PMI 04-C
DESIGN, MARKETING,
AND SALE OF COMBUSTEDTOBACCO PRODUCTS
Effective: 15 May 2021
Next review: 15 May 2023
Owner: President Combustibles Category & Global Combustibles Marketing, PMI
Approved by: Chief Executive Officer, PMI

KEY POINTS TO REMEMBER• The Code for Design, Marketing & Sales of Combusted
Tobacco Products and its Implementation Guidelines
establishes the core principles, practices, andgovernance processes to follow when developing,
designing, marketing, engaging with Adult Consumers
about, and selling PMI’s Combusted Tobacco Products.
A separate code governs Non-Combusted Alternatives.
• Smoking Combusted Tobacco Products causes serious
diseases and is addictive. PMI’s Combusted Tobacco
Products, Marketing, direct engagement, and sales
activities are solely for Adult Smokers who choose tocontinue smoking, and our activities are solely focusedon enabling Adult Smokers to make brand choices.
• We do not encourage people to start smoking, nor do
we discourage cessation. We do not want minors to
use any PMI Product and we do not market to minors.
We warn and remind Adult Smokers of the healtheffects of smoking and encourage Adult Smokers
who would otherwise continue to smoke to consider
switching to Non-Combusted Alternatives.

• The Code for Design, Sales & Marketing of Combusted
Tobacco Products helps ensure we market our
Combusted Tobacco Products responsibly by providing
clear rules (Sections 1-6), establishing a pre-deployment
review process (Section 7), requiring training for our
employees and third-party partners (Section 8), selfassessment and certification (Section 9), and, of course,
following all applicable laws (Section 10).
• Following the law is essential. In some places,
provisions in the relevant laws may exceed
requirements of this Code – and of course, you must
follow those. In other areas, the Code may impose
greater requirements than the law – and you must
follow the Code as well as the law. In all cases, youare accountable and must apply sound judgment.
Following the law and the principles, practices, andprocesses required by this Code is not only the rightthing to do but also helps us to ensure our products andactivities build our brands responsibly.

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DESIGN, MARKETING & SALE OF COMBUSTED TOBACCO PRODUCTS
PRINCIPLES
We are delivering a smoke-free world. Smoking
Combusted Tobacco Products causes serious disease.
Our mission is to design, substantiate, market, and sell
Non-Combusted Alternatives that are much better
alternatives for Adult Consumers who would otherwise
continue smoking.
Our Combusted Tobacco Products are solely for Adult
Smokers. We sell Combusted Tobacco Products andcompete for market share among Adult Smokers. We do notdevelop or market Combusted Tobacco Products in waysthat particularly appeal to minors. We do not encourage
people to start smoking, and we do not discourage people
from quitting or interfere with quit attempts.
We warn consumers about the health effects of PMI
Products. Smoking Combusted Tobacco Products causes
serious diseases and is addictive. All Advertising andConsumable Packaging must have health warnings, even if
the law does not require them.
We communicate about PMI Products to enable Adult
Smokers to make choices. We communicate about
our Combusted Tobacco Product brands so that Adult
Smokers can find and select the products they prefer. We
encourage Adult Smokers who would otherwise continue
to smoke to switch to Non-Combusted Alternatives.
We market truthfully and transparently. Ourcommunications and product claims must be accurate
and non-misleading. When we contract with third
party promotional staff or coaches to help us market orcommercialize our products, they must make clear they
are working for us.
We develop, design, and deploy Combusted Tobacco
Products in ways that are consistent with oursmoke-free mission. We are proud of our leadershipin Combusted Tobacco Products, and we intend tocontinue to responsibly sell cigarettes as long as there
is a significant legitimate demand. Our focus, however,remains on making Non-Combusted Alternatives
available for the hundreds of millions of Adult Smokers
who would otherwise continue to smoke; encouraging
them to fully switch to better products; and leading thetransformation of the industry. We will maintain ourleadership in Combusted Tobacco Products by focusing

on more impactful initiatives for Adult Smokers and usingthat leadership to help Adult Smokers switch to NonCombusted Alternatives.

