Open letter

Response from Dr Sania Nishtar
Response from Dr David Nabarro

Open letter to WHO DG candidates: keep policy and priority setting free of commercial influence

Katherine BrownEmail the author Katherine Brown

Patti Rundall  Tim Lobstein  Modi Mwatsana, Bill Jeffery

on behalf of 61 signatories; a full list of signatories is available in the appendix     Published: 27 April 2017

In May, 2017, WHO Member States will meet in Geneva for the 70th World Health Assembly (WHA) and a new WHO Director-General (DG) will be elected. As public-interest non-government organisations (NGOs) involved in global health governance and the prevention and treatment of chronic diseases, we believe that a fundamental consideration for Member States when electing the DG will be how the new leadership will ensure appropriate interactions with alcohol, food, pharmaceutical, and medical technology industries. We invite the three candidates to describe what steps they commit to take to ensure greater transparency, rigor, and public scrutiny of WHO's policy and regulatory and norm-setting activities so that they are adequately protected from undue commercial interests.

In May, 2016, WHA adopted the Framework of Engagement with Non-State Actors (FENSA), a policy due to be fully operational by May, 2018. While FENSA envisages that WHO will “exercise particular caution…when engaging with private sector entities …whose policies or activities are negatively affecting human health..”,1 the rhetoric and direction of WHO's reform process as well as WHO's chronic funding challenges have left us deeply concerned rather than reassured. We fear that instead of protecting WHO's mandate, FENSA risks relegating WHO to a limited role, unable to stand up for human rights and democratic decision making.

We draw attention to the conflict of interest statement signed by more than 175 NGOs and networks representing more than 2000 groups and first launched at the UN High-Level Meeting on Non-communicable Diseases in 2011: “The policy development stage should be free from industry involvement to ensure a ‘health in all policies’ approach, which is not compromised by the obvious conflicts of interests associated with food, alcohol, beverage and other industries, that are primarily answerable to shareholders.”2

Alcohol, food, pharmaceutical, and medical technology industries should comply with policies developed by WHO and its Member States. Their role is not in public health policy formulation, risk assessments, risk management, or priority setting, nor in determining normative quality standards and legally binding regulations to protect and promote public health. These processes must be undertaken in an environment free of commercial influence.

We believe that only a WHO that protects its independence and integrity of decision making will have the ability to fulfil its constitutional mandate, and look forward to your response to our request.

PR holds shares in Nestlé SA, for the purpose of attending the Annual General Meeting. All other authors declare no competing interests.

References

Jump to SectionSupplementary MaterialReferences

1. Sixty-ninth World Health Assembly. (Agenda item 11.3) (accessed April 21, 2017)Framework of engagement with non-state actors. ; May 28, 2016
   
   http://apps.who.int/gb/ebwha/pdf_files/WHA69/A69_R10-en.pdf?ua=1
   • View in Article
2. Conflict of Interest Coalition. (accessed April 21, 2017)Statement of concern. ; 2011
   
   http://info.babymilkaction.org/sites/info.babymilkaction.org/files/COIC150_0.pdf
   
   
   

   View in Article
   Signatories to 'Ensuring integrity, independence and credibility: Open letter to the candidates for WHO DG'
   
