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Investment incentives and the implementation of
the Framework Convention on Tobacco Control:
evidence from Zambia
Raphael Lencucha,
1
Jeffrey Drope,
2,3
Ronald Labonte,
4
Richard Zulu,
5
Fastone Goma
5
1
Faculty of Medicine, McGill
University, School of Physical
and Occupational Therapy,
Montreal, Quebec, Canada
2
Economic and Health Policy
Research, American Cancer
Society, Atlanta, Georgia, USA
3
Department of Political
Science, Marquette University,
Milwaukee, Wisconsin, USA
4
Institute of Population Health,
University of Ottawa, Ottawa,
Ontario, Canada
5
Faculty of Medicine, University
of Zambia, Lusaka, Zambia
Correspondence to
Dr Raphael Lencucha, Faculty
of Medicine, McGill University,
School of Physical and
Occupational Therapy, 3630
Promenade Sir William Osler,
Montreal, Quebec, Canada
H3G 1Y5;
raphael.lencucha@mcgill.ca
Received 23 January 2015
Accepted 9 June 2015
To cite: Lencucha R,
Drope J, Labonte R, et al.
Tob Control Published
Online First: [please include
Day Month Year]
doi:10.1136/tobaccocontrol-
2015-052250
ABSTRACT
Purpose Policy misalignment across different sectors of
government serves as one of the pivotal barriers to WHO
Framework Convention on Tobacco Control (FCTC)
implementation. This paper examines the logic used by
government officials to justify investment incentives to
increase tobacco processing and manufacturing in the
context of FCTC implementation in Zambia.
Methods We conducted qualitative semistructured
interviews with key informants from government, civil
society and intergovernmental economic organisations
(n=23). We supplemented the interview data with an
analysis of public documents pertaining to the policy of
economic development in Zambia.
Results We found gross misalignments between the
policies of the economic sector and efforts to implement
the provisions of the FCTC. Our interviews uncovered the
rationale used by officials in the economic sector to
justify providing economic incentives to bolster tobacco
processing and manufacturing in Zambia: (1) tobacco is
not consumed by Zambians/tobacco is an export
commodity, (2) economic benefits outweigh health costs
and (3) tobacco consumption is a personal choice.
Conclusions Much of the struggle Zambia has
experienced in implementing the FCTC can be attributed
to misalignments between the economic and health
sectors. Zambia’s development agenda seeks to bolster
agricultural processing and manufacturing. Tobacco
control proponents must recognise and work within this
context in order to foster productive strategies with
those working on tobacco supply issues. These findings
are broadly applicable to the global context. It is
important that the Ministry of Health monitors the
tobacco policy of and engages with these sectors to find
ways of harmonising FCTC implementation.
INTRODUCTION
Tobacco control initiatives require coordinated
interventions across all sectors of government. The
WHO Framework Convention on Tobacco Control
(FCTC) implementation requires coordination
among government sectors dealing with health,
agriculture, trade, industry and finance among
others. This requirement is reflected in Article 5.1
of the Treaty: “Each Party shall develop, imple-
ment, periodically update and review comprehen-
sive multisectoral national tobacco control…”
1
One
of the pressing challenges of FCTC implementation
is the struggle to enlist the support of the non-
health sectors of government who are either disen-
gaged from the issue of tobacco control or actively
pursue policies that are misaligned with the
provisions of the FCTC.
2
Despite this need,
whole-of-government approaches (WoG) to
tobacco control have yet to find their place as the
modus operandi of most governments.
34
The chal-
lenge of WoG is particularly salient in the imple-
mentation of the FCTC.
The FCTC is the first public health treaty to be
negotiated and ratified under the auspices of
WHO, and outlines measures to be implemented
by parties to the Convention that serve to reduce
the demand for and supply of tobacco.
1
To date,
180 countries are party to the Treaty (as of April
2015). Zambia ratified the FCTC in 2008. Since
this time, the Ministry of Health, through the
Tobacco Control Focal Point, has worked to imple-
ment policies and to establish legislation that aligns
with the treaty’s commitments and provisions.
Post-FCTC legislation was drafted in 2010, but as
of April 2015 has not yet been adopted into law.
5
The challenges of implementation are not unique
to Zambia, and our multicountry research is unco-
vering common barriers to implementation among
tobacco-growing countries with emerging econ-
omies.
