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THE INTERNATIONAL FOOD & BEVERAGE ALLIANCE SUBMISSION ON THE WORLD HEALTH ORGANIZATION’S DISCUSSION PAPER FOR THE GLOBAL COORDINATION

MECHANISM ON THE PREVENTION AND CONTROL OF NONCOMMUNICABLE DISEASES AND THE WORKING GROUP ON HOW TO REALIZE GOVERNMENTS’ COMMITMENTS TO ENGAGE

WITH THE PRIVATE SECTOR FOR THE PREVENTION AND CONTROL OF NCDS

The International Food & Beverage Alliance wishes to thank the World Health Organization (WHO) for

the opportunity to provide comments to the Working Group of the WHO Global Coordination

Mechanism on the Prevention and Control of NCDs (GCM/NCD), tasked with recommending ways and

means of encouraging Member States and the private sector to realize the commitment to strengthen

its contribution to NCD prevention and control included in paragraph 44 of the Political Declaration of

the High-level Meeting of the General Assembly on the Prevention and Control of Non-communicable

Diseases adopted by Member States in September 2011 (the Political Declaration). 1

GENERAL COMMENTS We recognize the magnitude of the NCDs burden to societies and share a commitment to tackling this

global problem. We believe the private sector has both an incentive and a responsibility to be part of

the global effort on NCD prevention. We understand the unique contribution our industry can make to

this effort and have committed our time, resources and expertise to do our part.

Collaborating with the private sector delivers a number of benefits. Industry can add valuable

perspectives; help achieve scale; open the possibility of innovative finance mechanisms where public

institutions are able to leverage private capital; provide leadership to encourage others to participate;

and bring together different skill sets that can, hopefully, deliver a better and more effective outcome.

We are pleased that the WHO, the UN and Member States have recognized that the solutions to the

problem of NCDs requires a whole of society approach with the engagement of all sectors, including

government, civil society and the private sector.

We too, believe – and experience has shown - that collaboration between governments, the private

sector and civil society is essential and multisectoral actions represent one of the most cost-effective

ways to address public health challenges. Today, public-private partnerships represent a permanent

place in the global public health landscape. This paper includes a few examples of successful

collaborations that have demonstrated measureable progress.

1 IFBA is a group of eleven companies – The Coca-Cola Company, Ferrero, General Mills, Grupo Bimbo, Kellogg’s, Mars, McDonald’s, Mondelēz International, Nestlé, PepsiCo and Unilever – who share a common goal of helping people around the world achieve balanced diets and healthy, active lifestyles.

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In 2008, our CEOs took the initiative to establish a set of public commitments – on product

reformulation and innovation, nutrition information, responsible advertising, promotion of balanced

diets and healthy lifestyles and public-private partnerships - in support of the implementation of the

2004 WHO Global Strategy on Diet, Physical Activity and Health. These global commitments reflect the

actions that the WHO and the UN have called upon the private sector to deliver, in the WHO 2004

Global Strategy on Diet, Physical Activity and Health, the WHO 2010 Recommendations on the

Marketing of Foods and Non-alcoholic Beverages to Children, the WHO Global Action Plan on the

Prevention and Control of Noncommunicable Diseases 2013-2020 and in paragraph 44 of the Political

Declaration.

As part of our ongoing global commitment to continuous improvement, in 2014, we adopted a set of

enhanced commitments that will guide our health and wellness strategies over the coming years. 2

IFBA members have committed to:

Innovate and reformulate to create products that offer healthier options;

Improve consumer information on nutrition. Over the next two years we will roll-out a consistent

nutrition labelling approach globally, providing information on key nutrients of public health interest

on-pack, in line with CODEX, as well as including calories on front-of-pack;

Market responsibly to children everywhere our products are sold around the world. Over the next

two years we will: 1) expand our existing commitments to cover significantly more media; 2) work

to ensure that companies do not use marketing techniques in ways that are primarily directed to

children under 12 for products that do not meet better-for-you nutrition criteria; and 3) in an effort

to enhance and expand regional and national pledges, harmonize nutrition criteria as they have

done for the EU and U.S.A. pledges; and

Promote healthier lifestyles and increased physical activity in communities around the world and in

workplace wellness programmes designed to promote, maintain and enhance the health and

wellbeing of the 3.5 million people we employ.

A commitment to transparency and accountability underpins our actions. Each year, IFBA reports

publically on its and its members’ progress, including commissioning a third party, Accenture Media

Management, to monitor and report on members’ compliance with IFBA’s global policy on marketing to

children. Our annual progress reports are available on IFBA’s website.

We believe our actions and the steps we have taken to date confirm our on-going commitment to do

our part as an industry to help address the global concern of NCDs. We are proud of the role we have

played in encouraging others to adopt our agenda. In 2011, the Consumer Goods Forum, a

collaboration of more than 400 retailers, manufacturers and service providers across 70 countries,

2 https://ifballiance.org/documents/2014/09/dr-chan-letter-final-15-9-14.pdf

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adopted resolutions on nutrition and health based on the IFBA commitments. We look forward to being

part of the work of the GCM/NCD in a substantive manner in 2015 and beyond.

We are strongly committed to ensuring our businesses and activities create and preserve the long-term

sustainability and health of the environment and communities we serve. We understand that even

greater efforts will have to be made if the goals of the Political Declaration and Global Action Plan on

NCDs are to be met. And we stand ready to do more, in collaboration and partnership with all

stakeholders that are prepared to work with us.

We would welcome the opportunity to provide sustained input to the GCM Private Sector Working

Group on an ongoing basis as it develops its recommendations. We would encourage the Working

Group to consider, as appropriate and within the boundaries of its mandate, to invite suitable private

sector representatives to exchange views with Working Group members.

SPECIFIC COMMENTS

Following we provide our responses to the five questions posed in the WHO discussion paper, taking

into account also the specific issues raised in four of the policy briefs accompanying the WHO discussion

paper:

Producing and promoting more food products consistent with a healthy diet;

Reducing the use of salt in the food industry to lower sodium consumption;

Taking measures to implement the WHO Set of Recommendations to reduce the exposure to the

marketing of unhealthy foods and non-alcoholic beverages to children; and

Promoting and creating an enabling environment for healthy behaviours among workers.