   NAME ORGANISATION
   
   Institute of Alcohol Studies, BROWN, Katherine
   World Obesity Federation, LOBSTEIN, Tim
   International Baby Food Action Network (IBFAN), RUNDALL, Patti
   UK Health Forum, MWATSAMA, Modi
   Center for Health Science and Law, JEFFRY, Bill
   The Alliance for Nutritional Health (Alianza por la Salud Alimentaria)  MACARI, Marisa
   World Cancer Research Fund International, ALLEN, Kate
   Global Alcohol Policy Alliance, BAKKE, Oystein
   International Blue Cross, BABB, Anne
   Alliance Against Conflict of Interest (AACI), GUPTA, Arun
   OXFAM, KAMAL-YANNI, Mohga
   International Association for Social Pediatrics and Child Health (ISSOP), SPENCER, Nick
   International Committee of Drug Bulletins (ISDB), BIJL, Dick
   International Lactation Consultant Association, PARKER, Meredith
   IOGT International, SPERKOVA, Kristina
   Medicus Mundi International. Network Health for All, SCWARTZ, Thomas
   Wemos, MEURS, Mariska
   Bread for the World – Protestant Development Service, HASSE, Mareike
   Public Eye (formerly known as Berne Declaration), DURISCH, Patrick
   El Poder del Consumidor, MACARI, Marisa
   Ntakuka East African Alcohol Policy Alliance, MELAU, William
   European Alcohol Policy Alliance (Eurocare), SKAR, Mariann
   European Centre for Monitoring Alcohol Marketing (EUCAM), VAN DALEN, Wim
   European Fetal Alcohol Spectrum Disorders Alliance, BLACK, Diane
   European Mutual help Network for Alcohol related problems (EMNA), PALMESINO, Ennio
   European Network of Teratology Information Services (ENTIS), WEBER-SCHOENDORFER, Corinna
   European Public Health Alliance (EPHA), RENSHAW, Nina
   Alcohol Policy Youth Network, GALKUS, Lukas
   AlcoHelp, MARTIN, Teryy
   Alcohol Action Ireland, COSTELLO, Suzanne
   Alcohol Focus Scotland, DOUGLAS, Alison
   Alcohol Forum Ireland, DOHERTY Kieran
   Alcohol Health Alliance, GILMORE, Ian
   Alcohol Justice, LIVINGSTON, Bruce Lee
   Association of Directors of Public Health, FURBER, Andrew
   British Association for the Study of the Liver, ALEXANDER, Graeme
   British Liver Trust, LANGFORD, Andrew
   British Society of Gastroenterology, MORIARTY, Kieran
   British Medical Association
   BUKO Pharma-Kampagne, SCHAABER, Jorg
   Crime and Security Research Institute, Cardiff University, SHEPARD, Jonathan
   Dutch Institute for Alcohol Policy STAP, VAN DALEN, Wim
   FASD Fachzentrum Berlin, BECKER, Gisela
   Fetal Alcohol Syndrome Foundation of the Netherlands, BLACK, Diane
   Finnish Association on Intellectual and Developmental Disabilities, SOMER, Sari
   Foundation for Alcohol Research & Education (FARE), THORN, Michael
   Forum Savonese del Terzo Settore, PESCE, Davide
   First Steps Nutrition Trust, CRAWLEY, Helen
   Innovation in Practice (HIP), DENTICO, Nicoletta Health
   Institute for Social Marketing, University of Stirling, BAULD, Linda
   IOGT NTO, DRAMSTAD, Kalle
   Lithuanian Tobacco and Alcohol Control Coalition, MIDTTUN, Nijole
   Royal College of Physicians and Surgeons of Glasgow, GALLOWAY, David
   Royal College of Physicians of Ireland, MURRAY, Frank
   SAF Group, IZUEL, Itziar
   School of Public Health, University of the Western Cape, Cape Town, South Africa,
   SCHNEIDER, Helene
   Scottish Health Action on Alcohol Problems (SHAAP)CARLIN, Eric,
   UK & European Birth Mother Network - FASD
   UK Centre for Tobacco and Alcohol Studies (UKCTAS) BAULD, Linda
   UK Faculty of Public Health, CAPEWELL, Simon,
   Violence Prevention Group, Cardiff Partnership, SHEPARD, Jonathan
   Vivre avec le SAF, METELSKI, Catherine,
   Royal College of General Practitioners

   annex

Have you signed this? If not, act now to safeguard the UN from Conflicts of Interest: July 10-11 2014

 Please ask health, human rights or development organisations to endorse the statement calling for effective safeguards against conflicts of interest. Large for-profit corporations and their front groups will be attending the Comprehensive Review and Assessment of the Progress achieved in the Prevention and Control of Non-communicable Diseases.  General Assembly, New York City, 10-11 July 2014 We are calling for clarity and for effective safeguards that will ensure that they are not allowed to influence the policies of the United Nations. If your organisation can endorse this statement send an email with your NAME, TITLE and SCANNED SIGNATURE  to:   Bill Jeffery, Centre for Science in the Public Interest: bjeffery@cspinet.org CSPI link here: http://www.cspinet.org/canada/foodstrategies.html Great if you can send a copy to me: prundall@babymilkaction.org Useful links 

1. The most recent version of the NGO-joint statement:  http://cspinet.org/canada/pdf/conflict-of-interest-safeguards_health-trump-trade.july2014.pdf

2. The most recent draft of the 2014 official political declaration of the United Nation is available here: http://www.who.int/nmh/events/2014/outcome-document.pdf?ua=1

