Benchmarking the transparency, comprehensiveness and specificity of population nutrition commitments of major food companies in Malaysia

Malaysia is among the countries with high obesity [1] and non-communicable disease (NCD) [2] rates in the South-East Asian region. The magnitude of risk for premature death from NCDs was 17% in Malaysia in 2016 [3]. ‘Dietary risks’ for NCDs in Malaysia account for 14.6% and ‘high body mass index’ accounts for 9.9% of disability-adjusted life years, as estimated by the Global Burden of Disease [4]. Key causes of unhealthy diets are rapid urbanisation, economic growth and social change coupled with trade liberalisation, which collectively trigger food system shifts towards convenience and ultra-processed foods [5‐8]. Almost 70% of Malaysia’s population is urbanised [9] with increased market concentration of ultra-processed foods such as sweet and savoury snacks, carbonated drinks, packaged foods, biscuits and confectionery [6]. A recent population study in urban Malaysia highlighted that increased atherogenic and insulinemic risk profiles and obesity were associated with dietary patterns high in calories, fat, and sugars [10].

Prevention of diet-related NCDs requires consideration of the production, marketing, and consumption of commercially produced ultra-processed food products [11, 12]. The scope for preventive action for improving population nutrition therefore extends to actions by commercial food producers. The WHO [13, 14] recognises the need for transnational, regional and local food and non-alcoholic beverage industries, retailers, and catering companies to take responsibility in tackling obesity and diet-related NCDs via product reformulation, nutrition labelling, responsible marketing to children and healthy food accessibility. The Malaysian government, through its Eleventh Malaysia Plan 2016–2020, identified the private sector as a key stakeholder in promoting health, specifically through corporate social responsibility (CSR) activities [15].

Malaysia’s National Plan of Action for Nutrition of Malaysia (NPANM) III 2016–2025 [16], and the National Strategic Plan for Non-communicable Disease (NSP-NCD) 2010–2014 [17] and NSP-NCD 2016–2025 [18] set the basis for food industry engagement as part of efforts to improve population nutrition and health. In response to the NSP-NCD, the Federation of Malaysian Manufacturers (FMM) developed a range of related commitments and also engaged more companies to participate in NCDs prevention and control programmes [19]. Industry commitments included self-regulation approaches such as the Responsible Advertising to Children (Malaysia Pledge), and participating in the Malaysian Healthier Choice Logo programme and sugar reformulation initiative [19‐21]. In addition, the Malaysian government has stated an intention to implement mandatory regulations such as imposing declarations for total sugars and sodium for all food products, restricting television advertising of foods and beverages high in fat, sugar and salt targeting children, and imposing a sugar tax on unhealthy foods and beverages [16]. Therefore, an independent monitoring framework is needed to generate baseline data to enable future comparisons if there is progress in implementing mandatory regulations.

Monitoring private-sector commitments to population nutrition and health [22] is critical to holding the food industry accountable for their role in efforts to improve population health. This initiative would foster evaluating the extent to which the ‘profit-only’ model of the food industry is shifting towards a ‘health viable profit’ model [23], whilst managing conflicts of interest in public-private partnerships [14, 24]. The Access to Nutrition Index (ATNI) [25] evaluates food and non-alcoholic beverage manufacturers’ commitments at a global level to reducing malnutrition and improving infant nutrition [25, 26]. A similar tool, the Business Impact Assessment - Obesity (BIA-Obesity) [27] uses less resource intensive methods to assess companies’ commitments in population nutrition and obesity at the national level. The BIA-Obesity assessment also includes quick service restaurants (QSR) and retailers such as supermarkets and convenience stores, in addition to food and non-alcoholic beverage manufacturers. The BIA-Obesity tool has previously been applied to Australia [28‐30], New Zealand [31], and Canada [32]. It has been recommended that BIA-Obesity country level evaluations be used to monitor and evaluate food industry’s progress towards meeting country specific nutrition policies and health criteria, while at the same time building a central database to enable cross-country comparisons [27, 33].