QUESTION 1: Are there other specific examples of engagement with the private sector on the

five areas included in the Political Declaration that have led to measurable progress?

Examples of reformulation initiatives and collaborations to reduce the burden of obesity and NCDs

IFBA members have worked in collaboration with governments and NGOs around the world in

multistakeholder initiatives to reduce salt, saturated fats and calories and to remove trans fats, and are

involved in various of the voluntary national reformulation initiatives noted in the WHO discussion

paper and policy brief, including in Argentina, Brazil, Canada, Mexico and the U.S.A. We also participate

in the UK’s Public Responsibility Deal. We are also part of PAHO’s multistakeholder initiative, the

“SaltSmart Consortium”, whose goal is to reduce salt intake to no less than 5 grams per day by 2020.

Mondelēz International, Nestlé and Unilever serve as the industry representatives on the steering group.

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In the U.S.A., leading food and beverage companies, including IFBA members, have been involved in a

wide-range of initiatives for more than a decade. These initiatives – including efforts to reformulate and

innovate products, provide clear nutrition labelling and consumer information, advertise responsibly,

enhance workplace wellness and partner with stakeholders in healthy eating and active living

programmes – have been documented by the U.S. Grocery Manufacturers Association (GMA). In 2014,

GMA published cumulative results (2002-2013) of these efforts by 69 member companies representing

about USD 245 billion in annual U.S. sales (approximately half of U.S. food and beverage sales). 3

Highlights include:

o 94% of companies reported nutritional improvements in over 30,000 products and sizes,

with reductions in saturated fat, trans-fat, calories, sugar and carbohydrates and sodium;

o 81% of companies reported providing enhanced front-of-pack labelling information; and

o 77% of companies reported sponsorship of national and local initiatives to improve nutrition

education and encourage regular physical activity, spending over USD 300 million in these

expenditures between 2002-2013.

A separate study by GMA in 2014 (yet to be published), showed a 16% reduction in sodium in member

company products purchased between 2008 and 2013, with decreases in those food categories

contributing the most to sodium intakes in the U.S.A.

IFBA members also participate in a number of successful multi-stakeholder initiatives aimed at reducing

the burden of obesity and NCDs and helping consumers to achieve a healthy diet. For example:

EU Platform on Diet, Physical Activity and Health: Led by the Commission, the EU Platform

provides a forum for European-level organizations including the food industry and consumer

protection NGOs, committed to tackling current trends in diet and physical activity. Currently,

there are more than 300 commitments undertaken by the Platform’s stakeholders, including the

food industry, public health advocates, NGOs, advertisers and the medical profession, ranging from

awareness campaigns to consumer actions on the importance of healthy diets and physical activity;

to labelling initiatives, such as the commitment of the EU food industry on front-of-pack GDA

labelling of food; to the addition by advertisers of nutrition criteria in defining foods not to be

advertised to children; to salt reductions strategies. The achievements of the commitments

undertaken in the context of the EU Platform are reviewed annually by the European Commission.4

EPODE and EIN. With more than 20 years of experience and a rigorous scientific evaluation, the

EPODE (Together Let’s Prevent Childhood Obesity) methodology developed in France has been

recognized by the international scientific community as innovative in tackling the problem of

3 Kelley Drye & Warren, LLP, Georgetown Economic Services, GMA 2014 Company Health & Wellness Initiatives Survey, August 2014. 4 http://ec.europa.eu/health/nutrition_physical_activity/platform/

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childhood obesity. EPODE's methodology is based on community based interventions (CBIs) aimed

at changing the environment and behaviors of children, families and local stakeholders with the

ultimate goal of promoting healthy lifestyles in families in a sustainable manner. EPODE comprises

four critical components: political commitment, public and private partnerships, community-based

actions, and evaluation. Peer-reviewed studies indicate that this multistakeholder approach has

already shown encouraging results in preventing childhood obesity in France and Belgium and has

reduced the socioeconomic gap in obesity prevalence in France. 5 6

The methodology has now been implemented in a number of countries worldwide, and provides a

valuable model that may be applicable to other lifestyle-related diseases. The Epode European

Network (EEN) and the EPODE International Network (EIN) have been created to support the

worldwide implementation of CBIs. The major partners in the EEN programme include four

committees, each one headed by one of four major European Universities (Amsterdam, Gent, Lille,

Saragoza), and four private partners, including IFBA members, Mars, Nestlé and Unilever. The Coca-

Cola Company and Nestlé are founding global private partners for EIN. These international

networks allow the sharing of experience and best practices for the continuous improvement of

the programmes. By 2012, CBIs inspired by the EPODE methodology had been implemented in 17

countries. The South Australian and Mexican Health Ministers adopted the methodology to

conceptualize and implement their “National plan on nutrition and Physical activity (Obesity

Prevention and Active Lifestyle (OPAL) programme and 5 Pasos strategy, respectively). Recently a

report from the Canadian Healthy Kids panel recommended implementation of the EPODE

methodology in Ontario.

Exercise is Medicine (EIM): This initiative, which is supported by The Coca-Cola Company, was

introduced in 2007 to encourage primary care physicians and other health care providers to include

exercise when designing treatment plans for patients. EIM strives to make physical activity (PA) a

“vital sign” and believes it is integral to the prevention and treatment of chronic diseases and

should be regularly assessed as part of medical care. EIM is present in 39 countries with regional

centers established in Africa, Australasia, China, Europe, Latin America, North America and

Southeast Asia. The EIM Global Health Initiative is transitioning from its initial phase of

infrastructure and awareness-building to programme implementation with a focus on low-to-

middle income countries where 80% of deaths due to NCDs already occur, but where a large gap in

research and implementation of PA strategies exists. A peer-reviewed study of the programme

concluded that broad implementation of PA counselling and referral systems, such as clinical

practice standard of care, has the potential to improve PA at the population level by

5 J-M Borys, L. Valdeyron et al, “EPODE – A Model for Reducing the Incidences of Obesity and Weight-related

Comorbitidies,” US Endocrinology, Vol. 9, Issue 1, September 2013. 6 T. M. Van Koperen, “Characterizing the EPODE logic model: unravelling the past and informing the future,” obesity review, doi:10.1111/j.1467-789x, 2012, 01067.

