evidence is largely high-income countries (HIC) focused, resulting in a literature gap for low- and middle-income countries (LMICs). Pakistan and its annual budget cycle are used as a case study for addressing this gap. Electronic English-language articles from newspapers in Pakistan (328) were sourced from LexisNexis and a sub-sample of Urdu-language electronic articles (12) were identified through internet searches. The articles were published between 2015 and 2020 and included claims/estimates relating to ITT, which were coded to identify cited data sources. Changes in media coverage before and after Pakistan’s annual budget announcements were explored via Wilcoxon signed rank and Poisson regression tests. Of the 357 claims/estimates analyzed, 66 (20%) were industry-funded. The most prevalent sources were national government bodies (36.6%) and tobacco companies or their representatives (15.1%). Wilcoxon signed-rank and Poisson regression tests on the frequency of English-language articles both created a p-value of < .05 for the frequency of relevant articles between the months of April and May, compared to the other months, indicating statistical significance. There was a statistically significant increase in the number of English-language articles featuring claims/estimates relating to Pakistan’s ITT in the months leading up to the annual budget each year. The government should consider measures to improve transparency standards within media coverage and promote factcheck journalism to safeguard against industry tactics to manipulate public discourses. This paper is, to the best of our knowledge, the largest exploration of the use of data sourced from the tobacco industry within a country’s media that has been undertaken to date, utilizing a team of seven coders across the United Kingdom and Pakistan. Our findings reveal weaknesses within media coverage of ITT in Pakistan, both in English and Urdu language publications. We encourage the government to consider new standards to enhance transparency and promote factcheck journalism within media coverage in the country.

Background Philip Morris International (PMI) claims to be transforming and has committed to a ‘smoke-free’ future. In 2020, it announced an ‘aspirational’ target for reduced cigarette shipments by 2025. Methods PMI cigarette shipment data are taken from PMI quarterly financial reports 2008–2023. Trends in these data before and after the 2020 announcement are analysed using linear regression, and auto regressive integrated moving average and error, trend, seasonal time-series models to assess if PMI’s 2025 target would be met on pre-existing trends, and if the trend changed after the announcement. These trends are also compared with the global retail market for cigarettes, using sales data from Euromonitor. Results Findings were consistent across all three models. PMI’s shipment target of 550 billion cigarette sticks by 2025 would readily have been met given pre-existing shipment trends. Following the 2020 announcement, the decline in PMI cigarette shipments stalled markedly with a statistically significant change in trend (pConclusions PMI’s 2025 target was not ‘aspirational’ but highly conservative—it would have been met based on pre-existing trends in declining cigarette shipments. Yet PMI will nonetheless fail to meet that target providing evidence it is not transforming. Stalling of the decline of PMI and global cigarette sales raises significant concerns about progress in global tobacco control.

Previous research has documented how British American Tobacco (BAT) and other transnational tobacco companies (TTCs) smuggled their own products into Iran in the 1990s in order to circumvent sanctions and other trade restrictions. In the early 2000s, BAT, along with other TTCs, signed legal agreements with Iranian authorities to sell its products legally and curb illicit tobacco trade (ITT). Our analysis of previously unreleased internal BAT documents (covering 2000–2014) suggests BAT remained potentially involved in ITT after those agreements were signed. Meanwhile, BAT engaged with government authorities to tackle ITT primarily for reputational and commercial purposes. With a business model based on a high number of contractors and distributors, extensive engagement with government authorities, and an anti-illicit trade strategy focusing more on reputation and growth than on effectively controlling its supply chain, further investigation into BAT’s activities in Iran – including potential sanctions breaching – may be warranted. This is especially relevant as, in April 2023, BAT agreed to pay penalties exceeding US$629 million to resolve charges of bank fraud and sanctions violations in North Korea, following a criminal investigation by the US Department of Justice and Office of Foreign Assets Control. Exploration of BAT’s activities in Iran would provide insight into the credibility of BAT’s response following these penalties, with the company having claimed that “Adhering to rigorous compliance and ethics standards has been, and remains, a top priority”.

This paper critically analyses contrasting estimates of Malaysia’s illicit cigarette trade in 2011, 2015 and 2019 by Bui et al and Koya et al who previously produced independent estimates at about the same time using tax gap analysis. Collaboration between the two authors’ teams emerged due to the discrepancies in their results, generating this paper to explore the methodological issues identified and hence produce revised estimates of the rate of illicit. Key issues identified were: Bui et al ’s assessment of legally imported cigarettes impacting all years; their exclusion of ad valorem duty affecting the 2011 and 2015 estimates; Koya et al overlooked the value of cigarettes for export market in their ad valorem calculation and used the sales value of imported tobacco/tobacco products, not just cigarettes, both of which impact estimates for 2011 and 2015. Recalculations using Koya et al ’s consumption data reveal that in 2019, illicit cigarettes accounted for about 70% of the market, which is higher than Bui et al ’s estimate (38%) but slightly lower than Koya et al ’s (72%). For 2011 and 2015 where ad valorem applied, the corrected estimates show a share of the illicit cigarette market of approximately 41.1% and 52.7%, respectively, differing from Bui et al ’s 0% in 2011 and 29.6% in 2015, and Koya et al ’s 51% in 2011 and 55% in 2015. This paper provides essential lessons for addressing methodological issues between authors’ teams and updated estimates of Malaysia’s illicit cigarette trade, verifying that Malaysia faces a substantial illicit cigarette trade problem.