

Middleton is guided by Altria Group’s
Mission, as well as Altria's
Code of Conduct, and is committed to marketing our products responsibly by building relationships between our brands and adult tobacco smokers while taking steps designed to limit reach to unintended audiences.
We primarily compete in the U.S large machine-made cigar category with
Black & Mild. We design our marketing programs to enhance brand awareness, recognition and loyalty among adult tobacco smokers to grow market share.
We have practices in place to focus our marketing activities toward adult tobacco smokers while limiting reach to unintended audiences.

Instead, we primarily connect with adult tobacco smokers in two ways:
- One-to-one consumer communications, which include direct mail, email, a consumer website and consumer marketing activities with age-verified adult tobacco smokers 21 years of age or older.
- At retail, where we present our brands to legal-aged tobacco smokers at the point of purchase. We offer programs to help merchandise our products and to help restrict underage access to cigars.
We have programs in place designed to connect with our intended audience while
helping to prevent underage access to cigars. For example:
- Age Verification: We communicate one-to-one with adult tobacco smokers, and use procedures to verify a person is 21 years of age or older prior to sending any branded information or allowing access to our consumer website. To assist retailers, we support the We Card® program that helps train and assist retail clerks to check ID's before selling tobacco products.
- In-store access: We work with retailers to restrict product access. In addition to state and local laws, our trade program provides incentives to retailers to merchandise our products in a non-self-service manner and reduce potential underage access.
- Product placement requests: We deny requests for permission to use or display our brands in any movies or television shows or other public entertainment media.