The Common Sense Alliance
The Common Sense Alliance was a group which described itself as a “growing community who question excessive regulation that lacks evidence and has not been fully thought through…” The Common Sense Alliance was formed as a company in May 2012, at the time when the EU Tobacco Products Directive Revision was being debated and the UK was in the midle of its first public consultation on Plain Packaging. The Alliance’s website was still active in August 2014 but was no longer available to view by December 2014. The Common Sense Alliance company was formally dissolved on 30 December 2014.
On their now defunct website they claimed that they were not a political group. Nevertheless their main activities show that they acted as a lobby group. The Alliance asked readers to support common sense and sign up against:
- standardised packaging for tobacco,
- the late night levy on businesses selling alcohol between 12am and 6am,
- taxes on fatty foods and nutrition labelling
- and later they added the revision of the EU Tobacco Products Directive.
They urged supporters to contact their local MPs with these views and provided a link to the ‘Write to them’ webpage. Their tagline was “Common Sense, not Nonsense”.
When it was in action, The Common Sense Alliance also had a Facebook page (which last posted on 31 March 2014) a Twitter account @commonsenseHQ (which no longer exists) and a CommonSenseHQ YouTube channel (which no longer exists).
- 1 Supported by British American Tobacco
- 2 Against Plain Packaging
- 3 Founding Members
- 4 Industry Responses to the UK Plain Packaging Consultation 2012
- 5 'Evidence’ presented to the House of Lords – No Mention of the Alliance
- 6 "Plain Packaging Lobbyists Under Fire Over Links to Tobacco Company"
- 7 Notes
Supported by British American Tobacco
The tobacco company is one of the five main supporters of the Alliance listed on the Alliance’s homepage. In correspondence between The Common Sense Alliance and the UK Department of Health, it was disclosed that the tobacco company finances some of the Alliance's work.
The website domain was registered by Basil Dutchak, who worked for Rothman’s tobacco company for 30 years and BAT for a further year before founding his own business B&K Associates Ltd in 2003. On his LinkedIn profile, Dutchak states that B&K Associates consists of “a team of sales experts who have been trained to the highest standard, primarily in the tobacco industry, who can deliver sales objectives particularly where new brands require additional support in early development.” Dutchak retained a working relationship with BAT. Speaking of Dutchak in 2010, BAT National Sales Manager Andy de Caso said:
- Basil has a unique and affective style in developing/delivering both coaching and training modules. As importantly the delivery of his courses are tailored to the clients’ requirements. He keeps abreast of real trends within the market place that influence consumers’ decisions and utilises these when training and coaching. B&K have played a key role in the development of first line managers and coaches and both performance and people measures have been improved (significantly in some areas) as a result of his involvement with my company.
In addition to BAT, The Common Sense Alliance was also supported by:
- Great Heck Brewing Co LTd - an independent alcohol brewing company,
- MSR Newsgroup Ltd - a Nottingham newsagent chain, and
- the Live Management Group (LMG) who organise live music events and festivals. The LMG are partnered with a company called MAMA Brand Partnerships that specialise in branding live music events, venues and festivals; most often alcohol branding. Rizla, an Imperial Tobacco owned cigarette rolling paper is one of the many brands that MAMA Brand Partnerships has promoted at live music events.
Against Plain Packaging
The Common Sense Alliance was against the plain packaging of tobacco products, arguing that:
- It would increase illicit trade as packets are less easily identified as genuine or illicit
- The economy would suffer from revenue lost to illegal tobacco product sales
- Once there is plain packaging for tobacco where will the government go next (slippery slope argument)
- Excessive regulation should be replaced with education for young people
- See the public health counter arguments to The Common Sense Alliance’s and indeed the tobacco industry’s view points against plain packaging.
The Common Sense Alliance website (Under the header ‘Supporters’) listed its founding members along with their credentials.
- Peter Sheridan – Former Assistant Chief Constable and Head of Organised Crime and Murder Investigation
- Roy Ramm – Former Commander of Specialist Operations at New Scotland Yard
- Rory Sutherland – Former President of the Institute of Practitioners in Advertising
- Mick Garton – Managing Director of MSR News Group
- Kami Kundi – Justice of the Peace, Regional Director of the National Asian Business Association
- Dr Jules Goddard - Research Fellow at London Business School
- Nash Gooderham – Chief Executive Officer of Live Management Group
- Madz/Meg Wilden – Owner of Flaming Frog Design
- Denzil Vallance – Great Heck Brewery Limited
- Paul Jones – LS West Midlands
- Shaun Simmons – G Simmons & Sons
Two of the founding members were ex-police officers. As detailed on each of their TobaccoTactics pages, both Peter Sheridan and Roy Ramm are experienced witness experts. They have both appeared before a Select Committee in Parliament to discuss the issue of tobacco smuggling in their police capacity. During their time with the Common Sense Alliance, both argued that plain packaging would lead to an increase in illicit trade in articles in the media and in Parliament – see details below. Both used their credentials as former police officers to make their point, while failing to mention their involvement in the Common Sense Alliance and its links to the tobacco industry.
