Re:KPMG response to 'Towards a greater understanding of illicit tobacco trade in Europe: a review of the PMI funded 'Project Star' report', published in Tobacco Control (BMJ) on 11th December 2013

Anna B Gilmore, Professor of Public Health,

Other Contributors:

April 01, 2014

Dear Editor

Cartwright (1) has clearly mis-read our article on PMI's Project Star report(2). The central premise of our article is not that illicit is overestimated but that the Project Star report cannot be relied on as a source of data on illicit until there is significantly greater transparency over the underlying methodology and data inputs and the contractual arrangements under which it is conducted. KPMG itself would appear to acknowledge this stating clearly in a disclaimer in each of its Project Star reports that the data cannot be relied on: "KPMG wishes all parties to be aware that KPMG's work for Philip Morris International was performed to meet specific terms of reference agreed between PMI and KPMG and that there were particular features determined for the purposes of the engagement. The Report should not therefore be regarded as suitable to be used or relied on by any other person for any other purpose."

This lack of transparency is again underlined by Cartwright's failure to mention in his letter that KPMG receives ?10million from PMI to produce Project Star, his largest contract (http://www.kpmg.com/uk/en/about/aboutkpmg/kpmgfoundation/pages/robin- cartwright.aspx). He also claims this is a project for the European Commission and Philip Morris yet the Commission denies this. It is increasingly difficult to see where the truth lies here. KPMG's claim that the Project Star reports are recognised across Europe as the most "comprehensive" study of its kind is not disputed. No-one else has the financial backing or the political self-interest, in the case of PMI, to produce a report of this size. But comprehensive does not equal accurate, reliable and transparent. It doesn't matter how many cigarette packs are collected if the empty pack survey is designed to overestimate illicit as growing evidence suggests industry empty pack surveys are(2). Our paper clearly acknowledges that the model used in the Project Star report has merit but while PMI are so closely involved in the report and supply the majority of data to be used in the model, it cannot be relied on. Overwhelming evidence shows the extent to which the tobacco industry is prepared to manipulate science and data in its own interest(3). The illicit trade in tobacco is no exception(2,4). Anna B Gilmore1, Silvano Gallus2, Andy Rowell1, Luk Joossens3 1Department for Health and UK Centre for Tobacco and Alcohol Studies (UKCTAS), University of Bath, Claverton Down Road, Bath, UK 2Department of Epidemiology, IRCCS--Istituto di Ricerche Farmacologiche Mario Negri,Milan, Italy 3Association of the European Cancer Leagues and Foundation Against Cancer, Brussels, Belgium

Competing interests: The authors of this letter authored the paper being criticised by Cartwright and ABG, SG & LJ were part of the PPACTE study which Cartwright also criticises.

(1) Cartwright RM. KPMG response to 'Towards a greater understanding of illicit tobacco trade in Europe: a review of the PMI funded 'Project Star' report'. Tobacco Control Published Online First 5 March 2014 http://tobaccocontrol.bmj.com/content/early/2014/01/16/tobaccocontrol-2013 -051240.full?sid=ffae5533-cd43-46d0-ae48-3f2d6c0d9b00#responses. (2) Gilmore AB, Rowell A, Gallus S et al. Towards a greater understanding of the illicit tobacco trade in Europe: a review of the PMI funded 'Project Star'. Tobacco Control Published Online First 11 December 2013 doi:10.1136/tobaccocontrol-2013-051240. (3) Michaels D. Doubt is our Product. New York: Oxford University Press, 2008. (4) Rowell A, Evans-Reeves K, Gilmore AB. Tobacco Industry Manipulation of Data on and Press Coverage of the Illicit Tobacco Trade in the UK. Tobacco Control (in press).

Conflict of Interest:

The authors of this letter authored the paper being criticised by Cartwright and ABG, SG & LJ were part of the PPACTE study which Cartwright also criticises.

Conflict of Interest

None declared