We conducted the first BIA-Obesity in an Asian country. The study included those food companies with national, regional and global presence and with the largest market shares in Malaysia, for each of the four sectors (food and non-alcoholic beverage manufacturing, QSR and retailer sectors). The study also generated recommendations for industry actions, in line with government’s priorities and international norms.

Six out of 33 companies agreed to participate in the BIA-Obesity assessment process. Twenty-four companies declined to participate, while three did not respond. Some declined companies provided reasons for non-participation such as resource limitations (n = 2), lack of priority as perceived by senior management (n = 3), lack of local staff with relevant skills (e.g. nutritionist) to help with evidence collection (n = 2), tight schedules (n = 3), restriction in the company policy for public disclosure (n = 1), and scepticism regarding the assessment (n = 2).

This was the first BIA-Obesity study to assess the nutrition commitments and disclosure practices of major food companies in Asia. In terms of overall scorings for the 33 companies, less than a quarter scored more than 25% (overall median score = 11.0%). Commitments and disclosures of companies in Malaysia were evaluated across six domains of the BIA-Obesity, providing overall median scores for domains ranging between 0 and 28%. Companies performed the worst for commitments related to product formulation, product accessibility, and promotion practices domains (all < 10%). Commitments were often non-specific to the Malaysian market and vague. Across the domains, lower scores were noted related to self-determination of ‘healthy’ products without external verification (e.g. the products that were deemed sufficiently ‘healthy’ to be marketed to children).

The weak nature of food company commitments and disclosures, as discussed above, has also been encountered in other studies. For instance, Cetthakrikul et al. [44] reported food companies in Thailand lacked sufficient specificity and often did not provide detailed criteria in food marketing to children, nutrition and health claims, and food accessibility. A review of commitments and disclosures of companies in 30 countries [33] also revealed wide variations in country specific policies of transnational chain restaurants regarding improving healthfulness of their menus, as well as time commitments to executing these targets. Lack of disclosures and uncertain application of global commitments within Malaysia were identified as issues for most of the global and regional companies. As explained by the ATNF [26], nutrition activities of such companies as reported in their global reports mainly applied to major markets, which might exclude smaller countries such as Malaysia.

The findings from this assessment performed for Malaysia highlights differences in commitments and disclosure practices of companies between high-income countries and low- and middle-income countries (LMICs). As the assessment criteria of BIA-Obesity were modified to suit the Malaysian context, direct country-comparisons could not be reliably made across the board. However, general patterns could still be observed, revealing lower median scores for Malaysia, compared to Australia [28‐30], New Zealand [31], and Canada [32]. Moreover, companies that were assessed in both Malaysia and Australia/ New Zealand, typically scored lower in Malaysia. In contrast, companies with market presence in both Malaysia and Canada [32] elicited similar scores in both countries. Sacks et al. [45] suggested that variation of policies within a company for different markets may reflect the different country contexts, including different regulatory pressures, and different consumer demand patterns, but the particular drivers of these variations warrant further exploration.

The Global Reporting Initiative (GRI) Standards serve as a guide to companies to practise sustainability reporting to align their corporate position in relation to SDG target 12.6. Publicly listed companies in the Malaysian stock market were more likely than non-listed companies to fulfil GRI as detected by this study, and most of these companies were in line with Malaysia’s NPANM III 2016–2025, the global WHO’s recommendations and/or SDGs. These companies also were participating in Malaysian government-led initiatives such as Healthier Choice Logo, BeSS (Clean, Safe and Healthy), and/or Malaysian Food Composition Database programmes. Additionally, two out of three companies were signatories to the Malaysia Pledge, practised an internal marketing policy with compliance audits, and published CSR activities including a policy to restrict political donations. Such activities complement some indicators included in the Sustainability Reporting Guide (SRG) recommended by the Bursa Malaysia [46], which is adapted from GRI. Thus, sustainability reporting would likely encourage the inclusion of population nutrition and health strategies into the business model as evidenced by GRI or SRG compliant companies. This study highlights the need for the government to consider regulatory changes to integrate recommendations for areas evaluated by BIA-Obesity Malaysia. This could lead to a nationally endorsed sustainability reporting system related to population nutrition for food and non-alcoholic beverage companies. Furthermore, formulating appropriate fiscal policies (e.g. taxation rebates or incentives) would encourage sustainability reporting and increase transparency in businesses.