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complementing and leveraging other efforts and to contribute to achieving global targets for the

reduction of inactivity and related morbidity and mortality. 7

The U.S. Healthy Weight Commitment: Founded in 2009, the Healthy Weight Commitment

Foundation (HWCF) is a partnership between industry, including IFBA members, NGOs and

educators whose aim is to reduce obesity - especially childhood obesity. Focusing its efforts on

families and schools, HWCF promotes ways to help people achieve a healthy weight through

energy balance – calories in and calories out. HWCF members voluntarily pledged to collectively

remove 1.5 trillion calories from their products (against a 2007 baseline) by the end of 2015. A

study published in 2014 by the American Journal of Preventive Medicine (AJPM) and funded by the

Robert Wood Johnson Foundation (RWJF) found that the companies had, by the end of 2012,

collectively cut 6.4 trillion calories, exceeding their 2015 goal by more than 400%. Companies

achieved this calorie-reduction goal by developing, introducing and selling more lower-calorie

options, changing recipes, where possible, to lower content of current products or reducing portion

sizes of existing single-serve products. Researchers at the Hudson Institute evaluated the impact of

HWCF’s commitment to sell fewer calories by testing whether lower-calorie products sold by HWCF

companies (whose members account for nearly 25% of calories consumed in the U.S.A.) grew over

the 5-year evaluation period and the impact of these sales on total company sales. 8 The study

concluded that these lower-calorie products are driving sales growth and recommended these

choices should continue to be pursued aggressively:

o 82% of sales growth driven by lower-calories - over 4x the rate of higher-calorie products;

o Sales increase of USD 1.25 billion sales for lower-calorie products vs. less than USD 300

million for higher-calorie products; and

o 10 of 15 new products with sales of USD 50 million+ were lower-calorie products. 9

HWCF has also created a families and schools programme. The Together Counts™ campaign,

promotes energy balance, the advantages of family meals and physical activity; and the

TogetherCounts.com website, designed in partnership with Discovery Education, provides free,

downloadable resources for families, teachers and children for Pre-K through elementary school.

Today, more than 19 million children are engaged with the curriculum. This successful U.S.A.

programme is also being implemented in Australia, under the auspices of the Healthier Australia

7 Felip Lobelo, et al. “The Exercise is Medicine Global Helath Initiatives: a 2014 update.” BJSM Online, April 28, 2014. 10.1136/bjsports-2013-093080. 8 Hank Cardello and Jeffrey Wolfson, Hudson Institute Report, May 2013. 9 Risa Lavizzo-Mourey, President and CEO of RWJF in an AJPM Fall 2014 Commentary said, "Through the HWCF and similar initiatives, industry is demonstrating that it can be part of the solution. So we both congratulate these companies and call upon them and other industry leaders to join together with the health community to go even further to help all children achieve a healthy weight."

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Commitment, an industry-led initiative in partnership with NGOs, to help reduce the incidence of

chronic preventable diseases and improve the nutritional quality of the Australian diet.

Health in Action (Northeast Brazil): In January 2010, Mondelēz International partnered with

INMED Partnerships for Children (INMED) to deliver a school-based health and nutrition program to

youth in Northeast Brazil. Health in Action, reaches 675,000 people - including over 160,000

school children (ages 5 – 14) who learn about the importance of good nutrition, physical activity,

basic hygiene and sanitation. To date, the programme has: improved nutritional intake – 100% of

participating schools have either large scale full gardens or smaller container or suspended gardens

that are managed by the children; improved BMI among 65% of children, with one third achieving

normal BMI; decreased anaemia with average anaemia rates reduced from one in five children to

one in ten children; decreased parasitic infections by up to 85%; and increased awareness and

understanding of good nutrition and active lifestyles among children by 21%. In 2014, working with

the Yale School of Public Health, Mondelēz convened leaders and community partners of seven

leading healthy lifestyle programmes supported by the company, including Health in Action, as part

of its Healthy Lifestyles Program Evaluation Workshop, with the goal of agreeing a common set of

metrics for measuring the success of their interventions and further improving evidence-based

programmes. From this consensus-building process, three critical indicators of success emerged

that will now be applied across all of the company’s programmes:

o Nutrition knowledge: percentage of program participants who improve their nutrition

knowledge

o Physical activity: percentage of participants who increase their daily amount of activity or

play; and

o Healthier eating: percentage of participants who report increased consumption of fruits,

vegetables and other fresh foods.

Kinder+Sport (Global): Launched in 2006 in Italy, with a mission to promote and support healthy

lifestyles among children and young generations through the encouragement of everyday sports

and physical activity. The programme is now active in 20 countries, including China, Hong Kong,

Korea, Mexico, Russia and Taiwan, with plans to roll-out to a further ten countries by the end of

2014. By the end of 2013, more than 12 million children and teens (6-18 years of age) had

participated in Kinder+Sport events since its launch. The project is built on a partnership model –

collaborations are established with national and international sports federations and sports centres

(currently numbering 50 partners). Since 2009, the Medical Sports Institute of Turin has been

monitoring school-aged children taking part in the “1,2,3… Minivolley - FIPAV e KINDER+SPORT”

programme to compare the effect on children entering the first year of secondary school who

participated in four years of continuous physical activity at school (three hours of volleyball each

week) to those of the same age that did not. Results of the monitoring showed the children

regularly practicing sports have better cognitive skills and better coordination. The monitoring also

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assessed the effect on the body mass index (BMI) and showed that the children enrolled in the

Kinder+Sport programme have a stable BMI over time compared to those not enrolled. BMI

indexes are in a normal weight range (for boys 18,66 and for girls 18,25) compared to those

children not enrolled in the programme (for boys 21,17 and for girls 21,15. Kinder+Sport has also

introduced a set of key performance indicators which will measure the number of “moved”

children and the effectiveness of the programmes.

