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obesity reviews doi: 10.1111/obr.

12289

Public Health

A proposed approach to systematically identify and


monitor the corporate political activity of the food
industry with respect to public health using publicly
available information

M. Mialon1, B. Swinburn1,2 and G. Sacks1

1
World Health Organization Collaborating Summary
Centre for Obesity Prevention, Deakin Unhealthy diets represent one of the major risk factors for non-communicable
University, Burwood, Victoria, Australia; diseases. There is currently a risk that the political influence of the food industry
2
School of Population Health, University of results in public health policies that do not adequately balance public and com-
Auckland, Auckland, New Zealand mercial interests. This paper aims to develop a framework for categorizing the
corporate political activity of the food industry with respect to public health and
Received 6 January 2015; revised 11 April proposes an approach to systematically identify and monitor it. The proposed
2015; accepted 12 April 2015 framework includes six strategies used by the food industry to influence public
health policies and outcomes: information and messaging; financial incentive;
Address for correspondence: Mrs M Mialon, constituency building; legal; policy substitution; opposition fragmentation and
World Health Organization Collaborating destabilization. The corporate political activity of the food industry could be
Centre for Obesity Prevention, Deakin identified and monitored through publicly available data sourced from the indus-
University, 221 Burwood Highway, Burwood, try itself, governments, the media and other sources. Steps for country-level
VIC 3125, Australia. monitoring include identification of key food industry actors and related sources
E-mail: mmialon@deakin.edu.au of information, followed by systematic data collection and analysis of relevant
documents, using the proposed framework as a basis for classification of results.
The proposed monitoring approach should be pilot tested in different countries as
part of efforts to increase the transparency and accountability of the food industry.
This approach has the potential to help redress any imbalance of interests and
thereby contribute to the prevention and control of non-communicable diseases.

Keywords: Corporate political activity, food industry, non-communicable dis-


eases, policy.

obesity reviews (2015) 16, 519–530

ways favourable to the firm’ (7)) (2,3). As has been recently


Introduction
emphasized by the Director-General of the World Health
Unhealthy diets, including high levels of consumption of Organization (WHO), Margaret Chan, the CPA of the food
food products high in saturated fat, sugar and salt, are industry represents a substantial challenge to NCD preven-
major risk factors for non-communicable diseases (NCDs) tion efforts (8). The dominance, in terms of market share,
globally (1–6). Correspondingly, the food industry has been of prominent food companies in many countries, coupled
identified as a vector of disease, through their supply of with their collective efforts as part of trade associations,
unhealthy food products, their marketing strategies and has meant that a small number of companies have a large
their corporate political activity (CPA; a term used here to degree of economic power, which readily translates to
refer to ‘corporate attempts to shape government policy in political power (4,9–11). Accordingly, there is a heightened

© 2015 World Obesity 519


16, 519–530, July 2015
520 Food industry political activity M. Mialon et al. obesity reviews

