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PH I LI P MORR I S SERVICES INC. ~ ~1.J"L . _ ~ P.O. BOX 8203, DUBAI TEL :522080 fj, nT•r r.~„. TELE FAX X: 46241 OUPOLD EM :5207a2 acsimile Transmission .Tr.,. .i;L. '~ r r.~.,ft.t~ ~ ,dk7 M• G!t.t'.T.vnY ~ T'1IL (09714) 520782 couy, fve; To: Mr. Robin Allen Date: July 14, 1991 Location: INFOTAB, Jebel Ali . .. JOMG, GLN, HHS From: Page 1 of : Bisharah G. Baroudi 3 Robin, UAE DRAFT VOLUNTARY CODE OF CIGARETTE ADVERTISING Please find below Philip Morris' comments on the latest draft of the mentioned code as distributed on March 3, 1991 : GENERAL COMMENTS The code should avoid stating the obvious, namely that the signatories will comply with the laws and regulations in force. This applies to the companies agreeing to have their advertising carry the Health Warning Label required by law, the statement that the companies agree to exclude television, radio and unauthorised outdoor surfaces from the media used for branded cigarette advertising, stating that point of sale material shall be placed in accordance with local regulations, and stating that consumer promotions are not permitted under the code in locations where they are expressly prohibited by law. We suggest deleting such statements/references. Philip Morris would like to suggest that issues/activities that are not quantifiable or measurable by nature should be addressed separately from those for which META can establish clearly defined limits/checks. This comment is relevant to the reference to "excessive use of outdoor sites" under article 1.2 and "excessive stickering" under article 2.3. These immeasurable limits/requirements belong more within a general statement which confirms the Industry's willingness to exercise self restraint. While excessive use of outdoor sites and excessive stickering, particularly on public property (e.g. walls, fly-overs, street lighting poles etc.) would certainly provoke the authorities into adopting and enforcing sweeping bans, it is extremely difficult in a code such as this to define limits for such activities. .12 2501173312

Page 2 SPECIFIC COMMENTS Article 1 - Media 1.1. Delete. 1.2. Delete television and radio. Include cinema before 7:00 or 8:00 PM as the case may be. Consider including media that are legal for use, but which the signatories are willing to forfeit. Reference to unauthorised outdoor surfaces as a medium that the signatories are willing to forfeit implies that such surfaces are currently being used without authorisation. We suggest removing reference to authorised versus unauthorised surfaces and simply state that outdoor surfaces located closer than 100 meters (or any distance to be agreed within META) from schools for under 18 year olds, hospitals, ministries and government offices will not be used. We propose a one-page maximum limit on the size of advertisements in daily newspapers in all cases and at all times. Therefore no need for differentiation between regular ads and ads related to brand launches and no need for limits on frequency. However, loose inserts should not be carried within the paper if it already contains an advertisement, whatever the size of the advertisement or the insert. Article 2 - Point of Sale Material / Promotions 2.1. We suggest re-wording this item to "Permanent point of sale material (e.g. stickers) shall only be placed in locations where cigarettes are sold. 2.2. Delete. 2.3. Relegate to a general statement on activities for which META cannot establish clearly defined limits/checks. Nevertheless, stickering should strictly observe item 2.1. under this article, and there should be no stickering except at point of sale. 2.4. Prudence is not a definable or measurable requirement (see previous comment and general comments). This item belongs in a general statement on self restraint. 2.5. This requirement belongs in a separate agreement among META members. It adds no value to the code in terms of its possible use with the authorities as evidence of voluntary self-regulation. 2.6. Present wording implies META members are currently breaking the law, and that this requirement will prevent further violation of regulations. We propose re-wording this item. 2.7. Philip Morris would prefer to maintain the right to hold special promotions during Ramadan, and proposes that members give up cinema advertising during the Holy month. N Ul a ~ 0 ti W GJ 0 W

Page 3 2.8. On-carton gift offers for any brand family in total should not exceed three months in duration in any given year. Article 3 - Sponsorship 3.1. We propose deleting "where prohibited by law or to specifically". sponsor events 3.2. This item, like item 2.5., does not add value to the code in terms of its possible use with the authorities as evidence of voluntary self-regulation, and should be relegated to a separate agreement. Article 4 - Qualitative Restrictions 4.4. We propose deleting the second part of the sentence starting from "except as part of .......". OTHER COMMENTS - The code does not specifically address the issue of road-side cigarette hoardings particularly along external roads (Dubai-Abu Dhabi road). The UAE Ministry of Health is particularly sensitive about these hoardings. It was indeed these same hoardings, although authorised by the Dubai Municipality, that provoked the Ministry of Health in 1990 to seek the reactivation of Council of Ministers Resolution No. 402 of 1980 which would have led to a sweeping ban affecting exterior signage at point of sale, promotions and sponsorship. Any effort by the Industry to establish its own voluntary limits on the use of hoardings along external roads, such as limiting these hoardings to one per brand family, would be a highly commendable and prudent move. - META members should seriously consider obtaining the agreement of non-META members (e.g. Burrus, JTI and Imperial) to this code, and the best manner by which this can be achieved. We hope the above comments are helpful and that they will be incorporated in the next draft of the code. We would appreciate receiving a copy of the re-draft before it is finalised for members' signature. Kind regards, Bisharah G. Baroudi