You're here: Home / Alcohol knowledge centre / The alcohol industry / Factsheets / Information and messaging

Information and messaging

Information and messaging strategies cover the array of ways in which alcohol companies seek to shape perceptions and understanding of alcohol, and how these are translated into action. The alcohol industry engages in every stage of the process of moving from evidence to policy, in particular:

  • Influencing the development of evidence by funding original research, and so prioritise its favoured research agenda
  • Interpreting existing evidence by synthesising, disseminating and evaluating existing research, framing problems and promoting solutions in a way that is favourable to the industry
  • Directly presenting evidence to policymakers to influence Government action – both when solicited in consultations, and also in the shape of unsolicited lobbying

These strategies can be supplemented by subtler messaging tactics. As described previously, corporate social responsibility projects can reinforce narratives such as the view that harmful drinking is an individual problem for a small minority of consumers. This can be achieved through marketing material, or more generally in media messages.

This section focuses on the three strategies for social and political activities: funding research, disseminating research and lobbying. 

Industry funding of research

Industry funding of research is problematic for two reasons. First, by selecting which research projects are supported and carried out, the alcohol industry can shape the overall research agenda, and shifting it towards its own preferred framing of alcohol problems and policy – for example, focusing on individual issues and interventions, and neglecting the structural and political.[1] Second, there is the possibility that receiving industry money can pressurise researchers to produce findings beneficial to their funders. This is often a matter of subtle cognitive biases as much as overt corruption or malfeasance. Babor and Robaina note that:

Although there is no systematic evidence that financial conflicts of interest have biased the findings of alcohol research, several studies have shown that conflicts of interest in health research in general are associated with biased research findings that favor commercial interests at the expense of patient welfare and public health.[2]

For example, systematic biases have been found in tobacco,[3] energy[4] and obesity[5] research, that funding can influence results. However, this has yet to be proven in alcohol research: a recent analysis found that industry-funded studies were, on average, no more positive about the health consequences of drinking (with research linking alcohol and strokes a notable exception).[6]

Industry funding for research can take a variety of forms. It can be funnelled through grant-making organisations that pool donations from companies. Of these, the most prominent are the European Foundation for Alcohol Research (ERAB), the Alcohol Beverage Medical Research Foundation and the Institut de Recherches Scientifiques sur les Boissons. Industry funding can also involve support for ‘in house’, trade body, think tank or external academic researchers. Finally, funding can finance research centres or other scientific organisations.[7] As well as paying for studies, the industry also influences research by sponsoring publications and academic conferences. For example, ICAP produced ten volumes in its ‘Alcohol and Society’ series, often co-authored by ICAP staff, academic researchers and industry representatives. It has sponsored a number of conferences, symposia and periodicals. One such symposium, in 2006, caused controversy when industry-funded researchers circulated a summary felt by participants to understate the extent of disagreement over the putative health benefits of drinking alcohol.[8] 

How to respond to industry influence is the matter of significant debate within the academic community, which seeks to minimise conflict of interest through “Objective appraisal rather than witch-hunt”, for example by requiring declarations of competing interests on publications.[9] Stenius and Babor identify four models for the relationship between industry and researchers.[10]

The first approach is a blanket prohibition, forbidding any contact with the alcohol industry, replicating the tight regulations around engaging with the tobacco industry. For example, in 2003, Stockholm University banned tobacco funding of research at the institution.

Second, there are relatively relaxed ‘partnership agreements’, which encourage dialogue between researchers and industry and have limited restrictions on accepting industry finance, recognising a ‘right’ to work with commercial agents. Such an approach is exemplified by the 1997 ICAP-sponsored ‘Dublin Principles’, which insist that “To increase knowledge about alcohol in all its aspects, the academic and scientific communities should be free to work together with the beverage alcohol industry, governments, and nongovernmental organizations”.[11]

A recent Spirits Europe briefing makes a more assertive case for a partnership approach to research, arguing not just that research involving the industry is legitimate but suggesting that research excluding the industry is flawed.[12] The report challenges the very system of academic peer review, arguing “it is not the panacea if the ‘peers’ share the same bias as the author” and questions “the objectivity of a number of activist researchers”. The solution, according to Spirits Europe, is close involvement of the industry in research: it suggests ‘stakeholders’ should be consulted on proposed methodology before research is conducted, should have advance access to presentations and should be allowed the right of reply to academic research funded by the EU.