3. Meeting details: http://www.un.org/en/ga/president/68/events/hlm_ncd.shtml

4. The meetings will be webcast July 10-11, 2014 at: http://webtv.un.org/

5. List of High Level Meeting political declarations since 1946:   http://www.un.org/Depts/dhl/resguide/resins.htm

5. The joint statement of NGOs and periodically updated list of  signatories is available at:  http://cspinet.org/canada/pdf/conflict-of-interest-safeguards_health-trump-trade.july2014.pdf Background In September 2011, governments  gathered at the United Nations headquarters in New York City to unanimously agree to a Political Declaration on the Prevention and Control of  Non-communicable Diseases.  This was the second UN declaration to focus on a health issue since World War II (the other focused on HIV-AIDS in 2001).    Out of concern for the lack of attention to conflicts of interest and the way corporations were inappropriately influencing the proceedings, a Conflict of Interest Coalition was formed. It had a very specific objective:  to call on  the United Nations General Assembly to bring in effective safeguards to protect public health policy setting from commercial interests.  Our 2011 Statement was rapidly endorsed by 162 NGOs and networks, representing over 2000 NGOs.    Government leaders will gather again in NYC on July 10-11, 2014 to take stock of progress. Supporters of the Coalition will be attending the meeting and will  raise the same concerns:  COIC/COIN 2014 Statement   CLICK HERE for background papers on the WHO website. The Public Private Partnership approach follows the vision for future global governance outlined in the World Economic Forum’s Global Redesign Initiative (WEF-GRI). As outlined in the NGO letter on ICN2 - according to the WEF’s key global public issues can be removed from UN agencies’ agendas whenever they risk resulting in policies or regulations ‘unfriendly’ to profit maximisation. “Stakeholderisation” blunts necessary political conflicts, brings TNCs in as the indispensable ‘stakeholder’ in any policy-making arena. This risks a loss of democratic principles, diverts attention from the role of corporations in causing malnutrition, in all of its forms, and the urgent need for regulation. The COI  statement was used in Informal interactive hearing with NGOs, civil society organizations, the private sector and academia on the prevention and control of non-communicable diseases on the 16th June.  http://www.babymilkaction.org/archives/926 If you would like to join the Conflict of Interest Network please contact me for the Terms of Reference. 

`TEXT of the Statement

*    The Conflict of Interest Network (COIN) is the formally constituted organisation that builds on  the Conflict of Interest Coalition Statement.

  On the occasion of the Comprehensive Review and Assessment of the Progress achieved in the Prevention and Control of Non-communicable Diseases.  General Assembly 10-11 July 2014 Call for reaffirmation of the 2011 Political Declaration and effective safeguards against conflicts of interest.

The Conflict of Interest Coalition/Network * was founded in June 2011 at this Assembly with a specific objective to help safeguard the United Nation’s integrity and independence and to ensure its ability to protect health and public health policy setting from commercial influence when dealing with policies related to noncommunicable diseases (NCDs).

Our ‘Statement of Concern’, sent to the UN President and the co-facilitators of the UN High Level Meeting on NCDs in September 2011, focuses on the lack of clarity regarding the role of corporations and their business interest associations in public policy-making and the urgent need to identify, manage and avoid conflicts of interest.

The Statement has been endorsed by 162 public health groups and networks representing more than 2,000 groups in most Member States and relates to the marketing of unhealthy foods, alcohol and tobacco products that continue to be a major contributor to the annual toll of 36 million deaths due to NCDs.

As new multi- and bi-lateral trade agreements are emerging, it is critically important that the UN and WHO, as the lead authority on this issue, support and defend Member States’ rights  and duty to protect public health through effective legally-binding controls on marketing.

We are calling on the UN to recognize the need for clarity and action on both individual and institutional conflicts of interest and propose that the following definitions may be useful:

“[Individual] conflicts of interest are defined as circumstances that  create a risk that professional judgements or actions regarding a primary interest will be unduly influenced by a secondary interest.”

“Institutional conflicts of interest arise when an institution’s own financial interest or those of its senior officials pose risks of  undue influence on decisions involving the institution’s primary  interests.” ¹

Reference:

1  Lo, B. and M. Field, Inst of Med. (US) Committee on Conflict of  Interest in Medical Research, Education and Practice, Eds. (2009).

