New WHO guidance can support transparent and informed engagement with the private sector

It has become increasingly common to refer to the corporate playbook when describing industry strategy and tactics to influence health policy.1 The playbook was revealed in tobacco industry documents that courts ordered to be placed in the public domain and included strategies to protect profits in response to growing evidence of the health harms of tobacco products. The tobacco playbook has been widely emulated by other health harming industries, including big food, alcohol, automobile, fossil fuels, gambling, and others. The playbook provided strategies for covertly influencing and undermining the role of the World Health Organization (WHO) in preventing and controlling non-communicable diseases and interfering with national level policies on non-communicable diseases.2

Despite the damage caused by industry influence, many public health professionals accept that engagement between private and public sectors may at times be necessary in the prevention and control of non-communicable diseases. It is important, however, that such interaction is based on health principles and is assessed for its public health benefits and risks. WHO was requested by its member states to provide guidance for doing so, which is due to be presented at an event in the margins of the World Health Assembly this week.

Preventing and controlling non-communicable diseases is a multisectoral challenge requiring a whole society response.3 To ensure policy coherence across sectors, comprehensive guidance on effective risk mitigation and monitoring of private sector engagement is required. WHO established a framework for its own engagement with industry in the form of the Framework of Engagement with Non-State Actors guidelines in 2016, which were seen as necessary but a missed opportunity for WHO to use its mandate to tackle the wider problem of governing industry activities and mitigating associated effects on health.4 Likewise, many countries have put measures in place to protect against industry influence and conflicts of interest in health policy making, again in many cases found to be lacking.5

Academics have proposed frameworks to inform country level approaches to engaging with food related industries,678 but authoritative guidance from WHO—the world’s leading health authority—is likely to have greater influence in helping to achieve public health goals. WHO drafted but did not finalise guidance to safeguard against possible conflicts of interest in nutrition programmes in 2017.9 The WHO regional office for the Americas elaborated on this guidance and published a roadmap for Preventing and Managing Conflicts of Interest in Country Level Nutrition Programs in 2021.10 In the same year, the World Health Assembly called on WHO to develop guidance to support its members to engage with the private sector in ways that promote more effective responses for non-communicable diseases.11 The guidance is proposed as a catalyst to promote informed decisions for public-private engagement to prevent and control non-communicable diseases.

We commend WHO for their principles based guidance that provides a step-by-step approach for government authorities to establish processes to assess, analyse, and make strategic decisions about whether to engage with the private sector. It also helps authorities to have a clear plan to mitigate risk and monitor adverse effects if they choose to proceed. But much work remains for WHO, particularly because many states have limited capacity to manage the implementation of procedures for engagement towards prevention and control of non-communicable diseases.

To support implementation, we encourage WHO to provide technical assistance to national and local governments. This should be focused on ensuring that credible and effective governance processes are in place and that public health is safeguarded from social, economic, and environmental harms arising from business practices, products, or services. We urge WHO to enhance knowledge exchange to support collective action on prevention and control of non-communicable diseases by developing and disseminating country specific examples of how the guidance can be applied in different contexts.

Governments have the ultimate responsibility of responding to the challenge of non-communicable diseases and should lead national efforts, including policy making. The private sector must respect and comply with the principles guiding private sector engagement detailed in the new WHO guidance. Industries must act in accordance with established terms of engagement with health authorities and not interfere with their integrity, impartiality, and independence when collaborating to develop, monitor, and evaluate goals, norms, policies, and strategies to tackle non-communicable diseases.

Having said that, we are not naive—many corporations will attempt to subvert government led efforts to tackle non-communicable diseases to maximise profits. To mitigate this, we encourage civil society to act on several fronts including supporting governments to develop transparent accountability mechanisms to ensure safe engagement with industry aligned with national NCD goals. This could include motivating and supporting governments to implement the WHO guidance and helping develop capacity for its use. Most importantly, civil society has a critical role in independent monitoring and evaluation and sharing evidence to better understand the effect of the guidance in decision making on private sector engagement for non-communicable diseases.

The food system is a major driver of biodiversity loss, freshwater use and quality, deforestation, and overfishing; it is the second largest contributor to climate change. In addition, the food system drives obesity and non-communicable diseases. Governments must be supported to engage with this behemoth, as well as other health harming industries, in ways that safeguard the health of people and planet.