WHY IT IS IMPORTANT FOR PMI
Consumer-centric product design, marketing, sales, anddirect engagement drive our commercial success and canpropel our Smoke-free vision.
They also have a significant impact on how consumers,
business partners, stakeholders, and regulators view us
and treat us and our products. Their role in encouraging
rapid positive change is key, and responsible marketing
practices allow us to lead by example.
Concerns that our products, marketing, and sales could
discourage cessation, encourage initiation, or particularly
appeal to minors can undermine our credibility, harm
our reputation, and even trigger adverse regulation,
threatening our ability to engage or jeopardizing productcategories. How we market and sell Combusted Tobacco
Products can either enhance or undermine our credibility– and trust and meaningful dialogue are indispensable forachieving our smoke-free vision.
This Code embodies the Company’s commitment to
responsible product development, design, marketing,consumer engagement, and sales. By honoring theseprinciples and practices, you safeguard the Company’s
reputation, preserve important channels for us to engage
with Adult Consumers, and enable our business success.

WHO MUST FOLLOWTHESE PRINCIPLES & PRACTICESAll PMI employees directly involved in developing or
deploying Adult Consumer-focused product, packaging,
Advertising, Marketing, consumer engagement, andSales initiatives for Combusted Tobacco Products must
follow this Code and the Implementation Guidelines that
accompany it.
All third parties contracted or engaged by the Company toconduct those activities must also follow the portions of
this Code and the Implementation Guidelines that relate
to the role they perform.

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PMI 04-C
DESIGN, MARKETING & SALE OF COMBUSTED TOBACCO PRODUCTS
DEFINITIONS
Accessories
Items PMI intends to be used withPMI Products – for example,
in the case of Combusted Tobacco
Products, a cigarette lighter oran ashtray.
Advertising
Any Branded commercial
communication by which We
promote a PMI Combusted Tobacco
Product to Adult Smokers, regardlessof the medium.
Adult
A person who is of legal age topurchase tobacco products or, where
no such age is defined in applicablelaw, is at least 18 years old.
Adult Smoker
An Adult who is a consumer of
Combusted Tobacco Products.
Adult Non-Combusted Alternative
Consumer
An Adult Consumer, who exclusively
or mostly uses Non-Combusted
Alternatives.
Adult Consumer
An Adult, who is a consumer of
Combusted Tobacco Products and/or
Non-Combusted Alternatives.
Affiliate
Philip Morris International Inc.
and each of its direct and indirect
subsidiaries which conduct, or
engage third parties to conduct,
Marketing.
Brand (Branding, Branded)
Containing a name, trademark, logo,
or other element that could easily
identify a brand of a Combusted
Tobacco Product made or sold by oron behalf of PMI.

Company (or PMI, or We)
Philip Morris International Inc. and its
direct and indirect subsidiaries and/or Affiliates.
Consumable Packaging
Packaging, wrapping, bundles, or any
other materials in which Combusted
Tobacco Products are offered for sale
to Adult Smokers. (For clarity, inserts
and onserts are not Consumable
Packaging for the purposes of this Code.)
Combusted Tobacco ProductA manufactured consumable productthat combusts tobacco and/or
generates smoke inhaled directly by
the user when it is used as intended.
Combusted tobacco products
include, for example, cigarettes,
cigarillos, cigars, “Roll Your Own”,“Make Your Own”, and pipe tobacco.
Implementation Guidelines
The mandatory Guidelines listed in
Section Implementation Guidelines,
Forms, and Attachments below.
Marketing
The set of commercial initiatives
and communications by which
We promote, offer, and sell PMI or
third-party business partners’
products to Adult Consumers.
Marketing includes Advertising.
Non-Combusted Alternative to
Cigarettes (or NCA)
A manufactured consumable product(whether made from tobacco ornot) that provides nicotine without
combusting tobacco and that
does not generate smoke inhaleddirectly by the user when it is used
as intended. NCAs include any
NCA Device necessary for the
consumption of the tobacco or
nicotine-containing substance.

