Dr. Gro Harlem Brundtland
Director General
World Health Organization
1211 Geneva 27
SWITZERLAND

5 April 2000

Re: Transparent and democratic decision-making within WHO



Dear Dr. Brundtland

I am writing to you, as a health professional, social scientist and citizen, to express my deep concern about what I can only call the censorship which seems to be operating within WHO. I witnessed this censorship as a contributor and participant at the WHO/UNICEF Technical Consultation on Infant and Young Child Feeding held on 13-17 March this year. It has grave implications for the institutional culture within WHO as a public policy making and standard setting agency.

You have already learned that Ellen Sokol disclaimed authorship of the background paper she had prepared for this Consultation ("How can we strengthen the implementation of the International Code of Marketing of Breastmilk Substitutes") because it had been so substantially altered by WHO staff. My concerns arise from a similar experience with my own paper.

I was commissioned to write a paper on "How globalisation affects infant feeding". In the terms of reference which had been agreed-upon, I proposed to explore whether the infant food industry should have a greater role in shaping national and global infant feeding policies or not. Part three of my paper thus deals with "infant feeding and global democratic governance". It draws attention to "issues management", a corporate public relations discipline which has begun to encompass "strategic sponsorships" and "partnerships" to build up "goodwill capital", which is regarded by transnational corporations as an invaluable resource to influence political and regulatory debates in their interest.

I concluded that infant food manufacturers should not be involved in policy-making on infant feeding. I based this conclusion on an analysis of infant food manufacturers' conduct in relation to their marketing practices, Code implementation, and international public debates, and on concerns about a more general conflict of interest between profit-making and public policy-making. I argued, however, that infant food manufacturers do have a role to play in infant feeding: namely, that of delivering good quality, reasonably priced products and of marketing them in a way that does not conflict with the International Code or subsequent WHA resolutions.

I learned on the evening before the Consultation that eight pages of reasoned argument (including the topics mentioned above) upon which I based my conclusions had been cut out of my paper. Moreover, the conclusion had been altered so that it no longer reflected my point of view. Critically, it left open the question of further industry involvement in global policy-making.

I was told that these and other changes to my paper stemmed from concerns within WHO's legal department about naming companies and because WHO is an evidence-based institution. These do not explain why the evidence for my conclusion was cut out.

Moreover, of all the papers prepared for this Consultation, only two were not distributed to participants beforehand: mine and Ellen Sokol's, even in their altered versions. I learnt of this only during the first day of the Consultation itself. When participants enquired why they had not been distributed, they were informed that the papers had not yet passed WHO's clearance system. This was the first time I had heard about such a clearance system; it was not mentioned in my terms of reference. I asked for a copy of WHO's clearance guidelines; to date, I have not received them.

When I presented my paper, I replaced the excised material with a list of concerns on "public-private partnerships" raised in a recent UNRISD publication. It includes, among other issues:

"self-censorship and reduced freedom of expression among officials of international agencies";

"institutional capture", whereby corporate interests come to dominate or heavily influence the decision-making processes of public-interest institutions;

and concerns that these partnerships "may serve to weaken key drivers of corporate responsibility, namely governmental and intergovernmental regulation . . . collective bargaining, as well as more critical forms of NGO activism and civil society protest." (Utting 2000:32-34)

I should point out that a commentator on an earlier draft of my paper asked me to specify what I meant by "transparency" and "democratic" decision-making in relation to the Commission for Global Governance's call for more democratic global governance mechanisms and in relation to the field of infant feeding. These terms are not easy to define, yet an example of what they are not was provided by the Consultation itself.

Not only Ellen Sokol and myself but also the Consultation's participants had to confront the issue of censorship when they were repeatedly told by WHO staff members that they could not discuss the appropriateness of the recommendation on the age of introduction of complementary foods. All of us experienced first hand that censorship is deeply anti-thetical to transparency and to democratic, informed decision-making. It is anti-thetical to the free exchange of ideas, to the free flow of arguments and counterarguments, which is essential to deliberations about crucial current policy questions such as the risks of close interaction between the public and commercial sector. It is anti-thetical to a proper scientific debate on the evidence underlying global health standards.

I should like to stress that I write not in order to air my grievances about my treatment at the Consultation, nor to encourage a search for "culprits" within WHO. I write so as to catalyse a candid debate on how WHO can recover an institutional climate which fosters two of the most invaluable assets of any international public agency: a reputation as an independent, public policy-making and standard-setting agency; and the motivation, enthusiasm, critical faculty, personal and professional integrity of its staff members.

I also hope that it will contribute to a climate where concerns about "partnerships" between UN agencies and the commercial sector can be openly discussed.

I look forward to hearing your response to the issues I have raised.

Yours sincerely,

Judith Richter

cc. Carol Bellamy, Executive Director, UNICEF
Authors of Background Papers for the Technical Consultation

Ref.: Peter Utting, Business Responsibility for Sustainable Development, UNRISD Occasional Paper, Geneva, January 2000