Evolution of the major alcohol companies key global policy vehicle through the prism of tax records 2011–19

The alcohol industry is a significant player in the global economy. In 2020, the industry was valued at $1.49 trillion (USD) [1]. The size of the alcohol market has significant implications for global health. Alcohol consumption is estimated to contribute causally to about 3.3 million deaths each year [2]. In the past 25 years, producers have expanded so that they produce and promote brands across continents [3, 4]. The top ten producers now account for the majority of worldwide consumption of beer and spirits respectively and have strategically targeted low- and middle-income countries and regions for expansion [4]. The concentrated nature of the market has led to the creation of organisations explicitly tasked with coordinating the political activities of the major alcohol producers [5].

Several theoretical frameworks have been developed to understand the nature of corporate political activities [6], particularly in the context of unhealthy commodity industries (UCIs), including alcohol and tobacco [7‐9]. According to these frameworks, several structural, institutional and ideological conditions provide key opportunities for industry to influence those with decision-making power. Alcohol researchers have identified key strategies that industry uses in pursuit of its political goals. These include lobbying [10‐17], framing [18‐27], litigation [28‐32], and corporate social responsibility (CSR) initiatives [33‐43]. Industry has also funded research studies in an effort to influence the content of scientific research and such evidence is used in policy making [35, 44‐54]. The alcohol industry has long exerted influence over the shaping of ideas related to alcohol, alcohol problems, alcohol policy, and the alcohol industry itself. This influence is aimed at ensuring that these strategies operate in synergy with one another [55].

Little is known, however, about the organisations that lead the alcohol industry’s political activities, particularly at the global level (though, there are recent exceptions, for example [56]). Similar to other industries [57, 58], trade associations are often the key vehicles for coordinating industry actors’ political activities. Trade associations can mobilise different actors from across a single sector (for example, alcohol) or within a specific segment of the sector (for example, production or retail) [59]. Social aspects public relations organisations (SAPROs) are distinct from trade associations in that they are primarily designed to advance the alcohol industry’s CSR goals [34, 38, 42]. These organisations are “outwardly established to reduce alcohol-related harms” [60] but their core function is “to manage issues that may be detrimental to [the alcohol industry’s] interests, particularly in areas that overlap with public health” [61]. While SAPROs share some key similarities with tobacco industry front organisations [37, 62], these organisations are specific to the alcohol industry. The International Alliance for Responsible Drinking (IARD) is the only SAPRO operating globally. Most SAPROs, such as Drinkaware in the UK, are organised at the national level.

There are studies of IARD’s predecessor, the International Center for Alcohol Policies (ICAP) [45, 63‐66]. One key study analysed publically available material produced by ICAP, including policy papers, conference proceedings, and tax filings. According to this investigation, ICAP engaged in several key activities, including lobbying, promoting collaborations between public health researchers and industry, and creating a parallel scientific literature on alcohol. ICAP’s main aim was to challenge the World Health Organization’s (WHO) position as the pre-eminent voice on alcohol policy issues [45]. A range of alcohol industry actors, including ICAP, have also been highly active in alcohol policymaking processes at the domestic and global level [21, 56, 59]. Moreover, only a few jurisdictions have embraced the WHO’s “best buys” policies [67] – that is, tougher restrictions on alcohol pricing, promotion and availability [68] (though, there are key recent developments in several countries, including Scotland, Ireland, and Lithuania) [69‐71]. Yet the precise programs developed by ICAP to influence policy have not been adequately described or analysed.

IARD was formed in 2014 out of a merger of ICAP (which had been created by several alcohol producers in 1995), and the Global Alcohol Producers Group, a trade association [72]. Compared to ICAP, IARD’s actions have hardly been studied at all [21], indicating that little is known about a potential threat to global health.

One persistent challenge in analysing alcohol industry activity, including organisations such as ICAP and IARD, is the paucity of data relating to internal operations [59]. This study aims to deepen understanding of the alcohol industry’s political activities at the global level. Specifically, it seeks to enrich understanding of alcohol industry activity at the global level through careful description and analysis of ICAP and IARD’s tax filings. Analysis of tax records, in the context of other ICAP and IARD data, can help address the deficit in understanding how these organisations have operated, the nature of their relationships with each other, and potentially yield insights into the political organisation of the alcohol industry.