Magic Breakfast (U.K.): PepsiCo is working with disadvantaged communities to provide healthy

meals for at-risk families. In the U.K., PepsiCo’s Quaker and Tropicana businesses have partnered

with the U.K. charity, Magic Breakfast, to deliver free breakfasts to children at schools in the

greatest need, with a goal of removing hunger as a barrier to learning in U.K. schools. The charity

currently provides a nutritious breakfast to more than 16,000 children, across more than 350

primary schools where 35% or more of the children are eligible for Free School Meals. 673,429

servings of porridge have been donated by Quaker since 2009. In 2013 alone, 92,430 litres of 100%

fruit juice have been donated by Tropicana. An online poll conducted by Magic Breakfast in July

2014 surveying the views of 164 teachers showed that 81% of teachers believe that children who

attend Magic Breakfast clubs show improved attainment and attendance.

Nestlé Healthy Kids Global Programme: This programme, a partnership among Nestlé, EPODE

International Network, the International Association of Athletics Federation and 280 partners

including national and local governments, NGOs, nutrition health institutes and sport federations, is

aimed at raising nutrition and health knowledge and promoting physical activity among school-age

children around the world. At the end of 2013, the programme had been launched in 68 countries,

reaching 6.9 million children. Healthy Kids programmes are based on a multi-partnership approach

with expert teams to develop the programmes and local implementing partners. Nestlé believes

the success of the programme lies in the quality of the experts who develop the educational

materials and curricula to meet the specific needs of local communities. With the knowledge that

the programmes work best when children take part regularly, Nestlé developed stricter

participation criteria. The company monitors and evaluates the impact of the programme with its

scientific partners regularly and is continuing to develop new ways to measure the effectiveness of

the programme and share best practices.

Project Laserbeam (Bangladesh and Indonesia): Unilever and Mondelēz International are working

alongside UN agencies (WFP0, NGOs (CARE, BRAC, Water Aid, Friendship and GAIN) and other

private companies in this multistakeholder and multisectoral programme that aims to directly

reduce under-nutrition through food and micronutrient intake and indirectly improve nutrition

through improved water, sanitation, hygiene, food security and income generation in Bangladesh

and Indonesia. The nutrition initiatives have had an impact; since 2009 the number of people going

to bed hungry each night has fallen from one in seven to one in nine in 2014. Project Laser Beam

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worked by scaling up successful existing solutions, rather than devising new ones, to help

implement them quickly and efficiently in communities in need. It brought together expertise from

the public and private sectors, showing how partners can work together to have a significant and

lasting impact on changing lives for the better. The project finished in 2014 and reached more than

2.48 million people in Bangladesh.

Project Peanut Butter (Ghana, Malawi, Sierra Leone): General Mills is helping Project Peanut

Butter (PBB), founded in 2004, to provide needed nutritional and medical support primarily to

children suffering from severe acute malnutrition in sub-Saharan Africa and to improve efficiencies

and increase the quality of ready-to-use therapeutic foods (RUTF). The peanut butter paste offers

high-quality nutrition children need to recover, survive and even thrive. The company is also

providing marketing support to help the programme expand its efforts to other countries in Africa.

Tapping into the extensive food industry experience of volunteers from General Mills and other

industry partners, PBB operates multiple clinic sites providing food, treatment and training to

approximately 80,000 children each year. In 2007, the UN, WHO and the World Food Programme

recognized RUTF with home-based therapy as the standard of care for severely malnourished

children worldwide.

Further examples of IFBA members’ collaborations can be found in the IFBA Review of Progress Report,

2008 – 2013 and on the website. 10 11 12

Nutrition Labelling

Helping consumers make informed and healthy choices is a key element of IFBA’s 2008 commitment in

support of WHO’s 2004 Global Strategy on Diet, Physical Activity and Health.

Fact- and science-based labelling systems, which provide meaningful and understandable nutrition

information on individual foods and their place in the overall diet, together with effective consumer

education, allow consumers to make the dietary decisions to meet their individual nutritional needs.

At a global level, IFBA members are committed to providing nutrition information per serving and/or per

100 grams for the key nutrients of public health interest – calories, total fat, saturated fats,

carbohydrates, total sugars and sodium/salt. To provide information on how a product contributes to

an overall diet, members are also in the process of adding the percentage that each nutrient provides of

the recommended daily amount (expressed as Daily Intake (DI), Daily Value (DV) or Guideline Daily

Amount (GDA).

10 https://ifballiance.org/documents/2014/09/ifba-progress-report-2008-2013-final-11-sept-2014.pdf 11 Examples of IFBA members’ initiatives promoting healthy lifestyles: https://ifballiance.org/our-commitments/promotion-of-physical-activity-healthy-lifestyles/ 12 Examples of IFBA members’ multistakeholder collaborations: https://ifballiance.org/our-commitments/collaboration/

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To help consumers quickly and easily compare products while shopping, IFBA members are also

voluntarily adding GDAs on the front-of-pack (FOP) and implementing voluntary FOP labelling systems,

supported by consumer education campaigns, around the world. To date, standardized FOP labels have

been introduced in Mexico (“Checa y Elige”) and the U.S.A. (“Facts Up Front”), and industry has

collaborated with governments to launch FOP labelling systems in Malaysia and the Philippines. In 2012,

members adopted a harmonized GDA labelling system across the EU. Other examples include:

Thailand: Following the nation-wide introduction of new FOP nutrition labels in the form of GDAs,

several leading food and beverage companies in Thailand, including IFBA members, joined forces to

establish a Consumer Education Fund, which is administered by the Federation of Thai Industries

(FTI). The fund was used in 2012 to support a successful public-private partnership with the Thai

Food & Drug Administration, which launched a Consumer GDA Roadshow with the objective of

“supplying consumers with sufficient and accurate information to enable them to choose food

wisely.”