risk that food industry profits will be privileged above other is increasingly penetrating with ultra-processed food prod-
considerations, resulting in food governance and public ucts (32–34). However, there is a growing interest in CPA
health policy that does not adequately balance public and in those countries, as illustrated by the recent analysis of
commercial interests (2). the CPA of Coca Cola in China and India over the last
In their pursuit of ongoing earnings growth, many influ- decades (35). The Access to Nutrition Index (ATNI) is
ential food industry actors may have an inherent conflict of perhaps the most comprehensive monitoring initiative
interest with NCD prevention efforts,1 particularly where regarding the food industry and public health (14). Never-
company profitability is dependent on the high volume theless, ATNI takes CPA into account to a limited extent by
sales of ultra-processed foods that are major contributors measuring self-disclosed formal lobbying as one indicator
to the NCD epidemic (2). This has led public health experts in its methodology, which represents only one of the many
to propose that that companies producing unhealthy prod- practices identified in the literature on the CPA of the food
ucts should not be involved in the development phase of industry (36).
public health policies (13). CPA with respect to public health has been extensively
Many groups in the public health community have iden- described in other sectors, such as the tobacco, alcohol and
tified the need to increase mechanisms for accountability of pharmaceutical industries (2,3,37–41). In particular, the
the food industry and have called for greater transparency negative influence of the tobacco industry on public health
from food companies (14–17). Despite this, there is cur- policies and outcomes has been substantially documented,
rently limited monitoring of the CPA of the food industry primarily because litigation against the tobacco industry
with respect to public health. At the global level, there are allowed the release of thousands of internal documents
a number of standards that have been developed to guide which shed light on the practices adopted by the industry
socially responsible activities of companies, e.g. the United (42,43). The CPA of the tobacco industry could help
Nations (UN) Global Compact, the UN Guiding Principles contextualize the CPA of the food industry. However, while
on Business and Human Rights and the ISO 26 000 stand- the tobacco control community has access to internal docu-
ard (18–20). However, while anti-corruption measures and ments from the tobacco industry, research on the CPA of
political donations are often included in these standards, the food industry is currently largely limited to publicly
they do not explicitly include all aspects of CPA, and, available information and key informants (42–45).
unlike with the tobacco industry, they do not explicitly INFORMAS (International Network for Food and
recognize the potential conflict of interest between the food Obesity/NCD Research, Monitoring and Action Support)
industry and public health (13). The standards are also proposes to monitor various aspects of food environments,
voluntary with low compliance and have proved ineffective including the policies and actions of the food industry, with
in casting light on the CPA of the food industry (21). When a focus on the most prominent food industry actors in a
independent bodies have monitored food companies for given country in terms of market share (46). The systematic
their policies and actions regarding the NCD epidemic, identification and monitoring of the CPA of the food indus-
results have consistently shown that, despite voluntary try is part of this project (14). As part of INFORMAS, this
engagement, little progress has been observed in terms of paper aims to (i) propose a framework for classifying the
public health outcomes (22–25). A number of independent CPA of the food industry with respect to public health and
organizations regularly identify elements of the CPA of the (ii) propose an approach to systematically identify and
food industry (26–31). Previous approaches to identify and monitor the CPA of the food industry at the country-level.
monitor the CPA of the food industry have not been sys-
tematic and many examples have been anecdotal. Most
Methods
practices have been described in the United States, with
little data related to other countries, particularly low- and A narrative review of the academic literature was con-
middle-income countries (LMICs), which the food industry ducted to identify previous efforts to describe, identify and
monitor the CPA of the food, tobacco, alcohol and other
1
The term conflict of interest is defined here as: ‘A conflict of interest can industries with respect to public health. The initial search
occur when a Partner’s ability to exercise judgment in one role is impaired strategy involved a review of the public health and business
by his or her obligations in another role or by the existence of competing literature, including books, scholarly articles and other rel-
interests. Such situations create a risk of a tendency towards bias in evant sources, with the key words ‘influence’ or ‘tactic’ and
favour of one interest over another or that the individual would not fulfil his ‘industry’ or ‘corporation’ and ‘health’. This was sup-
or her duties impartially [. . .]. A conflict of interest may exist even if no plemented by snowball searching to identify additional
unethical or improper act results from it. It can create an appearance of documents in the grey literature. Relevant frameworks for
impropriety that can undermine confidence in the individual, his/her con- classifying CPA were identified and these were adapted to
stituency or organisation. Both actual and perceived conflicts of interest the CPA of the food industry based on the findings of the
can undermine the reputation and work of the Partnership’ (12). literature review. In parallel, methods for identifying and

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obesity reviews Food industry political activity M. Mialon et al. 521

