In early 2018, the world of global health was shaken by a serious scandal. The Global Fund to Fight HIV, Tuberculosis, and Malaria had announced to partner with Heineken – despite the fundamental conflict of interest with the fund’s objective to tackle the burden of HIV and AIDS. This partnership was beneficial only to the global beer giant because it gave Heineken credibility in its marketing to consumers and legitimacy as a partner to governments. The response from communities around the world was swift and strong. After investigative reporting showed how Heineken is exploiting young women to sell and promote beer (“beer girls”) the Global Fund decided to suspend the partnership.
The case is the context for WHO’s information note to all staff members establishing principles and providing guidance for the interaction with Big Alcohol.
Several governments, inter-governmental agencies, such as UNITAR, and non-governmental organisations (NGOs) have come under criticism for partnering with the alcohol industry – and thereby aiding Big Alcohol to achieve their strategic objectives.
The WHO’s internal information note illustrate the pressure the alcohol industry must be exerting on WHO staff at all levels, pushing for partnerships and for being involved in public policy development.
As the WHO seeks to implement the Framework for Engagement with Non-State Actors (FENSA), keeping the alcohol industry at arm’s length is of importance to protect the organization’s mission, work and norm-setting leadership in global health.
Here is the leaked information note:
WORLD HEALTH ORGANIZATION Information Note: 12/2019
Subject: Principles and guidance for interaction between WHO Secretariat and the alcohol industry
Distribution: All WHO, IARC, ICC and staff members worldwide
Date: 29 March 2019
1. Purpose
The principles and guidance for interaction between WHO Secretariat and the alcohol industry, aligned with and operationalised in accordance with FENSA, were developed for internal use of WHO Secretariat to assist in appropriate interaction with representatives of the alcohol industry for achieving positive outcomes for public health.
2. Definition
For the purposes of this document the term “alcohol industry” means manufacturers of alcoholic beverages, wholesale distributors, major retailers and importers that deal solely and exclusively in alcohol beverages or whose primary income comes from trade in alcohol beverages. In addition, in this document the term “alcohol industry” includes business associations or other non-State actors representing or funded largely by any of the afore-mentioned entities, as well as alcohol industry lobbyists and commercial interests in alcohol beverage trade other than above when the interaction with WHO can be linked to their interests in alcohol beverage trade. Other non-State actors who receive funding from the alcohol industry (including funding for research) or have considerable links to the above-mentioned entities should be reviewed on an ad hoc basis in order to determine whether they should also be viewed as “alcohol industry”.
3. Context
The public health objectives of WHO in relation to alcohol should serve as the basis for any interaction with the alcohol industry. Any dialogue between WHO and the alcohol industry or engagement of alcohol industry in any meeting between WHO and non-State actors should comply with the guidance provided in this document. The appropriate engagement of the alcohol industry in implementation of the WHO Global strategy to reduce the harmful use of alcohol is defined in paragraph 45 (d) “Global action: key roles and components”. The nature of interaction between the WHO Secretariat and the alcohol industry should be limited to a dialogue and exchange of information for achieving positive outcomes for public health. Interaction with the alcohol industry within a given framework should not lead to or imply “partnership”, “collaboration” or any other similar type of engagement that could give the impression of a formal joint relationship, the reason being that such engagements would put at risk the integrity, credibility and independence of WHO’s work.
4. Meetings
Meetings between the WHO Secretariat and the alcohol industry can be considered only when such interaction is deemed necessary by the WHO Secretariat. The purpose, objectives and scope of the meeting and how it will contribute to WHO public health objectives should be determined in advance by the WHO Secretariat. The WHO Secretariat should be informed in advance of the names, positions and affiliations of each participant of the meeting representing the alcohol industry. WHO should be (a) solely responsible for developing the meeting agenda / programme, (b) inviting participants and (c) preparing the meeting report or other outcome document. Should the alcohol industry approach WHO Secretariat for a meeting (informal or formal), WHO representatives should clearly indicate, prior to the meeting, preferably in writing, to the alcohol industry representatives, that the meeting does not imply collaboration or partnership between WHO and the alcohol industry and that no partnership, collaboration or similar relationship may be implied in any representation or publications by the industry. The organizers should also be informed that the agenda of the meeting should be communicated beforehand to WHO and its approval by the Secretariat in line with the guidance provided in paragraph 7 is required before confirming its participation to the meeting.