PMI Marketing Review Council
A group comprising the President
Smoke-Free Products Category &Chief Consumer Officer, President
Combustibles Category & Global
Combustibles Marketing, Senior Vice
President Global Communications,
Senior Vice President & GeneralCounsel, and Senior Vice President
External Affairs (or their designees)that is responsible for providing input
and guidance to Affiliate Deployment
Review Groups and deciding onquestions, issues, or exceptions
requested by Affiliates.
PMI Product
A Combusted Tobacco Product, NonCombusted Alternative Consumable,or Non-Combusted Alternative Device
made or sold by or on behalf of PMI.
Premium
A value added offer, service, or otherreward sold or otherwise provided toan Adult Consumer, including loyalty
recognitions provided, for example,
as part of loyalty program, that is not
a Non-Combusted Alternative
or Accessory.
Sales
The commercial initiatives by which
We provide PMI Products to Adult
Consumers in exchange for monetary
value or other consideration, as aresult of which an Adult Consumer
has access to a PMI Product.
Trade Partner
Any representative of a retail outlet,
legal age meeting point (LAMP),or other business or individual thatis engaged by an Affiliate for theretail sale of PMI Combusted
Tobacco Products.

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PMI 04-C
DESIGN, MARKETING & SALE OF COMBUSTED TOBACCO PRODUCTS
PMI MANDATORY PRACTICES
1. Products and packaging.
1.1 Product and packaging development and design. PMI Combusted Tobacco Product Branding and Consumable
Packaging features and attributes must clearly reflect our intention that they are for Adult Smokers and not for
non-smokers. They must not have particular appeal for minors.
1.2 Product branding. Branding is used on Consumable Packaging in order to help Adult Smokers learn about,understand, select, and find the PMI Combusted Tobacco Product they prefer. Branding must be designed andintended for Adult Smokers and must not have particular appeal to minors.
1.3 Consumable Packaging. Standard brand presentation (i.e., brand name, trademark and/or logo) must predominate
in all Consumable Packaging designs. Visuals that have been used in Advertising must not be used on
Consumable Packaging. Any text placed on the external part of such packaging must be factual, brand-related
and/or product specific.
1.4 Accessories and Premiums. Accessories and Premiums must be for Adult Smokers and must not have particularappeal to minors.

	Accessories. Combusted Tobacco Product Branding may be used on or in Accessories, such as cigarette lightersor ashtrays.
Premiums. Combusted Tobacco Product Branding may not be used on Premiums (including Value Added Offers
or Rewards).
2. Marketing.
2.1 Marketing content. Marketing content must reflect our intended focus on Adult Smokers.
Detailed requirements are contained in PMI 04-C G1 Marketing and Sales of Combusted Tobacco Products.
	Marketing must not make express or implied health claims about PMI Combusted Tobacco Products.
	Marketing must be respectful and, in our best judgment, must not perpetuate negative gender, ethnic,
or cultural stereotypes.
2.2 No product placement. You must not pay or give anything of value to include the use of Combusted Tobacco
Products, a Combusted Tobacco Product brand name, or items bearing a PMI Combusted Tobacco Productbrand name in entertainment programs, films, or theatrical productions in or on the Internet, cinema, television,
radio, video game, or any other program that is intended for or disseminated to the general public.
2.3 No use of social media. PMI does not use social media for Marketing, Advertising, or any other promotional
communications related to Combusted Tobacco Products. In other words, you must not use social media,
as defined in PMI 18-C Using Computer Technology, to advertise or promote PMI Combusted Tobacco
Products, events, or promotional activities, or engage with Adult Smokers. This applies to all Marketing, direct
engagement, campaigns, or activities, whether they are Branded or not. You must not create and deploy any
Marketing content for the purpose of generating or prompting social media posts about PMI Combusted
Tobacco Products. The same rule applies to third parties contracted by or acting on behalf of PMI, including
agencies, sales experts, promotional, front line and event staff.
2.4 Location and execution of Marketing. Advertising, Marketing, and Sales materials must be placed where they arelikely to reach Adult Smokers and not in places or channels frequented primarily by minors.