   

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:  Lida.lhotska@gifa.org

For TWN Gopa Kumar:  kumargopakm@gmail.com

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  http://www.bmj.com/content/348/bmj.g3351/rr

TWN article:  WHO:  Secretariat “scare mongering” on FENSA  http://twn.my/title2/health.info/2015/hi151011.htm

http://www.babymilkaction.org/archives/4192

http://www.babymilkaction.org/archives/4127

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

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

 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] http://www.who.int/dg/speeches/2015/europe-regional-committee/en/

 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

General Assembly 2014

    General Assembly: Informal interactive hearing with NGOs, civil society organizations, the private sector and academia on the prevention and control of non-communicable diseases (NCDs)

Round Table 2: “Mobilizing whole of society efforts for NCD prevention and control at national and regional levels: gaps, solutions, innovations and collaborative multi-sectoral partnerships, and fostering private sector and non-health sector    ...Read More

Thanks to  Bill Jeffrey of Centre for Science in the Public Interest  for delivering part of our statement on behalf of the Conflict of Interest Coalition/Network at the General Assembly.  COIC 161.June 2014 v2

The  afternoon session on partnerships can be seen on this link

http://webtv.un.org/live-now/watch/general-assembly-informal-interactive-hearing-with-non-governmental-organizations-civil-society-organizations-the-private-sector-and-academia-on-the-prevention-and-control-of-non-communicable-diseases/1667942224001/

 

  COIC 161.June 2014 v2

Explanatory Note

The Statement of Concern below was developed by the Conflicts of Interest Coalition (COIC) and was submitted to the President of the UN General Assembly in September 2011.  It has now been endorsed by 162 national, regional and global networks and organisations working in different fields of public health, including medicine, nutrition, cancer, diabetes, heart, liver and lung disease, mental health, infant feeding, food safety and development.   

The principles and recommendations of this Statement can be applied to all areas of public health policy setting, but in particular to work on NCDs. 

The statement  focuses on the lack of clarity regarding the role of the private sector in public policy-making and calls for the development of a Code of Conduct and Ethical Framework to help protect the integrity of  the UN's  public policy decision-making, to ensure it is transparent and to identify, safeguard against and manage potential conflicts of interest.

The Statement calls for:

a clear distinction to be made between business-interest not-for-profit organisations (BINGOs) and public interest non-governmental organisations (PINGOs) 

a clear  differentiation between policy and norms and standards development  and appropriate involvement in implementation. 

Since the major causes of preventable death are driven by diseases related to tobacco, poor diet, physical inactivity and alcohol drinking, the endorsers of the Statement are concerned about the overuse of the term  ‘partnerships’  - without any clarification of what this term means.  We remain concerned that  public-private partnerships in these areas can counteract efforts to protect and improve public health.

The Conflict of Interest Coalition is calling on WHO to develop  guidance for Member States to identify conflicts and eliminate those that are not permissible. We ask that WHO perform thorough risk/benefit analyses on partnerships and provide surveillance on those considered acceptable. 

Transparency, although an essential requirement and first step, is not a sufficient safeguard in and of itself against negative impacts of conflicts of interest.

* The Conflicts of Interest Coalition comprises civil society organisations united by the common objective of safeguarding public health policy-making against commercial conflicts of interest through the development of a Code of Conduct and Ethical Framework for interactions with the private sector.

Conflict of Interest statement has 161 endorsers - and counting

For a pdf with the updated list of endorsers - click here.
Remember, whenever you want to download the latest version of the Conflicts of Interest Coalition statement of concern on conflicts of interest, all you have to do is click on the COI Coalition logo at the top right of every page - or the link underneath it.COIC Statement of Concernhttp://info.babymilkaction.org/sites/info.babymilkaction.org/files/COIC%20161.16.4.12_0.pdf

The Rio Political Declaration on Social Determinants of Health

The World Health Organisation (WHO) World Conference on Social Determinants of Health issued the Rio Declaration on 21 October 2011. Click here for a press release from Baby Milk Action.

The draft official Rio Declaration included text calling for collaboration with stakeholders, including the private sector. The Conflicts of Interests Coalition statement of concern was distributed to delegates and the final text makes reference to conflicts of interest in three places:

"Foster collaboration with the private sector, safeguarding against conflict of interests, to contribute to achieving health through policies and actions on social determinants of health;"

"Promote inclusive and transparent governance approaches, which engage early with affected sectors at all levels of governments, as well as support social participation and involve civil society and the private sector, safeguarding against conflict of interests;"

"Promote appropriate monitoring systems that take into consideration the role of all relevant stakeholders including civil society, nongovernmental organizations as well as the private sector, with appropriate safeguard against conflict of interests, in the monitoring and evaluation process;"

Lida Lhotska, the European Coordinator of the International Baby Food Action Network (IBFAN), commented:

"The call to safeguard against conflict of interests is much welcome. However, it should not apply only to Member States but also to WHO as an agency which will be supporting Member States in their efforts to implement the Declaration. WHO in fact does have a unique opportunity to develop a comprehensive institutional policy that would guarantee adequate safeguard against both individual and organisational conflicts of interests as part of the announced WHO's reform."