Meetings between the WHO Secretariat and the alcohol industry should in no case take place at alcohol industry premises, or entities that are considered not at arm’s length from the alcohol industry (lobbyists or similar entities) and with the presence of the Legal Counsel as appropriate. At meetings with the alcohol industry WHO Secretariat has to be represented by at least two staff members. WHO personnel should moderate the meeting if it is sought by the WHO. There should be no jointly-signed documents, written commitments, contracts or memoranda of understanding on the circumstances or outcomes of the meeting between WHO and the alcohol industry as this implies a relationship. WHO staff present at the meetings should produce and sign an internal note for the record and make this note available to the Department of Mental Health and Substance Abuse (MSD) and the Department of Partnerships and non-State actors (PNA), which will consider further dissemination of the note.
5. Funding
WHO activities cannot be funded directly or indirectly by the alcohol industry as defined in paragraph 2. WHO programmes shall not enter into collaboration with third parties on projects / activities that have been funded directly or indirectly by the alcohol industry as defined in paragraph 2. In-kind contributions to WHO projects and activities from the alcohol industry, such as contributing products, services, secondment of staff, cannot be accepted. When reviewing the designation and redesignation of WHO Collaborating Centres, the concerned WHO programme should ensure that the entity`s activities are not funded directly or indirectly by the alcohol industry. WHO staff should avoid participating in events organized or largely funded by the alcohol industry. If such participation is considered as absolutely necessary and will take place, it is important that the Department of Mental Health and Substance Abuse and the Department of Partnerships and non-State actors (PNA) are informed about WHO staff participation in the event and its outcomes as stipulated in paragraph 7.
6. Support to Member States
Whenever WHO staff are asked for advice from a national government or a national governmental official on the appropriate engagement with the alcohol industry at national level, WHO staff should clearly state that this is at the discretion of each Member State, but at the same time point to potential risks that include (but are not limited to): (a) conflict of interest; (b) undue or improper influence exercised by the private sector entities on public health’s work, especially in (but not limited to) policies, norms and standard setting; (c) the engagement may be primarily used to serve the interests of the alcohol industry with limited or no benefits for public health; (d) the engagement may be considered as conferring an endorsement of the alcohol industry’s name, brand, product, views or activity; and (e) the engagement may be considered as a whitewashing of the alcohol industry’s image through an engagement with the Government. The Government should be informed that the WHO Secretariat does not engage the alcohol industry in alcohol policy development and formulation, and does not enter into partnership or collaboration with the alcohol industry in implementation of public health measures, including those to reduce the harmful use of alcohol. Further, that no funding or in-kind contributions are accepted by WHO from alcohol industry sources and that any engagement between the WHO Secretariat and the alcohol industry is restricted to information sharing and consultations for the benefit of public health. The alcohol industry is encouraged to take actions in accordance with paragraph 45 (d) in Global strategy to reduce the harmful use of alcohol, but this should in no way prevent or restrict the Government from implementing effective and cost-effective interventions to reduce the harmful use of alcohol.
7. Process
In order to support WHO Staff regarding requests for interaction from the alcohol industry and to secure a coherent and predictable approach from the Organization to such requests, all WHO offices are encouraged to inform their respective FENSA Designated Focal points, the Department of Partnerships and non-State actors (PNA) and the Department of Mental Health and Substance Abuse (MSD) of any such request for interaction by the alcohol industry or any meetings or consultations planned and their intended outcomes prior to any interaction. The respective FENSA Designated Focal points, the Department of Partnerships and non‑State actors (PNA) and the Department of Mental Health and Substance Abuse (MSD) may also be consulted in advance of such meetings for any advice or relevant information about previous meetings or similar meeting requests in other parts of the Organization, as well as developments at a global level which may be relevant to matters to be discussed at any requested meeting.