Sutherland was described by The Common Sense Alliance as the Former President of the Institute of Practitioners in Advertising. The Alliance’s website did not mention that he was the current Vice Chairman of The Ogilvy Group UK. The Group is part of Ogilvy & Mather, a global advertising and public relations company which lists British American Tobacco as one of its largest clients worldwide. The fact that BAT is a client is not easy to find at the websites of Ogilvy & Mather or the Ogilvy Group, but on LinkedIn people specify that their job role with the Ogilvy Group UK includes working on the BAT account.
Furthermore, Ogilvy has a long history of working with the Tobacco Industry, for more information see the Ogilvy Group page.
Industry Responses to the UK Plain Packaging Consultation 2012
Two of the founding members of the Alliance, Peter Sheridan and Roy Ramm, were cited as expert witnesses by tobacco companies in their submissions to the 2012 UK Consultation on Standardised Packaging (Sheridan by BAT and Ramm by PMI).
Furthermore, the plain packaging views of both Ramm and Sheridan have been quoted by the media, by anti-plain packaging campaigns such as Hands Off Our Packs and in personally penned pieces in both the Huffington Post and The Daily Mail :
- Sheridan guest column piece for the Daily Mail, 22 June 2012
- Ramm in the Huffington Post: Government plans for plain packaging will boost illicit trade
- Sheridan in the Huffington Post: Plain Packaging Will Create a Fertile Ground for Tobacco Smuggling, 3 December 2012
On 9th August 2012, Peter Sheridan was listed as the Director of the BAT supported Common Sense Alliance. However in publications regarding plain packaging only his credentials as former police officer were mentioned.
'Evidence’ presented to the House of Lords – No Mention of the Alliance
On 13th March 2013, Anna Soubry, then Public Health Secretary, and Andrew Black, Tobacco Programme Manager at the Department of Health were asked to attend an inquiry on the European Tobacco Products Directive (TPD) held by the House of Lords EU Sub-Committee on Home Affairs, Health and Education.
The sub-committee are “responsible for scrutinising health legislation”.
The Lords in attendance were Lord Hannay of Chiswick (Chairman), Lord Avebury, Lord Blencathra, Viscount Bridgeman, Lord Richard and Lord Sharkey.
During the session, Lord Blencathra refers to evidence provided in a letter by Roy Ramm (joint authored with Peter Sheridan), “who is former commander of Scotland Yard’s SOCA”. Lord Blencathra describes that the evidence that they have received from Ramm suggests that plain packaging would:
- “…give a huge boost to the counterfeit trade and that a lot of that money would go into criminal organisations, including some terrorist organisations.”
- “…give a huge boost to the counterfeit trade across Europe..” as “any kid could reproduce plain packaging on his laptop computer and a cheap printer.”
- “The tobacco manufacturers and the companies state that he best way…to prevent counterfeiting is to constantly change sophisticated packaging…”
Asked whether she accepted any of these arguments, Public Health Secretary Soubry, stated “I am afraid that I do not.” Soubry goes on to explain to the sub-committee why this is the case. (See image for an extract of the transcript.)
Later in the hearing, Viscount Bridgeman asked some questions on illicit trade based on a meeting he had with Peter Sheridan. Viscount Bridgeman asked whether counterfeit packaging would be harder to detect. Soubry responded that the term ‘plain packaging’ was misleading and that ‘standardised packaging’ would still include sophisticated security holograms.
The Lords asked that the Minister respond to the letter by Ramm and Sheridan, addressing the points made and sending a copy of any response to the Sub-Committee. Despite the high level of influence both Ramm and Sheridan achieved in this hearing, there is no mention of eithers involvement with The Common Sense Alliance. The letter in question, received upon request from the Sub-Committee was written in February 2013 by Ramm and Sheridan. It stated that plain packaging would increase illicit trade and fund terrorist organisations. Once again their relationship with The Common Sense Alliance, and therefore BAT, was not disclosed.
"Plain Packaging Lobbyists Under Fire Over Links to Tobacco Company"
The Common Sense Alliance was the subject of a national press story in the Observer on Sunday on the 28th April 2013: "Former police officers who gave evidence to Lords on upcoming legislation worked for Common Sense Alliance, funded by BAT."
- Internet Archive Way Back Machine, Cached www.thecommonsensealliance.com, 15 August 2014, accessed January 2015
- Companies House, Common Sense Alliance, Company Number 08080577
- UK Department of Health, Letter from Peter Sheridan to Tobacco Programme Manager, UK Department for Health, 15 April 2013, accessed July 2014
- Basil Dutchak, Basil Dutchak, Owner B&K Associates, LinkedIn, accessed April 2013
- Andy de Caso, Andy de Caso, Sales Director at SKYCIG UK, LinkedIn, accessed April 2013
- Madz Widen, Madz Widen, LinkedIn, accessed April 2013
- See for instance: LinkedIn, David Fox, accessed April 2013
- Steven Alexander, Plain pack cigarettes a ‘smuggler’s charter’, Belfast Telegraph, 26 September 2012, accessed April 2013
- Angela Harbutt, Anti-tobacco activists protest too much, Hands Off Our Packs Campaign Blog, 2 October 2012, accessed April 2013
- House of Lords, Unrevised transcript of evidence taken before The Select Committee on the European Union Home Affairs, Health and Education Committee, Inquiry on Tobacco Products Directive, 13 March 2013, accessed April 2013
- Plain Packaging Lobbyists Under Fire Over Links to Tobacco Company, the Guardian, 28 April 2013, accessed May 2013.