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PMI 04-C
DESIGN, MARKETING & SALE OF COMBUSTED TOBACCO PRODUCTS
	Advertising and Marketing materials may only be placed in media channels (including digital channels), venues,
events, or locations that are not directed to minors and whose audience is reasonably estimated to be at least
75% Adults. For details on location and execution of Advertising, including digital channels, observe PMI 04-C
G1 Guidelines for Marketing and Sales of Combusted Tobacco Products.
2.5 Trade communications. All written promotional communications intended for Trade Partners must clearly state“For Trade Only. Not for Distribution to Consumers.” Advertisements and Marketing materials in publications
intended for general circulation to the trade must have health warnings in black text on a white background,
occupying no less than 10% of the total area of the advertisement.
3. Direct engagement.
3.1 General. We (and third parties we contract) engage directly with Adult Smokers (“Direct Communication”) ina variety of ways, including in person; via a range of technologies including direct mail, consumer websites orapps, e-mail, and text messages; and through online and offline sales channels, among others. We engage with
Adult Smokers as a group (“Consumer Engagement”) through Consumable Packaging and inserts; pack scanningtechnologies; and websites and events, among others.
	All Company activities involving Direct Communications with Adult Consumers about Combusted Tobacco
Products must follow the practices contained in PMI 04-C G1 Marketing and Sales of Combusted Tobacco Products
and the age control processes set out in PMI 04-C G3 Omnichannel Youth Access Prevention.
3.2 S
 upporting better choices. You may only engage about Combusted Tobacco Products with Adult Smokers. Do not
engage with Adult Non-Combusted Alternative Consumers about Combusted Tobacco Products.
3.3 Third parties. All promotional and event staff who are not Company employees but are contracted by and acting
on behalf of the Company to engage in Direct Communications with Adult Smokers must be of legal age topurchase PMI Combusted Tobacco Products and at least 21 years old and shall be required by contract not topost about PMI Products or related events on social media.
3.4 Transparency. PMI employees or contractors who engage in Direct Communications with Adult Smokers,
including in the context of Advertising and Marketing platforms or campaigns, must make it clear that they are
working for or acting on behalf of PMI.
4. Sales.
4.1 Sale and delivery. PMI Combusted Tobacco Products, Accessories, or Premiums may only be sold (or provided)and delivered directly only to age-verified Adult Smokers. For more details on those measures, follow PMI 04-C
G3 Omnichannel Youth Access Prevention.
4.2 Product samples. Subject to applicable laws, PMI Combusted Tobacco Products may be offered free in limited
quantities (typically no more than one pack) to age-verified Adult Smokers as part of product trial.
4.3 Switch-selling. Subject to applicable laws, PMI may offer to an Adult Smoker to switch or swap a PMI Combusted
Tobacco Product for a competitive Combusted Tobacco Product they have already purchased.
4.4 Not for Adult Non-Combusted Alternative Consumers. Combusted Tobacco Products may not be offered as
samples, swapped, or switch-sold to an Adult Non-Combusted Alternative Consumer.