6
One of these barriers relates to incentives
to attract domestic and foreign direct investment
(FDI). The general logic underlying government
investment incentives is twofold.
7
First, incentives
are provided to stimulate economic growth or
create value for the country by attracting capital,
regardless of its origin, foreign or domestic.
8
Second, incentives are a means of attracting invest-
ment to a country in a competitive global market-
place,
9
intended to induce investment that
otherwise would not be made.
For Zambia, the pursuit of investment has
become central to the political economy of the
country’s future development. Despite consistent
economic growth over the past decade, Zambia
continues to struggle with high levels of poverty,
income inequality, and in 2012, was ranked 163 of
187 countries on the Human Development
Index.
10
Zambia’s economy relies heavily on
mineral exports, notably copper. However, since
2002, Zambia has focused on diversifying its
economy by supporting the agricultural and service
sectors. According to a report by United Nations
Conference on Trade and Development (UNCTAD)
the “challenge (for Zambia) is to attract more
investments in sectors other than mining.”
11
The
former president of Zambia, Michael Sata, noted
“the aim of (his) government is to continue with
policy and institutional reforms with the key object-
ive of making the country more attractive to
domestic and foreign private investment.”
12
FDI
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has increased significantly from US$72 million in 2001 to US
$1.7 billion in 2012.
13
Much of the FDI inflows are tied to the
copper sector. The mining sector in general continues to be the
largest attractor of FDI (approximately 70% of total investment
pledges in 2008).
11
Although agriculture only accounted for
22% of gross domestic product (GDP) in 2011, it is important
for the livelihoods of the majority of Zambians, accounting for
approximately 67% of employment and “has likewise been
attracting FDI particularly in the areas of production of horti-
cultural and floricultural products, as well as fruits, cotton,
maize, tobacco and sugar.”
11
It is in this context of government-
supported economic diversification and development that
tobacco production, processing and manufacturing are being
encouraged through investment incentives, representing a dis-
crepancy between economic goals and tobacco control commit-
ments. This paper focuses on how these two dissonant goals are
rationalised by different actors.
METHODS
The findings presented in this paper are a result of a larger mul-
ticountry study in Kenya, Malawi and Zambia. This multicoun-
try case study examines the political economy of tobacco
control. The case study methodology is oriented towards using
multiple methods to understand a complex phenomenon within
a particular context.
14 15
The findings presented in this paper
refer only to our research in Zambia. The findings are derived
from data collected through semistructured interviews with
representatives from the Department of Industry (n=3), Foreign
Affairs (n=2), Foreign Trade (n=2), Agriculture and
Agribusiness (n=5), WHO country office (n=1), Ministry of
Health (n=2), Tobacco Board of Zambia (n=1), Common
Market for Eastern and Southern Africa headquarters (n=1),
health-based civil society organisations (n=3) and tobacco
industry representatives (n=3). The key informants were identi-
fied using purposive sampling and were included because of
their involvement in our area of interest, namely the political
economy of tobacco and tobacco control. All interviews were
conducted in the workplace of the informants by international
and Zambian researchers associated with the study. All but two
of the interviewees agreed to be recorded. Notes were taken
during the interviews with these two participants. Interview
length ranged between 10 and 60 min, with the length of the
majority of interviews being approximately 45 min. We supple-
mented the interview data with public documents on Zambia’s
economic development plans and tobacco investment. The key
informants directed our research team to the key strategic docu-
ments with the Zambia Development Agency (ZDA) that
informed their work. In addition to documents identified by the
key informants, we collected other public documents pertaining
to Zambia’s development agenda, such as reports produced by
the UNCTAD. The study protocol received ethics approval by
the Institutional Review Boards of McGill University,
Morehouse University (American Cancer Society) and the
University of Zambia. All interviews were transcribed verbatim
and analysed using thematic analysis.
16
The transcripts were
entered into NVivo qualitative software for data management.
The qualitative analysis was conducted by the lead author and
used both deductive coding (based on the interview questions)
as well as inductive coding. The results were discussed with
team members, two of whom were experienced Zambian
researchers active in the health and tobacco area, for
verification.