These standards are much less common than the third and fourth models: conflict of interest policies and ethical analysis approaches. Conflict of interest policies involve voluntary guidelines, typically policed by journals and professional bodies, such as the principles promulgated by the Federation of American Societies for Experimental Biology or the RESPECT code. These, for example, provide ethical guidance on disclosing competing interests, or accepting funding.

Ethical analysis approaches, by contrast, rely on the specific judgement of individual researchers, rather than formal rules. Consequently, they seek to develop their moral reasoning skills. For example, ethical training can teach researchers frameworks for considering the different types of risk involved in a research project.

Industry dissemination and framing of evidence

As much as influencing research activity itself, the alcohol industry plays a role in shaping public and political perceptions of alcohol in general, and scientific evidence in particular. For example, as mentioned previously, ICAP was accused of operating as a shadow WHO for many years – according to David Jernigan: “Much of the ICAP’s activities have focused on countering the influence of the WHO and leading alcohol researchers by essentially functioning like a WHO unit on alcohol, with certain key omissions”.[13] In other words, it was perceived to be acting as a rebuttal team for drinks companies to shape public debate: “ICAP publications were often collaborations between academics and industry representatives that would conclude the opposite of what WHO publications were concluding”.[14] 

In general, the organisation is seen as pursuing academic arguments favourable to the alcohol industry: its publications “excluded or attempted to refute evidence regarding the most effective strategies to reduce and prevent alcohol-related harm”, for example challenging the view that raising taxes and reducing availability reduces alcohol harm. [15]

The industry’s use of research and evidence reflects and reinforces many of the messages it promotes in relation to alcohol more generally, in its marketing and CSR activities. For example, the alcohol industry regularly emphasises individual personal responsibility, rather than seeing alcohol harm as a social problem with structural causes. The industry also tends to focus on a ‘problem minority’, rejecting the view that the general population ought to be concerned about its alcohol consumption.[16] These fundamental assumptions run through advertising which carries individualised warnings, CSR projects that focus on educating consumers rather and research which emphasises the role of families or genes, rather than structural factors in harmful drinking. These are also the ideas that the industry tends to draw on when engaging with policymakers, as shown by the case studies below.

One prominent recent study follows the development and promotion of SABMiller-funded research published by think tanks and consultancies at critical stages of the formulation of the UK Government’s alcohol strategy.[17] In December 2012, while the Government was considering whether to introduce a minimum unit price (MUP) for alcohol, three SABMiller-funded reports (from Demos, London Economics and the Centre for Economics and Business Research) were released. The Demos report, Feeling the Effects, was launched at an event in the Houses of Parliament and publicised at the conferences of the leading British political parties. According to a Demos employee, it was made clear from the outset that SABMiller wanted the report to emphasise the influence of parenting on alcohol consumption, and the final report reflects this agenda, with a quote on the cover claiming that “Effective parenting is the best way to call time on Britain’s binge drinking”.[18] While the report makes little reference to MUP, according to Hawkins and McCambridge, “The press release, however, frames interventions on parenting styles as a direct alternative to MUP”.[19] They suggest the reports, and others like them, may have been influential in the Government’s ultimate decision not to proceed with MUP.

Official consultations are a more direct way of using evidence to shape policy. These are commonly held on important matters of policy or regulation. Though in principle the openness of consultations means that other organisations have an equal opportunity to influence to the industry, it has been suggested that industry actors have disproportionate involvement in pre-consultations to determine the terms of the official consultation.[20] Moreover, this influence is consolidated through roundtable meetings throughout the consultation and follow-up meetings after the conclusion of the consultation.