U.S. A.: Facts Up Front has been supported by a USD 17 million consumer education campaign

including a paid media campaign conducted in 2014, in-store marketing, a consumer-facing website

and robust social media.

IFBA members are also collaborating with governments to increase nutrition literacy. For example:

The Nutrition Facts Education Campaign (Canada): In support of the Government of Canada’s on-

going commitment to promote healthy eating by helping Canadians make more informed nutrition

choices, IFBA members partnered with Health Canada in the fall of 2010 on the Nutrition Facts

Education Campaign. This multi-media campaign focuses on increasing understanding of the

nutrition facts table, and in particular the % Daily Value, and explains how Canadians can use this

information to make healthier choices. The campaign includes a multi-faceted approach with

messaging on food packages, in store and in national media (print, television and online) on how to

read labels and eat healthy. It also directs consumers to Health Canada’s educational website, and

online interactive tools, including shopping tips. In the first year of the campaign, messaging was

placed on more than 300 million units of products.

Marketing to Children

In 2008, IFBA companies made responsible marketing to children a critical part of their effort to

promote balanced diets and healthy, active lifestyles, and voluntarily adopted an approach restricting

how and what they advertise to children.

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This approach promotes product innovation, reformulation and choice; and through education and

communication promotes the benefits of healthy diets and physical activity among children, and was

designed within a framework in which voluntary industry initiatives are combined with regional and

national regulatory bodies to create a system which is cost-effective, measurable and responsive to the

unique needs of different nations.

In 2009, IFBA members adopted a worldwide policy not to promote food and beverage products to

children under 12 years of age unless the products meet specific nutrition criteria based on national and

international dietary guidelines.

This policy, which is in line with the 2010 WHO Set of Recommendations on the Marketing of Foods and

Non-alcoholic Beverages to Children sets out the minimum criteria for advertising and marketing

communications that are paid for, or controlled by, IFBA companies in every country where they market

their products. And through regional and national pledge programmes based on the core tenets of the

IFBA Global Policy we have led the way to encourage regional and local food companies that are not

members of IFBA – more than 30 companies - to join in these pledges and improve the types of products

advertised to children, and to promote balanced diets and healthy, active lifestyles. By the end of 2014,

responsible marketing pledges had been implemented in 50 countries worldwide.

We understand the need to demonstrate the tangible impact of this voluntary commitment and

invested significant resources in comprehensive annual third-party compliance monitoring of our policy.

For the past five years, we have engaged Accenture Media Management, a leading global provider of

media auditing services.

The monitoring exercise is performed on a random sample of companies’ advertisements in the three

most-used media – television, print and the internet – and provides a snapshot of a globally

representative sample of markets – including countries where national pledges have been launched and

countries without national pledges. Over the years, Accenture has examined advertisements in

Argentina, Australia, Brazil, Canada, Chile, China, Colombia, India, Indonesia, Malaysia, Mexico, New

Zealand, the Philippines, Russia, Saudi Arabia, Singapore, South Africa, Thailand, Ukraine and U.S.A.

To ensure transparency and credibility, all the media data analyzed by Accenture is obtained from

sources independent of IFBA companies and their associated media agencies. Accenture also chooses

the period to be monitored after the advertising has already been purchased by the companies.

Since 2009, over the course of the past five years, the compliance rate for television advertising has

been above 86% in every market analyzed, and 100% for print and internet advertising. In 2013,

Accenture reported a 96.9% compliance rate for television advertising and 100% for print and internet

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advertising in child-directed media. 13 All instances of non-compliance are reported to the IFBA members

concerned in order for corrective action to be taken.

Similar consistently high levels of compliance have been reported by third party reviews for pledges in

Australia,14 Canada,15 the EU 16 and the U.S.A. 17

To ensure compliance with IFBA’s global policy, members have developed specific internal policies and

implemented training sessions for their marketing departments and media buying agencies.

The steps we have taken are progressive and have proven effective in helping to drive change in the

marketplace, reducing the marketing of products high in fats, sugar and salt to children, and increasing

the promotion of healthy choices.

Year after year independent data has demonstrated a shift towards the promotion of healthy choices:

Australia: In May 2012, the Australian Grocery Council (AFGC) released the results of an

independent study undertaken in 2011 which indicated that the Responsible Children’s Marketing

Initiative (RCMI) was having a positive effect on reducing children’s exposure to high fat, sugar and

salt food and beverage (non-core) advertising. The study found that advertisements for non-core

foods had fallen to 1.6% of all food and beverage advertisements in Australia across eight channels

and 0.7% across all channels, representing a 60% decrease compared with 2010. 18

Canada: A spot check by Advertising Standards Canada of children’s television advertising in 2012

by signatories to the Canadian Children’s Food and Beverage Advertising Initiative (CAI) revealed

that by far the majority of advertising directed to children was for toys, games, DVDs, in-theatre

movies and attractions. Food and beverage commercials accounted for only 20% of the total

number of commercials aired during the survey period, down from 25% in 2011; and 86% of

advertisements were for “better-for-you” products. The balance, 14%, was advertising by non-

signatories that would not meet CAI nutrition criteria. 19

13 Accenture Media Management, 2013 Compliance Monitoring Report for the International Food & Beverage Alliance on Global Advertising on TV, Print and Internet, March 2014 14 Australian Food and Grocery Council, Responsible Children’s Marketing Initiative, 2011 Compliance Report 2011 15 Advertising Standards Canada, The Canadian Children’s Food and Beverage Advertising Initiative, 2012 Compliance Report, September 2013 16 EU Pledge, 2013 Monitoring Report. 17 Council of Better Business Bureau, The Children’s Food & Beverage Advertising Initiative In Action, A Report on Compliance and Progress during 2013, December 2014 18 Australian Food and Grocery Council, Food and Beverage Advertising Activity Report, May 2012, 8 19 Advertising Standards Canada, The Canadian Children’s Food and Beverage Advertising Initiative: 2012 Compliance Report, 6-7

