KPMG

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Background

KPMG is a global accountancy firm, one of the so-called “Big Four”, along with Deloitte, PricewaterhouseCoopers (PwC) and Ernst and Young.
In 2019 KPMG employed 219,000 people across 147 countries and territories and had global revenues of $29.75billion.1

Relationship with the Tobacco Industry

KPMG has strong ties to the tobacco industry dating back decades. It audits individual firms, conducts analysis that is used by the industry to resist tobacco control legislation, and has provided strategy advice to a tobacco company seeking to burnish its corporate reputation.

Work for the tobacco industry has generated multi-million dollar fees. For example, from 1994 – 1998 KPMG generated revenues of approximately US$47million from consulting and information technology engagements with one tobacco company, Philip Morris (PM).2 Work included conducting a business case study in 1995 on ways to improve the visibility in shops – “an important advertising medium” as PM put – of Marlborough and other PM brands.3 A further substantial KPMG engagement in 1999 was to improve PM’s records and information management systems.45  KPMG earned UK£24.7million from British American Tobacco (BAT) in 2019 for audit and audit-related services.6

Audit Work for Tobacco Companies

  •  British American Tobacco (BAT): KPMG has provided external auditing services to BAT since 2015,7 and BAT says it doesn’t anticipate putting the contract out to tender before it is required to do so in 2025.6
  • Reynolds American: KPMG has audited this firm since at least 2000.8
  • Conwood Capital Corporation: KPMG was the auditor for smokeless tobacco company Conwood in 1997-98.2
  • Cigarette Company of Jamaica: KPMG audited for the Cigarette Company of Jamaica in 1989.9

Helping BAT Redefine Itself as a ‘Responsible Business’ to Regain Influence

In the late 1990s, as the tobacco industry’s 40 year campaign to deny the health effects of tobacco was exposed and tobacco companies found themselves facing increased regulation and excluded from public policy discussions, BAT sought to reposition itself as the responsible company in a controversial industry in a bid to regain its influence and “control of its own destiny”.10

Two of the Big Four firms pitched for the work to help BAT develop its corporate responsibility programme: BAT’s then external auditors, PwC in May 1999 – the same month that the World Health Assembly approved the start of negotiations on the Framework Convention on Tobacco Control, the first global public health treaty11 – and in July that year, KPMG.

In a preliminary meeting with BAT, KPMG stressed that the tobacco giant needed to “address the controversy regarding [its] product”.12 “To hang [BAT’s] flag on the mast of corporate responsibility without addressing this issue would be a futile effort,” KPMG said. A board-level public commitment from BAT to “deal with the smoking and health issue”, was needed. KPMG was clear, however, that there was no need for the tobacco giant “to adopt a strategy to get out of the tobacco industry”.

A KPMG presentation in November 1999, called ‘The Project; The Way Forward’10, gives some insight into BAT’s rationale for wanting to become a leader in corporate responsibility, which has little to do with dealing with “the smoking and health issue”:

BAT is keen to engage with its stakeholders, who include governments and regulators, to facilitate the development of fair regulation. But engagement has proved difficult because of the level of distrust of BAT and the tobacco industry. However, BAT believes that it can contribute proactively to the debate on regulation through a demonstration of willingness for a responsible level of self-regulation.”

In other words, BAT was not motivated by its corporate responsibility to address the multiple harms caused by its products and actions, but by a desire to show that it can responsibly police itself and, as a result, reestablish its influence over public policy.10

The proposed strategy included a series of actions that KPMG determined would be credible enough to show that BAT was a “responsible company within a controversial industry”. Broadly these were designed to demonstrate “a new and ethical business approach”; “a genuine long-term commitment to… minimising health risks”; and a commitment to ensuring consumers are “fully informed” and have “a free choice”.

Crucially, KPMG’s recommendations focused on BAT taking voluntary action on public health issues, such as curbing underage smoking, and working with governments to “guide legislation”. It also proposed extensive funding of research and on making high profile gestures, such as publicly withdrawing from the “slow-moving and historically defensive” industry group, the Tobacco Manufacturers’ Association.

In this way, perceptions of BAT would shift and, according to KPMG, the tobacco firm would begin to “regain influence and control of its future”.

