International Tax and Investment Center

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The International Tax and Investment Center (ITIC) was founded in 1993. It claims to be an independent, non-profit research and education foundation.[1]

Background

ITIC has offices in Azerbaijan, Kazakhstan, the Philippines, Russia, Ukraine, the United Kingdom (UK), the United States (US), and works in many more countries around the world.

Two years after its inception, ITIC reported that its principle asset was in providing its sponsors “a seat at the policy-making table.”[2]

Relationship with the Tobacco Industry

Until 2017, ITIC received funding from all of the transnational tobacco companies (TTCs): Philip Morris (PMI), Japan Tobacco International (JTI), British American Tobacco (BAT), and Imperial Tobacco.[3] In May 2017, the UK’s Financial Times reported that ITIC asked tobacco representatives to resign from its board and would no longer accept sponsorship from tobacco companies.[4] This move followed criticism in 2015 from Dr Doug Bettcher, Head of Non-Communicable Disease at the World Health Organization, who “urged all countries to follow a non-engagement policy with ITIC” because of ITIC's relationship with the tobacco industry:

“ITIC has published extensively in favour of the tobacco industry’s false positions on excise taxation, investment and illicit trade in tobacco products…ITIC have used their international conferences.. to lobby government officials against tobacco taxation.” [5]

Two years later in May 2017, ITIC President Daniel Witt stated:

“The anti-tobacco campaigns became too great a distraction from ITIC’s mission, and this was a necessary step to safeguard ITIC’s reputation and ensure its long-term effectiveness.[4]

This page details some of ITIC’s tobacco related activities since the turn of the 21st century.

See International Tax and Investment Center - A History of Tobacco Industry Facilitation for information on ITIC’s activities during the 1990s.

Tobacco Industry Facilitation

Hosting High Level Meetings

ITIC has hosted high level meetings with officials, members of national and regional governance organisations, and international institutions, thereby providing tobacco industry allies access to individuals and organisations it could otherwise be difficult to access directly – for example, access has been given to representatives of the World Bank (WB) and International Monetary Fund (IMF),[6] Members of the European Parliament (MEPs), senior officials of the European Commission,[7]and representatives from global governments[8][9][7]

Advising and Lobbying Governments on Tobacco Taxation Policy

Evidence shows that ITIC has met with and advised high-level government representatives worldwide,[10][11] including:

  • Advising the Ukrainian Tax Committee in 2008 to model tobacco tax rates after Russia, a country with a high smuggling rate.[10]
  • Advising the Ukrainian government on operation and customs control of duty free retail outlets and published reports on tobacco taxation, including one report in Eastern Europe urging that accession countries be given a longer time to implement tax increases to make sure that tobacco remains "affordable".[12]
  • Sponsoring conferences on tobacco tax policy including a 2008 seminar on Eastern European tobacco taxation in Hungary, where 40 government officials from new EU member states attended.[13]

The World Health Organization’s (WHO) Framework Convention on Tobacco Control (FCTC) is a global public health treaty intended to reduce the burden of disease from tobacco.

Article 5.3 of the FCTC strongly advises that public policy should be free from the vested interests of the tobacco industry and its associates.[14] By facilitating meetings and conferences which allows the tobacco industry undue access to policymakers and government officials and provides opportunity to influence policy, ITIC has contravened Article 5.3.

Image 1: Excerpt from ITIC private invitation to Ministers of Finance on the eve of COP 6

Lobbying Against Tobacco Taxation in Private Meeting Ahead of COP 6

On 12 October 2014, the morning before the Sixth Conference of the Parties (COP) of the FCTC, ITIC hosted an exclusive event in Moscow for representatives from Ministries of Finance.[15] This was a violation of Article 5.3.

