Supporting tobacco harm reduction is more than just pragmatic positioning to appease financial analysts and stakeholders. For Imperial Brands, one of the world’s major tobacco companies, THR represents a consumer-focused commitment to helping individuals switch to less harmful forms of tobacco. It's a strategy that balances both head and heart, reflecting a thoughtful approach to the future of safer nicotine products.
Featuring:
Joe Thompson
Group Science & Regulatory Affairs Director, Imperial Brands
imperialbrandsplc.com
Transcription:
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Brent Stafford: Hi, I'm Brent Stafford and welcome to another edition of RegWatch on GFN.TV. We're here in Warsaw, Poland for the Global Forum on Nicotine 2024 and sitting with me is Joe Thompson. How's it going, Joe?
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Joe Thompson: Very well, thank you.
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Brent Stafford: So, you are the Group Science and Regulatory Affairs Director at Imperial Brands.
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Joe Thompson: That's correct.
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Brent Stafford: Let me ask you, and I ask this often to folks in the industry, is that why the grouping of science and regulatory affairs?
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Joe Thompson: Yeah, it's a good question. I think mainly because we're a heavily regulated industry. We're heavily scrutinized. and much of the science we're doing is for compliance reasons. It's to comply with technical product regulation. So it enables us to do that, it enables the science we're going to take, enables us to assess product safety, which is often relative to combustibles. It provides the data that we give to governments and regulators worldwide. I think we were reporting 53 to 58 countries, providing them with technical data, scientific data on our products. Some of those products need to be approved before sale. Proving out harm reduction and engaging with regulators on the science of our products. So the two kind of go hand in hand, so often you'll find the science and regulatory teams very tightly net, and that's the case for Imperial. So is your background science or is it on the regulator side? Both. So I've been with Imperial for over 20 years. I'm a scientist by training, physiology, then toxicology, but I've been on both the regulatory and the scientific side for a long time. Tell me about the challenges that your company faces dealing with the regulators. Well, let's first start with the consumer, because we serve the consumer and about identifying their needs and creating products for them that they choose. As part of that, you have the scientific data that you generate and you provide that to regulators. I think some of the challenges probably for the regulator is, do they trust the data? Do they trust the science? And Our part in that is being open, being transparent, ensuring that the science that we provide is peer-reviewed. It's open to scrutiny, open to challenge, but certainly that trust, building that trust with regulators is probably the biggest challenge.
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Brent Stafford: In your experience, has the regulator ever looked at the user as a consumer?
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Joe Thompson: No, not in my experience. They tend not to look at them as consumers. In fact, sometimes refer to them as patients. So they've medicalised it? They've medicalised it. It's a generalisation, not in every market, but certainly that's been an experience, but never referred to as consumers. So you mentioned it, you're NGPs. Yes. Tell me about that. So NGP is a term we use for next generation products, which is non-combustible consumer products that contain nicotine. So we have three main categories, three main brands. We have a heated tobacco product called Pulse, we have a vaping product with the brands Blue, and we have oral nicotine pouches and the brands Zonex.
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Brent Stafford: Now, Blue actually has gotten some traction, hasn't it?
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Joe Thompson: Yes. Yes, it has. So, Blue is probably one of the biggest brands, vaping brands globally. It's got quite a long history in the US. But we've developed the product, we've had different iterations of devices, and it's now gaining traction. We had a bit of a reset in terms of strategy across NGP maybe four years ago, and said, look, these products aren't meeting consumers' needs. We need to look again, develop them further, and then go into markets where there is a genuine demand for them, where the regulation is clear, and where we've got a right to play and a right to win. So there was a bit of humility there and humbling of actually looking at ourselves and looking at what the consumer really needs and begin to develop that. And we've continued that in terms of our innovation and are continually looking across the board for heated and for vaping to say, okay, well what do we need to change, what's working for consumers, what's not, what's going to help them move from combustible cigarettes to a potentially less risky product. So, how important then is tobacco harm reduction for Imperial? Critically important. We are absolutely committed right from the PLC board all the way through the organisation to making a meaningful contribution to harm reduction.
