WHO's Draft over-arching Framework of engagement with non-State actors

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I will be joining IBFAN's team at the World Health Assembly next week. In addition to topics such as Maternal, infant and Young Child nutrition - there will be discussion about WHO's Reform and the  Draft over-arching Framework of engagement with non-State actors. See links below and for a letter published in  BMJ online.   CLICK HERE for WHA Agenda

CLICK HERE   for WHO's Draft overarching framework of engagement with non-State actors 

CLICK HERE and HERE  for link to some of our comments on the previous version

CLICK HERE  for a letter in Today's BMJ by Judith Richter  (12.5.14)

CLICK HERE and HERE  for some IBFAN comments on the previous Framework

CLICK HERE for articles about WHO and Non State Actors in Update 46


Time to turn the tide: WHO’s engagement with non-State actors & the politics of stakeholder-governance and conflicts of interest

12 May 2014

I am deeply concerned that WHO’s so-called reform will side-line those who work in the spirit of ‘Health for All’ and expand the influence of business corporations and venture philanthropies over global public health matters as well as reinforce the trend towards fragmented, plutocratic, global governance.

Nearly three years ago, the journalist Nigel Hawkes pointed out in the BMJ, that several international non-governmental organisations (NGOs) had highlighted the problematic link between the WHO Director-General Dr. Chan’s suggestion to re-fill WHO’s coffers with funds from business and big philanthropic bodies through an “innovative financing mechanism” and the sudden introduction of an ambitious agenda for WHO reform. Dr. Chan proposed to include these funders in the making and shaping of health policies through a new World Health Forum. This proposal was published only days before the 2011 World Health Assembly giving insufficient time for proper analysis. Member States and NGOs were stunned to discover that the Director-General had already committed WHO to holding a first World Health Forum in 2012.

WHO’s Member States regained initiative. By the end of 2011 they had rejected the World Health Forum and attempted to reframe the reform agenda. They requested that “dialogue and cooperation with other stakeholders should be strengthened as appropriate while taking into account the importance of… managing conflicts of interest” and to explore “options for a framework to guide interaction between all stakeholders active in health.” (EBSS/2/DIV/2, para 2 (g) & (i), my emphasis)

In October 2013, after a change of terminology, WHO presented a Discussion paper on WHO engagement with non-State actors and draft outline of WHO’s plan to ensure Due diligence, management of risks & transparency at an informal consultation with Member States, NGOs and commercial actors. WHO leadership quashed considered criticisms by NGOs using statements such as: “we all have vested interests” and “don’t demonize transnational corporations”. NGOs and sceptical Member States were asked to “join the narrative of the 21st century.”

Member States and public interest NGOs found both papers wanting and requested changes. The successor of the October papers, the Background document, was discussed in March this year in a second consultation, open to Member States only. From what we know, it remained controversial. Member States have yet again criticised WHO for not providing all the documents needed for informed and timely discussion. They have noted the absence of a clear conflict of interest policy and requested that the forthcoming World Health Assembly (May 2014) gives guidance on the way to finalise the policy on engagement with non-State actors.

Ten days before the 2014 World Health Assembly, the WHO Secretariat finally issued the latest version of the policy Framework on engagement of non-State actors (A67/6). Unfortunately, the previous shortcomings were not addressed. Therefore, the fundamental question remains: will the WHO leadership and some influential Member States (specifically the US and UK) muster the political will to prevent this reform from opening the floodgates to corporate influence on global and national decision-making processes in public health matters?

I cling to a spark of hope, given the request of some Member States for further discussion of this crucial policy Framework at the Assembly. This discussion can provide an opportunity to turn the tide if it allows for the reopening of the fundamental debate about the premises underlying WHO’s reform. We need responses to the following questions:


1. Why must WHO – and all of us – enter into closer relations with corporations as indispensable ‘stakeholders’ in decision making processes?

2. Why must we ignore the blurring of the nature and roles of actors through terms such as ‘stakeholders’ and ‘non-State actors’?

3. Why do Member States find it acceptable that an international public agency can be funded by market-led donors?

4. What action can Member States take to increase their core contributions to WHO?

5. When will WHO at long last work on the establishment of a genuine institutional conflict of interest policy with accurate definitions and effective procedures?


If there is no opening up of the debate, WHO’s reform risks to continue following a path charted out by the World Economic Forum’s Global Redesign Initiative (WEF-GRI). The WEF advocates a system of ‘stakeholder’ governance with corporations being the key ‘stakeholders’ in all kind of decision-making fora. According to this design, key global public issues can be removed from UN agencies’ agendas whenever they risk resulting in policies or regulations ‘unfriendly’ to profit maximisation. Broad horizontal policy issues can be turned into vertical multi-stakeholder initiatives implemented through market-led approaches (such as the UN’s post-2015 MDGs).


Without a reopening of the debate, it will prove impossible to resist those whose goal is to turn our highest public health authority into a mere convenor and coordinator of multi-stakeholder- and public-private initiatives (which, by design, have business representatives on their decision-making boards). The resulting loss of democratic principles could simultaneously destroy the accountability of WHO to the people and the people’s trust in the World Health Organization.


If Member States want WHO to come out of the reform a strong agency, capable of fulfilling its constitutional mandate and functions, they should insist during the upcoming World Health Assembly debate on a policy framework which:

1. Is based on a correct understanding of conflicts of interest theory;

2. Clearly recognizes the fundamentally different nature of market-based actors, whose primary institutional interest - the fiduciary duty to their shareholders - is to maximise profits.


As the former Professor of Harvard Business School, David Korten said:

“Behind its carefully crafted public relations image and the many fine and ethical people it may employ, the body of a corporation is its corporate charter, a legal document, and money is its blood. It is at its core an alien entity with one goal: to reproduce money to replicate and nourish itself… It owes only one true allegiance: to the financial markets, which are more totally creatures of money than even the corporation itself.”



Gleckman, H. (2013). "Multi-stakeholder Governance Seeks to Dislodge Multilateralism." Policy Innovations - A publication of Carnegie Council (15 November)


Gopakumar, K. M. (2014). "WHO: No consensus on draft policy on non-State actors." SUNS (7777).


Korten, D. C. (1995). When corporations rule the world. West Hartford, Kumarian Press & San Francisco, Berret-Koehler Publisher, p. 67

Lo, B. and M. Field, editors. Institute of Medicine (US) Committee on Conflict of Interest in Medical Research, Education and Practice, Eds. (2009). Conflict of interest in medical research, education and practice. Washington DC, National Academics Press, in particular, pp. 6, 14, 218


Pingeot, L. (2013). Corporate influence in the Post-2015 process. Working Paper. Aachen, Berlin, Bonn & New York, Brot für die Welt, Global Policy Forum, Misereor, January


Richter, J. (2012). "WHO reform and public interest safeguards: An historical perspective. Editorial." Social Medicine 6(3): 141-150.


WHO (2014). "Framework of engagement with non-State actors: Report by the Secretariat " Sixty-seventh World Health Assembly, Provisional agenda item 11.3 Doc. A67/6, World Health Organization, Geneva, May



For further documents, see WHO’s reform website (in particular “governance” & “documents”)


Competing interests: None declared

Judith Richter, Freelance Researcher & Associate Senior Research Fellow Institute of Biomedical Ethics Centre for Ethics of the University of Zurich, Pestalozzistrasse 24 CH-8032 Zürich