monitoring the CPA of the tobacco industry, as developed cation. The exception is that some authors include food
by the WHO and different tobacco control groups, were industry practices that are directly related to the processing
identified. These were adapted for the purposes of identi- of products, services and marketing in their classifications;
fying and monitoring the CPA of the food industry. whereas, in the broader literature, these are generally con-
sidered to be separate from the definition of CPA (65). The
strategies described for the tobacco industry appear to
Proposed framework for classifying the
encompass all of the practices identified for the food
corporate political activity of the food industry
industry.
with respect to public health
Based on the various publications on the CPA of the food
CPA of corporations, in a general sense, has been well industry and on the taxonomy proposed by Savell et al.,
documented in the business literature (47). From a public Table 1 presents a proposed framework of the CPA of the
health perspective, perhaps the most comprehensive tax- food industry. Only minor adjustments to the terms used to
onomy of CPA is described by Savell et al. with respect to describe the CPA of the tobacco industry have been made.
the tobacco industry (48). Six long-term strategies have For example, the term ‘opposition fragmentation and
been described: information strategy; financial incentive destabilization’ is preferred to ‘constituency fragmentation
strategy; constituency building strategy; policy substitu- and destabilization’ as it better distinguishes between
tion strategy; legal strategy; constituency fragmentation/ efforts to build constituency and efforts to disrupt those
destabilization strategy. In order to meet these long-term opposing industry activities.
strategies, the tobacco industry uses different practices in In proposing the classification of the various strategies
the short term (47). The information strategy includes and practices, it is recognized that certain practices are
practices through which the industry disseminates infor- likely to relate to multiple different strategies. For example,
mation that is beneficial to its activities in order to influ- if the food industry issues a media release to highlight their
ence public health policies and outcomes in a way that new policy to reduce the salt content of its products, it
would favour corporations (48). Through the financial could be classified as (i) an information and messaging
incentives strategy, the industry provides funds, gifts and strategy: ‘frame the debate on diet- and public health-
other incentives to politicians, political parties and other related issues: emphasize the food industry’s actions to
decision makers (44). The aim of the constituency build- address diet- and public health-related issues’ or as (ii) a
ing strategy is to gain the favour of public opinion as well policy substitution strategy. In these cases, the practice can
as other stakeholders such as the media and the public be classified as serving both strategies. It is also noted that
health community (42). When threatened by regulation, the proposed framework is not definitive, but should be
the industry proposes alternatives such as voluntary ini- modified as new findings on the CPA of the food industry
tiatives or self-regulation (41,49,50). The industry also emerge.
sues its opponents and challenges public policies in courts
as part of a legal strategy (40,51). Finally, the constitu-
Proposed approach to implement the
ency fragmentation and destabilization strategy refers to
framework for identifying and monitoring the
the practices employed by the industry to prevent and
corporate political activity of the food industry
counteract criticism of a company’s products or practices
with respect to public health
(48).
Because some tobacco companies shared ownership of a In response to the increased political influence of the
number of alcohol and food firms, documents released after tobacco industry and because of the major risks to health
litigation against the tobacco industry (the ‘Tobacco associated with tobacco consumption, the WHO has
Master Settlement Agreement’) have been analysed to recently published a technical guideline for the surveillance
understand the practices of alcohol and food companies of the CPA of the tobacco industry (66). This is the fruit of
(42,52). These studies have consistently found that alcohol decades of investigation into the tobacco industry docu-
and food corporations used practices similar to the ones of ments and of research on the CPA of the tobacco industry.
the tobacco industry to influence public health policies and There are a number of tobacco control groups that have
outcomes (40,53,54). Where studies have specifically inves- contributed to, implemented or refined the recommenda-
tigated the CPA of the food industry, most focus on isolated tions of the WHO for monitoring tobacco industry tactics
practices and most were published in the last decade (55– (66–69). Their approaches have been adapted, based on the
59). There are only a small number of publications where literature and on the proposed framework, to identify and
multiple practices are described (60–64). While these monitor the CPA of the food industry.
authors do not explicitly use the terminology adopted by Figure 1 summarizes the approach proposed to system-
Savell et al., there is substantial overlap between their atically identify and monitor the CPA of the food industry
description of industry practices and Savell et al.’s classifi- in a particular country. This proposed approach consists of

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522 Food industry political activity M. Mialon et al. obesity reviews

Table 1 Framework for categorizing the corporate political activity of the food industry with respect to public health

Strategies Practices Mechanisms

Information and Lobby policy makers (60,75–78) Lobby directly and indirectly (through third parties) to influence legislation and
messaging regulation so that it is favourable to the industry
Stress the economic importance Stress the number of jobs supported and the money generated for the
of the industry (79) economy
Promote deregulation (80–82) Highlight the potential burden associated with regulation (losses of jobs,
administrative burden)
Demonize the ‘nanny state’
Threaten to withdraw investments if new public health policies are introduced
Frame the debate on diet- and Shift the blame away from the food industry, e.g. focus on individual
public health-related issues responsibility, role of parents, physical inactivity
(58,63,83–85) Promote the good intentions and stress the good traits of the food industry
Emphasize the food industry’s actions to address public health-related issues
Shape the evidence base on diet- Fund research, including through academics, ghost writers, own research
and public health-related institutions and front groups
issues (61,75,78,82,86,87) Pay scientists as advisers, consultants or spokespersons
Cherry pick data that favours the industry
Disseminate and use non-peer reviewed or unpublished evidence
Participate in and host scientific events
Provide industry-sponsored education materials
Suppress or influence the dissemination of research
Emphasize disagreement among scientists and focus on doubt in science
Criticize evidence and emphasize its complexity and uncertainty

