Thursday, November 12, 2015

NGOs criticise WHO's 'non paper' on conflicts of interest

NGOs criticise WHO's  'non paper' on conflicts of interest

22.10.2015 For the past 4 years and as part of the WHO reform, WHO and its governing bodies are discussing new set of policies, currently called Framework of Engagement With Non State Actors (FENSA). This is a critically important document as its final shape will determine whether WHO will be an agency able to protect its independence, integrity and credibility. The International Baby Food Action Network (IBFAN),  Third World Network (TWN) and other Public-interest NGOs  and networks have been closely following the process. Negotiations have taking place in Geneva this week and tomorrow - Friday 23rd October -  Member States will discuss  a new problematic document - referred to as a  NonPaper [1]   that has been prepared by WHO's Secretariat.  This paper lists supposed  risks of implementing FENSA and suggests that it would have “detrimental consequences on the work of WHO.”  In response to the "non-paper''  66 NGOs  working in health, right to food and nutrition or human rights have written to Dr Chan, Director General of WHO,  calling on her to protect the UN and overall policy-making from corporate takeover.  CLICK HERE:   NGOtoChan_22.10.15 (2). The NGOs express concern that the "non-paper'' is an attempt by the Secretariat to prevent the further strengthening of  FENSA that would allow it to become a much-needed  robust framework that would insulate WHO from corporate capture and other undue influences.  Currently WHO does not have transparent effective policies and tools to prevent such undue influences. The "non-paper'' lists  potential ‘unintended consequences’ often in an exaggerated manner, as assumptions, without providing any empirical evidence to back up these claims.
The letter reminds Dr Chan of her statementat the Regional Committee of Europe on 15 September 2015 in which she said : “The new distribution of power raises an absolutely critical question for health in the sustainable development era. Who really governs the policies that shape our health? Is it democratically elected officials acting in the public interest? Is it multinational corporations acting in their own interest? Or is it both? That is, governments making policies that are heavily influenced by corporate lobbies.” 
1   Implication of Implementing the Framework of Engagement with Non State Actors - Non Paper  prepared by the WHO Secretariatfor consideration by the informal meeting of Member States on 19-23 October.

For more information contact;
For IBFAN: Patti Rundall 07786 523493   or Lida Lhotska:
For TWN Gopa Kumar:

The letter with late endorsers NGOtoChan_22.10.15PLUSextras..
further information can be found here:
Rapid Response on the BMJ Time to debate WHO’s understanding of conflicts of interest
TWN article:  WHO:  Secretariat “scare mongering” on FENSA

Civil Society Letter of Concern on FENSA “non-paper”

 To Dr. Margaret Chan,
Director General World Health Organization (WHO)

 Dear Dr. Chan

 We, the undersigned, are from public-interest civil society networks and organizations who stand for a strong, independent World Health Organization (WHO) that does its work with integrity and deserves the trust of global citizens.

 We write to express our concern about the “non-paper” titled “Implications of Implementing Framework of Engagement with Non-state Actors” that was issued by the Secretariat on 14 October 2015. WHO Members States initiated the development of the Framework of Engagement with Non-State Actors (FENSA) to safeguard the independence, integrity and credibility of the WHO when engaging with ‘non-state actors’ (NSAs).

