The International Diabetes Federation (IDF) response to the WHO first draft of the Framework for

country action across sectors for health and health equity, March 2015

The International Diabetes Federation (IDF) is an umbrella organization of over 230 national diabetes
associations in 170 countries and territories, representing the interests of the growing number of people
with diabetes and those at risk. IDF mission is to promote diabetes care, prevention and a cure worldwide,
so our vision of living in a world without diabetes can be achieved.

The International Diabetes Federation (IDF) welcomes the opportunity to comment on this draft Framework
from the diabetes perspective. As a founding federation of the NCD Alliance, IDF also fully supports and
reinforces all comments made in the NCD Alliance submission.

2.3. Implementation of actions

The draft Framework states that implementing actions across sectors “requires conscientious effort and
judicious use of evidence”, as well as tools “to put theory into practice”. Cross-sectorial actions have already
proven to be effective in addressing tobacco consumption – one of the main four risk factors for Non-
communicable Diseases (NCDs). Given the increasing NCD burden experienced by all societies (in both high-
and low- and middle-income countries) extrapolating successful tobacco control measures to address other
risk factors – namely unhealthy diets, physical inactivity and alcohol abuse – should be a public health
priority.

IDF estimates that at least 70% of cases of type 2 diabetes can be prevented by adopting a healthy diet and a
more active lifestyle. This would equate to 150 million fewer new cases by 2035. Achieving the WHO global
target of halting the escalating epidemic of diabetes is therefore within reach, but it will require urgent and
significant cooperation between government departments. IDF recommends a strategy parallel to that of
tobacco control should be developed and implemented, including the following:

 Ministries of Health and Education: development of health interventions and promotion to raise
awareness across the whole population
 Ministries of Agriculture and Finance: incentivise the production of affordable and healthy food
 Ministries of Industry and Consumer Affairs: regulation of the sugar, salt and fat content of
processed foods and marketing restrictions of products with high levels of those constituents
 Ministries of Public Works and Transportation: encouragement of physical activity, including the
provision of safe walking and cycling routes’

Effective monitoring tools need to be developed and implemented, to allow tracking of progress and
identifying where actions need to be reinforced.

3.1. Sector roles and responsibilities

3.2. Managing conflict of interest

As the draft Framework mentions, in many countries the health authorities and other public sector actors
can lead effective health actions across sectors. However, some Member States might not have the capacity
to coordinate actions across the different players involved and could benefit from WHO and other UN
organisations’ support as well as that of NSAs. WHO leadership will also be essential to ensure
implementation of the NCDs Global Action Plan and Global Coordination Mechanism, so they can deliver
the best possible outcomes at the global and national levels.

International organisations can play an important role in ensuring coherent policy actions on health and
health determinants. In the case of IDF, we can monitor the performance of Member States through 230
national diabetes associations in 170 countries and territories. Likewise, given their expertise on diabetes-
related health determinants and inequalities at a national level, our national member associations stand
ready to support their Member States in implementation appropriate actions. As highlighted by IDF’s
Global Diabetes Scorecard1, many national diabetes associations already collaborate with their governments
and even contribute to policy-making.

IDF agrees that both Member States and national and international organisations need to take precautions
in order to avoid potential conflicts of interest when interacting with non-state actors (NSA). However, a
clearer distinction needs to be made between the private sector – which, by definition, has an economic
interest which, in some cases, can be in conflict with public health interests – and non-government
organisations (NGOs) – which, as the draft Framework mentions “play a critical role in promoting health
action across sectors due to their significant influence on the state”.

1
Global Diabetes Scorecard: Tracking progress for action. International Diabetes Federation. 2014.
http://www.idf.org/global-diabetes-scorecard/