In an attempt to stall anticipated tobacco taxes, set to be agreed upon at the COP, the ITIC briefing was open to “invitation-only” officials and aimed to “ensure there is a balanced approach to important excise taxation issues”.[16]

In a private invitation sent to select delegates from around the world, ITIC urged Ministers of Finance to insist that “the government delegations [to the COP] include representatives from their Ministries of Finance and/or Tax Administrations who can lead the debate from the fiscal perspective” (see Image 1). The meeting, held at a luxury resort in Moscow in collaboration with the Eurasian Economic Commission, included a “Review of Best and Worst Practices of Tobacco Excises” as well as a “Panel Discussion on the Next Steps”.[16]

Regular Meeting with Africa Tax Dialogue

Africa Tax Dialogue meetings provide a forum for ITIC to effectively represent tobacco industry interests on matters of tax and illicit trade in Africa, and allows its representatives direct access to the policy makers and Ministers of Government who attend the meetings.[8][7]At the African Tax Dialogue meeting in Tanzania in July 2014, ITIC’s president Daniel Witt and Senior Advisors Jeffrey Owens and Sijibren Cnossen were brought together alongside the Tanzanian Minister of Finance Saada Mkuya Salum, where they took part in a special workshop on ”Combating Illicit Trade of Excisable Goods”.[8]

Meetings About the EU Tobacco Products Directive

ITIC-facilitated meetings on behalf of the tobacco industry have been used to lobby against further regulation of tobacco and smoking, such as the EU Tobacco Products Directive (TPD):

  • In 2009, ITIC received additional funding from BAT, JTI and Philip Morris for a conference on tobacco smuggling (“Anti-Illicit trade of tobacco products”) between 4-6 November in Brussels. ITIC representatives spoke, along with speakers from the EU Anti-Fraud Office (OLAF), and other law enforcement agencies. It was chaired by Elizabeth Allen, who retired from British Customs in March 2009.[17]
  • In May 2011, the Kangaroo Group hosted a Forum on Intellectual Property, Counterfeiting and Piracy, which was addressed by ITIC president Daniel Witt. The Kangaroo Group, based in Brussels, is a business lobby association comprising of representatives of the European Parliament, Commission and Council, academia, media and the business sector.[18]. Its members include: JTI, Philip Morris, BAT and Imperial Tobacco as well as the Confederation of European Community Cigarette Manufacturers (CECCM).[19] During his address, Witt reiterated the industry position that the introduction of plain packaging for tobacco products “should be carefully looked at on the grounds that they could very well worsen the problem, making life easier for counterfeiters to flood EU markets with cheap fakes.”[20]
  • In December 2011, Witt penned an article with Edit Herczog from the European Parliament’s Industry, Research and Energy committee, which warned that “If new laws are not carefully considered in terms of how they may impact the black market, rather than tackling smoking, they may end up transferring the wellbeing of EU citizens to the hands of criminals.”[21]
  • In July 2012, ITIC also participated in the World Customs Organisation (WCO) Global Excise Summit in Brussels.[22]

PMI Commissioned Research Reports on the Illicit Tobacco Trade

Funded by PMI, ITIC has partnered with Oxford Economics, which describes itself as one of the world’s leading independent global advisory firms, to product reports on the illicit tobacco trade in Asia.

Asia 11 – Illicit Tobacco Indicator 2012

In September 2013, Oxford Economics published the findings of its Asia-11 study that it conducted with ITIC on behalf of Philip Morris Asia (an affiliate of PMI), in order to quantify the illicit trade in 11 Asia Pacific markets.[23]

Asia-11 refers to a group of markets which includes Australia, Brunei, Hong Kong, Indonesia, Malaysia, Pakistan, Philippines, Singapore, Taiwan, Thailand, and Vietnam.

The report claimed that:[24]

  • 66.5 billion (9%) cigarettes consumed in the countries surveyed were illicit – either illegally imported (5.6%) or illegally manufactured locally (3.4%);
  • Brunei, Hong Kong, Malaysia and Singapore, countries with high tobacco taxes, had the highest volumes of illicit cigarettes – over 25% in 2012;
  • Governments were losing billions of dollars lost tax revenue due to illicit trade.

The Asia-11 report was critiqued by the Southeast Asia Tobacco Control Alliance (SEATCA). SEATCA argued that the Asia-11 report was biased in favour of the tobacco industry because:

  • the big four transnational tobacco companies are members of ITIC (one of the authors);
  • the report was funded by Philip Morris International;
  • the report’s conclusions were in line with the industry’s rhetoric that illicit trade is an ever increasing problem and that public health interventions like tax increases should be modest.

