Mystery Shopper Programme

Juul Labs UK operates a Mystery Shopper Programme to monitor retailer compliance with age-verification laws and company policies.

Juul Labs UK conducts retailer compliance checks through its Mystery Shopper Programme to help JUUL retailers assess their compliance with age-verification laws and Juul Labs UK’s underage use prevention policies.

Challenge 25 mandates that before a sale, the staff request and inspect a government-issued ID for anyone appearing below the age of 25 to prove that they are over the age of 18. Third-party auditors may go into your retail locations to shop for JUUL products and perform the Challenge 25 compliance check.

Juul Labs UK contracts Serve Legal as an independent, third-party to conduct mystery shopper visits. Serve Legal is a market-leading provider of age-verification and compliance testing services in the United Kingdom and Ireland.

Serve Legal recruits 18/19-year-old auditors to shop for JUUL products. Retailers will incur a violation if the shop assistant fails to request a photographic ID of a shopper who appears under the age of 25 years to verify that they are of legal-purchasing age.

Juul Labs UK implements a Three-Strikes Enforcement Policy for retailers that incur a violation. This policy enforces escalating penalties for retailers with subsequent violations, including and up to a potential sales ban.

Below is a detailed summary of the actions taken by Juul Labs UK for every subsequent violation:

	3 Strikes Policy	Responsibilities and Actions
Fail 1	Communicated to the retailer by the following methods: Juul Labs UK sends an auto- generated email Notification Letter to the retailer, informing them of the failed compliance check Where there is no email address, letters will be posted by mail	Verbal communication and training: All sites that receive a first failed compliance check should receive Challenge 25 (C25) training materials prior to retesting Retailers are re-tested 60-90 days after the first failed shop
Fail 2	Communicated to the retailer by the following methods: Juul Labs UK sends an auto-generated email Notification Letter to the retailer, informing them of the failed compliance check Where there is no email address, letters will be posted by mail	Additional C25 training All sites that receive a second failed compliance check should receive additional C25 training materials prior to retesting Retailers are re-tested 60-90 days after the second failed shop
Fail 3	Communicated to the retailer by the following methods: Juul Labs UK institutes a 90-day suspension period that prohibits the retailer from selling JUUL products during the suspension period Retailers receive a letter informing them of their suspension	Suspension Retailers are subject to a 90-day suspension period from selling JUUL Products Retailers should receive communications from Juul Labs UK requesting that the retailer complete team training prior to reactivation The retailer is re-tested within 30 days of reactivation

3 Strikes Policy

Responsibilities and Actions

Fail 1

Communicated to the retailer by the following methods:

Juul Labs UK sends an auto- generated email Notification Letter to the retailer, informing them of the failed compliance check
Where there is no email address, letters will be posted by mail

Verbal communication and training:

All sites that receive a first failed compliance check should receive Challenge 25 (C25) training materials prior to retesting
Retailers are re-tested 60-90 days after the first failed shop

Fail 2

Communicated to the retailer by the following methods:

Juul Labs UK sends an auto-generated email Notification Letter to the retailer, informing them of the failed compliance check
Where there is no email address, letters will be posted by mail

Additional C25 training

All sites that receive a second failed compliance check should receive additional C25 training materials prior to retesting
Retailers are re-tested 60-90 days after the second failed shop

Fail 3

Communicated to the retailer by the following methods:

Juul Labs UK institutes a 90-day suspension period that prohibits the retailer from selling JUUL products during the suspension period
Retailers receive a letter informing them of their suspension

Suspension

Retailers are subject to a 90-day suspension period from selling JUUL Products
Retailers should receive communications from Juul Labs UK requesting that the retailer complete team training prior to reactivation
The retailer is re-tested within 30 days of reactivation