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DESIGN, MARKETING & SALE OF COMBUSTED TOBACCO PRODUCTS
5. Risk and product communication.
5.1 Health warnings. All Consumable Packaging, Advertising and Marketing materials for Combusted Tobacco
Products must have health warnings. If the law does not require or specify health warning content andappearance, observe PMI 04-C G1 Marketing and Sales of Combusted Tobacco Products.
5.2 Substantiation. All statements in Advertising Marketing materials, on Consumable Packaging, and inengagements with Adult Smokers and Trade Partners must be accurate and not misleading, including about thehealth risks of smoking. All product-related claims must be adequately substantiated.
5.3 Bridging communication. When communicating with Adult Smokers about Non-Combusted Alternatives
through inserts in PMI Combusted Tobacco Products, consumer websites, communication for Trade Partners
or otherwise, use statements and messages that are approved by the Substantiation Task Force in accordancewith PMI 04-CG5 Guidelines for Consumer Messages on Non-Combusted Alternatives. Any local adaptations
must remain accurate and not misleading and true to the essence of the original statements approved by PMI
Substantiation Task Force.
5.4 No reduced-risk communication. You must not claim or suggest that any Combusted Tobacco Product is lesshazardous or reduces risk compared to any other Combusted Tobacco Product.
5.5 Tar, Nicotine and/or CO disclaimer. If there is a legal requirement to print tar, nicotine or CO yields on Consumable
Packaging or Advertising, you may voluntarily print tar, nicotine and/or CO yield numbers on Advertising and on
Consumable Packaging in addition to those required by law, as long as you also print the following statement in aclearly legible typeface and size: “The amount of [tar, nicotine and/or CO] you inhale will vary depending on how you
smoke the cigarette.”
6. Third parties and Trade Partners.
6.1 Third parties. Third parties that are contracted by and acting on behalf of PMI to design, develop, Advertise,
Market, or Sell PMI Combusted Tobacco Products must comply with this Code and Implementation Guidelines,
as applicable to their activities. They must be adequately trained and required in writing (e.g. by contract) tocomply with this Code.
6.2 Trade partners. Trade Partners that are not contracted by or acting on behalf of PMI should be encouraged toabide by this Code. For example, consider encouraging their efforts to prevent unauthorized youth purchaseof Combusted Tobacco Products and providing them assistance, training, tools, and/or incentives to support
actions and behavior consistent with this Code.
7. Governance: Pre-deployment review.
7.1 Governance process. Each PMI Affiliate must have in place a Deployment Review Group (“DRG”) that provides
a robust process for reviewing and approving -new product, packaging, consumer facing programs, campaigns,
or initiatives before they are deployed. The DRG must include the Affiliate heads (or their designees) of
Combustible Category, Smoke-Free Category (Consumer Experience and Marketing and Digital), Commercial
Operations, Law, Global Communications, and External Affairs functions (or the Affiliate equivalents of thosefunctions). Programs, campaigns, or initiatives that are included in centrally-developed “toolboxes” may besubject to an abbreviated procedure but must at a minimum be reviewed by representatives of the Affiliate Law,
External Affairs and Global Communications functions (or the Affiliate equivalent of those functions).
7.2 If you propose deploying a program, campaign, or initiative, you are responsible for assessing• that the proposal responds to Adult Smokers’ needs and makes sound commercial sense;

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PMI 04-C
DESIGN, MARKETING & SALE OF COMBUSTED TOBACCO PRODUCTS• its conformity with relevant laws;• its consistency with this Code and Guidelines, and in particular the risk that it could be perceived as focusing
on non-smokers, encouraging initiation, discouraging cessation, or particularly appealing to minors, and ways
to resolve or mitigate those concerns; and• the risks the proposal may present to PMI’s smoke free mission, corporate reputation, and interactions withkey stakeholders.
	Empirical data help inform decisions but are not always available. You can also rely upon input and assessmentsfrom the PMI Marketing Review Council; experience from other countries that deployed the initiative; market
observation and analysis; input from colleagues in Law, External Affairs, and Global Communications; and yourbest judgment.
7.3 Making decisions.
	
New Combusted Tobacco Products. A new Combusted Tobacco Product or product feature should be deployed
only if (1) it meets (or is designed to meet) a significant Adult Smoker need or preference, based on consumer
insights or market observation; and (2) data, analysis, market factors (for example, if Non-Combusted
Alternatives are available or banned), and/or planned actions provide a good faith basis that deployment would
not encourage Non-Combusted Alternative users to revert to Combusted Tobacco Products or undermine
PMI’s regulatory strategies.
	
