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Lorillard Coupon Redemption Policy Manuel June 1, 1981

3. The bi-weekly invoice procedure will remain intact, with brand breakouts attached to final monthly invoice. 4. The check register will be sent directly to Lorillard Controller. 5. All coupons submissions that are challenged and sent to NYO will contain all the details plus a payment history. Sequencially coded coupons will be sent in sequence order. A) Payment history will include payment direct from Donnelley, clearing houses or both. 6. No procedure in this manuel will be changed unless properly directed by Lorillard. 89'72326"f

know he's been sent a letter and has since submitted suspect coupons. 6. If a submission of any amount is challenged for misredemption, the retailer is not to be put on the exception report. If the amount of what is determined misredeemed is under $25.00 (excluding sequential violations), an attachment "B" letter will be sent along with the payment. This retailer will be put in the CRT as an "L" retailer and the following 3 submissions will be checked. If they are clean this retailer will come off the "L" listing. 7. Submissions over $25 that are "gang cut", "mint" or washed & dried will be placed on the exception report until Lorillard is challenged. If challenged, any submission between $25-$50 will be paid and sent letter "B". Donnelley will send this letter only once and will keep it on file. From this point follow procedure no. 6. 8. Submissions over $50 and Lorillard is challenged will be forwarded to Lorillard NY0 for review. 9. Submissions headed "Excessive transactions" will remain on the report. 10. Submissions which are first time submissions will be sent a questionnaire (Attachment C) as stated in "Lorillard Procedure no. 5". If, however we do not get a response in 30 days a second questionnaire will be sent. If no response comes through this retailer will go on a separate.exception report and listed as "no response to questionnaire". All returned questionnaires marked "out of business", "moved", "closed" etc. will be completely deleted from our report but kept on our data base. The data base will remain updated with these retailers. The invoice plus a small representation of the types of coupons will be held. The balance of the coupons will be destroyed. Lorillard Inquiry Procedure 1. All inquiries to Donnelley will be handled by the information and Review team. 2. Direct inquiries will be sent appropriate correspondence (attachments D, E, F, G) to the retailer. 3. Inquires stemming from our NYO will be handled by phone within 24 hrs. Disposition will be determined and appropriate action will follow. 4. Lorillard will have final say as to disposition of any challenged submissions. Miscellaneous 1. All reports now in operation will remain so, 89'y23266 2. Seeding of coupons will be done once a quarter. Results of the seeding will be sent to our NYO.

Donnelley Coupon Redemption Services is located in Elm City, N.C. and is solely responsible for all Lorillard coupon redemption activities. Donnelley will adhere to the procedures as stated in this manuel. All deviations from any of the procedures must be first approved by Lorillard. This manuel will supercede all manuels prior to this date of June 1, 1981. Lorillard Product List (Family Names) Kent True Golden Lights Old Gold Triumph Max Newport Beech-Nut Maverick Lorillard Redemption System 1. Mail is received and recorded daily. A date is placed on all submissions when received. 2. Retailer is checked on the redeemer data base (CRT) to determine if this retailer is active, new or suspect. 3. Name & address will be verified before coupons go to the team. 4. Suspect submissions will be sent to team supervisor for special handling. . 5. First time redeemers will be sent questionnaire. (attachment C) and coupons will be held at Donnelley until completed questionnaire is returned. Submissions are processed by face value as follows after retailer is found to be an active redeemer and not on the suspect list. 1. Invoices are verified by number of coupons submitted multiplied by the value of the coupon. 2. Coupons are sorted by value at the redemption stations. 3. Coupons will then be sorted by code and counted for report. 4. Invoices are given a six digit sequence number for accounting purposes. 5. The invoices are keyed and edits are run to stop errors not found by m the redemption team. LO ~ 6. Checks will be written for all cleared invoices. W ~ 7. Check registers are printed showing name, address, sequence number, account number, number of coupons and total amount of money. yo

Types of Reports Issued 1- Redemption Report - issued monthly 2 - Exception Report - issued month}y 3 - Statistical Report- issued monthly 4 - Check Registers - issued weekly Lorillard issues coupon codes by job numbers. A job number is identification for a code or group of codes with the same value, media type and same issue date. The redemption Report is sorted by brand and job number within the brand. The Statistical Report shows accumlative activity by job number. It is sorted by brand and job number within the brand. Lorillard Exception Report Procedures 1. Eliminate all accounts over one year old and with only one submission. 2. Qualified submissions under $50 and not accompanied by an invoice will be paid and Donnelley will prepare coupon work sheet. 3. Qualified submissions over $50 not accompanied by an invoice will be handled by Donnelley's information and Review Section. The retailer will be sent a letter (attachment A for his signature of reconciliation. The work sheet will be sent with 2 copies and self- addressed postage paid envelope. When a signed copy is sent back the payment procedure will commence. After 30 days, if a letter of reconciliation is not received a follow up attachment A letter (attached) is sent. If there is no answer to the follow-up letter this submission will be held until challenged. If challenged an attachment "A" letter is sent for reconciliation. 4. All submissions containing "Sequencially numbered" coupons will be placed on report until challenged. Sequencial numbering will be determined if a submission has four or more coupons in numbered order. 5. Submissions under $25 that appear "gang cut", "mint" or"washed & dried" will be paid and sent form letter B. Donnelley will keep this letter on file and only send notice once. This retailer will not be put on the exception report but will be designated with an "L" in the computer. If a retailer has been sent a form letter and submits qualified coupons he is to be paid. Three proper sub- missions by an "L" retailer will take said retailer off the "L" listing, Any subsequent misredeemed submissions will place the retailer back on the Exception Report with the notation of why and with "letter sent"'also,bycthe_reason. This will let us