McCambridge et al have studied the alcohol industry’s use and interpretation of evidence in one such prominent consultation – on the Scottish Government’s alcohol strategy, including the question of whether or not to introduce MUP.[21] According to their analysis of industry submissions to the consultation, the industry’s responses were fundamentally unbalanced: “Strong evidence is misrepresented and weak evidence is promoted. Unsubstantiated claims are made about the adverse effects of unfavoured policy proposals and advocacy of policies favoured by industry is not supported by the presentation of evidence”.[22] They observe that though many industry submissions criticised whole-population approaches to addressing alcohol harm, half the submissions do not provide any references, and some references that are provided do not support this argument. Though they neglect published academic evidence, McCambridge et al observe that a number of the submissions rely on their own commissioned research, though this is rarely transparently reported and peer-reviewed. The industry responses make numerous claims about the supposed adverse effects of proposed policies, such as strengthening the black market and increasing the prevalence of underage drinking, without evidence. Moreover, the industry’s preferred measures, such as increasing education and better enforcement of existing laws are falsely presented as inconsistent with policies such as MUP, and the weakness of the evidence base supporting them is not acknowledged. McCambridge et al conclude that “The potential for corporations with vested interests to interfere with the evaluation of scientific evidence by policy makers needs to be restricted for effective policies to be designed”.[23]

Industry lobbying

The alcohol industry, like many other sectors affected by regulation, invests significant time, effort and money in directly trying to shape government policy. In the US in 2014, drinks companies declared spending $24.7 million on lobbyists, engaging both in-house public affairs teams and specialist agencies to develop their political strategies.[24] Moreover, they spent a further $17.1 million on campaign contributions to support particular politicians or parties.[25] Whilst it is likely that the picture is similar in the UK, it has less stringent requirements on disclosure, resulting in a situation where, according to David Miller, a specialist in lobbying transparency, “we have no idea how much the drink[s] industry spends on lobbying, either in house or in hiring consultancies, what it lobbies on, and who it contacts”.[26]

However, as Hawkins and Holden argue, alcohol industry lobbying in the UK is not simply a question of financial resources. Their interviews of lobbyists, officials and politicians, find that industry actors attempt to build long-term relationships with policy makers, though at times they employ a more transactional issue-by-issue approach as required.[27] Industry actors also use other resources to gain access to actors and key stages of the policy process, including their ability to provide policy solutions for governments, such as self-regulatory regimes. Civil servants, ministers, special advisers and backbench and opposition MPs all provide different opportunities to influence policy, and are approached in different ways.

A. The government

Civil servants are typically the ‘first port of call’ for lobbying for two reasons: first, because they are responsible for drafting, implementing and enforcing legislation; second, because they are advisers and gatekeepers to ministers. According to Hawkins and Holden, alcohol industry actors enjoy a high level of access to officials in key Westminster departments, such as the Department of Health, the Home Office and the Treasury: “You can pick up the phone to them, you can talk to them, it’s not a problem of access”.[28] David Wilson, public affairs director for the BBPA, claims that his organisation “will have daily contacts with officials”.[29] These discussions with the civil service typically focus on the industry’s perspective on technical, operational questions about how to deliver the details of policy.

Contact with ministers is typically less frequent and less detailed, focused instead on “selling them how your idea ties in with their political objectives”.[30] Nevertheless, such meetings are still a regular occurrence: one national trade association claimed to meet the public health minister three to four times a year, and organises ‘behind closed door’ lunches for their members to discuss specific issues.[31] For example, then Treasury Secretary Sajid Javid met with Greene King, the BBPA, the WSTA, the Federation of Wholesale Distributors, the SWA, the Association of Convenience Stores, and the National Association of Cider Makers between January and February 2013, while the Government’s consultation on whether to introduce MUP was still ongoing.[32] Meetings with ministers’ special advisers are easier to achieve and are seen as nearly as effective – though they lack the profile of the minister, they are often as influential.

