IBFAN Comments on SUN

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IBFAN's  Discussion Paper on the  Scaling Up Nutrition (SUN) initiative - outlining our concerns about the role of businesses and why we cannot be part of SUN has been posted onto the SUN wesbite here  just above a link to the launch of the SUN Business network 

While  IBFAN and many of its allies cannot support the SUN initiative we are open to discuss our recommendations with the SUN leadership, governments and public interest groups.  The paper can be accessed on this link

IBFAN's comments have now been shared with David Nabarro, the Coordinator of SUN. In response he sent a letter expressing his comments and those of Anthony Lake, Executive Director of UNICEF, and  Chair of the SUN Lead Group. The letter can be found HERE.  A key concern is governance - and how SUN can call itself a 'government  led'  initiative - when GAIN and others on its LEAD GROUP are putting pressure on Governments to weaken their legislation to allow the promotion of baby foods.  


We have made several changes to the Paper  as a result. Below is part of a response to that letter and the rationale for the  pieces that have been changed or remain the same.


IBFAN clearly shares a common motivation with SUN  to address malnutrition. We  also greatly respect  many of the people involved in SUN. The paper was not meant to disparage those who are putting their energies into SUN for the best of reasons.   We are aware that many countries are already implementing the recommendations and may not need to be reminded   -  but there are many others that might welcome a checklist.


Opening para on SUN:  We have removed the  sentence regarding IBFAN's concerns about calling SUN a "Movement' because it is not people-led. While IBFAN  still has  concerns about this  it is not central to our critique.


Concern no 1 on  Promotion of Business Partnerships  been changed to:  PLATFORMS WITH BUSINESS

SUN encourages governments - especially the world’s most poorly resourced - to set up multi-stakeholder ‘platforms’ with the SUN Business Network. These Platforms can give businesses and their front groups unprecedented opportunities to influence the setting and shaping of nutrition strategies and policies.


We are pleased to have an assurance that SUN is advocating that Governments should be firmly in the driving seat of policy setting.  The governance issue  is really important.  However a central part of the SUN Strategy seems to be the setting up of partnerships and multi-stakeholder platforms with businesses.  We understand the need to hear all voices, but cannot agree that the best way to do this is through Platforms and Partnerships.  On Page 2 we give an example of our 5 year experience  on  EU Commission's Platform on Diet and Physical Activity where there is strong civil society representation, but where the powerful businesses can easily sway decisions and thinking in their favour. The EU Platform is not a policy deciding body - but unless checked,  the discussions can easily distort policy makers perceptions about the best way forward. Civil society often don't have the energy to check the validity of everything the companies say.  We can see no reference to the risks of Platforms in any SUN documents.     

We hope that SUN can encourage Governments not to fall into the trap of agreeing to arrive at polices by consensus with everyone round the table - as the UK has done with its Responsibility Deals.  We would welcome clarity regarding the following sentences in the Strategy which concern us:

  • "Align actions around high quality and well-costed country plans, with an agreed results framework and mutual accountability" 
  • "Be mutually accountable: act so all stakeholders feel responsible for and are held collectively accountable to the joint commitments." 
  • "Identify common objectives and agree a framework of results around which to align and intensify actions"

Concern No 2 Stays the same.  We are pleased that countries are addressing the double burden of malnutrition and have been working for some time to help them. But there is no mention of NCDs in the SUN papers  and we have to assume that any company that is not selling infant formula would be welcome to join SUN.


Concern No 3 Stays the same:  We are pleased to have an assurance in David Nabarro's  accompanying email that "mechanisms for the handling of Conflicts of Interest is given high priority within the SUN Movement Lead Group and Secretariat."  However this  text is far from adequate. It refers only to "infant formula manufacturers,"  the 14 WHA resolutions are missing  (including the last two very important ones) and there is no information about how  'violations'  will be evaluated.  There exclusion does not refer to  manufacturers of supplements, and bodies  like GAIN that are in effect representing companies such as Danone who might have a direct interest in influencing policies.   We have been told that  Unilever played a big role in devising this wording and  that any changes would have to be agreed by all stakeholders/the Lead Group.  This  takes us  back to the Concern No 1.    

Nestle is currently visiting governments all over Africa  to offer infant nutrition education help.  Will SUN be giving advice directly to Governments about this conflict of interest?  We note  that the Every Woman Every Child Initiative allows any company to make a Commitment.


Concern 4Stays the same  The assurance that  SUN consistently emphasises monitoring and evaluation is welcome. Can policies that are found to be  ineffective be stopped mid stream - if companies have been given  'guarantees' or 'Advance Market Commitments'for xxx many years?  Many people are now saying  "the train has left the station and  there's no turning back"  in relation to some dubious product based interventions..


Concern 5  Changed to be more specific:  In the new Strategy (2012-15) SUN does not mention continued breastfeeding alongside family foods.

We welcome the assurance that continued breastfeeding will be emphasized.  Its a shame it is not mentioned  in the Strategy or the  Progress Report.  We are pleased that the SUN Progress Report  mentions the importance of International Code implementation and maternity protection.



SUN IBFAN 28.11.122.pdf256.86 KB
Nabarro reply to Patti Rundall.pdf101.25 KB