Marketing Approach

Consumer Communications

We work hard to market our products to adult tobacco consumers and to limit the reach of our materials to unintended audiences, including non-users and people under the legal age to purchase tobacco products. We limit access to our tobacco brand websites to adult tobacco consumers 21+.  We require consumers to confirm that they are adult tobacco consumers and we use an electronic age-verification process to ensure they are 21 years of age or older. 

• One-to-one Communications: We use direct mail and email to support the launch of products, invite adult tobacco consumers to consumer engagement programs, announce brand promotions and deliver coupons and other communications. We maintain a secure database of qualified adult tobacco consumers that are age-verified and have told us they would like to hear from us. A person may request to no longer receive communications from us at any time.
• Consumer Websites: Our age-restricted brand websites enable adult tobacco consumers to interact with our brands. We use these sites to build brand equity, deliver news and provide promotional support.

• Consumer Marketing Activities: We offer consumer engagement programs that reinforce brand equity, support the launch of new products and deliver promotions to adult tobacco consumers.
  
  

Protecting our Consumers – Data Security

We collect personal information as part of our age-verified adult tobacco consumer database and we take protecting that data seriously. We continue to make investments in administrative, technical and physical safeguards intended to protect our information systems and data from cyber-threats, including human error and malicious acts. Our safeguards include employee training, testing and auditing protocols, backup systems and business continuity plans, maintenance of security policies and procedures, monitoring of networks and systems, and third-party risk.

Determining Magazine Advertising Placement

We advertise in magazines to build awareness of our brands with adult tobacco consumers. When selecting the magazines, we're careful to pick those publications that are predominately read by adults. Where we use print advertising (newspapers, magazines, periodicals or other publications), we are guided by the Food and Drug Administration’s proposed definition of the term "adult publication". Under this standard, an adult publication is one:

• whose readers younger than 18 years of age constitute 15 percent or less of the total readership as measured by competent and reliable survey evidence; and
• that is read by fewer than two million persons younger than 18 years of age as measured by competent and reliable survey evidence.

If a magazine doesn't meet these criteria, we won't advertise in it.

Trade Programs

We offer trade programs to retailers and wholesalers that help them responsibly manage the smokeless tobacco category. Our retail trade program is built on effective category management principles, including:

• merchandising our products in an organized way;
• having our brands in-stock and available;
• having our most popular brands in the preferred positions;
• clearly communicating price and promotional offers; and
• deterring access by underage purchasers.

The program also includes several features to help prevent underage access to tobacco products that go beyond federal law, including:

• training store personnel who sell tobacco products using We Card^TM or equivalent training;
• displaying We Card or equivalent signage;
• using an age verification tool;
• placing retail signage that tells adults not to buy tobacco products for kids; and
• adhering to the Smokeless Tobacco Master Settlement Agreement.

In addition, we've developed rigorous compliance and training systems to govern retail marketing materials. We also limit the number of USSTC signs at retail.