New comments on WHO’s engagement with non-State actors

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Today is the last day for comments on the Public web consultation on WHO’s engagement with non-State actors. 

The  background papers and submission form for comments can be found on this link: at: 

CLICK HERE for comments from IBFAN (in addition to those sent as a member of DGH below)

CLICK HERE for response from Democratising Global Health Coalition, Health Innovation in Practice (HIP), International Baby Food Action Network (IBFAN), Medicus Mundi International Network (MMI), Medico International, NGO Forum for Health, Third World Network (TWN), WEMOS,  World Social Forum on Health and Social Security


CLICK HERE for the submission from Corporate Accountability International 

CLICK HERE for response from the International Obesity Forum

CLICK HERE for response from the Conflict of Interest Coalition




SUMMARY OF IBFAN’s Recommendations in addition to those sent by Democratising Global Health Coalition and Conflict of Interest Coalition.. 

  • There is a need for overarching principles for interactions with all non-State actors, 
  • WHO must develop a new comprehensive organization-wide policy addressing the avoidance and management of individual and institutional conflicts of interest with the protection of public health as the prime concern.
  • There is a need for 3 separate policies – for NGOs, private commercial entities (producers of goods and services) and those who represent their interests, and Philanthropies.
  • WHO should strengthen its engagement with NGOs
  • In view of the very real risks of undue influence, especially if commercial entities (and their front bodies) systematically violate WHA Resolutions and recommendations or work against them, IBFAN considers that it is unnecessary, risky and inappropriate for such actors to make oral interventions during meetings setting WHO's standard and norms.
  • Such actors should be invited to take part in web consultations (such as this) and to provide information when needed and appropriate. Written submissions allow for better evaluation of impact, helping Member States make sound judgments.
  •  If further consultation/interaction with such actors is deemed necessary and appropriate it must be in line with the agreed policy (see above).
  • WHO must publicise its policies on conflicts of interest more widely to create greater understanding of these critical issues and encourage good practice at national and regional level.
  • There is a need for a review of WHO’s accreditation processes, including the work programmes
  • WHO should not accept financing from commercial enterprises for activities leading to production of WHO guidelines or recommendations, especially when these entities violate or work against WHA Resolutions.
  • WHO must ensure that the financing dialogue facilitates open discussion of the risks and benefits of different types of financing.
  • Contributions from Non-State actors should only be accepted for the Global Programme of Work – ie untied to specific topics. Tied funding can result in disproportionate funding being allocated to fashionable  topics at the expense of core work.  This has the potential not only to distort WHO’s priorities, but to distort public perceptions of what needs to be done to achieve health for all.
  • WHO should not be involved in the provision of incentives to commercial companies such as bonds or guarantees, especially when they run for several years.  This does not allow for the frequent evaluation that is needed to establish and maintain the effectiveness of programmes.
  • WHO must publicise its policies on conflicts of interest more widely to create greater understanding of these critical issues and encourage good practice at national and regional level.
  • WHO must not equate  financial gain for WHO with benefit for public health.    
  • WHO must pay close attention to terminology and wherever possible use non-emotive, descriptive language.  Terms such as “partnership” can have strong emotional and commercial value, and should be qualified as to whether the engagement or interaction is a form of a sponsorship, contribution in kind, product development, secondment, information gathering exercise?  

WHO should avoid any attempt to “ensure a mutually derived benefit” for non-State actors, especially when they are commercial entities

Such ideas are described in box 5.1 in (page 25) in  the IDS/ACF  paper Aid for Nutrition: Using innovative financing to end undernutrition  « First, developed country governments could guarantee a future market for products, and thereby give private companies confidence to invest in R&D and product development. A good example is the Advance Market Commitment (AMC) process, where governments guarantee the price of vaccines developed by pharmaceutical companies. This template could be a useful mechanism for the development of fortified foods, and ensuring the availability — and affordability — of materials for complementary and therapeutic feeding at scale. 





Here is the WHO text setting out the rationale for the consultation :

In response to the request of the Executive Board of WHO (Decision EB132(11)) to conduct public web-based consultations on the draft principles and policies of engagement with non-State actors, the WHO Secretariat welcomes interested parties to provide comments on the questions and issues related to WHO’s engagement with non-State actors (as outlined at the link below).

 Inputs received from this consultation will inform the further development of principles, policies and procedures related to WHO’s engagement with non-State actors, including nongovernmental organizations and private commercial entities. All comments submitted are subject to review by the Secretariat prior to the Secretariat posting them on the WHO website. WHO reserves the right to summarize and/or edit any submission in consultation with the submitting party.

Corporate Accountability International response to engagement with non-State actors.pdf36.76 KB
COIC NGO submission3.pdf143.79 KB
DGH Response - WHO consultation non state_ actors - 24 03 13.pdf636.8 KB
IOF response WHO non-state actors consulation.pdf175.08 KB