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Brent Stafford: So, tobacco control, you know, the critics will always say, well, if they were really serious, they would just stop selling combustible cigarettes.
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Joe Thompson: They would say that, but that's a little bit of a naive view. I think, you know, let's start here. Tobacco should be controlled. Harm reduction is part of tobacco control. And the reality is that all the work that has gone into next-generation products and in developing those products and providing them for consumers, for them to choose, is funded by cigarettes, and actually the consumer will ultimately choose. The consumer will choose the cigarette or the consumer will choose the next generation product. You can have the best product in terms of scientific safety profile, reduced risk product, but if the consumer does not wish to choose it, then you don't have harm reduction.
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Brent Stafford: Joe, what I really love about this conversation is how much you're referring to the user as a consumer. It strikes me that regulators don't see them as consumers. Public health, tobacco control, they don't see them as consumers, but yet they are consumers.
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Joe Thompson: They are consumers, and they're adults, they're informed adults, and they want to make a choice. And whether a consumer is smoking or using next-generation products, they're doing so for moments of enjoyment and pleasure, and it's their choice to make.
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Brent Stafford: Is the vapour product more popular than, say, the heated tobacco product?
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Joe Thompson: It really depends country by country, or as we'd refer, market by market. So, if you look at the UK, vaping products have proved very popular and have you know, demonstrated some success in terms of harm reduction, you can see the parallel between smoking rates declining at the same time as vaping rates increasing. Other markets such as Greece, Italy, heated tobacco product seems to be the consumer's choice.
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Brent Stafford: One of the questions that I always like, and it's always a tough one, is that how do you handle the use of the term safety?
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Joe Thompson: Yes, so we tend not to use the term safety. Let's be clear, these products are marketed to adult smokers and we assess them in terms of their risk, their relative risk to combustible cigarettes. And science is very clear in building confidence that these are substantially less risky than cigarettes. They offer great potential for harm reduction, but we don't have long-term data, we don't have epidemiology data yet, it will come, that could make stronger statements than that. So, we don't refer to the products as safe or safety.
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Brent Stafford: Do you think that when that data does finally come in, that anybody's going to take it seriously? Because it just seems that science from a tobacco company is ex-nominated from the conversation?
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Joe Thompson: I think that's the challenge and that will always be there, will be always questioned. I think there are two things. All that we can do is be open and transparent with our science, ensure that it's published, open it to peer review, to criticism, to challenge on the one hand. And on the other hand, it's not just the industry that's researching this. So you have academic institutions globally, there's over 100 clinical trials that have been conducted on vaping products that demonstrate relative safety over a two-year period. So there's a lot of science out there that is not industry generated. So, of course, the industry knows its products best and you would expect, in fact, we've got a common law obligation to be experts on our own products. So, the science we do is sound, is solid, but recognise it will always be viewed with some scepticism.
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Brent Stafford: So, does the company utilise value, say, the meta-analyses coming out of Cochrane and, say, the science coming out of University College London?
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Joe Thompson: Yes, absolutely we do, and we monitor all of the scientific and medical literature on a daily basis and assess that and look at that to say, okay, what's that telling us about those products, their safety profile, their risk reduction potential, and we do that across the category as well as looking specifically at our own products.
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Brent Stafford: Your team shared a brochure from Imperial with me and there was a section in there called the THR equation unpacked.
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Joe Thompson: Tell us about that. So the tobacco harm reduction equation is really the framework by which you can reduce the demand and supply of combustible cigarettes. and it has a short version and a long version. The short version says this, that you get population harm reduction when you have a product with potential to reduce risk to the individual multiplied by consumers choosing to use the product. The longer version recognises that there's a bigger piece around consumer acceptance, which talks about the appeal of the product, so the product must appeal to adult consumers, and also addresses unintended consequences. So does the product, and to what extent does it appeal to non-smokers or to youth who we would not want to be using our product, does it appeal and does it use them? And therefore that subtracts from the equation, and of course you need the greater good, the greater benefit to harm reduction and population as a whole to vastly outweigh the risks with unintended use.