Opportunities to bridge to Non-Combusted Alternatives. We should do our utmost to encourage Adult Smokers to
fully switch to Non-Combusted Alternatives where they are available. Therefore, for launches of new Combusted
Tobacco Products you should consider appropriate ways of raising awareness of, and informing Adult Smokers
about, PMI Non-Combusted Alternatives and the benefits of switching versus continued smoking.
7.4 Documentation. In accordance with PMI 01-C Managing Company Information, each Affiliate must keep a record of
proposals considered by the DRG and the decisions taken.
7.5 Escalation, clarification, or exceptions. Questions, clarifications, or requests for interpretation of this Code may bereferred to the PMI Marketing Review Council. Any exceptions to PMI 04-C must be submitted in writing to PMIMarketing Review Council and approved by the President Combustibles Category & Global Combustibles Marketing.
8. Training.
8.1 All PMI employees directly involved in developing or deploying Adult Consumer-focused product, packaging,
Advertising, Marketing, consumer engagement, and Sales initiatives for Combusted Tobacco Products mustreceive training on this Code and related Implementation Guidelines.
8.2 All third parties that are contracted by and acting on behalf of PMI to develop or deploy Adult Consumerfocused product, packaging, Advertising, Marketing, consumer engagement, and Sales initiatives for Combusted
Tobacco Products (including agencies, brand ambassadors and other promotional staff, coaches, sales experts,
call center agents, front line staff, event staff, and shop assistants) must be trained on the parts of the Code andrelated Implementation Guidelines that are relevant to their activities.
8.3 The Affiliate Heads, the Regional functional heads responsible for Combusted Tobacco Products, and thePresident Combustibles Category & Global Combustibles Marketing or his/her delegates are accountable for
implementing these trainings for all employees in, and third parties contracted by, their respective organizations.
Trainings must be repeated at least every two years.

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PMI 04-C
DESIGN, MARKETING & SALE OF COMBUSTED TOBACCO PRODUCTS
9. Implementation and certification.
9.1 On at least an annual basis, each Affiliate DRG must perform a self-assessment to determine if the practices
required in this Code and its associated Guidelines are implemented across all relevant channels and operating
adequately and trainings required by Section 8 were conducted.
	Members of the DRG and the Head of the Affiliate must certify that the proposals approved by the DRG, as
executed, complied with the Code and Mandatory Guidelines or, where discrepancies are noted, that they were
investigated, resolved, and/or rectified, as applicable.
	Results and actions resulting from the self-assessment are to be documented and shared with the relevant
Regional Vice President.
9.2 Each Regional Vice President Combustible Category, or his/her designee, must attest and report on an annual
basis to the President Combustibles Category & Global Combustibles Marketing a summary and a conclusionon the effectiveness of the systems implemented and operated in the applicable markets covered within theirregion. The attestation should consolidate and outline the results of the self-assessment activities performed by
the markets in their region.
9.3 In addition to Affiliate and Regional reporting and certification, the President Combustibles Category & Global
Combustibles Marketing or his/her delegates will consider Adult Consumer, stakeholder, and media reaction
to Affiliate Marketing and sales initiatives when they are deployed. If PMI has reason to believe activities areinconsistent with this Code or undermine PMI’s reputation, the President Combustibles Category & Global
Combustibles Marketing or his/her delegates will investigate and act in conjunction with the relevant Affiliate toaddress those concerns.
10. Compliance with all applicable laws.
	In addition to the requirements of this Code, PMI Products, packaging, and Marketing and Sales activities
must follow applicable laws, meet standards of decency, and be acceptable within the culture and norms of thecountry where they will be implemented. This Code’s requirements are minimum standards. While applicablelaws always prevail, these standards and the requirements to apply sound judgment apply when there are no
applicable laws or when stricter than the applicable laws.
11. Exception Handling.
	Requests for exceptions to PMI 04-C Design, Marketing & Sale of Combusted Tobacco Products,
must be submitted in writing to PMI Marketing Review Council and approved by the President Combustibles
Category & Global Combustibles Marketing.
12. Ask Questions and Give Feedback	If you have any questions regarding the content or the interpretation of PMI 04-C Design, Marketing & Sale ofCombusted Tobacco Products, please contact your Affiliate/Regional functional heads responsible for Combusted
Tobacco Products or President Combustibles Category & Global Combustibles Marketing.

IMPLEMENTATION GUIDELINES, FORMS, AND ATTACHMENTS
PMI 04-C G1 Marketing and Sales of Combusted Tobacco Products
PMI 04-C G3 Omnichannel Youth Access Prevention

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