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EU: A review in 2014 by Accenture Media Management sought to measure the change since 2005

(the year the EU Platform was launched) in the balance of food and beverage products advertising

to children in order to assess the impact of the pledge and corporate policies implemented as a

result of the pledge. Accenture reported a substantial decline in children’s exposure to advertising

for products that do not meet pledge members’ nutrition criteria since 2005 – an 88% reduction in

programmes with an audience composed of over 35% of children. These figures confirm the overall

trend towards a significant decrease - an average reduction of 83% in the six years since members

made these commitments (2009 vs. 2014). Accenture also reported that since 2005 children are

exposed to 52% less ads across all programmes for products that do not meet the nutrition criteria;

and they see 42% less ads for all products across all programmes. 20

U.S.A.: In 2014, the Council of Better Business Bureaus in the U.S.A. analyzed television ads aired in

children’s programming, a repeat of analyses conducted in 2009, 2010, 2012 and 2013. Of the 1,274

ads analyzed, 23% were for food and beverages. In 2014, 90% of the ads were for foods containing

fruit, vegetables, non/low-fat dairy, whole grains, or at least a “good” source of what the 2010

Dietary Guidelines for Americans call “nutrients of concern” because they are not consumed in

sufficient amounts (calcium, fibre, potassium and vitamin D), up from 83% in 2013 – confirming an

upward trend based on past analyses. 21

The WHO discussion paper and policy brief state that “statutory regulation is essential,” to reduce the

marketing of unhealthy foods and non-alcoholic beverages to children. However, we do not believe it is

a choice between regulation and self-regulation. We believe self-regulation has its place in the policy

mix. Among other things it is quick and flexible and can therefore swiftly respond to societal concerns.

Our approach to responsible marketing and the improvements we have made over the years

demonstrates our continued commitment to strengthen and adapt self-regulatory measures to changing

needs.

This self-regulatory approach has been welcomed by regulators as effective in helping to drive change in

the marketplace and in improving the nutrition of foods marketed to children. 22 23 24 Moreover, and

20 EU Pledge, 2014 Monitoring Report 21 Council of Better Business Bureau, The Children’s Food & Beverage Advertising Initiative In Action, A Report on Compliance and Progress during 2013, December 2014 22 In June 2013, Tonio Borg, European Commissioner for Health and Consumer Policy endorsed the achievements of the EU Pledge, “One excellent example of a commitment emanating from the Platform is the EU Pledge, whereby 20 leading food and beverage companies have committed themselves not to advertise to target children below the age of 12. The effectiveness of the Pledge is made evident by the latest monitoring report – which you saw yesterday – which showed a downward trend in children’s exposure to food advertising.” 23 European Parliament resolution of 22 May 2013 on the Implementation of the Audio-Visual Media Services (AVMS) Directive (2012/2132(INI)), welcomed advertising self-regulation as a complement to regulation and

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contrary to what is stated in the WHO discussion paper and policy brief, the implementation and

therefore impact of the IFBA responsible marketing policy is global in nature.

Promoting Healthy Behaviours Among Workers

In 2008, IFBA members committed to collaborate with governments, civil society and other stakeholders

to help raise consumer awareness on balanced diets and to help promote greater physical activity and

healthier lifestyles. We have also committed to help implement the strategies called for in the WHO

Global Action Plan on NCDs, aimed at reducing the prevalence of insufficient physical activity.

And our commitment extends to the workplace. The health and well-being of the 3.5 million people

IFBA members employ is an important priority for IFBA members. Workplace initiatives can yield

significant benefits in reducing both the personal and economic burden of NCDs. All IFBA members have

introduced workplace wellness programmes. Although different in approach, all members offer

smoking cessation programmes; many provide information and counselling on nutrition, fitness, mental

health and stress management; free health risk assessments and personalized improvement

programmes; on-site fitness centres, gym memberships or access to recreation areas; and healthy dining

choices. For example:

Unilever (Lamplighter): Unilever employs more than 170,000 people across 190 countries. Lamplighter,

the company's award-winning global employee programme aims to improve the nutrition, fitness and

mental resilience of employees. Introduced in 2001, Lamplighter tracks and measures the health of

employees as well as the return on investment. It has been independently assessed and has proven to

reduce healthcare costs, reduce absenteeism, increase presenteeism, increase productivity, reduce

premiums on health insurance, improve morale and well-being, reduce accidents at work and improve

engagement and performance. The programme has evidenced a reduction in high risk cases by 35% in

some countries and research has shown a final return of EURO 4.30 for every EURO 1 invested. The

programme combines health risk assessment, measuring the risk factors in employees — smoking, blood

pressure, blood cholesterol, blood sugar, body mass index, waist/hip circumference and fitness — for

evidence of NCDs at baseline and then six months later, with behavioural counselling on exercise,

nutrition and mental resilience. As a measure of risk attenuation, the company measures year-on-year

reduction in the proportion of high risk cases for NCDs. To date, Lamplighter has reached more than

recognized the efforts of the food and beverage industry on marketing to children in the context of the EU Pledge and the industry’s commitment to the EU Platform on Diet, Physical Activity and Health. 24 Federal Trade Commission, A Review of Food Marketing to Children and Adolescents: Follow-up Report, December, 2012, 4. The FTC noted the overall improvement in the nutrition of products offered to children and said: “[It] believes that food industry self-regulation is beginning to bring about important changes in the marketing of foods to children under 12. The Commission encourages companies to continue to enhance and expand upon these efforts.”

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55,000 employees in 50 countries across Asia, Africa, Middle East, Turkey, Latin America and Europe,

moving towards a long-term goal of extending the programme it to all countries where the company

operates. Unilever is committed to sharing its programme and collaborating with other organizations

that can make a significant difference to overall positive global health. The programme is replicable and

has been shared with governments, global and national organizations and local departments of health in

various countries around the world.

QUESTION 2: What were the critical success factors for these successful examples?