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Brent Stafford: Yeah, that's tough. You know, even though I've been on just the pure vaping side, the industry is struggling a lot with the fact that now, you know, some decade and a half coming up two decades later, there are, you know, young adults who never smoked who are choosing to use nicotine vaping products. And that's causing a massive concern. We're talking adults. People of majority age choosing to use these products and somehow to the critics that doesn't feel right because it's a new generation of users. Do you have any thoughts on that?
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Joe Thompson: Yes, I think certainly from Imperial's perspective we're marketing only to adult smokers, adult vapers, but yes, we recognise that there is a number of non-smokers or never-smokers that are choosing to use nicotine-containing products. What does that tell me? It tells me that there is demand for that. We'll see what society says about that demand, I think. It's a sticky weekend, isn't it? Yeah, well, I think time will tell and we'll see what society says about that. But a lot of the issue and the concern comes from, frankly, the misperceptions around nicotine, which is, you know, The misperception is, well, nicotine equals tobacco, therefore, equals disease. Therefore, nicotine must equal disease. And it's a complete misunderstanding of the safety profile of nicotine. And it misunderstands that actually it's the components within cigarette smoke are the problem, not the nicotine.
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Brent Stafford: Should the conversation be switched to recreational nicotine?
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Joe Thompson: I think, as I said before, I think it's probably a question for society in time. We're marketing to adult smokers.
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Brent Stafford: Well, I bring that up only because nicotine is already legal in most places recreationally. It is. In a cigarette. It is. Yeah. Yeah. So, it seems to need tobacco control in some places or, you know, recreational nicotine is okay as long as you use it in a cigarette.
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Joe Thompson: You'd have to ask them what their thinking is around that.
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Brent Stafford: Joe, you mentioned that there was a bit of a humbling moment for the company over the last couple of years, just in terms of your approach. I noticed that in the brochure, which was there was kind of a mention that we're not the biggest guy on the block and to take that into account with the planning. How is that?
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Joe Thompson: Yes, absolutely. So we're trying to really ensure that we have good consumer insights and really understand our consumers and the consumers that we're trying to meet their needs, and then doing that in a targeted way, both in how we innovate and how we develop products, but then also which markets we go to and where we pilot. and then get feedback and feedback from consumers before taking decisions on do we roll products out to other markets.
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Brent Stafford: What can you tell us about the experience in the US? Can you address anything there? I mean, it's a bit of a quagmire, right?
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Joe Thompson: I think certainly in the United States they've set out a framework which allows for regulatory oversight, approval of products that are deemed appropriate for the protection of public health, and potentially to be marketed with the right authorisation as reduced risk. The reality has been very difficult and many companies have spent millions of pounds, millions of dollars, trying to pass the standard, pass the test, without… it's like taking an exam but you don't really know what the syllabus is or the pass mark. And it's, I think, looking from the UK across it seems a bit of a mess, and further confused by the FDA approving a combustible cigarette as a modified risk tobacco product, which seems very odd to me. There is a combustible cigarette which has a lower level of nicotine that has been… Century 21 or century… 21st century, I believe, was the company. But yeah, but the FDA deemed that that's a modified-risk tobacco product, and yet vaping products with potential to reduce risk have been denied or are under lengthy scientific review?
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Brent Stafford: Well, in the last couple of years, while they refused to really grant marketing orders for vapour products, they have approved 1,200 new combustible cigarettes. It's a lot. Yeah. So, under the SE, substantial equivalent.
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Joe Thompson: Okay, substantial equivalent.
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Brent Stafford: Yeah. So, but that's still putting 1,200 cigarettes on the market. It is. So, FDA Commissioner Robert Califf, in an appearance before the House Oversight Committee back in early May, maybe late April, He was asked multiple times about tobacco harm reduction and whether or not the FDA believes in tobacco harm reduction. And not only does it appear like they don't believe it, his answer over and over and over again was that THR is an industry term. He referred to it as that.