Regular bilateral meetings with ministers and officials are seen as natural, normal and legitimate by the alcohol industry. By contrast, Hawkins and Holden observe that “Public health activists claimed that they are simply not able to obtain the level of access to government granted to industry actors”.[33] These close working relationships are often the result of personal connections. One trade association lobbyist reports: “I’ve got good influences in European Parliament; my children have worked there, my daughter’s in the Cabinet Office, you know. I know these guys, they’re friends of mine; I was a Tory candidate, you know”.[34]

B. Backbench MPs and peers

MPs and peers outside the cabinet are a further source of influence on government policy, with their ability to challenge and scrutinize the Government in parliamentary debates and committees, or to put issues on the agenda through their campaigns. Those with constituency links to the alcohol industry, such as breweries or distilleries, are often targeted for meetings.[35] All Party Parliamentary Groups (APPGs) are another source of access. These are informal cross-party organisations for parliamentarians who share an interest in a particular issue. In the last parliament, the All Party Beer Group was the largest of all APPGs, with almost half of all MPs members.[36] It is funded by alcohol producers, as are the APPGs on cider and wine and spirits.[37] Typically, trade bodies provide administrative support, with one secretary claiming that in return they are expected to “help deliver the audience” for funding companies.[38] For example, networking events such as dinners and tasting sessions are organised so that industry representatives can meet informally with ministers and MPs. According to one brewer, “this is the whole concept actually – we are buying a table, each company, and then we have MPs sitting with us”.[39] APPGs also produce research and publish reports, which can help shape policy. Backbench MPs chairing such groups are more likely to meet and influence ministers. Nevertheless, some argue that APPGs have limited policy content and are ineffective at securing policy goals, though Hawkins and Holden suggest that they are still significant as a forum for long-term relationship building.

C. The opposition

Alcohol industry lobbying often extends to opposition political parties, both in an effort to pressurise the government of the day and as a way of cultivating relationships with potential future governments. The opposition presents a particular opportunity for lobbyists because of its relative lack of resources. Shadow ministers typically have few staff covering a wide brief, and so look to outside groups for support with data and research. For example, prior to the 2010 UK General Election, industry actors were closely involved in the Conservative Party’s Public Health Commission, which contributed to the development of its public health policy.[40]

D. Developing countries

Governments in developing countries are particularly vulnerable to the lobbying strategies outlined, for the same reason as opposition parties in rich countries – because their relative lack of resources and policy capacity leaves them reliant on outsiders. For example, global brewers have used schemes to cultivate local African crops such as the ones described to negotiate favourable and preferential tax terms. SABMiller’s cassava beer Impala is charged a quarter of the standard excise rate in Mozambique.[41] The alcohol industry has resisted a number of proposals by developing country governments to regulate alcohol – for example, industry lobbying is believed to have obstructed plans to raise the legal drinking age in South Africa. Governments have in some cases overridden the objections of the industry to force through legislation such as restrictions on availability in Kenya and an alcohol levy in Botswana. Nevertheless, alcohol companies appear to have substantial influence over regulation in developing countries. One striking analysis of national alcohol policy documents from Lesotho, Malawi, Uganda and Botswana has found that they are “almost identical in wording and structure and that they are likely to originate from the same source”, namely SABMiller’s Policy and Issues Manager Mitch Ramsay (the document’s author is listed as ‘mramsay’).[42] In other words, industry representatives effectively dictated policy to these governments.