RESULTS
One of the major initiatives of the Zambian government to
attract investment was the creation of the ZDA in 2006, with
the mandate to “foster economic growth and development by
promoting trade and investment in Zambia through an efficient,
effective and coordinated private sector led economic develop-
ment strategy.”
17
Tobacco export promotion is one of the coun-
try’s priorities, now absorbed within the work of the ZDA,
justified primarily by its importance to farmers:
It is a key industry especially for the farmers …We have more
than twenty thousand small scale farmers growing tobacco at the
moment meaning that each farmer is able to take care of about
six members of the family and when we do the math we will
actually see how important this sector is in this country and how
critical this industry is in reducing poverty levels. (ZDA
informant)
Tobacco production receives incentives in terms of machinery
and agrichemical imports, on which ‘duty and VAT are not
paid’. The key informant from ZDA was not aware of the
FCTC, and acknowledged that ZDA does get involved in trade
and tobacco disputes in “bilateral and multilateral discussions …
in Geneva …articulating our interests.”
ZDA is also responsible for the governance of Multi-Facility
Economic Zones (MFEZ) and industrial parks that were estab-
lished in 2005 with investors from Japan and China. The
MFEZs (special industrial zones for both export-oriented and
domestic-oriented industries) were established to “create a plat-
form for Zambia to achieve economic development by attracting
significant domestic and foreign direct investment (FDI)
through a strengthened policy and legislative environment,”and
are characterised by “the best features of free trade zones
(FTZs), export processing zones (EPZs) and the industrial
parks/zones concept.”
18
In addition to bolstering governance
and infrastructure to create an attractive investment environ-
ment, the ZDA provides a list of investment incentives offered
to investors who intend to establish operations in the MFEZs,
or whose investment aligns with Zambia’s development priority
sectors. There are seven MFEZ priority sectors and 12 general
priority sectors including agroprocessing and manufacturing of
agricultural products, including tobacco. The principal require-
ment to receive an investment incentive from the ZDA is out-
lined in Article 56: “An investor investing not less than five
hundred thousand United States Dollars or the equivalent in
convertible currency, in a priority sector or product, is entitled
to incentives as specified by or under the Income Tax Act or
Customs and Excise Act.”
17
The priority given to agroproces-
sing and manufacturing is supported by the objective to establish
value addition within Zambia,
19
including efforts “to increase
tobacco processing for more value-added.”
11
This objective of value-addition is currently being enacted
through government support for the establishment of a tobacco
processing and manufacturing plant in the Makeni Industrial
Park (an MFEZ) in Lusaka by Roland Imperial Tobacco
Company (RITCO), a Zambian company.
20–22
At present, the
plant is intended simply to process tobacco leaf. However, as a
senior staff person with the MFEZ noted, “in the long run, [the
company has] indicated it is in phases, in phase one they are
processing and laying the ground work, and then when they get
to phase three, that is when they begin to manufacturing the fin-
ished product [cigarettes].”In a public pronouncement, the
chief executive officer of RITCO claimed, ‘we invested more
than US$8 million in our new cigarette plant in Lusaka, which
can produce two billion cigarettes per year, or around twice the
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cigarettes sold in Zambia annually.’
22
This amount far exceeds
the US$500 000 minimum investment that is required to qualify
for the incentives outlined by the ZDA.
17 19 23
Whether restricted to leaf processing only, or proceeding to
finished product (not all Zambian informants thought this
would be likely), the company would benefit from government
support in the form of no tariffs or VATon imported machinery
or raw goods. As well, “the government is funding this [MFEZ]
…they had to put up a requisite structure [electricity, roads,
water] to make sure that the place is conducive for our investors
both local and foreign”(MFEZ informant). It would also be
exempt from any tax on profits for the first 5 years, paying only
50% of the standard corporate rate for the next 3 years, and
75% for the following 2 years. Only after 10 years would
profits be taxed at Zambia’s normal corporate rate. These bene-
fits would apply to tobacco, as with any other agroindustry
product that comprises one of ZDA’s priority investment areas,
and to processed leaf or finished products regardless of whether
these are meant for the domestic or export market. That these
incentives could give an unfair advantage over other Zambian
tobacco leaf processors or a manufacturer (one of our infor-
mants stated that another manufacturing plant was getting estab-
lished outside of an MFEZ) “has not yet been discussed,
because the primary objective of these zones is to promote
investment”(MFEZ informant).