Furthermore, a peer-reviewed study published in the journal Tobacco Control attempted to validate Oxford Economic’s and ITIC’s estimate that 35.9% of tobacco consumed in Hong Kong in 2012 was illicit. Using data from government reports and publically available routine data, the authors of the Tobacco Control article estimated that illicit cigarette consumption was between 8.2% and 15.4% of the total cigarette consumption in Hong Kong in 2012.[25] The OE/ITIC report was written by Elizabeth Allen. Since her retirement from Her Majesty’s Revenue and Customs (HMRC) in March 2009, Allen carried out three successive policy development reviews for the UK Government’s Office as well as acted as a consultant and programme advisor for ITIC.[26]

Asia 14 – Illicit Tobacco Indicator 2013

In September 2014, on behalf of PMI, Oxford Economics and ITIC published Asia-14, Illicit Tobacco Indicator for 2013.[27] Asia-14 refers to a group of markets, which includes all of the aforementioned countries in the Asia-11 report plus, three additional countries, Cambodia, Laos and Myanmar.

Oxford Economics and ITIC claimed that in 2013:

  • 10.9% of cigarettes consumed in Asia-14 were illicit;
  • Illicit consumption rose in 7 out of the 11 markets examined in the previous Asia-11 report;
  • Government tax losses totalled 3.9 billion US dollars.

Again, SEATCA offered a critique of the PMI funded report undertaken by Dr Hana Ross, an expert on the economics of tobacco control.[28][29] Ross claimed that the figures and statistics presented in the Asia-14 report were “incorrect”, “unverified/unverifiable”, “not comparable across countries” and “inconsistent with results from other studies” in the region.[29]

In particular Ross criticised the report’s lack of transparency in relation to its Empty Pack Survey (EPS) methodology used to estimate levels of illicit:

"The Empty Packs Survey (EPS), which is a crucial component of the “IT Flows model” upon which most of the report is based, does not fully disclose its sampling frame, the timing of data collection, the criteria for distinguishing legal and illegal packs, and other crucial survey parameters, even though the validity of data generated by the survey are very sensitive to such issues."
"No information is provided about the packs that could not be classified as illegal or legal with certainty, and whether or not the collected packs are available for reinspection."
Image 2. Asia-16 report: Hong Kong published by Oxford Economics October 2015

EPS methodology involves the collection of discarded packets in order to identify non-domestic packs which have not paid the country specific duty. This methodology has been criticised for its inability to distinguish between different types of foreign tobacco - legal cross-border duty-free product and that which has been illegally smuggled into the country - thereby leading to overestimations of illicit.[30]

Asia 16 – Illicit Tobacco Indicator 2014

In October 2015, again on behalf of PMI, Oxford Economics and ITIC published Asia-16, Illicit Tobacco Indicator for 2014, however, access to the full report requires a membership log in account. Nevertheless, a report for Hong Kong alone is available online. (Image 2)[31]

Asia-16 refers to a group of markets, which includes all of the aforementioned countries in the Asia-14 report plus, two extra countries Macao and South Korea.

In late 2015, press coverage of the Asia-16 report in the Philippines and Macau highlighted the potential bias of the reports and referred to previous critiques of the Asia-11 and Asia-14 reports offered by SEATCA.[32][33]

Establishing Academic Groups

Academy of Public Finance – Vienna University of Economics and Business

Having established “successful” tax training programmes in Azerbaijan and Kazakhstan, in 2012 ITIC expanded its training courses into 12 countries across the Eurasia region. [34] These were conducted in collaboration with the Institute for Austrian and International Tax Law at Vienna University of Economics and Business, the International Finance Corp and the accountancy firm, Ernst & Young. Together, the institutions launched the Academy of Public Finance as a public/private initiative, offering policymakers and administrators training in three core areas of taxation over two years.[35][36]

In its September 2013 monthly Bulletin, ITIC confirmed that the Academy of Public Finance had received start-up funds from Japan Tobacco International (JTI), stating:

“We are most grateful to JT International who provided expert advice on practical tax matters and made a two-year sponsorship commitment to finance the start-up and secretariat infrastructure that will be based at Vienna University of Economics and Business.”[34]

Leading the development of the Academy of Public Finance was Dr. Jeffrey Owens, Professor and current Director of the Global Tax Policy Center (GTPC) at the Institute for Austrian and International Tax Law.[37] Owens, who previously worked on tax matters at the Organisation for Economic Co-operation and Development (OECD) and as a government advisor on tax and business issues has served as a “distinguished fellow” at ITIC since May 2012.[9]

