Towards Preventing and Managing Conflict of Interest in Nutrition Policy? An Analysis of Submissions to a Consultation on a Draft WHO Tool

Abstract

<jats:p> <jats:bold>Background:</jats:bold> With multi-stakeholder approaches central to efforts to address global health challenges, debates around conflict of interest (COI) are increasingly prominent. The World Health Organization (WHO) recently developed a proposed tool to support member states in preventing and managing COI in nutrition policy. We analysed responses to an online consultation to explore how actors from across sectors understand COI and the ways in which they use this concept to frame the terms of commercial sector engagement in health governance. <jats:bold>Methods:</jats:bold> Submissions from 44 Member States, international organisations, non-governmental organizations (NGOs), academic institutions and commercial sector actors were coded using a thematic framework informed by framing theory. Respondents’ orientation to the tool aligned with two broad frames, ie, a ‘collaboration and partnership’ frame that endorsed multi-stakeholder approaches and a ‘restricted engagement’ frame that highlighted core tensions between public health and food industry actors. <jats:bold>Results:</jats:bold> Responses to the WHO tool reflected contrasting conceptualisations of COI and implications for health governance. While most Member States, NGOs, and academic institutions strongly supported the tool, commercial sector organisations depicted it as inappropriate, unworkable and incompatible with the Sustainable Development Goals (SGDs). Commercial sector respondents advanced a narrow, individual-level understanding of COI, seen as adequately addressed by existing mechanisms for disclosure, and viewed the WHO tool as unduly restricting scope for private sector engagement in nutrition policy. In contrast, health-focused NGOs and several Member States drew on a more expansive understanding of COI that recognised scope for wider tensions between public health goals and commercial interests and associated governance challenges. These submissions mostly welcomed the tool as an innovative approach to preventing and managing such conflicts, although some NGOs sought broader exclusion of corporate actors from policy engagement. <jats:bold>Conclusion:</jats:bold> Submissions on the WHO tool illustrate how contrasting positions on COI are central to understanding broader debates in nutrition policy and across global health governance. Effective health governance requires greater understanding of how COI can be conceptualised and managed amid high levels of contestation on policy engagement with commercial sector actors. This requires both ongoing innovation in governance tools and more extensive conceptual and empirical research. </jats:p>

Tackling NCDs: The Need to Address Alcohol Industry Interference and Policy Incoherence Across Sectors Comment on "Towards Preventing and Managing Conflict of Interest in Nutrition Policy? An Analysis of Submissions to a Consultation on a Draft WHO Tool"

“…alston and colleagues 1 address an important issue in global health, that of how to manage non-state actors' engagement with governments and intergovernmental organisations in ways that do not undermine or interfere with their mandates to promote public health. The need to develop mechanisms and tools to prevent industry interference that weakens public policy-making for health is important for all areas of government.…”

The World Health Organization, Corporate Power, and the Prevention and Management of Conflicts of Interest in Nutrition Policy Comment on "Towards Preventing and Managing Conflict of Interest in Nutrition Policy? An Analysis of Submissions to a Consultation on a Draft WHO Tool"

“…Ralston and colleagues' scholarly study of the 2017 WHO consultation on the decision-making tool provides a fascinating account of business thinking on nutrition policy. 10 The take home message of the paper -that all commercial actors were highly critical of the tool -is instructive, if unsurprising. More importantly, their analysis of the policy frames used by commercial actors provides an important guide to the discursive architecture that underpins contemporary corporate political activity within nutrition policy.…”

“…Ralston and colleagues note that commercial actors articulated a 'collaboration and partnership' frame which was strongly critical of the tool as exclusionary, viewed its recommendations as inconsistent with principles of good governance, and presented conflicts of interest as compatible with extensive engagement and adequately addressed by existing practices. 10 The key to understanding this frame and, more generally, commercial actors' submissions to consultations is that they typically draw on a broader, logically coherent, integrated system of concepts, ideas, and beliefs. Collectively, these constitute a discursive framework advocating a programme and style of governance consistent with strong corporate earnings [13][14][15] and represent an important building block of corporations' 'discursive power' in so far as they seek to shape how policy problems and solutions are interpreted and acted on.…”

“…[3][4][5][6][7][8][9] The decisionmaking tool encompasses a six-step process of risk assessment, balancing and mitigation. 1,10,11 It applies generally to non-state actors and is presented as a resource that 'governments may decide, at their discretion, to follow…completely or partially. ' 1 However, if followed closely it stands to revolutionise businessgovernment relations in nutrition policy in much the same way as Article 5.3 of the WHO Framework Convention on Tobacco Control (FCTC), which aims to protect tobacco policies from tobacco industry political influence.…”

“…1 However, if followed closely it stands to revolutionise businessgovernment relations in nutrition policy in much the same way as Article 5.3 of the WHO Framework Convention on Tobacco Control (FCTC), which aims to protect tobacco policies from tobacco industry political influence. 10,12 The potential policy implications of the decision-making tool are illustrated by 'exclusionary criteria' -outlined in Step Two -to determine whether governments should engage with a non-state actor. These include whether the actor aims to participate in 'policy development' -which is broadly defined to encompass agenda setting, policy formulation and decision-making -or 'contribute (in-kind or financially) to activities related to government normative work or public officials. '…”