We are working knowing we have been told [by ZDA] to win
investors …we are being pushed that we need investors [yet] I
know that it has been the objective of the government to regulate
[tobacco] consumption …so you may say that if they are doing
that then are contradicting that …We market [investment] on
the marketing point of view not on the health point of view …If
we say we look at the health point then we would be negative for
us [and] we have to show the positive side. (MFEZ informant)
Our interviews with representatives from Zambia’s
Department of Industry (DoI) and Department of Foreign Trade
(DoFT) similarly found that these departments were also
actively encouraging tobacco companies to set up processing
and manufacturing facilities in Zambia. The participants expli-
citly stated that they encouraged the provision of investment
incentives to make this happen, for both the domestic and inter-
national markets. Both department representatives viewed
tobacco manufacturing as a potential growth area for Zambia’s
economic development objectives. This encouragement was situ-
ated in the development strategy targeting value addition
(namely manufacturing of agricultural products grown in
Zambia) within the economy: “the agricultural sector will con-
tinue to be a strategic area of focus in promoting economic
growth, reducing poverty and creating employment.”
24
Since
the closing of the British American Tobacco manufacturing
plant in Lusaka in 2006,
25
all the cured tobacco was being
exported for manufacturing in other countries.
When asked about the role of the FCTC in the policies of
their respective departments (ie, DoI and DoFT), the partici-
pants only had a vague understanding of its provisions or what
commitments Zambia had made towards its implementation.
A high-level key informant from the DoFT was unsure whether
the treaty was in force in Zambia, and noted “implementation
hasn’t started yet.”This statement may have been in reference
to stalled comprehensive tobacco control legislation, although
the treaty had come into force in Zambia in August 2008. It is
difficult to identify whether there is a true lack of understanding
of the FCTC and its relation to the economic policies of the
country by these informants, or whether their government
departments are intentionally acting contrary to its provisions.
We sensed from the interviews that the FCTC was simply not
considered to be relevant to the work of either the DoI or the
DoFT, and was situated as a singular Department of Health ini-
tiative. When we asked the participants about the relationship
between investment incentives for tobacco processing and
manufacturing and the health aspects of tobacco consumption,
one participant stated that: “It is our view that the benefits to
the economy will outweigh the health costs”(DoI informant).
Another participant, making the same argument as the inter-
viewee from the MFEZ, noted “our concern is to promote
industrial development and because smoking was a personal
decision, we are not concerned with the health aspects”(DoI).
The view that Zambia’s tobacco production, and even its
potential future cigarette manufacturing, would not add to its
domestic smoking rates was echoed by tobacco industry infor-
mants, one of whom was quite explicit:
There is this myth that the more tobacco we grow here the more
smokers we will have. We do not grow tobacco for local con-
sumption but rather for the growing market like China. There is
no correlation with the level of growing tobacco in Zambia to
the level of smoking. It doesn’t exist. In fact there is a reduction
in smoking in Zambia (tobacco industry informant).
The most recent WHO tobacco report on Zambia, however,
estimates that in 2012, 24% of males were current cigarette
smokers and 22% of them smoked daily, an increase of 2 and 5
percentiles, respectively, over the previous year.
26
Female rates
remain considerably lower, but are rising among adolescents.
27
When asked that, even assuming Zambian tobacco was strictly
for export, if it still meant someone else will be consuming a
hazardous product, the response was swift, “even if we do not
grow tobacco in Zambia, somebody else will grow it [and
export it] so you see what I mean, it will still be there.”The
Tobacco Association of Zambia (TAZ), representing farmers,
noted that “the harmful effects on the human being is not
debatable, it has been proven, we have all seen it”but that “it
all borders on educating the person, that you have a choice in
life and should manage your life accordingly”(TAZ informant).
These qualitative findings provide important insights into the
rationale used by members of the government’s economic sector
when developing policy pertaining to tobacco; this often resem-
bles the arguments of Zambia’s tobacco industry and farming
representatives, and suggests that there is deep misalignment
between FCTC commitments and efforts to implement the
treaty across relevant sectors of the government. The tension
this creates was best captured in the somewhat wistful comment
made by our MFEZ informant near the end of the interview:
“I think somehow there must be harmonization of government
policy; then that will make it much easier for stakeholders.”