It is notable that KPMG – which advised BAT in the strategy document that it “needs to demonstrate honesty, openness and transparency in everything it does” to position itself as a leader on corporate responsibility – has a history of working on deceptive tobacco campaigns that have sought to undermine tobacco control measures. For example, conducting studies for third-party tobacco groups, such as the  Coalition Against Regressive Taxation that were used by the industry to oppose tobacco taxes and regulations.1314

Helping BAT Counter the Threat of a Global Public Health Treaty

At the same time as advising BAT on its corporate responsibility strategy, KPMG began work on a project to promote BAT – and tobacco industry as a whole – as socially responsible in the context of the tobacco industry’s campaign to counter the World Health Organisation’s proposed Framework Convention on Tobacco Control (FCTC).15

The FCTC, which was adopted in 2003, introduces global standards designed to limit the use of tobacco through rules covering its production, sale, distribution, advertisement, and taxation. The industry, led by BAT, sought to head off the threat it posed to its business by promoting a voluntary global tobacco industry regulatory regime as an alternative to the FCTC.11 BAT also developed a voluntary advertising code to be overseen by an independent audit body, as a backup.11 It is notable that KPMG warned in its BAT strategy document ‘The Way Forward’ that the perception exists that “resisting legislation initiatives on advertising and promotional activity… signals irresponsibility and a lack of concern for the issues”.10

KPMG proposed to help BAT build a “credible proposition” in relation to its work to counter the FCTC; highlight areas of BAT’s plan that may damage its credibility and ensure that BAT’s proposals became a “powerful tool” for the tobacco firm and wider industry, rather than seen as a “spoiling tactic, which backfires on BAT”.15

Producing Information to Support Tobacco Lobbying

KPMG, like the other Big Four firms, has produced tobacco-funded studies that have been used to support industry lobbying against tobacco control regulations and are often directed at persuading policymakers and the media.

For example, Peat Marwick, which merged with KPMG in 1987 to form KPMG, produced Economic Impact Studies for the Canadian Tobacco Manufacturers’ Council from 1978 to at least 1987.16 KPMG has also produced studies for tobacco industry allies and proxies, such as a 1989 study on the American tax system for the Coalition Against Regressive Taxation (CART), a collection of industries organised by the tobacco industry lobbyists to counter the threat of increased excise taxes;17 market research in 1998 for the American Beverage Institute on the impact of the Californian smoking ban on the hospitality industry;18 and a 2000 study for the National Association of Convenience Stores on the impact of a ban on self-service cigarettes sales.19

KPMG’s Illicit Tobacco Studies Used to Oppose Plain Packaging in the UK

One of the central arguments used by the tobacco industry to oppose the introduction of plain packaging regulations has been that plain, or standardised packaging will lead to an increase in illicit tobacco , principally because it will make counterfeiting easier.

Since 2005 KPMG has produced reports on the scale of the illicit trade in tobacco products in the European Union (EU) and in Australia which have been used in the media to argue against the introduction of plain packaging.202122

Philip Morris International’s (PMI) 2012 strategy to prevent plain packaging in the UK, for example, mentioned a KMPG report as part of a “workstream” which included “submissions (including reports and studies)” (see Image 1).

Image 1. PMI Corporate Affairs Update, March 2012

KPMG’s research has been severely criticised in both Australia and the UK (see below), with questions raised about its independence and whether the company effectively acted as a third party advocate for the tobacco industry.

Project Star

In 2004, PMI signed an Anti-Counterfeit and Anti-Contraband Cooperation Agreement with the European Commission.23 As part of this agreement, PMI commissioned KPMG “to measure the size of the legal, contraband and counterfeit markets for tobacco products in each of the 25 EU Member States”. KPMG’s study of the illicit market was to be undertaken on an annual basis.

Initially KPMG’s remit was to produce an annual PowerPoint presentation. but by 2010 the research findings were written up in a report called “Project Star”, which was eventually published in 2011 after a European Freedom of Information Request, albeit with sections redacted. 24 25

The PMI contract has been estimated to be worth £10 million, and is led by Robin Cartwright, who joined KPMG from the British security service MI5.26

Methodology and Data Criticised

In April 2013, PMI claimed that levels of illicit tobacco in the EU rose from 10.4% in 2011, to 11.1% in 2012, citing KPMG’s 2013 Project Star study as evidence.27

This was not an accurate reflection of the data according to the study’s small print. The report warned that, due to a subtle change in methodology the 2012 data could not be accurately compared with the previous year’s data, and that this change would lead to an overestimate in 2012 compared to 2011.28

Academics, including University of Bath researchers, conducted a review of the 2010 Project Star report and compared the KPMG data to independent data. They concluded that there was little information provided on the Project Star methodology used to produce the illicit estimates, and that Project Star underestimated legal cross-border sales by using interviews and what are termed Empty Pack Surveys (EPSs).

The paper outlined problems with EPSs, one of the main ways which KPMG analyses the extent of the illicit market:

  • EPSs cannot distinguish between foreign packets that have had duty paid and those which have not;
  • No details were provided about the timing of pack surveys (apart from in Germany). Tourist seasons would see more foreign packs and so this information would provide important context;
  • No methodological information was given to discern whether EPSs were conducted via a random selection of areas to ensure that the sample was representative of the population. No description was given of how areas were selected and only large cities were included and therefore non-urban areas were under-represented. For example, those who are more deprived are more likely to use illicit tobacco293031 and live in urban areas.3233

Furthermore, there was inadequate external validation of the data, which was mostly validated by tobacco companies who arguably have a vested interest in overestimating the illicit trade.