The common success factors for the examples mentioned above include the following:

o Clearly defined goals and objectives agreed by all participants

o Clearly defined roles and responsibilities

o A sustained alignment of efforts based on an agreed set of actions

o Clearly defined and simple KPIs or metrics to measure progress

o Independent review and evaluation of progress and success/failure

o Sharing of best practices to ensure continuous improvement

o Replication (and/or scaling up) of successful existing programmes (rather than inventing new

ones) to allow for quicker implementation and efficiency

o Flexibility and adaptability

o Transparency and accountability

The main reasons for the success of Unilever’s Workplace Wellness Programme can be attributed to the

following:

o Leading by example: Endorsement and support of senior leadership; the behavior of leadership

has encouraged participation in the Lamplighter Program more than any medical advice from

doctors.

o Measurement and availability of data: Producing data on health and wellbeing was new to most

of the participants in Unilever’s programme, and they found it not merely of interest but actively

motivating to continue maintaining a healthy lifestyle.

o Coaching and specialist interventions: Giving individuals intensive personal coaching over six

months seemed to get them to a level at which the healthy lifestyle was accepted by the

participants. The challenge, as always with health, is sustainable behavior, and a long-term

commitment. To ensure the programme remains relevant and current, Unilever constantly

reviews the programme, adding new dimensions.

o Business alignment: The key to a health and wellbeing programme’s sustainability is ensuring

that it is aligned with the company’s core mission and business objectives.

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QUESTION 3: Are there other challenges or bottlenecks to making further progress with

calling on the private sector to contribute meaningfully to NCD prevention and control that

are not addressed in this section?

We agree with many of the challenges that have been identified, and would add the following:

1.

Since 2004, IFBA members have been steadily reducing or removing key ingredients of public health

concern – salt, sugar, saturated fats and trans fat – and increasing beneficial ingredients – fibre, whole

grains, fruits and vegetables and low-fat dairy. We are fortifying, as appropriate, commonly consumed

products with vitamins and minerals to address micronutrient deficiencies. We are reducing calories by

offering smaller portion sizes and providing portion guidance. Building on the substantial progress made

to date on sodium reduction, IFBA members will continue reducing sodium in their products, wherever

possible, with due regard to WHO’s recommendation for daily salt intake.

The progress we have made is substantial – reformulating and developing tens of thousands of products

offering more options to suit dietary needs – and our work continues. 25

Notwithstanding the progress made to date, our industry faces a number of constraints in improving

global nutrition. Many recommendations to food companies to reformulate product to reduce salt,

saturated fats and sugar, while appearing to be simple, are in fact, much more complex, requiring

deeper insights into the limitations of science, the role of supply chains, farmers, retailers and

consumers and the impact of commodity prices. Switching ingredients or developing alternatives is a

complicated process which necessitates a well-structured, long-term plan, requiring consideration of

issues such as customer affordability, taste and preference, sourcing and manufacturing processes, and

investment in research and consumer insights.

We also face a number of challenges outside of our control that influence our ability to design more

food and beverage choices that contribute to healthier eating and drinking. For example, global

environmental disruptions which affect crop availability and impact the cost of commodities; continued

environmental pressures; increased global consumption and the use of crops such as corn and soybean

for alternative fuels; increased consumption of meat in developing countries which exacerbates

resource scarcity for grain and crop production (meat-based diets require more energy, land and water

resources than vegetarian diets); and the lack of capacity in public sector nutrition science which

presents a serious obstacle to corporate innovation.

25 IFBA 2008-2013 Progress Report

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There is no single or simple approach to product reformulation or new product development. While we

have virtually eliminated industrial trans fats, there are limits to saturated fat reduction, for example in

meat and dairy products. Even salt reduction strategies, which the WHO discussion paper and policy

brief suggest is “the most straightforward reformulation option,” is a complex process. One common

misperception is that sodium can easily be removed from manufactured foods. But reducing sodium

levels is complicated and challenging, both technically and in terms of consumer acceptance. While

significant strides have been made, in many instances there are limits of a functional nature. In

addition:

o Each country/region is unique with distinctive dietary patterns and the source of sodium in

consumers’ diets will vary accordingly. Efforts to reduce sodium levels must be based on

research and scientific evidence to identify all of the sources where consumers are actually

getting their salt – i.e. packaged foods, home cooking, restaurants, or food services. Although

IFBA member companies are present all over the world, in most countries the marketplace is

dominated by many local companies. Recommendations for reduction strategies should be

inclusive and address all of sources of sodium.

o A “one-size fits all” approach is not practical. There is no single baseline – acceptable sodium

intake levels vary country by country.

o Sodium intake data is critical and there is a lack of accurate, consistent and measureable data at

the local level. Governments must establish dietary intake surveys that reflect dietary habits and

intake standards.

o Consumer education and awareness are key components of any salt reduction strategy and all

stakeholders have a role to play. Governments must promote the need for sodium reduction on

a national basis, raise consumer demand for low-sodium diets and encourage local stakeholders

to support sodium reduction initiatives. Health care professionals can raise consumer demand

for low-sodium diets and help progress suitable sodium substitutes. NGOs can raise consumer

demand and encourage all local stakeholders to participate in sodium reduction initiatives. IFBA

members can (and do) provide label data on sodium content and nutrition information to

consumers; and participate with governments and NGOs on public awareness campaigns.

o Monitoring and impact assessments are critical. Governments need to identify and track, based

on local data, national consumption habits; track the overall impact on public health of the

entire sodium reduction initiative; and track the impact of specific elements, including consumer

education/awareness initiatives, voluntary industry efforts and changes over time of population

consumption patterns.

Based on our experience, we believe the most effective means to improving the nutritional profile of

products is to adopt a comprehensive approach to reformulation taking all nutrients, where relevant,

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into account and not simply addressing single nutrients independently. Reductions will be gradual and

incremental.

2.

