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26th March 2014
WHO has published a draft proposal for a Framework and set of policies to address its engagement with Non State Actors (NSAs). Member States are being invited to discuss these proposals at WHO’s HQ in Geneva on 27th and 28th March. Public Interest NGOs are not invited. IBFAN has been following the process closely and finds serious flaws, inconsistencies and contradictions in the proposals.
Despite the many statements of WHO’s Director General, Margaret Chan, that WHO’s policies, norms and standards setting processes should be protected from commercial influence, if the new proposals were to be adopted, the corporate influence would increase. IBFAN fears that this would compromise WHO’s integrity, independence and its ability to fulfil its mandate.
In particular, the proposals introduce a new risky element, allowing Official Relations status, with all its related privileges, for International Business Associations. Up to now, if businesses wanted to attend governing body meetings in order to lobby Member States delegations, they could wear a public badge, or, if they wanted to speak, inveigle their way onto government delegations. Some, over the years have slipped through WHO’s admission procedures, pretending to be NGOs. The new proposals open the door wide to participation by any business member of these Associations, except tobacco or arms companies. This would, in effect, legitimize businesses lobbying role at WHO’s global policy-setting meetings – the very thing that WHO alleges that it is trying to avoid. In addition to turning WHO governing bodies meetings into multi-stakeholder public-private gatherings, the proposals would also allow businesses greater engagement at programme level, through agreed 3-year plans with WHO.
Lida Lhotska, IBFAN NGO Liaison to WHO says: “If these new policy proposals are adopted, IBFAN fears that WHO will be unable to lead and support Member States in taking the bold decisions necessary to tackle global health challenges. For example, irresponsible marketing is a major underlying cause of Non Communicable Diseases (NCDs). In tackling NCDs, acknowledged to be a major threat to public health, will WHO prefer to engage in partnerships with corporations, who would prefer campaigns for promoting ‘slightly better for you products’– or will WHO help Member States bring in legally-binding controls that truly protect right to health of their citizens?”
1 Business front groups that have managed to gain Official NGO status: International Special Dietary Foods Industries (ISDI, representing the baby feeding industry) ISDI lost this status in January 2014, Croplife International (representing Monsanto, Syngenta, Bayer, CropScience, Dow Agrosciences, DuPont and other companies promoting GMO technologies ), International Life Sciences Institute (ILSI, representing Nestlé, Coca Cola, Kellogg, Pepsi, Monsanto, Ajinomoto, Danone, General Mills and others) and the Industry Council for Development (representing Nestlé, Mars, Unilever and Ajinomoto)
Another business entity that would benefit from the proposals is the International Food and Beverage Alliance ( (representing Nestlé, Pepsi, Mars, Coca Cola, Unilever and other food giants ). IFBA members sign up to 5 commitments
1. Reformulate and develop new products that support the goals of improving diets;
2. Provide clear and fact‐based nutrition information to all consumers;
3. Extend responsible advertising and marketing initiatives to children globally;
4. Promote balanced diets and healthy, active lifestyles; and
5. Actively support public‐private partnerships that support the WHO 2004 Global Strategy on Diet, Physical Activity and Health.
If translated into a 3 year plan, these would push WHO towards public-private partnerships and ‘responsible advertising’ of ‘slightly better for you junk food.’
Note: In 2014 an EU Action Plan on Childhood Obesity 2014-2020 was passed. Among the 8 actions considered ‘doable’ was a no food and drink sponsorship in schools rule. Food and advertising industries wanted a larger role in its development but the Commission (DGSANCO) and Member States stressed the importance of governments staying in the ‘Drivers Seat’ on matters relating to health. (Click here)
IBFAN is concerned that the proposals:
· Fail to include the principal that increased engagement should contribute to the fulfilment of the WHO’s mandate and give added value to public health.
· Fail to acknowledge the fundamentally different nature of the two principal sets of actors: public-interest actors (guided by public-health agenda) and private commercial sector (guided by market profit-making logic) as if both sets of external actors had or could have a primary interest in line with the WHO public interest mandate.
· Fail to acknowledge the different level the increased level of risk that commercial interests pose to WHO integrity, independence and trustworthiness/credibility.
· Increases commercial entities access to WHO’s governing body meetings and informal consultations where WHO’s policies, norms and standards are set, and grants them the right to take part in 3 year work plans with WHO.
· Fail to address the problem of hybrid entities (public-private partnerships and multi-stakeholder arrangements), even though these entities have companies/corporations on their boards and as funders, and more often than not represent interests of the commercial sector.
· Contain no analysis of underlying causes for institutional and individual Conflict of Interest (COI) in relation to different actors and different forms of engagement. Moreover, throughout the text of all the draft policies, while COI is mentioned several times, there is no attempt to develop a systematic and comprehensive framework of COI safeguards to ensure avoidance of those COI that must be eliminated and appropriate management of the remaining ones.
· Fail to state that financial resources to implement the policy will come from WHO’s regular budget. This would prevent any conflict of interest and unpredictability in the scrutiny and oversight of the policies and procedures.