FENSA was to provide a robust framework for engagement with NSAs to ensure the protection of the Organization from undue influence especially in its norms and standard setting functions. The non-paper prepared by the Secretariat, portrays the implementation of FENSA as having “detrimental consequences on the work of WHO”, provides no constructive contribution to the new Member State-led process. We question the motives behind such a paper as it comes in the middle of negotiations. It is purported prepared on the basis of a decision of the World Health Assembly (WHA). Yet, we do not find any such decision reflected in the WHA resolutions or the list of decisions. We are very concerned that the paper by the Secretariat can undermine further strengthening of a FENSA and prevent it becoming a truly robust framework, as the paper lists the potential ‘unintended consequences’ often in an exaggerated manner, as assumptions, without providing any empirical evidence to back up these claims. A robust framework is essential to protect the integrity, independence and credibility of WHO as it carries out its essential norm-setting tasks. We refer here to your address at the Regional Committee of Europe on 15 September 2015, in which you stated: “The new distribution of power raises an absolutely critical question for health in the sustainable development era. Who really governs the policies that shape our health? Is it democratically elected officials acting in the public interest? Is it multinational corporations acting in their own interest? Or is it both? That is, governments making policies that are heavily influenced by corporate lobbies.”[1] While fully agreeing with your concern, we would like to point out that it is high time to take measures in the Organization to insulate WHO from corporate capture and other undue influences. It will be a step in the right direction if the final framework contains effective provisions for identifying risks of undue corporate influence, including conflicts of interest, and measures to avoid and when not possible, manage, such risks in a transparent and effective manner. Moreover, currently, WHO does not have transparent and effective policies and tools to prevent such undue influences and risks. As you are aware, the Organization lacks a comprehensive conflicts of interest policy within which the existing tools could be implemented, and new ones identified and developed, including capacity building for WHO staff. Therefore, it is very disconcerting that the FENSA provisions on conflicts of interest contain conceptual errors, despite repeated attempts by public interest advocates to highlight these in the governing body debates and in NGO statements. It is urgent to fix those errors. We call upon you to ensure that your Secretariat supports a constructive finalization of a FENSA that includes robust provisions to prevent undue influence from the private corporate sector, including corporate philanthropy foundations, and that the secondary interest of WHO to secure funding does not collide with the WHO constitutional mandate, a conflict of interest that global public health cannot afford. We thus kindly ask you to ensure that the Secretariat act in good faith and protect the independence, integrity and credibility of WHO. We stand ready to support your efforts in that direction.   [1]
 Endorsers   (this list is being updated regularly)
  1. ACT+  Alliance for Tobacco Control and Health Promotion (Brazil)
  2. Action on Sugar and World Action on Salt and Health
  3. Alcohol Policy Youth Network
  4. All India Drug Action Network
  5. All Nepal Peasants Federation
  6. Alliance Against Conflict of Interest (AACI)
  7. Anti Drug Abuse Association of Lesotho (ADAAL)
  8. Arugaan Philippines
  9. Asia Pacific Farmers Forum, South Asia
  10. Asociacion Centro Feminista de Informacion y Accion – CEFEMINA
  11. Associação Mama Mater/IBFAN Portugal
  12. Association of Breastfeeding Mothers
  13. Baby Milk Action
  14. Bangladesh Breastfeeding Foundation
  15. Berne Declaration
  16. Blue Cross Norway
  17. Blue Cross Thaba Bosiu Centre (TBC)
  18. Breastfeeding Network (UK)
  19. Breastfeeding Promotion Network of India (BPNI)
  20. Centre for Science in the Public Interest (Canada)
  21. CESTA Friends of the Earth El Salvador
  22. Corporate Accountability International
  23. Diverse Women for Diversity (India)
  24. El Poder del Consumidor (Mexico)
  25. FIAN International
  26. FIAN Nepal and National Network on Right to Food Nepal
  27. First steps Nutrition Trust  (UK)
  28. Foundation for Research in Science, Technology & Ecology
  29. Global Policy Forum
  30. GNRTFN secretariat
  31. Haburas Foundation/ Friends of the Earth Timor-Leste
  32. Health Equalities Group
  33. Health Innovation in Practice (HIP), Geneva
  34. ICCO COOPERATION, India Office
  35. Initiative for Health & Equity in Society (India)
  36. Institute for Socioeconomic Studies - INESC (Brazil)
  37. International Baby Food Action Network (IBFAN)
  38. International Code Documentation Centre (ICDC)
  39. Knowledge Ecology International
  40. La Leche League Great Britain (UK)
  41. Lactation Consultants of Great Britain
  42. Medico International
  43. Medicus Mundi International – Network Health for All
  44. Mother and Infant Research Unit, University of Dundee (UK)
  45. NCT (UK)
  46. Osservatorio Italiano sulla Salute Globale (OISG)
  47. People’s Health Movement (Global)
  48. REDES-FoE (Uruguay)
  49. Responsible Approaches to Infant Feeding (RAIF). New Zealand
  50. RIPESS Intercontinental
  51. Royal College of Paediatrics and Child Health (UK)
  52. SAAPA Lesotho
  53. Society for International Development –SID (Italy)
  54. South Asia Food Sovereignty Network
  55. South Asia Peasants Coalition
  56. The European Alcohol Policy Alliance
  57. The Housing and Land Rights Network
  58. Third World Network (TWN)
  59. UK Faculty of Public Health
  60. UK Health Forum
  61. WEMOS Foundation
  62. World Breastfeeding Tends Initiative
  63. World Obesity Federation
  64. World Public Health Nutrition Association
  65. Young Professionals Chronic Disease Network (YP-CDN)
  66. Youth Network No Excuse Slovenia


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