Financial incentive Fund and provide financial Provide donations, gifts, entertainment or other financial inducements
incentives to political parties
and policymakers (78,80,81)

Constituency building Establish relationships with key Promote public-private interactions, including philanthropic, transactional and
opinion leaders and health transformational relationships
organizations (81,88–92) Support professional organizations through funding and/or advertising in their
publications
Establish informal relationships with key opinion leaders
Seek involvement in the Undertake corporate philanthropy
community (33,56,93,94) Support physical activity initiatives
Support events (such as for youth or the arts) and community-level initiatives
Establish relationships with Seek involvement in working groups, technical groups and advisory groups
policymakers (60,77,78) Provide technical support and advice to policymakers
Use the ‘revolving door’, i.e. ex-food industry staff work in government
organizations and vice versa
Establish relationships with the Establish close relationships with media organizations, journalists and bloggers
media (78) to facilitate media advocacy

Legal Use legal action (or the threat Litigate or threaten to litigate against governments, organizations or individuals
thereof) against public policies
or opponents (60,81,82,95)
Influence the development of Influence the development of trade and investment agreements such that
trade and investment clauses favourable to the industry are included (e.g. limited trade
agreements (81,96) restrictions, mechanisms for corporations to sue governments)

Policy substitution Develop and promote alternatives Develop and promote voluntary codes, self-regulation and non-regulatory
to policies (55,97–100) initiatives

Opposition Criticize public health advocates Criticize public health advocates personally and publicly, e.g. through the
fragmentation and (61,63,78) media, blogs
destabilization Create multiple voices against Establish fake grassroots organizations (‘astroturfing’)
public health measures Procure the support of community and business groups to oppose public
(63,78,101) health measures
Infiltrate, monitor and distract Monitor the operations and advocacy strategies of public health advocates,
public health advocates, groups and organizations
groups and organizations (40) Support the placement of industry-friendly personnel within health
organizations

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obesity reviews Food industry political activity M. Mialon et al. 523

Phase 1: Phase 2: Phase 4:


Phase 3: Phase 5:
Identification of Data analysis using
Selection of food Ongoing data Reporting of results
sources of the framework in an
industry actors collection for policy action
information iterative process

Figure 1 Proposed approach to systematically monitor the corporate political activity of the food industry.

systematic document analysis, at the country level, using of information were identified and could be targeted for
the framework presented in Table 1. A database can be retrieving information related to the CPA of the food indus-
used to record details about the industry practices identified try. Searches would target publicly available information
(a sample database structure is provided in Table S1). only. These sources are presented in Table 2. They include
industry materials, government materials, such as annual
returns of political parties and submissions to public con-
Phase 1: selection of food industry actors
sultations, as well as materials from universities, profes-
The sampling of food industry actors is purposive and sional organizations and conferences on diet- and public
based on methods recommended by INFORMAS for select- health-related issues. Sources of information may also
ing organizations of interest in a given country (14). include direct requests to government departments, univer-
Euromonitor is a tool that can be used for this identifica- sities and professional organizations, potentially using
tion (70). An alternative to the use of Euromonitor could be Freedom of Information (FOI) requests or equivalent leg-
the selection of the most prominent food industry actors in islation as a basis for the requests. Table 2 also presents a
a given country based on market surveys (including house- number of indirect sources of information, for which no
hold expenditure surveys and reports prepared by govern- systematic approach to collect data has been developed to
ment trade, industry or agriculture departments) (71). In date.
each country, five to ten food industry actors could initially As per the principles of INFORMAS, a stepped approach
be selected among to data collection and analysis is suggested in order to take
into account different levels of resources and data availabil-
• The largest processed food manufacturers (including
ity in different countries. As a ‘minimal’ step, in any given
food importers, if applicable) (in terms of market shares);
country, the industry-owned materials, including social
• The largest non-alcoholic beverage manufacturers (in
media accounts, as well as the media, could be identified
terms of market shares);
and monitored. Government materials and other materials
• The largest fast food companies (in terms of market
could represent an ‘expanded’ set of data. Data collection
shares);
could start at the national level and then move on to
• The largest food retailers (in terms of market shares);
subnational (e.g. state and/or local) levels.
• The major national trade associations related to food.
The suggested frequency with which to monitor is
Search engines such as Google could be used to retrieve annually for most sources of information and monthly for
country-specific websites of each food industry actor. The news or weekly for social media.
main subsidiaries as well as the main brands for food and
beverage products of processed food and beverage compa-
nies should also be identified (e.g. Milo for Nestlé or Phases 3 and 4: data collection and analysis
Gatorade for PepsiCo). Investigators should also keep track
It is proposed that these phases involve a thematic qualita-
of buy-outs and spin-offs of companies over time, including
tive analysis that could be conducted simultaneously to
transfer of brands between companies.
data collection in an iterative process. For each source of
information described in Table 2, data collection and
Phase 2: identification of sources of information analysis consists of

