Roy Ramm was listed as one of the founding members of The Common Sense Alliance. The Common Sense Alliance was founded in August 2012, at the time when the EU Tobacco Products Directive Revision was being debated and the UK was at the close of its first consultation on Plain Packaging and was gearing up to review the responses. The Alliance’s website is no longer active. It was available to view in August 2014 but had been removed by December 2014. On its now defunct website the Common Sense Alliance described itself as a "growing community who question excessive regulation that lacks evidence and has not been fully thought through..."  The group opposed regulation such as:
- Plain packaging for tobacco products
- Levies on premises serving alcohol between 12am and 6am
- Levies on fatty foods and nutritional labelling on food packaging
- and later they added the revision of the EU Tobacco Products Directive.
Although they claimed not to be a political group, the Alliance effectively acted as a lobby group, mobilising support for its causes. For more information visit The Common Sense Alliance page on TobaccoTactics.
Ramm was Commander of Specialist Operations for New Scotland Yard. He started working for New Scotland Yard in 1970 and was employed there for 26 years. Although Ramm left the police in 1996, and the illicit trade landscape may have changed over the past two decades, he is still cited for his expertise in this area.
In 2013, Ramm was listed on his LinkedIn profile as holding a number of positions:
- Head of Governance and Public Affairs at casino company London Clubs International
- Chairman of Emerald Casino Resort in South Africa
- Advisor on crime and terrorism
- Senior security consultant
- Media commentator on crime and terrorism
Against Plain Packaging
Both Ramm and Peter Sheridan – (another founding member of the The Common Sense Alliance who is also an ex-police officer) – are experienced expert witnesses. In their capacity as police officers, both have appeared before a Select Committee in Parliament to discuss the issue of tobacco smuggling. Both subsequently used their credentials as former police officers and their previous experience in illicit tobacco to lobby against plain packaging while omitting to disclose their involvement with The Common Sense Alliance and the Alliance’s link to British American Tobacco.
In his capacity as a former police officer, Ramm’s opinion that smuggling will increase as a result of plain packaging for tobacco products (published in the Huffington Post), was cited on numerous occasions in the media. In his Huffington Post piece written during the UK consultation period in July 2012, Ramm argued that plain packaging would boost illicit trade. He argued plain packaging would “be disastrous” because:
- It would remove the simplest mechanism for the consumer to tell if the product is counterfeit or not;
- It would be easier to counterfeit than branded packs;
- Organised crime groups would be encouraged to produce more illicit tobacco;
- Would provide organised crime groups with the ability to produce a wider range of brands if all they need to change is the brand name;
- Children that do like branded packs would be driven into the hands of organised crime to buy the illegally imported branded products they desire.
These arguments are the same as those promoted by the tobacco industry. To explore the public health side of the argument please read Countering Industry Arguments Against Plain Packaging: It will Lead to Increased Smuggling.
Philip Morris International’s Response to the UK Standardised Packaging Consultation
In their submission to the 2012 standardised packaging consultation in the UK, Philip Morris International (PMI) argued that standardised packaging would lead to an increase in illicit tobacco. To support their case PMI used a quote from Ramm's piece in the Huffington Post:
- "If the only branded cigarettes in the UK become illegal imports, then instead of the government's plans protecting children they will be driving them into the hands of organised crime to buy the branded product they desire."
To qualify this evidence, PMI correctly described Ramm as a "Former Commander of Specialist Operations at New Scotland Yard". However, his involvement with The Common Sense Alliance was not mentioned, although he was listed as one of the founding members and the Alliance was set up around the same time (The Common Sense Alliance webpage was officially registered on the 22 June 2012). When considering the submissions to the UK consultation on plain packaging post August 2012, Department of Health officials would not have been aware of a connection between Ramm and The Common Sense Alliance.
Lobbying the Lords
On 28 February 2013, Ramm and Peter Sheridan wrote a letter to Lord Hannay concerning the potential implications of the revised EU Tobacco Products Directive (TPD) on the illicit trade of tobacco products. Lord Hannay of Chiswick is the Chair of the House of Lords EU Sub Committee F, which is responsible for considering the EU review of the TPD.
The letter detailed the credentials of both Ramm and Sheridan as former police officers, including positions held and relevant expertise in illicit trade. It did not however disclose that the two were in any way linked to either The Common Sense Alliance or BAT. For more detail on this lobbying, see 'Evidence’ presented to the House of Lords – No Mention of the Alliance on The Common Sense Alliance page.
Another Link to the Tobacco Industry
A news article in The Observer on Sunday 28 April 2013 exposed The Common Sense Alliance as a lobby group and Ramm and Sheridan as lobbyists. Both parties insisted that they were acting in a personal capacity and that neither had been paid by the tobacco industry. However, The Common Sense Alliance, a group both Ramm and Sheridan were founding members of, was financially supported by BAT.
In addition, the letter to Lord Hannay was sent by Goddard Global, a "multinational firm that provides the secretariat for the Alliance." A BAT spokesman confirmed it also employed the lobbying firm."
Speaking about Ramm and Sheridan, CEO of Action on Smoking and Health, Deborah Arnott said:
- It beggars belief that Peter Sheridan and Roy Ramm can try to claim they were acting in a personal capacity when one is a director [Sheridan] and the other a founder member [Ramm] of an organisation funded by BAT.
Ex-Police’s Letter to the Telegraph
For a full list of signatories – please see the full text of the letter.
- Internet Archive Way Back Machine, Cached www.thecommonsensealliance.com, 15 August 2014, accessed January 2015
- R. Ramm, LinkedIn profile, LinkedIn, accessed April 2013
- Comsec, Investigation Services, 2011, accessed April 2013
- Say No to Plain Packs, The Facts, Forest, 2012, accessed April 2013
- Hands Off Our Packs, Harbutt: Anti-tobacco activists protest too much, Forest, 2 October 2012, accessed April 2013
- R. Ramm, Government plans for plain packaging will boost illicit trade, The Huffington Post Blog, 2 July 2012, accessed April 2013
- PMI, Standardised tobacco packaging will harm public health and cost UK taxpayers billions: A response to the Department of Health consultation on standardised packaging of tobacco products, 9 August 2012, p15
- register.com,Who Is Lookup , accessed May 2013
- Companies House Direct, The Common Sense Alliance, Sheridan was appointed on 7 August 2012, accessed April 2013
- J. Doward, Plain packaging lobbyists under fire over links to tobacco company, The Observer, 28 April 2013, accessed April 2013
- UK Department of Health, Letter from Peter Sheridan to Tobacco Programme Manager, UK Department for Health, 15 April 2013, accessed July 2014
- I. Johnston, C. Bird, D. Wilson, et al, Counterfeit cigarettes, Letters, The Telegraph, 9 February 2015, accessed February 2015
- C. Hope, Police could struggle to cope with counterfeit cigarettes, warn ex-cops, The Telegraph, 9 February 2015, accessed February 2015