The alcohol industry and global governance

Many of the issues concerning alcohol industry influence over policy at a national level have been replayed at the level of global institutions, particularly the World Health Organisation. The WHO has an important role in coordinating global health policy, and providing research and support in policy development to member states. However, the alcohol industry has consistently sought to shape the WHO’s programme on alcohol, and has regularly demanded acceptance by the WHO as a legitimate partner in health policy discussions.[43] As mentioned already, the industry-funded SAPRO ICAP drew on researchers recruited from the WHO. According to David Jernigan, “ICAP staff are frequent visitors to the WHO in Geneva and are a reliable presence during WHO Executive Board and World Health Assembly meetings”.[44] He claims that their “advocacy led to the delay and near-failure in 2007 and 2008 efforts to create the Global Strategy”.[45] 

Despite this influence, in 2010 the WHO agreed a non-binding Global Strategy, recommending a set of best practice policies to reduce alcohol harm.[46] However, it’s ambivalence on engagement with the alcohol industry remains controversial. In sharp contrast, the WHO rejects any sort of interaction with the tobacco industry, a position formalised in the Framework Convention on Tobacco Control[47] It has been suggested, that alcohol producers ultimately fears the ‘pariah’ status currently reserved for the tobacco companies[48], with growing objections to the idea of ‘tobacco exceptionalism’ – that tobacco producers should be treated completely differently to other unhealthy commodity industries.[49]

A 2013 speech by WHO Director-General Margaret Chan fuelled expectations that the organisation would distance itself from alcohol producers, as Chan argued “it is not just Big Tobacco anymore. Public health must also contend with Big Food, Big Soda, and Big Alcohol. All of these industries fear regulation, and protect themselves by using the same tactics…In the view of WHO, the formulation of health policies must be protected from distortion by commercial or vested interests”.[50]

However, this commitment has been questioned, given the long-running negotiations over the WHO’s Framework of Engagement with Non State Actors (FENSA), which is intended to clarify the role that organisations such as alcohol producers, SAPROs and NGOs ought to play in policy development. Following four years of discussion, in October 2015, a number of NGOs expressed concern that discussions were focused unnecessarily on “exaggerated” ‘unintended consequences’ of restricting engagement with non-states organisations – primarily that enforcing such a system would be cumbersome and bureaucratic – and that this risks undermining the whole project.[51]

Limitations on lobbying effectiveness

Many of these points of access to the Government are also open to NGOs, charities and academic experts providing opposing perspectives to the industry. These groups also hold meetings with MPs and officials and also respond to consultations. UK charity Alcohol Concern acts as secretariat to The APPG on Alcohol Harm.[52] Indeed, Holden and Hawkins report that in Scotland, public health advocates successfully displaced the industry in their close cooperation with the Scottish National Party (SNP) Government that came to power in 2007.[53] Organisations such as the British Medical Association Scotland, Alcohol Focus Scotland and Scottish Health Action on Alcohol Problems have been praised for running a disciplined and coordinated campaign, promoting policies such as MUP while the SNP were in opposition, and challenging and supporting them in introducing a new alcohol strategy. According to Holden and Hawkins:

The close relationship that existed between the PH [public health] bodies and the Scottish government reflected the willingness of the latter to utilise the expertise of the former and to draw on the evidence base available to inform policy decisions…The representatives of one industry association claimed wryly that it was getting ever harder to meet with officials or ministers because they were overwhelmed with doctors demanding to meet with them to discuss alcohol pricing.[54]

Nevertheless, many public health groups – and independent academics – believe that the industry has systematic advantages when it comes to influencing policy. The financial resources of alcohol companies allow them to engage specialist public affairs agencies.[55] It also allows them to contribute to political parties and APPGs and ‘buy time’ with policymakers. Moreover, their economic importance is perceived to strengthen their bargaining power. One public health advocate believes “the agenda is set by people who have got the time and effort to talk the hind leg off a donkey. And we just don’t have that level of time and resource”.[56] Consequently, according to Hawkins and Holden, under usual circumstances “public health activists claimed that they are simply not able to obtain the level of access to government granted to industry actors”.[57]

However, another caveat on the power of the industry to dictate alcohol policy is the level of internal disagreement in its aims. One trade association representative claims that: “This is a very, very fragmented industry. No one likes each other very much; the on-trade hates the off-trade, wine and spirit and beer companies they’re all arguing about various things”.[58]

Holden et al examine the strategic conflicts which exist within the UK alcohol industry.[59] They find that many in the on-trade believe the off-trade is underregulated, and fear that supermarkets will put pubs out of business, while many in the off-trade see this as a “victim complex”. Different drinks categories have distinct, contradictory policy agendas. The spirits industry tends to believe duty should be based on alcohol content, though this would raise the price of beer.[60] The beer industry generally believes cider should be taxed in the same manner as beer, though many cider producers believe they incur special costs than warrant special protections.[61] Spirits, white cider and strong lager are all singled out by competitors as being associated with binge drinking.