Transparency is a key element of accountability [47]. This element was central to recommendations made across most BIA-Obesity domains, which emphasised the importance of public disclosures of company commitments and/or regular reporting for population nutrition and health. Participating companies in our study who provided more evidence for the BIA-Obesity assessment were also more likely to make public their policy information and this concurred with findings from similar studies in New Zealand, Australia, and Canada [28, 31, 32]. These may indicate preparedness for evidence compilation and global company policies tuned towards population nutrition and health. They also may have a greater tendency to publicise related commitments because of global pressure for public-private partnerships to tackle obesity and NCDs prevention [44].

The observed low levels of commitment from companies towards population nutrition puts into question the effectiveness of food industry self-regulation in this area. Moreover, we note that a preference for voluntary industry initiatives in the area of nutrition have been identified as a key strategy used by the food industry as part of efforts to influence public policy in their favour [48]. This ‘policy substitution’ strategy is often coupled with other corporate political activities, such as direct lobbying of government and constituency building activities (including public-private partnerships), to weaken or delay public policy responses [49‐51]. In light of well-documented corporate political activities, governments are being urged to implement clear, transparent, and robust guidelines on conflicts of interest and processes to mitigate industry influence on public policy development [23]. Conflict of interest management processes need not completely exclude engagement with industry, particularly as part of policy implementation, but the risks associated with such engagement need to be closely managed. In addition, there is a need for government-led monitoring and evaluation to determine the effectiveness of industry self-regulation on food environment policies.

Varying approaches to nutrition labelling by companies, particularly FOP labelling, were observed in this study. Draper et al. [52] warned that multiple FOP labelling formats in a market would likely limit consumer understanding and lower usage. Relatedly, public health advocates have proposed the application of consistent FOP labelling on all products to improve consumer food choices [53]. Specific to the Healthier Choice Logo programme in Malaysia, its use was viewed as conflicting with stronger FOP labelling implementation [54]. A case in point at the time of this study is the Healthier Choice Logo criteria were limited to selected foods within categories [55] such as cereals which excluded bread but included instant noodles [55] which is viewed as an ultra-processed food [56].

Few sampled companies in this study had committed to the self-regulatory Malaysia Pledge restricting food marketing targeting children. Some concerns regarding the likely population health benefits of the Malaysia Pledge were raised at a WHO bi-regional forum [57], pointing to the lack of reliable systems in place to monitor progress, the small number of signatories, and lack of robust nutrition criteria underpinning the pledge. Most of the assessed companies favoured setting age below 12 years as a cut-off to control unhealthy food promotion to children, whereas the United Nations Committee on the Rights of the Child [58] recommended 18 years old as the target cut-off. All these implied the need to strengthen regulation of unhealthy food marketing following strict criteria as per the recommendation of the Review Panel, which was also echoed in an earlier study that called for stronger government-led actions in Malaysia [59].

In the area of product accessibility, a key recommendation from this study emphasised a need for pricing practices that would make healthier products more affordable to the bottom and middle income household groups in Malaysia through sustained lower prices, with less focus on temporary price promotions. A need was also identified for the food retail and manufacturer sectors to improve the placement of healthier products to facilitate easier identification by consumers. The proposed tax incentives for healthier foods as recommended in the NPANM III 2016–2025 [16] may provide incentives for the food industry to shift to the ‘health viable profit’ model, as mooted by Swinburn et al. [23].

In the context of CSR activities, strong branding or product promotion was observed in Malaysia. Since 2007, CSR has been mandatory for companies listed on the Malaysian stock market, with tax incentives for implementation. However, opinion is that most businesses favoured CSR activities linked to philanthropy, rather than population health [46]. Besides, we found little evidence on the effectiveness of reported CSR targeting population health. Kraak et al. [50] indicated that the major challenge in public-private partnerships is to manage conflicts of interest and only allow healthier products for brand-use activities. Therefore, a stricter recommendation was proposed for healthy lifestyle and nutrition programmes to be free from companies’ products and/or brands.