Moreover, the report revealed that approximately 25% of the illicit trade market in Europe in 2010 was made up of genuine PMI brands. This is against the Illicit Trade Protocol, where tobacco companies are accountable for ensuring their supply chain is adequately controlled. PMI did not publish this data when presenting the findings of the 2010 report.

In other words, far from showing the level of illicit trade in the UK to be rising, the figures suggested it was actually falling. This corroborated data from Her Majesty Revenue and Customs (HMRC) indicating that the illicit tobacco trade has actually been declining over time, although a small increase from 2011-12 to 2012-13 was noted in the estimated figures from 2012-13. The 2012-13 estimated figure for the UK was 9% which is the same as the 2010-11 figure.34

Cited in PMI Submission to 2012 UK Plain Packaging Consultation

To argue that illicit trade is a significant problem in the UK, PMI cited KPMG’s Project Star report in its submission to the 2012 UK Consultation on plain packaging stating: “nearly 11 billion units of illicit tobacco products are consumed in the UK each year, equal to more than 10% of the total UK cigarette market…”3536 PMI goes on to argue that plain packaging will make the current situation worse. For a counter argument go here:

Project Sun

In 2014, the annual Project Star report was changed to Project Sun, with the report no longer commissioned by the European Commission, but by four tobacco companies: BAT, Imperial Tobacco, Japan Tobacco International (JTI), and PMI.37

Contradicted Industry Argument That Illicit Levels Were Rising Rapidly in UK

When the British government announced that it was to consult on introducing plain packaging in 2011, dozens of industry-generated reports in the UK media argued that levels of illicit cigarettes were increasing rapidly, and that plain packaging would make the situation worse.38 See also:

Project Sun actually revised its estimate for the UK illicit trade downwards for 2013. The report stated that “alternative data sources suggest this 2012 estimate may have overstated non-domestic incidence for the full year”. KPMG claimed that additional data which were not previously available to them “suggest there has been a more gradual decline from 2011 to 2013″.

Despite this admission, neither KPMG nor the tobacco companies made any attempt to correct the misleading stories in the British press in light of the new analysis.

KPMG’s Australian Illicit Tobacco Data Strongly Criticised

KPMG has also produced bi-annual reports, commissioned by tobacco companies, to examine whether the introduction of plain packaging in Australia led to an increase in tobacco smuggling.39

The reports have been strongly criticised by the Australian government, academics and Sir Cyril Chantler (see below), the paediatrician who examined the health benefits of plain packaging for the UK government.

“Substantially exaggerates” size of illicit in Australia

In a damning critique of KPMG’s research on illicit trade, the Australian Government published the following:

“The tobacco industry‘s estimates of the size of the illicit market are not considered to be accurate. A KPMG report prepared for the tobacco industry (British American Tobacco Australia, Philip Morris Ltd and Imperial Tobacco Australia Ltd) and released on 4 November 2013, claims that during 2012-2013, consumption of illicit tobacco grew from 11.8 per cent to 13.3 per cent of total tobacco consumption in Australia. The report claims that this represents a loss of $1 billion in excise revenue.”40

The government continued: “Like previous illicit trade reports commissioned by the tobacco industry, the KPMG report appears to substantially exaggerate the size of the illicit tobacco market in Australia and the consequent loss of excise and duty revenue.”

The Government’s criticism was in part based on analysis of KPMG’s methodology by Quit Victoria and the Cancer Council Victoria, who concluded that:

“In addition to the very real possibility of over-sampling of foreign packs, the proportion of foreign packs that are contraband is also likely to be overestimated due to KPMG substantial underestimation of legal non-domestic consumption. KPMG appears to have underestimated likely amounts brought into Australia both by Australian residents returning from overseas visits and by overseas students and other visitors. And it has neglected to include foreign packs brought in by individual travellers or mailed in excess of personal limits but on which customs duty has been paid. The total market for illicit tobacco in Australia is likely to be substantially smaller than is suggested in the KPMG report”.41

“I do not have confidence in KPMG’s assessment”

In his report on the health benefits of introducing plain packaging published by the British Government, Sir Cyril Chantler wrote:42 “Tobacco manufacturers cite the industry funded KPMG report on illicit tobacco in Australia, which purports to show that there has been a large increase in illicit trade since the introduction of plain packaging. I have considered both this report and a critique. My team have also met with KPMG in order to understand their methods.”

Sir Chantler concluded that: “I do not have confidence in KPMG’s assessment of the size of – or changes in – the illicit market in Australia.”