In this context, trade associations play a critical role in coordinating and unifying the drinks industry and ensuring it has a coherent set of policy demands. However, the breadth of different concerns covered by large organisations like the BBPA and WSTA means that, according to Holden et al, “the arguments made by trade associations often represent the lowest common denominator on which all members can agree”.[62] At the same time, the larger members of trade bodies are powerful enough to act independently – for example, Tesco broke ranks with the WSTA and decided to support government intervention on alcohol pricing.[63]

 

Previous: Policy substitution       |       Next: Financial incentives


[1] Edwards, G. et al (2004), An invitation to an alcohol industry lobby to help decide public funding of research and professional training: a decision that should be reversed, Addiction 99, pp. 1,235–6.

[2] Babor, Robaina. & Jernigan, op. cit.

[3] Barnes, D. et al (1995), Environmental Tobacco Smoke: The Brown and Williamson Documents, Journal of the American Medical Association 274:3, pp. 248–53.

[4] Shrader-Frechette, K. (2011), Climate Change, Nuclear Economics, and Conflicts of Interest, Science and Engineering Ethics 17:1, pp. 75–107.

[5] Bes-Rastrollo, M. et al (2013), Financial Conflicts of Interests and Reporting Bias Regarding the Association between Sugar-Sweetened Beverages and Weight Gain: A Systematic Review of Systematic Reviews, PLOS Medicine.

[6] McCambridge, J. & Hartwell, G. (2015) Has industry funding biased studies of the protective effects of alcohol on

cardiovascular disease? A preliminary investigation of prospective cohort studies. Drug and Alcohol Review 34, pp. 58–66.

[7] Babor, Robaina. & Jernigan, op. cit.

[8] Ibid, 208.

[9] Editorial (1996), Science and the drinks industry: cause for concern. Addiction 91, pp. 5–9.

[10] Stenius, K. & Babor, T. (2010), The alcohol industry and public interest science. Addiction 105, pp. 191–98.

[11] National College of Ireland (1997), The Dublin Principles. [Accessed 14 March 2016].

[12] Spirits Europe (2014), The Body of Evidence: Policy-Making and Research. [Accessed 14 March 2016].

[13] Jernigan, D. (2012), p. 82.

[14] Jernigan, D. (2012), pp. 82–3.

[15] Ibid.

[16] Hawkins, B. & Holden, C. (2013), Framing the alcohol policy debate: industry actors and regulation of the UK beverage alcohol market, Critical Policy Studies 7:1, pp. 53–71.

[17] Hawkins & McCambridge (2014), Industry Actors, Think Tanks, and Alcohol Policy in the United Kingdom. American Journal of Public Health 104, pp. 1,363–9.

[18] Birdwell, J. et al (2012), Feeling the Effects. London: Demos.

[19] Ibid, p. 1,365.

[20] Hawkins & Holden, ‘Water dripping on a stone?’, op. cit., p. 62–3.

[21] McCambridge, J., Hawkins, B. & Holden, C. (2013), Industry Use of Evidence to Influence Alcohol Policy: A Case Study of Submissions to the 2008 Scottish Government Consultation, PLOS Medicine 10, pp. 1–6.

[22] McCambridge et al (2013), op. cit., p. 2.

[23] Ibid

[24] OpenSecrets.org, Beer, Wine & Liquor Industry Profile: Summary, 2014 [Online]. [Accessed 18 December 2015].

[25] OpenSecrets.org, Beer Wine & Liquor: Long-Term Contribution Trends [Online]. [Accessed 18 December 2015].