Many of the indicators set in the WHO frameworks are related to public health outcomes and are too

broad to be used meaningfully as key performance indicators (KPIs) for the private sector. Therefore, it

will be necessary for us to work in partnership in the context of the GCM/NCD to improve the availability

of jointly supported specific KPIs. For example, further technical work is necessary to develop and agree

accepted methodologies for the measurement of salt intake reduction.

3.

Outdated or confusing definitions, for example, “healthy” vs “unhealthy foods” can cloud the

relationship between WHO and industry. Clear definitions, based on sound science, would lead to

better health and risk communication. Similarly, clear definitions of “actual” and “perceived” conflict of

interest and a WHO-endorsed framework with clear rules of engagement and management of such

conflicts of interest is critical. Without such guidance the current confusion will continue, where activist

NGOS often erroneously categorize industry’s consultation as conflict of interest.

4.

Regulatory frameworks are not always supportive of innovation. For instance, the combined use of

sugar and alternative sweeteners and food and beverage products, aimed at reducing overall sugar

content and caloric value, is not allowed in some countries, despite the demonstrated safety of such

formulations, which are well accepted in many markets. More generally, innovation requires a

regulatory framework that incentivizes it, with regard for example to the ingredient reduction

thresholds that need to be attained in order to indicate this reduction on product labels.

5.

Alignment between WHO’s engagement with non-State actors and the Political Declaration is necessary.

The UN Political Declaration calls for a whole of society approach and a multistakeholder approach.

However, in practice the engagement between WHO and industry is generally conducted at an informal

level. Industry’s contribution can be enhanced by ongoing dialogue with WHO, transparency of the

process and formalization of the engagement. Certain Member States have frameworks for

engagement which can be replicated, for example in the U.S.A., the Food & Drug Administration will

consult with all relevant stakeholders on certain policy issues.

6.

We are also challenged by the levels of mistrust aimed at corporate entities generally. Specifically, we

are concerned that this general attitude towards all business fails to recognize the progress we have

achieved in support of the stated priorities of the WHO and could have a detrimental impact on the

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progress of our engagement with Member States. Furthermore, we are concerned, as we move to

strengthen our work in communities where we do business and try to engage local SMEs and other

industry partners in these efforts that others will not join our efforts if they feel that they are not

recognized for their efforts. We have committed to do our part to assist in efforts to address NCDs and

it is critical that the WHO and Member States see industry as a willing and effective partner.

Working together – achieving collaboration and collective impact – requires a systematic approach that

focuses on the relationships between stakeholders, a sustained alignment of efforts based on an agreed

set of actions and measured progress towards stated objectives. Building trust among stakeholders is a

first and critical step. In addition to facilitating engagement among key stakeholders, we believe if we

are going to make a difference in the fight against NCDs, the GCM/NCD must work to create a culture of

engagement conducive to effective cooperation based on inclusiveness, openness, and shared values.

7.

The WHO guideline development process needs to utilize all scientific evidence, including that provided

by industry, to inform their decision-making process. We respect WHO’s normative, standard setting

role and have no desire or intention to interfere in this process. However, we believe that access to

relevant industry science, especially if it is peer-reviewed and third-party validated, will not compromise

the independent view of WHO’s experts, but rather will benefit the process and generate confidence in

the ultimate guidelines and recommendations.

QUESTION 4: What other actions or approaches will assist governments in managing

institutional conflicts of interest when engaging with the private sector on NCD prevention

and control?

We recognize and respect the role, responsibilities and independence of the WHO and the sovereignty

of Member States. We also recognize that policy creation and decision-making is the exclusive

prerogative of Member States.

It is not our role to set or define policy. However, we do maintain important dialogues on both business

and public health-related issues with national and local governments. We provide technical expertise,

for example, on salt reformulation, or on our understanding as to how consumers relate to diet, to help

inform the development of policy and explain how WHO policies and guidelines will be implemented by

industry.

In all of these settings, both as industry and as individual companies, we make clear our interests in a

transparent manner.

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We also recognize and respect the need to safeguard the WHO and public health from undue influence

and reputational risks. We hold the view that all parties – not just the private sector but NGOs and

others - have interests which may sometimes conflict. We believe that conflicts of interest and other

risks can be managed by a comprehensive, robust and transparent disclosure standard based on a

principle of full disclosure of real, perceived or potential conflicts of interest and a clear process to

identify, manage and resolve these appropriately in an unbiased and timely manner. We also believe

that all stakeholders, including governments and the WHO, need to disclose the nature of their

interactions.

We welcome and support the process laid out in the WHO draft framework of engagement with non-

State actors (dated 15 December 2014), which will apply across all levels of the WHO, including the

development of a comprehensive public database. We see this as an important tool for the pursuit of a

whole of society approach and the development of effective multistakeholder actions for the benefit of

global public health. We encourage governments to adopt a similar disclosure standard and process.

QUESTION 5: Are there other themes or issues that the working group should consider in

developing advice for Member States on ways and means of realizing the commitment to call

on the private sector, as outlined in the Political Declaration?

We cannot separate the issues of NCDs from food insecurity, climate change, the profound changes in

agriculture, or the challenges facing the food industry in improving global nutrition. Further progress in

the prevention of nutrition-related chronic disease depends on collaborations across multiple sectors for

the effective development and distribution of packaged foods.

We believe the approach can be further strengthened with recommendations on how to foster joint

work across sectors, and particularly for those beyond health. For example:

o Policies to virtually eliminate trans fat and move to healthier oils, such as high-oleic sunflower,

cannot be undertaken by the food industry without the engagement of the agricultural sector;

o The globalization of trade has a role to play in preventing NCDs, as trade is a key market enabler,

contributing to improved access to food supplies. At a time when the world is facing food and

grain shortages, we need to look at opening trade channels, not closing borders. Open and well-

functioning markets are essential to allow for the transfer of knowledge and more investment in

agriculture; and

o Food safety must be fully integrated into the food and nutrition security agenda. Apart from the

negative impact on health, unsafe food can cause significant social and economic costs.

Improving the safety and quality of food at all stages of the supply chain and strengthening of

national food control systems is critical.

6 February 2015