One of the salient conditions underlying policy misalignment
and lack of harmonisation is that tobacco control is under-
resourced. There will need to be great effort to strengthen the
system of implementation within countries such as Zambia. One
individual serves as the FCTC focal point, but is responsible for
a diverse portfolio of responsibilities beyond tobacco control.
Along with other African countries at the FCTC Conference of
Parties meetings, Zambia has complained about the lack of
resources to implement tobacco control. A senior policy worker
in the Ministry of Health thought that one reason why the com-
prehensive tobacco control legislation has been stuck for 4 years
is that, “We had the challenge of funding, because initially
tobacco was not on our agenda and …we [had] different
budget lines …[and] it gives us a gap because we don’thave
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funds to use for that purpose.”There is no multisectoral body
in Zambia charged with FCTC implementation, and the differ-
ent sectors ‘are not coordinating properly’(Ministry of Health
informant). DoI, DoFT, and Agriculture noted that they did not
work with the Ministry of Health around issues of tobacco and
tobacco control. There is, however, an active, but small group
of civil society organisations and individuals within government
working in tobacco control, but it must contend with a politic-
ally active and highly resourced tobacco industry whose own
interests in ‘coordinating’is about:
Sitting together. You see look we agree on most of the things but
because we do not sit together we assume that we don’t agree. We
need to sit together as an industry …The problem in this country
is that we do not have an apex, one organization where all players
meet for cross cutting issues. (tobacco industry informant)
DISCUSSION
Our findings on the Zambia’s tobacco investment incentives
point to an urgent need for proponents of the FCTC (domestic
and international) to engage with the ZDA, DoI and DoFT to
generate economic policies that align with FCTC commitments.
The question is how to do this?
The Zambian government, like many governments around
the world, is fragmented when it comes to governing tobacco
and tobacco control. This fragmentation exists not only intern-
ally, but also at different levels whereby the DoI, DoFT and
ZDA are linked with different economic development agencies
within the United Nations system and the Department of
Health is operating in relation to WHO and the Framework
Convention Secretariat. Fragmentation is a not a new phenom-
enon, and undergirds calls made within the United Nations
System to “strengthen multisectoral and inter-agency responses
for the full implementation of the WHO FCTC.”
28
To label the
lack of communication, coordination and cooperation between
sectors as fragmentation is only theoretically valid if there is an
underlying need to act collectively. In the case of FCTC imple-
mentation, fragmentation exists because comprehensive tobacco
control implementation (invoking all components of the treaty
including supply and demand measures) requires interventions
in different sectors and levels of government. In this sense,
FCTC implementation poses a collective action problem that
challenges institutional designs that create departmental silos
with minimal interaction and strong jurisdictional boundaries
between sectors. In fact, the integrity of traditional departmen-
tal jurisdiction is reflected in the authority to “operate within a
spatial and functional realm.”
29
A logical starting point to facili-
tate intersectoral working is to establish a forum for dialogue.
The forum itself is not a panacea, but rather an initial point of
contact. Brazil presents a good example of how a high-level
decision from the President created a forum (CONICQ—ie, the
intersectoral coordinating mechanism for the implementation of
the FCTC) that brought together 13 different ministries and
departments to work on FCTC implementation.
30 31
It will
likely require a high-level decision to create such a forum in
Zambia. Another basic starting point for those working on
FCTC implementation in countries like Zambia is to begin to
establish and propagate norms embedded in the FCTC. In this
case, it will be the responsibility of proponents of tobacco
control to reinforce the binding legal nature of commitments
made to the FCTC to other sectors of government. The guide-
lines for Article 5.3 explicitly state, “Parties should not grant
incentives, privileges or benefits to the tobacco industry to estab-
lish or run their business”(Article 5.3 guidelines, p8); but
evidence from this research suggests they are presently violating
in Zambia.
It is possible that the first reaction to our findings might be
that the tobacco industry has co-opted FCTC implementation
by ‘capturing’the economic sector. Regulatory capture, “specif-
ically the process through which regulated (companies) end up
manipulating state agencies that are supposed to control
them,”
32
is a common occurrence in tobacco politics.