The Africa Tax Institute

According to its website, ITIC has been working with 20 African countries since 2000 and has claimed that “in a large part, the ITIC policy recommendations on excise reform have been enacted and are part of the current law in Kenya and Ghana.”[9]A key partner in ITIC’s operations in Africa is the Africa Tax Institute.[35]

The Africa Tax Institute (ATI) is a research group based in the Department of Economics, University of Pretoria, South Africa, which claims to be “devoted to training, research, and technical assistance in the areas of tax policy and tax administration on the African continent.”[38] In June 2015, the ATI announced collaboration with the GTPC at the Vienna University of Economics and Business,[39] thereby expanding the Academy’s influence and reach on the continent. ITIC maintains a strong presence in the ATI through the Advisory Board, where senior ITIC Economics Advisor Sijibren Cnossen holds a position.[40]

Sijibren Cnossen, a Professor of Economics at Maastricht University, the Netherlands[41][40] and a Professor of Economics at the University of Pretoria has also served as an advisor to the OECD and advised governments on tax system and policy issues.[42] ATI’s director, Riël Franzsen of the Faculty of Economic and Management Sciences at the University of Pretoria, has also assisted ITIC in a role as “Senior Advisor”.[43]

Africa Tax Dialogue in Mozambique

In June 2015, ITIC announced that all three - Owens, Cnossen and Franzsen - would sit on the organising committee, representing ITIC for the 7th Africa Tax Dialogue in Maputo, Mozambique 17-19 November 2015.[44]

Lobbying Against Plain Packaging

ITIC’s tobacco industry funded 2011 report, The Illicit Trade in Tobacco Products and How to Tackle It, has been used to lobby policy makers against plain packaging proposals in Brussels, Australia and the UK.

  • At a meeting on intellectual property, counterfeiting and piracy in Brussels in 2011, Daniel Witt, President of ITIC, called on policy makers to assess any potential impact on aggravating illicit trade that measures such as the introduction of plain packaging for cigarettes may have.[45] (for more detail, see below).
  • It was cited in the submission to the Australian consultation on plain packaging by Amcor, the world’s largest packaging company.[46].
  • Philip Morris used the report in its submission to the UK 2012 consultation on plain packaging to arouse concern amongst policy makers by linking smuggling, organised crime and terrorism with detrimental impacts on local communities and children:
Image 3: PMI identifies ITIC as an International Media messenger in its anti-plain packaging strategy, PMI Corporate Affairs Update, February 2012 (slide 38)
“The criminal gangs that smuggle and sell the vast majority of the nearly nine billion illicit cigarettes (and HRT [Hand Rolled Tobacco] equivalents) consumed in the UK each year operate in the hearts of local communities. Illicit cigarettes are not the only things these criminal groups bring to local neighbourhoods: they also bring smuggled alcohol, guns, drugs, and violence.(131) The man on the corner selling cigarettes to kids from the boot of his car is not acting alone – his sales fund serious organised crime and terrorism.(132)” [47]

While footnote (132) refers to the ITIC report, footnote (131) is a reference to a quote from Peter Sheridan in an article in the Daily Mail.[48] Sheridan is a former policeman often cited for his experience and expert knowledge of the fight against smuggling. His links to BAT were not disclosed by PMI.

PMI Identified ITIC as a Key Media Messenger

In 2013 leaked internal tobacco industry documents, including powerpoints, revealed the extent of PMI’s anti-Plain Packaging campaign in the UK during the previous year. The leaked documents cover the crucial time leading up to, and during the UK’s first public consultation run by the British Government in 2012. As part of its strategy, PMI identified key media messengers that it wanted to use to promote its arguments. It identified ITIC as an international media messenger. For more information see PMI’s Anti-PP Media Campaign and PMI’s “Illicit Trade” Anti-Plain Packaging Campaign

Complaints to NGOs, Academics and Peer-Review Publishers

In 2016 ITIC sent a series of complaints to NGOs (SEATCA, Action for Smoking and Health London, and the Smokefree Parnerhsip in Brussels) ,[49][50] academics[51] and the peer-review journal Tobacco Control, all of whom had criticised ITIC’s activities. ITIC’s complaints made three inter-related claims:

1. ITIC’s research should be considered credible despite its industry links;
2. ITIC is not a lobby group;
3. Public health organisations ought to engage with ITIC given its tax expertise.

SEATCA published an open letter response to ITIC which you can read here.