[26] Miller, D. & Harkins, C. (2014), Can the influence of the alcohol industry be curtailed? 8 January. BMJ Blogs. [Online] [Accessed 18 December 2015].

[27] Hawkins, B. & Holden, C. (2014), ‘Water dripping stone’? Industry lobbying and alcohol policy, Policy & Politics 42, pp. 55–70.

[28] Hawkins & Holden, ‘Water dripping on a stone?’, op. cit., p. 59.

[29] Gornall, J. (2014), Under the influence, BMJ 348:f7646.

[30] Hawkins & Holden, ‘Water dripping on a stone?’, op. cit., p. 59.

[31] Ibid.

[32] Gornall, op. cit.

[33] Hawkins & Holden, ‘Water dripping on a stone?’, op. cit., p. 61.

[34] Hawkins & Holden, ‘Water dripping on a stone?’, op. cit., p. 62.

[35] Hawkins & Holden, ‘Water dripping on a stone?’, op. cit., p. 60; Holden, C. & Hawkins, B. (2012), ‘Whisky gloss’: The alcohol industry, devolution and policy communities in Scotland, Public Policy and Administration 28, pp. 253–73.

[36] Gornall, op. cit.

[37] UK Parliament, Register of All-Party Parliamentary Groups: Beer. [Online]. [Accessed 18 December 2015]. UK Parliament, Register of All-Party Parliamentary Groups: Cider. [Online]. [Accessed 18 December 2015]. UK Parliament, Register of All-Party Parliamentary Groups: Wine and Spirit. [Online]. [Accessed 18 December 2015].

[38] Holden & Hawkins, ‘Water dripping on a stone?’, p. 63.

[39] Ibid.

[40] Holden & Hawkins, ‘Water dripping on a stone?’, p. 61.

[41] Babor, Robaina & Jernigan, op. cit.

[42] Bakke, O. & Endal, D. (2010), Alcohol policies out of context: drinks industry supplanting government role in alcohol policies in sub-Saharan Africa, Addiction 105, pp. 22–8.

[43] Room, R. (2005), Alcohol and the World Health Organization: The ups and downs of two decades, Nordisk Alcohol & Narkotatidskrift 22, pp. 146–62.

[44] Jernigan (2012), op. cit., p. 85.

[45] Ibid.

[46] Schmitz, H.P. (2015), The global health network on alcohol control: successes and limits of evidence-based advocacy, Health Policy and Planning, pp. 1–11.

[47] Collin, J. (2012), Tobacco control, global health policy and development: towards policy coherence in global governance, Tobacco Control 21, pp. 274–80.

[48] Room, op. cit.

[49] Collin (2012), op. cit.

[50] Chan, M. (2013), WHO Director-General addresses health promotion conference, 10 June, Helsinki, Finland. [Accessed 10 March 2016].

[51] Eurocare (2015), NGOs criticise WHO’s ‘non paper’ on conflicts of interest, Eurocare website [online]. [Accessed 10 March 2016].

[52] UK Parliament, Register of All-Party Parliamentary Groups: Alcohol Harm. [Online]. [Accessed 18 December 2015].

[53] Holden & Hawkins, ‘Whisky gloss’, op. cit.

[54] Holden & Hawkins, ‘Whisky gloss’, op. cit., p. 259.

[55] Holden & Hawkins, ‘Water dripping on a stone?’

[56] Holden & Hawkins, ‘Water dripping on a stone?’, p. 63.

[57] Holden & Hawkins, ‘Water dripping on a stone?’, p. 61.

[58] Holden, C. et al (2012), Cleavages and co-operation in the UK alcohol industry: A qualitative study, BMC Public Health 12:483.

[59] Ibid.

[60] Scotch Whisky Association (2015), SWA Budget Submission 2015. [Accessed 9 March 2016].

[61] Lyons, M. (2016), Cider industry needs cut in duty, MPs told, Off Licence News (11 February). [Accessed 9 March 2016].

[62] Ibid.

[63] Ibid.