Other KPMG Research on Illicit Tobacco: Northern Africa, India and New Zealand

On 26 July 2017, KPMG released a report on illicit cigarette trade in the Maghreb region in Northern Africa, commissioned by PMI.43 The report included additional qualitative analysis conducted by the Royal United Services Institute for Defence and Security Studies (RUSI) – an organisation that, like KPMG, was awarded funding from PMI IMPACT (a PMI research funding initiative) to conduct research on illicit trade and organised crime.44

On 12 October 2017, KPMG released a report in conjunction with the Federation of Indian Chambers of Commerce & Industry (FICCI) (an association of Indian business organisations), titled ‘Illicit trade: Fueling terror financing and organised crime’.45 As with many other KPMG reports, its findings were widely-publicised by media outlets.464748

On 20 July 2018, KPMG released a report on illicit tobacco in New Zealand, commissioned by Imperial Tobacco NZ.49 The report included data from a consumer survey carried out by Kantar New Zealand, commissioned by BAT NZ, Imperial Tobacco NZ and PMI. It estimated that 9.2% of total tobacco consumption in New Zealand was illicit.50 Previous estimates from 2009 suggested illicit tobacco made up only 1.0 – 1.1% of total tobacco consumption in New Zealand.51 The 2018 report was released approximately four months after New Zealand’s Ministry of Health announced a review of tobacco excise tax,52 and was publicised throughout the national media.535455 Acting Prime Minister Winston Peters responded to the report by suggesting high tobacco excise tax was fuelling violent crime.

Potential Conflicts of Interest

As well as providing consultancy and other services to the tobacco industry, the Big Four accountancy firms also provide services to governments around the world. This can lead to potential conflicts of interest.

Embroiled in South African Controversy

In December 2014, KPMG was commissioned by South African President Jacob Zuma to conduct an investigation into allegations that a covert unit with the South African Revenue Service (SARS) had spied on the President and other politically-connected figures.56

It followed allegations that some senior KPMG South Africa executives were involved with businesses linked to the Gupta brothers – a powerful family who were accused of using their friendship with Zuma to profit financially and influence ministerial appointments. In September 2017, KPMG announced that it was withdrawing the findings and conclusions of its report on its SARS investigation.57

The KMPG report was described by some as a contribution toward ‘state capture’ of the SARS, with former finance minister Pravin Gordhman stating that: “KPMG had no basis‚ except subservience to a malicious SARS management‚ to malign a number of individuals and facilitate the capture of a vital state institution.”58

KPMG came under scrutiny for serving as auditors for BAT, who also featured in the SARS allegations. The former UK public relations company Bell Pottinger was also implicated for its relationship to the Gupta family, ultimately leading to it being forced into administration.

“Conflicting” Role in Tobacco Privatisation in Uzbekistan

A 2007 peer-reviewed paper59 examining the privatisation of the tobacco industry in post-Soviet states, demonstrated that KPMG had a “potentially conflicting” role in the privatisation processes, by not only being appointed by the State Privatisation Agency (GKI) to advise on privatisation, but also lobbying for Philip Morris International (PMI) in the country.

Controversies Outside of the Tobacco Industry

Like all the big accountancy firms, KPMG has been implicated in a number of high profile scandals and controversies in recent years. These include:

Audit failures

KPMG has been investigated and fined for the poor quality of its audits. In its 2020 annual audit quality review, the Financial Reporting Council ranked KPMG bottom among the []Big Four firms, with only 61% of its sampled audits meeting industry standards.60 In 2020 KPMG faced a £250m lawsuit over alleged negligence in its audits of the outsourcing group, Carillion, which collapsed in 2018.61

Selling tax avoidance

Like the other Big Four firms, KPMG has a history of developing and marketing complex tax avoidance schemes. Academics at the Centre for Accountability and Global Development at the University of Essex, writing in 2013 on the ‘Tax Avoidance Industry’ state:

“KPMG devoted substantial resources and maintained an extensive infrastructure to produce a continuing supply of generic tax products to sell to clients, using a process which pressured its tax professionals to generate new ideas, move them quickly through the development process, and approve, at times, illegal or potentially abusive tax shelters.”62

Role in privatisation

KPMG has been involved in the privatisation of public assets and services, providing advice to both governments looking to sell off and outsource services and corporations seeking to profit from the process. For example, the firm has been involved in recent efforts to restructure the National Health Service (NHS) in England. In 2010, KPMG’s head of health, Mark Britnall, told a conference of private sector executives that future NHS reforms would show “no mercy” to the NHS and offer a “big opportunity” to the for-profit sector. He also said the NHS will be transformed into a “state insurance provider, not a state deliverer” of care.63

Corporate culture

In 2019 KPMG was reported to the UK’s Financial Reporting Council by a former employee who called on it to investigate how the firm responded to complaints about a top partner accused of bullying.64

TobaccoTactics Resources

Relevant Links

TCRG Research

References

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