Recruits High-Level ex-Tax Officials

In May 2015 the former Head of Corporate Tax at HMRC, Dave Hartnett, was criticised for taking a position as a Director at ITIC alongside representatives from the tobacco industry.

Hartnett had previously been involved in disputes over “generous” tax deals with global corporations and had been condemned for his advisory work with HSBC, an international corporate bank, since leaving HMRC.[5] Health campaigners expressed concerns that Hartnett should have declared his role, as he chaired meetings for ITIC and presented at its conferences less than two years after leaving his senior civil servant position.[5] In a statement, Hartnett claimed that he was, along with other “leading figures in taxation”, a nominal director of ITIC:

“I am not paid for that role [with ITIC]… I am not an executive director and do not in any way direct the strategy or business of ITIC. I know ITIC as a not-for-profit research and education organisation, which supports the development of tax systems in less developed countries.”[5]

Subsequently, the World Bank announced it was pulling out of a tax conference funded by several of its transnational tobacco company supporters given mounting concerns about ITIC and its role in undermining health policy.[5]

Backlash Against ITIC

In May 2015, the tobacco control community successfully pressurised the World Bank to withdraw its financial support for the 12th Annual Asia Pacific Tax Forum in New Delhi, which was being organized by ITIC and therefore indirectly sponsored by tobacco companies.[52] In May 2017, the UK’s Financial Times reported that ITIC asked tobacco representatives to resign from its board and no longer accepts sponsorship from tobacco companies.[4]