Based on the recommendations made to identify and • Reading each document to identify practices that may
monitor the CPA of the tobacco industry and on the litera- influence public health policies and outcomes according to
ture on the CPA of the food industry, a number of sources the framework of the CPA of the food industry presented in

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524 Food industry political activity M. Mialon et al. obesity reviews

Table 2 Sources of information to systematically monitor the corporate political activity of the food industry

Category Source of information Organizations Suggested


or level frequency with
analysed which to monitor

Industry own Country-specific website of the industry actor for information on diet-related issues: Sample of Annually (For new
materials • Composition of diet-related committees food projects: 2 years
• Webpages, reports industry retrospective
• Voluntary initiatives, commitments and policies actors, monitoring for
• Awards to researchers national submissions to
• Research units or groups working on diet-related issues public
• Submissions to public consultations consultations)
• Education materials
Country-specific corporate social responsibility (CSR) webpages/report or
website/webpages/information in annual reports of a company’s CSR activities (or the
company’s country-specific activities on its international website)
Country-specific website of the industry actor: Monthly
• News and media releases
Industry actor social media accounts (Twitter, and others where relevant) Weekly

Government Websites of Ministries (and related agencies) responsible for diet- and public National Annually (For new
materials health-related issues: projects: 2 years
• Working groups on diet-related issues and conflicts of interest of members retrospective
• Public-private initiatives on diet-related issues monitoring only
• Submissions to public consultations from the food industry and its allies (including third for FOI requests
parties such as front groups) on diet- and public health-related issues and submissions
• Freedom of Information (FOI) disclosure log: information on diet-related issues to public
• Minister’s diary disclosures: information on diet-related issues consultations)
• Declarations of interests
• Requests, either directly or through FOI legislation for:
○ A list of meetings of food industry representatives from the selected sample of

industry actors, with officials and/or representatives of the government;


○ Minutes and other reports of these meetings;

○ All correspondence (including emails) between food industry representatives from the

selected sample of industry actors and officials and/or representatives from the government
Websites of Parliament and Senate: National
• Submissions to public consultations from the food industry and its allies (including third
parties such as front groups) on diet- and public health-related issues
• FOI disclosure logs
• Declarations of interests of all members
• Requests, either directly or through FOI legislation for:
○ A list of meetings of food industry representatives from the selected sample of

industry actors, with officials and/or representatives of the government;


○ Minutes and other reports of these meetings;

○ All correspondence (including emails) between food industry representatives from the

selected sample of industry actors, with officials and/or representatives from the
government
Register of lobbyists National
Websites of major political parties and websites of commissions in charge of elections: National, all
• Donations for elections from the food industry parties
• Political parties annual return: donations from the food industry
Website of government: National Monthly
• News and media releases

Materials from Websites of a selection of major universities with a school/department of nutrition/dietetics National Annually (For new
universities or physical activity: projects: 2 years
and • Research projects, fellowships or grants funded by the selected food industry actors retrospective
professional • Prizes or awards offered to students by selected food industry actors monitoring for
bodies • If information is not available online, it can be directly requested from the universities FOI requests
through an FOI request or a letter to the Vice Chancellor, Deputy Vice Chancellor for only)
research, and research office, including a request for details of relationships or
interactions with the food industry, as well as any relevant policies on relationships and
funding rules with respect to the industry.