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Joe Thompson: I think that's astonishing, frankly, and I think that those involved in harm reduction would be appalled, because there are many that are not supporters of the tobacco industry, but they have great belief in harm reduction, so I think they'd be appalled by that. And in fact, Maybe he needs to speak to his own advisors, because I think harm reduction goes back certainly 1994, Neil Benowitz, Jack Henningfield, both respected scientists in their fields, terms Harm Reduction Institute of Medicine Clearing the Smoke publication in 2001 sets out a framework for tobacco harm reduction, sets out the reasons why, uses analogy from other harm reduction programmes and sets out, well, this is how you would do it scientifically. So it's not an industry invention, would love to take credit for it, but I can't take credit for that.
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Brent Stafford: Yeah, it sounds like to me that just because the industry is starting to use it, they're saying that they're denigrating it, right? They're saying, well, the tobacco industry is not a valid participant in tobacco harm reduction. I guess that's what they're saying.
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Joe Thompson: Which is, I think, crazy. There's over a billion smokers out there. There's a billion people on their own journeys. And we have a role in understanding those consumer needs and providing them with choice. And part of that choice is products that have the potential to reduce their own risks.
00:19:17 --> 00:19:23
Brent Stafford: So when you look around here in Warsaw at the Global Forum on Nicotine, why is an event like this important?
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Joe Thompson: Why is it important? I think because the industry is part of the solution, and it's important for us to understand different views and different perspectives and to be humble about that and to learn. So that's why we're here, we've got a contribution to make, but actually we want to listen, we want to learn, we want to understand the views of stakeholders, what the challenges are, what the barriers are to harm reduction and identify what our role is in supporting it.
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Brent Stafford: So as a question I ask anybody who works in the tobacco industry, and it's the last couple of years I've asked this question, is that like, do you kind of feel like you've been pinched, like there's no room for redemption? Because here you are trying to put forward something that is much safer, much safer than the combustible tobacco. and yet you're getting raked over the coals.
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Joe Thompson: I don't think we look at it in terms of redemption at all, I think we look at it in terms of consumer, what's the consumer's need there, and how do we meet those needs, and how do you do that responsibly with cigarettes, but how do you offer them products whereby they can control their own risk, reduce their own risk of disease, and understand the drivers and the barriers to help them shift to potentially less risky products.
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Brent Stafford: How important is it for the industry to demonstrate commitment to tobacco harm reduction?
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Joe Thompson: To demonstrate it? I think it's very important. I think it's what, well, to ourselves as an employee of the company, it's what we expect of each other. and certainly to shareholders, to investors, it's what's expected. It's our public commitment and that's what we're working towards, to make a real impact on harm reduction through our next generation products, and that includes being able to demonstrate that in market. So we've, as part of our ongoing monitoring of the science, we've recently conducted what we term actual use studies, which is to to give smokers with no intention, or to monitor smokers with no intention of quitting smoking, use of our NGPs over a six-week and then a 24-week period to see, well, do they work for you? Does it help you reduce your smoking? Did it help you quit smoking? And that's all important evidence points to say, okay, well, you can have the science in the laboratory, you can have the science in the clinic, but actually, are consumers using them and does it help them on their journey to reduce combustible cigarettes?
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Brent Stafford: Are you witnessing any of the phenomenon that's called accidental quitting?
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Joe Thompson: I'm a victim of accidental quitting, so yes. or tell, do you tell? Yeah, so I was a smoker and occasionally vaped but none of the products really, I only vaped Imperials products but didn't really do anything to help and then we had a product called My Blue and which actually is the product that's available, I think, in the US. And I gradually was vaping more and smoking less. And now I don't smoke at all and I vape occasionally. Congratulations.
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Brent Stafford: You mentioned shareholders. How important is it to demonstrate that your commitment to tobacco harm reduction to actual shareholders and key stakeholders?
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Joe Thompson: Yeah, there's an expectation that we will do that. It's part of our ESG strategy. They certainly ask us questions. Analysts ask us questions. So there is an expectation there. But there's a head part to it and there's a heart part to it. And the heart part is that it's the right thing to do.