TobaccoTactics Resources

Relevant Link

Tax and Investment Center Website

TCRG Research

Notes

  1. International Tax and Investment Center, Homepage, accessed June 2012
  2. International Tax and Investment Center, 1995 Results and Work in Progress, 1995, Bates No: 800210512-800210513, accessed October 2015
  3. International Tax and Investment Center, Sponsors Roster, accessed October 2015
  4. 4.0 4.1 4.2 P. McClean, Big Tobacco lobby group quits smoking industry. Financial Times, 19 May 2017
  5. 5.0 5.1 5.2 5.3 5.4 J. Doward, Former UK tax chief under fire for joining smoking lobbyists, The Guardian, 16 May 2015, accessed June 2015
  6. International Tax and Investment Center, ITIC Participates in IMF/World Bank Spring Meetings and Conference on International Taxation, 19 April 2015, accessed October 2015
  7. 7.0 7.1 7.2 International Tax and Investment Center, 11th Annual Eurasia Tax Forum, Bulletin, September 2015, accessed October 2015
  8. 8.0 8.1 8.2 International Tax and Investment Center, ITIC Special Edition Bulletin Africa Tax Dialogue, accessed October 2015
  9. 9.0 9.1 9.2 International Tax and Investment Center, Africa Program, accessed October 2015
  10. 10.0 10.1 Tobacco Free Kids, The Truth about the International Tax and Investment Center, May 2010, accessed October 2015
  11. U.S. Department of Treasury, Internal Revenue Service, Form 990, Return of Organization Exempt from Income tax, 2008, accessed October 2015
  12. G. Hastings, K. Angus, The Influence of the Tobacco Industry on European Tobacco-Control Policy, in Tobacco or Health in the European Union, Past, Present and Future, Chapter 6, accessed October 2015
  13. International Tax and Investment Center, Promoting Tax & Investment Reforms, Annual Report 2008, accessed June 2012
  14. World Health Organisation, Guidelines for implementation of Article 5.3 of the WHO Framework Convention on Tobacco Control, accessed October 2015
  15. D. Robinson, Tobacco lobby aims to derail WHO on tax increases, Financial Times, 6 October 2014, accessed October 2015
  16. 16.0 16.1 D. Witt, President of ITIC, International Briefing on Tobacco Excise Taxation for Ministry of Finance and Tax Administration Representatives, 12 August 2014
  17. International Tax and Investment Center, Anti-Illicit Trade of Tobacco Products, Conference Brochure, International Conference, Brussels, 4-6 November 2009
  18. Kangaroo Group,Who we are, accessed October 2015
  19. Kangaroo Group, The Board of the Kangaroo Group, 22 November 2011, accessed June 2012
  20. PR Newswire, ITIC (International Tax and Investment Center) Raises Alarm to EU Policy Makers About Galloping Illicit Tobacco Trade, 27 May 2011, accessed October 2015
  21. E. Herczog, D. Witt, Tobacco smuggling: Edit Herczog MEP, The parliament.com, 1 December 2011, accessed June 2012
  22. International Tax and Investment Center, Calendar of Events, accessed June 2012
  23. ITIC, Oxford Economics. Asia-11 Illicit Tobacco Indicator 2012, 2013, accessed January 2016
  24. Southeast Asia Tobacco Control Alliance, Asia -11 Illicit Tobacco Indicator 2012: More Myth than Fact A Critique by SEATCA, 2014, accessed January 2016
  25. J. Chen, S. McGhee, J. Townsend et al, Did the tobacco industry inflate estimates of illicit cigarette consumption in Asia. An empirical analysis, Tobacco Control, 2015, 24:e161-7
  26. International Tax and Investment Center, The Illicit Trade in Tobacco Products and How to Tackle It, 19 April 2011, pdf of report available from the ITIC website, accessed June 2012
  27. Asia-14, Illicit Tobacco Indicator 2013, prepared by the International Tax and Investment Center and Oxford Economics, September 2014, accessed January 2016
  28. The Economics of Tobacco Control Project, Hana Ross: Principle Research Officer and SALDRU Affiliate, University of Cape Town, accessed February 2016
  29. 29.0 29.1 H. Ross, A critique of the ITIC/OE Asia-14 Illicit Tobacco Indicator 2013, 20 May 2015, accessed January 2016
  30. A. B. Gilmore, A. Rowell, S. Gallus et al, Towards a greater understanding of the illicit tobacco trade in Europe: a review of the PMI funded ‘Project Star’ report, Tobacco Control, 2014;23:e51-e61
  31. Asia-16 Illicit tobacco Indicator 2014, Prepared by Oxford Economics, October 2015, accessed December 2015
  32. Report: ‘One in three cigarettes illegal’ findings questioned by experts, Macau Daily Times, 5 November 2015, accessed January 2016
  33. M. U. Caraballo, Oxford Economics rejects bias claims over tobacco studies, The Manila Times, 30 September 2015, accessed December 2015
  34. 34.0 34.1 International Tax and Investment Center, ITIC Bulletin September 2013, 9 September 2013, accessed October 2015
  35. 35.0 35.1 International Tax and Investment Center, Academy of Public Finance, accessed October 2015
  36. Vienna University of Economic and Business, Institute for Austrian and International Tax Law Academy of Public Finance, accessed October 2015
  37. Vienna University of Economic and Business, Institute for Austrian and International Tax Law, Global Tax Policy Center, accessed October 2015
  38. University of Pretoria, The African Tax Institute, accessed October 2015
  39. University of Pretoria, ATI engaged with the WU Global Tax Policy Center, 12 June 2015, accessed October 2015
  40. 40.0 40.1 University of Pretoria, Africa Tax Institute, ATI Advisory Board, accessed October 2015
  41. The MIT Press, Sijibren Cnossen, accessed October 2015
  42. International Tax and Investment Center, Sijibren Cnossen Senior Advisor, accessed October 2015
  43. International Tax and Investment Center, Riël Franzsen Senior Advisor, accessed October 2015
  44. International Tax and Investment Center, ITIC Bulletin May/June 2015, 27 May 2015, accessed October 2015
  45. ITIC warns on growing illicit tobacco trade, Tobacco Journal, 30 May 2011, accessed October 2015
  46. Amcor, Submission to the Common Wealth Government to the Tobacco Plain Packaging Bill 2011, 3 June 2011, accessed August 2013
  47. Philip Morris International, Standardised tobacco packaging will harm public health and cost UK taxpayers billions: A response to the Department of Health consultation on standardised packaging of tobacco products, 9 August 2012, accessed March 2017
  48. P. Sheridan,Plans for plain packaging of cigarettes are a charter for organised crime and a danger to our children, 22 June 2012, accessed October 2015
  49. D. Witt. Joint letter to F. Berteletti Director of the Smokefree Partnership and Deborah Arnott, Chief Executive of Action on Smoking and Health UK. 29 April 2016
  50. G. Johns. Letter to B. Ritthiphakdee, Executive Director, Southeast Asia Tobacco Control Alliance. 20 April 2016
  51. Letter to G. Breakwell, Vice Chancellor at the University of Bath. 9 May 2016
  52. S. Dey, Bank exits event funded by tobacco companies, The Times of India, 2 May 2015, accessed October 2015.