Alcohol industry interference has been identified as a major barrier to reducing alcohol-related harm. Public health actors have consistently argued that alcohol industry involvement in policymaking represents a conflict of interest (COI) because of private companies’ fiduciary responsibility to maximise shareholder value, and thus to prioritise profits over public health.
As the World Health Organisation states:
Overwhelming evidence indicates that companies producing and selling unhealthy commodities have defeated, delayed or weakened the design, implementation and evaluation of public policies worldwide.
In addition, the alcohol industry has used a range of strategies:
to legitimise its participation in the public health agenda strengthening the narrative that policies and regulations work only if economic operators sit at the table.
Despite this, alcohol industry groups continue to occupy a prominent place in UK alcohol policy, enjoying significant access to policy makers and participating in various self- and co-regulatory initiatives with government.
International guidelines exist to protect public health policy from commercial vested interests in relation to tobacco control, infant formula, and unhealthy food. However, there is no such equivalent in the field of alcohol policy and there is little guidance available for policy makers, NGOs and researchers to manage COI when engaging alcohol industry actors. The lack of established guidelines and principles means that there is also no internationally agreed definition of what constitutes a COI in the context of alcohol. Similarly, little is known about how different policy actors define the concept, how they view alcohol industry engagement in the policy process, and how this informs their professional practise.
Our recent study addresses this knowledge gap, by exploring how alcohol policy actors understand the concept of COI in relation to alcohol industry engagement with UK public health policy. It draws on 26 interviews with alcohol policy actors, including civil servants, health campaigners, medical professionals, researchers, parliamentarians, and alcohol industry representatives. Recruiting alcohol industry participants was challenging, with only two representatives agreeing to interview, so supplementary data was obtained from industry responses to a Health Select Committee inquiry.
Understanding Conflicts of Interest
A key finding was that many participants struggled to articulate a clear definition of COI, despite claiming to hold strong beliefs about the issue. This highlights the need for greater engagement with this concept, and reflection on policy practise, to support alcohol policy actors in their goals to protect health policy against industry interference. Financial COIs – i.e., being in receipt of funds from organisations whose objectives were contrary to the goals of a particular programme or activity – was seen as representing the clearest example of COI.
However, it was widely acknowledged by respondents that COI were not limited to financial transactions and included a range of non-financial conflicts such as personal relationships and obligations, professional experience, and membership of organisations, boards or networks. Concerns were raised though about equating these interests with financial COI, reflecting the view that commercial financial COI should have a ‘special status’ compared to other interests in alcohol policy settings. Similarly, COI and alcohol industry involvement in alcohol policy were described as variable and context specific, depending on the type of industry actor, the stage of policy process, and the type of engagement activity.
Type of industry actor
Participants identified a variety of alcohol industry actors, including retailers (both on- and off-trade), producers (of different types of alcoholic beverages and multinational and domestic), trade associations, Social Aspects/Public Relations Organisations (SAPROs) and non-governmental organisations (NGOs), think tanks, and individual experts in receipt of industry funding representing different forms of COI. On-trade retailers were described by participants as presenting a ‘lower’ level of COI compared to off-trade retailers, and multinational producers were described as more ‘highly conflicted’ than domestic or artisanal producers. For example, one industry representative described how small, domestic and artisan producers were more socially responsible and connected with their local consumers compared to large, multinational producers active around the world. The latter were seen as dominating alcohol trade associations and, therefore, wielding greater influence over UK alcohol policy than smaller domestic producers and retailers.
Beliefs on the level of COI associated with NGOs and individual experts in receipt of industry funding varied according to type of organisation and funding relationship. Industry- funded SAPROs such as Drinkaware and pro-business think tanks such as the Institute of Economic Affairs [that has received alcohol industry funding] were described as presenting a more insidious form of COI than alcohol companies and/or trade associations. Their operations were described as covert and deceptive because of their claims to independence, and thus legitimacy, in their engagement in policy development and implementation. However, NGOs that received modest sums of money from alcohol industry bodies (but did not rely on industry funds to exist), and whose objectives and activities were perceived as in the public interest, were considered as presenting less of a conflict.