33–35
We suggest that although this may be, and likely is, part of the
scenario in Zambia, there are other contextual factors that
create a pull towards providing investment incentives for
tobacco manufacturing. Zambia is a tobacco producer and
exporter. The priority for the country is to diversify its eco-
nomic output while supporting value-addition in its processing
and manufacturing within the country. In this context, tobacco
is a logical target for value-addition (leaf processing and manu-
facturing) given that the supply chain is well established. This is
not to say that the provision of investment incentives is good
practice; in fact, we suggest the opposite. Understanding this
context will allow tobacco control proponents to target the
underlying logic used by government officials who are promot-
ing tobacco production, while also developing an empathetic
stance when working to develop collaborative relationships with
other government sectors. Understanding this context provides
the basis for finding a remedy for this policy misalignment from
the perspective of FCTC implementation. There are numerous
interventions that can address this misalignment between eco-
nomic policy pertaining to tobacco and commitments to imple-
ment the provisions of the FCTC. The arguments used by our
key informants in favour of bolstering tobacco manufacturing
through government investment incentives suggests that dis-
course in the economic sector is largely influenced by the stand-
ard arguments (eg, job loss/gain, revenue generation, personal
choice) perpetuated by the tobacco industry over the years, par-
ticularly in tobacco growing countries.
36 37
Studies, like this
one, provide important information to sensitise tobacco control
proponents to the perspectives and approaches being fostered
outside of the health sector. This sensitisation is particularly
important as countries begin to implement intersectoral coord-
inating mechanisms for FCTC implementation as per Article
5.2. It is recognised that the political economic context must be
confronted and engaged with by tobacco control proponents for
any lasting success in tobacco control policy to be made.
238–40
At a more abstract level, this study suggests a need to establish
and integrate norms pertaining to the economics of tobacco and
tobacco control. Our interviews revealed that the logic employed
within the economic sector, that tobacco is a viable and sustain-
able economic commodity, still persists despite numerous studies
to the contrary.
41–43
The argument that tobacco is an export
commodity and therefore, not linked to the health of the popula-
tion within the country is contrary to the intent of the FCTC to
reduce tobacco consumption worldwide (and not simply in any
given country).Without comprehensive tobacco control measures
in place it is predicted that consumption among Zambians will
increase.
27 44–47
It is reported that RITCO is in discussion with
Japan Tobacco Incorporated ( JTI) to produce JTI brands for the
Zambian market.
22
RITCO itself has indicated that they will be
developing new brands to be sold in the domestic market. The
proliferation of tobacco products without the protection of com-
prehensive tobacco control measures will most likely lead to dra-
matic increases in consumption.
Government investment incentives that support tobacco
industry development are deeply problematic for FCTC imple-
mentation. This finding in Zambia’s case, which we speculate is
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likely to be repeated in most other low-income tobacco-
producing countries that are also parties to the FCTC, points to
an urgent need to foster WoG FCTC implementation.
What this paper adds
▸Successful implementation of the WHO Framework
Convention on Tobacco Control (FCTC) will require
whole-of-government (WoG) engagement.
▸There continues to exist gross misalignments between the
economic policies of tobacco producing countries, such as
Zambia, who are providing investment incentives to support
tobacco industry activity, and making commitments to
implement the provisions of the FCTC.
▸Providing investment incentives to stimulate tobacco
processing and manufacturing is contrary to Article 5.3 of
the FCTC, and is a crucial component to be addressed by
tobacco control proponents to reduce the supply of tobacco.
▸Our study provides important insights into the underlying
logic used by officials to justify investment incentives that
support tobacco processing and manufacturing.
Contributors RLen, RLab, RZ and FG contributed to data collection. RLen and
RLab undertook data analysis. RLen wrote the first draft of the manuscript. JD, RLab
and FG contributed to the conceptualisation and writing of the manuscript.
Funding This analysis is derived from research supported by the National Institute
on Drug Abuse, the Fogarty International Center, and the National Cancer Institute
of the National Institutes of Health under Award Number R01DA035158.
Competing interests None declared.
Ethics approval IRB of Mcgill University, Morehouse University (American Cancer
Society) and University of Zambia.
Provenance and peer review Not commissioned; externally peer reviewed.
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Lencucha R, et al.Tob Control 2015;0:1–5. doi:10.1136/tobaccocontrol-2015-052250 5
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Investment incentives and the
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