The BIA-Obesity tool assessed the strength of profiling systems used by companies for the purposes of food formulation, labelling, marketing to children, and accessibility. In this study, WHO nutrient profiling systems [42, 43] were used as the benchmarks for assessing the healthiness of relevant product portfolios of companies. Recommendations generated by the Review Panel for relevant domains also referred to these profiling systems. The WHO systems enable a country model to consider the regulation of taxation, labelling, and guidelines for healthy food provision in public food service settings [14]. Adoption of the WHO systems would ensure a consistent approach to determining nutrient limits for the classification of a ‘healthy’ product across a range of policy domains [26, 60, 61]. For food companies in Malaysia, it will be important to align relevant policies with ‘reputable’ nutrient profiling systems, rather than generating custom-fit profiling to suit an individual company’s product range.

Through the BIA-Obesity Malaysia process, civil society provided critical assessment and valuable recommendations that focussed on public interests without commercial influence. This academic-led assessment of companies provides strong evidence to the government on the lack of progress in relation to existing self-regulatory policy approaches, which should provide some impetus to shift towards mandatory policies. For the food industry, this study provides evidence of the limitations of existing commitments and disclosure practices to improve related to population nutrition and disclosure practices. A first step for companies would be to formulate SMART commitments and to improve public disclosure of such commitments. The results of this study can also be used by civil society advocates to increase uptake of the study’s recommendations.

This study had several methodological strengths. The tool used has been adapted from INFORMAS, which was earlier implemented in Australia [28‐30], New Zealand [31], and Canada [32]. The development process was independent from the food and beverage industry [27]. The tool was modified to suit the local context by taking account of local nutrition policies in the assessment criteria to better reflect a country-specific assessment. The innovation of the process included the appointment of the Expert and Review Panels with balanced representation from the government, NGO and academic backgrounds. A positive characteristic of this study was the test agreement adopting the ‘simple majority rule’ approach which recorded 94.2% agreement between the Expert Panel members. Dissemination of preliminary individual scorecards to companies and holding a closed-door meeting with industry prior to public release of the findings also ensured that the conduct of the study through to the final stages, remained transparent and unbiased.

However, this study had a number of important limitations. Firstly, this study only conducted Phase I of the BIA-Obesity methods, which assessed commitments and disclosures of food companies in relation to population nutrition and health. Although some corporate political activities like corporate philanthropy were assessed to some extent in this study, other practices identified by Mialon et al. [48] such as political lobbying, funding of research and political donations warrant further investigation. A critical evaluation of the healthiness of companies’ product portfolios and the extent of their marketing practices is also recommended as a follow up study. Secondly, the low level of participation by food companies (n = 6/33) limited the extent of data collection which led to dependence on only publicly available information for non-participating companies. To overcome issues associated with low participation rates, market surveys were conducted to validate evidence and increase credibility of information presented for assessment. The level of participation from companies likely reflected these companies’ first-time experience with the BIA-Obesity assessment and it is anticipated that future follow-up assessments may overcome this reservation to engage, as has been the experience of similar initiatives elsewhere [25, 26]. If more food companies participated in the BIA-Obesity process, even with the option of providing information on a confidential basis, this is likely to improve the completeness of the evidence, instead of heavily relying on publicly available information. Moreover, future periodic monitoring via BIA-Obesity may improve food company disclosure practices and thus the accuracy of publicly available information used in the assessment.

This study provided an understanding and critical assessment of the Malaysian food industry’s current commitments to improving population nutrition, along with recommendations for change. The lack of efficacious self-regulation in food reformulation, labelling, and marketing, brand-associated CSR activities, and the lack of a uniform credible nutrition profiling system implies that policy makers need to adopt mandatory regulations as part of efforts to create healthier food environments. Appropriate regulatory changes by the government with non-compliance consequences would foster greater adherence of the food industry to policies prioritising population nutrition and health. Furthermore, this study highlighted the need for greater transparency in food company reporting to strengthen accountability for improving population nutrition.