Stage of policy process
Participants identified industry engagement at different stages of the policy process as representing different levels of risk linked to COI. The policy adoption and implementation stages were described as key opportunities for industry to influence policies by drawing on their technical expertise and capabilities. Responding to public consultations and recorded formal meetings with officials and ministers, that were a matter of public record, were seen as examples of how industry could inform the finer details of policies. However, public health actors reported that industry influence during the agenda setting/problem identification stage carried particular risks for public health, as industry could frame the policy debate in ways that narrow the scope for evidence-based policies and promote ineffective substitute alternatives such as voluntary partnerships. Industry involvement of policy evaluation programmes was also cited as presenting risks, linked with one industry representative even stating that corporations shouldn’t be marking their own homework.
Type of engagement
Variable levels of support and/or concern were expressed by participants regarding different types of industry contact. For example, engagement was seen as legitimate to facilitate the implementation of server training schemes for licensed retail staff and product reformulation to reduce alcohol content. In contrast, there was widespread opposition to alcohol industry involvement in pricing policies. Any involvement of commercial actors in setting the level for minimum unit pricing and alcohol duty structures was referenced by several participants as a ‘red line’ not to be crossed.
Corporate hospitality outside of parliament, such as invitations to sporting events or drinks parties, was cited as presenting a risk of COI. Civil servants described how they often received such invitations, but declined as they viewed attending social events to be inappropriate.
Whilst agreeing on the need to refuse alcohol industry funding in order to protect against COI, several participants would consider other, non-financial forms of engagement if certain conditions were in place. Sharing a public platform, attending events and roundtable meetings where industry was present was described as a ‘grey area’ for health campaigners, who preferred to judge on a case-by-case basis whether the risk, or at least the perception, of COI was too great.
Transparency was considered to be a key factor in managing COI and protecting public policies from industry influence. Unrecorded, informal engagements with decision makers were seen as undesirable, and could lead to negative outcomes. Formal engagements in the policy process that were a matter of public record such as meetings with officials and entertainment within parliament were considered acceptable forms of alcohol industry engagement. However, whilst declarations of interest were described as important, they were not sufficient to eliminate COI. Rather, they were described as instruments which can be used to manage and mitigate risks associated with covert influence.
Similarities in tactics between the alcohol industry and other health-harming commodity industries – most notably tobacco and hyper-processed foods – were identified. However, despite the similarities described by some participants regarding the industry’s corporate political activities, the majority of interviewees did not think that the alcohol industry should be subjected to the same restrictions as the tobacco industry, which is excluded from many aspects of the public policy process under Article 5.3 of the WHO Framework Convention on Tobacco control. Perhaps unsurprisingly, alcohol industry representatives strongly resisted comparisons between tobacco and alcohol products. More notably, public health participants also described differences between the two products and industries, citing the UK Government’s long-term aim to eradicate smoking as a rationale for their different treatment. It was acknowledged that the majority of people in the UK enjoy alcohol which, unlike smoking, is seen as a normal part of everyday life. Consequently, the alcohol industry should not be excluded from health policy in the same way the tobacco industry has been.
What are the implications of this research?
This study helps understand how different policy actors view alcohol industry involvement in policy, and their beliefs on what sorts of interaction are appropriate and not appropriate. In so doing it seeks to address the current lack of alcohol-specific guidance on COI and a lack of agreement amongst researchers, policymakers and civil society actors on what constitutes a COI and thus what forms of industry engagement should be precluded. Alcohol is a unique policy challenge and, whilst many lessons can be drawn from responses to COI in other areas of public health, appropriate tools to protect alcohol policy from commercial interference will require a tailored approach.
IAS will draw on this research to inform the development of guidelines for UK government to mitigate risks associated with commercial conflicts of interest in alcohol policy settings. Such guidelines could acknowledge the status quo but work to limit industry interference in future and allow for the enactment of public health policies to save lives. With alcohol harm rates at record levels, action on the known barriers to progress is urgently needed.
Written by Dr Katherine Severi, Chief Executive, Institute of Alcohol Studies, and Dr Benjamin Hawkins, Senior Research Associate, University of Cambridge.
All IAS Blogposts are published with the permission of the author. The views expressed are solely the author’s own and do not necessarily represent the views of the Institute of Alcohol Studies.