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Anti-Illicit trade

 
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Illicit trade in smuggled or counterfeit products harms our business. We must do our part to stop it

No involvement in, or support for, illicit trade in our products

We must ensure that:
  • we do not knowingly engage in unlawful trade in the Group‘s products
  • our business practices only support legitimate trade in Group products
  • we collaborate with authorities in any investigation of illicit trade

The illicit tobacco trade has a negative impact on society. It deprives governments of revenue, encourages crime, misleads consumers into buying poor quality products, undermines the regulation of legitimate trade, and makes it more difficult to prevent underage sales.

It also harms our business, devalues our brands, and our investment in local operations and distribution.

High excise taxes, differential tax rates, weak border controls, and poor enforcement all contribute to illicit trade. However, we fully support governments and regulators in seeking to eliminate it in all its forms.

Maintaining controls designed to prevent illicit trade in our products

We must maintain controls designed to prevent our products being sold unlawfully by our customers or diverted into other countries. These controls should include:
  • implementing the Supply Chain Compliance Procedure , ‘know your customer‘ and ‘know your supplier‘ including the Third Party ABAC Procedure  and any other relevant measures to ensure supply reflects legitimate U.S. demand
  • procedures for investigating, suspending and terminating dealings with customers or suppliers suspected of involvement in illicit trade
‘Know your customer’ and ‘know your supplier’ including the Third Party ABAC Procedure  and the Supply Chain Compliance Procedure  are important procedures. They are necessary for ensuring that Group products are only sold to reputable customers, made using reputable suppliers and in quantities reflecting legitimate U.S. demand.

We should make our position on illicit trade clear to our customers and suppliers. Wherever possible, we should seek contractual rights to investigate, suspend and cease our dealings with them if we believe they are involved in unlawful trade in our products.

If you suspect Group products have entered illicit trade channels, notify your local LEX Counsel immediately.

Monitoring and assessing the U.S. market

RAI companies should  monitor the U.S. market and assess the extent to which our products are sold unlawfully or diverted to other countries since such illicit activity weakens the legitimate distribution channel and undermines the integrity of our products.

Who to talk to

Your line manager
Higher management
Your local LEX Counsel
Head of Compliance:
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