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obesity reviews Food industry political activity M. Mialon et al. 525

Table 2 Continued

Category Source of information Organizations Suggested


or level frequency with
analysed which to monitor

Websites of a selection of major conferences on diet-, public health- or physical National Annually
activity-related issues:
• Sponsors from the food industry
• A list of booths, as well as other marketing opportunities paid for by the food industry
• Education materials and tote bags provided by the food industry
• A list of speakers (including in oral, poster and symposium presentations) who work or
receive funds from the food industry and the topic of their presentations
• Awards and prizes from the food industry
Websites of a selection of major professional bodies related to diet-, public health- or National
physical activity-related issues:
• Funds received from or sponsors from the food industry
• Marketing opportunities paid for by the food industry
• Awards and prizes granted to professionals or students from the food industry
• Professional education resources (including publications or oral presentations)
supported by the food industry
If information is not available online, it can be directly requested from the organizations,
including details of relationships or interactions with the food industry that they think
might be helpful, as well as any relevant policies on relationships and funding rules with
respect to the industry.
News related to the selected food industry actors and diet-related issues in newspapers, National Monthly
on Google News and through subscriptions to news updates on websites such as Food
Navigator or Australian Food News

Other sources Google Scholar Alert with key words such as: ‘influence or tactic and industry or National and Indirect data
corporation and health and [name of the country]’ international collection,
Websites of United Nations agencies responsible for diet- related issues and their regional information not
offices for information on diet-related issues: monitored per se,
• Food and Agriculture Organization: http://www.fao.org/ but recorded if
• World Food Programme: http://www.wfp.org/ relevant to the
• Codex Alimentarius: http://www.codexalimentarius.org/ framework
• World Health Organization: www.who.int/
• United Nations Standing Committee on Nutrition: http://www.unscn.org/
• UNICEF: http://www.unicef.org/
• World Trade Organization: http://www.wto.org/
• United Nations Industrial Development Organization: http://www.unido.org/
International websites of food industry actors
Websites of international food trade associations
Websites of front groups, think tanks working on diet-related issues:
• All webpages with topics related to diet-related health issues
• Twitter pages
• Submissions to public consultations
Websites of conferences on CSR and food industry-related topics
Websites of business journals and other business news platforms
LinkedIn, Viadeo and other professionals social media (for information about the ‘revolving
door’)
Websites of public relations agencies working on behalf of the food industry:
• Submissions to public consultations
• Clients from the food industry
Websites of not-for-profit organizations
Websites of research units, researchers and other scientific organizations conducting
research on public health-, diet- or physical activity-related issues
Educational material supplied to schools and parents by the food industry
Websites of other organizations working on diet- and public health-related issues

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526 Food industry political activity M. Mialon et al. obesity reviews

Table 1 (47,48). The proposed framework should be modi- on previous literature in the area and approaches to
fied according to the findings. monitor the CPA of other industries, in particular the
• Recording the practices in a database and saving evi- tobacco industry. While previous monitoring efforts with
dence (e.g. screenshots, scanned copies of material); respect to the policies and practices of the food industry
• Where practical, taking notes of negative cases (e.g. have predominantly focused on the products and market-
documents where no practices related to CPA have been ing activities of the food industry, the proposed approach
found, e.g. no industry-interests represented on govern- aims to capture aspects of CPA that have not previously
ment working groups on diet-related issues). been taken into account in a systematic way. The proposed
monitoring approach could be used to highlight various
For some sources of information (e.g. CSR reports or
aspects of the CPA of the food industry, with the aim of
submissions to public consultations), the analysis can be
increasing transparency regarding the potential influence
conducted after data collection. In parallel, a database of
of commercial interests on public health policies and
front groups, as well as a database of individuals with a
outcomes.
conflict of interest with the food industry could be created.
The intention is for the proposed monitoring approach
to be implemented at the country-level by civil society
Phase 5: reporting organizations, including researchers working on CPA and
non-government organizations related to public health
For this phase, it is proposed that a narrative synthesis is and/or consumer interests. While it is recognized that the
prepared, with illustrative examples of the CPA of the food proposed approach may be most suited to high-income
industry, in a given country. For example, for each food countries and in countries with democratic political
industry actor, strategies that are most commonly used systems in particular, aspects of the protocol, such as the
could be identified and described. In addition, case studies monitoring of industry-owned materials and of the media,
for specific food industry actors could be prepared. This have the potential to be applied more universally. Relevant
approach has been used for similar reporting of the CPA of sources of information may be limited in LMICs, given the
other industries (49,50,72,73). limited availability of company websites at the national
Potential quantitative indicators could include the level, the lack of FOI (or equivalent) legislation in many
number of researchers with conflicts of interest in national countries and less pressure (e.g. from public health advo-
working groups on diet- or public health-related issues, the cacy and consumer groups) for companies operating in
amount received from the food industry by political parties LMICs to disclose relevant information. For these reasons,
or the number of food-industry sponsors of national sport- the proposed stepped approach could be pilot tested in
ing organizations. This list of indicators could be refined different countries in order to evaluate its applicability in
depending on sources of information and data available in different contexts. Where monitoring is carried out across
specific countries. As data for different countries emerge, multiple countries and over time, it will facilitate compari-
scorecards illustrating the range of practices used by differ- son of the strategies and practices used by individual com-
ent companies could be developed. panies in different countries, as well as a comparison of
Given the large amount of data that could potentially be in-country and cross-country trends. The proposed moni-
collected using the proposed approach, the development toring could also be carried out at the global (e.g. UN and
of a publicly accessible website could be considered to its agencies) or regional level (e.g. European Union) to
provide broad access to the data collected. The http:// understand the CPA of the food industry more broadly.
tobaccotactics.org website, developed by researchers at the The proposed framework is based on various aspects of
University of Bath (United Kingdom), which monitor the CPA previously identified in the business and public health
CPA of the tobacco industry, is a model that could be literature. While the proposed categorization of strategies
investigated for potential adaption for use with respect to and practices seeks to be comprehensive, the integrated
the food industry (69). Social media is also likely to be an nature of CPA means that the categories are not mutually
avenue for highlighting details of practices used by compa- exclusive. Accordingly, some subjectivity will be needed in
nies, with a view to exposing these practices to a broad order to classify practices that are identified through moni-
audience and highlighting the potential risks to public toring activities. Any new practice should be included in the
health from these practices. proposed framework. Importantly, the framework is based
on the classification of CPA in other industries, most
notably the tobacco industry. This will help facilitate com-
Discussion
parison of practices used by different industries and it is
This paper has proposed a framework for classifying the hoped that the use of common terminology will help bring
CPA of the food industry with respect to public health and together different groups that are examining corporate
an approach to systematically identify and monitor it based influences on public health.

16, 519–530, July 2015 © 2015 World Obesity


obesity reviews Food industry political activity M. Mialon et al. 527

While the proposed monitoring approach is designed to CPA over time, the transparency and accountability of
be relatively inexpensive to conduct, in order to minimize companies in the food industry can be increased. In addi-
resources needed for monitoring, it is recommended that tion, implementation of the proposed monitoring approach
the focus is only on a prioritized selection of companies in could help identify mechanisms to better balance public
each country. The advantage of this approach is that moni- and commercial interests related to public health policy.
toring is focused on the companies that are likely to have
the most influence in each country. However, this approach
does not capture the practices of smaller companies in Conflict of interest statement
a systematic way. To overcome this limit, a case-study
This work was supported by the Australian National
approach could be considered.
Health and Medical Research Council (NHMRC) under
A limitation of the proposed monitoring approach is that
grant number APP1041020. The NHMRC had no role in
it will only identify publicly available information, which
the design, analysis or writing of this article.
can be incomplete, not representative of all practices, and
often lacks detail. CPA is also reflected through personal
connections, informal discussions and other activities (e.g. Acknowledgements
free lunches) that are not going to be captured with the
proposed approach. To partially overcome this limitation, The authors would like to their colleague Professor Anna
the proposed approach could be supplemented with inter- Gilmore, who provided insight and expertise that greatly
views with key stakeholders, such as politicians, civil serv- assisted the development of the proposed framework and
ants or public health advocates, as well as whistleblowers approach.
from the food industry. The use of stakeholder interviews
could be particularly relevant in LMICs where other data
sources may be more limited. Methods to gather additional Supporting information
information using crowd-sourcing and social media should Additional Supporting Information may be found in the
also be explored. Timing of data collection is also crucial online version of this article, http://dx.doi.org/10.1111/
because the nature of CPA is likely to change over time and obr.12021
the nature and intensity of CPA is likely to vary according
to the political climate. For example, the food industry Table S1. Proposed structure of database to record infor-
might be more likely to use the policy substitution strategy mation about the corporate political activity of the food
or the legal strategy in a period when regulation is actively industry.
being considered by the government in a given country.
Whereas, when governments that are philosophically less
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