We began with a scoping exercise to identify potential data sources. This included examining IARD’s website and references to IARD on the individual member companies’ (see below) websites for triangulation and analytic purposes. Informed by the earlier work [45], we collected a later set of ICAP and IARD’s Internal Revenue Service (IRS) tax documents between 2011 and 2019. Non-profit organisations in the US are required to submit an IRS Form 990 every year. The disclosure of detailed information, including on key programs and expenditures, provides a key potential data source for understanding the internal operation of US-based SAPROs.

We searched for and collected ICAP and IARD’s tax documents using ProPublica’s Nonprofit Explorer database (https://​projects.​propublica.​org/​nonprofits). ProPublica houses public documents, including federal tax filings, which can shed light on issues pertinent to the public interest. Using the search term “International Alliance for Responsible Drinking”, we retrieved tax filings for both ICAP and IARD from 2011 to 2019. ML reviewed these filings (ICAP, 2011–14 and IARD, 2015–19) and produced annual data summaries.

We used thematic analysis to guide data collection and analysis [73]. ML placed the tax documents into NVivo. To identify main expenditures (i.e., programs) over time, ML inductively generated several thematic codes. The coding approach was informed by previous research on ICAP [45], IARD [43], and alcohol policymaking [59]. Specifically, particular attention was paid to external-facing activities, including lobbying, stakeholder engagement, and research. ML compiled and analysed relevant financial information, including expenditure data. Finally, ML and JM placed these data in the context of what was known about these organisations in other cited data sources.

This study aims to deepen understanding of the alcohol industry’s political activities at the global level. The study enriches understanding of alcohol industry activities through careful description and analysis of ICAP and IARD’s tax filings.

Since 1995 the major alcohol companies have worked together in ICAP, then IARD, to manage their interests at the global level, beginning when the companies themselves became globally operating entities. Through several activities, including CSR, research, and public affairs, these organisations have successfully positioned themselves as a rival source of information on alcohol-related matters to the WHO and the public health community. These activities operate as a package of inter-connected approaches developed over time to attain political goals. This study examines these operations in as much detail as is afforded by the data source. The first contribution made by this report is to open up the internal operations and strategic priorities of these organisations to external scrutiny. Both ICAP and IARD have been prominent in an era of global alcohol policy inertia in which ineffective partnerships with the industry have largely been the norm globally, contrary to the alcohol policy evidence base that stronger industry regulation is needed, particularly population-level alcohol control measures [68]. Yet IARD has evaded substantial prior scrutiny. Existing studies of ICAP have focused on materials, including toolkits, policy reports, and research, which have been tailored for public consumption [45, 99, 100]. Exclusive reliance on such data sources is potentially limiting for understanding the alcohol industry, its strategic drivers, and the nature of the threat posed to global health. Public-facing materials can be crafted in ways designed to obscure organisations’ nature, purpose, and tactics. This study is one of the few studies to make use of materials generated by ICAP/IARD staff that, while in the public domain, have a different quality from other public-facing materials. Non-profit organisations are legally required to ensure that the information provided to authorities is both accurate and verifiable. This study offers a useful vantage point for appreciating the nature of the long-term and multi-pronged public affairs program, in particular, which receives little mention in the public-facing materials.

This analysis also provides a lens through which to observe possible changes to the global alcohol industry’s strategy over time. The findings suggest ICAP’s evolution into IARD has not been accompanied by major shifts in how these organisations present themselves to tax authorities in the US, and by extension in how they operate. The activities appear marked more by continuity than by change, so it is appropriate to regard this study as offering preliminary evidence to support an understanding of IARD as an evolution of essentially the same entity as ICAP. There are, however, identifiable changes in presentation, and we in no way suggest these are trivial. Rather, this makes further study of the more visible and well-documented activities of ICAP helpful for developing the research agenda on IARD. Indeed, the success of IARD in largely evading research scrutiny provides a further reason to fill this important evidence gap and comparative analysis with ICAP is one useful frame for further analysis.

The study underscores the industry’s complex and multi-level approach to lobbying. Both ICAP and IARD tax records describe longstanding efforts to build relationships with WHO. Moreover, IARD’s involvement with public affairs firms that specialise in dealing with WHO, the UK government and EU officials provides further indications of the importance of lobbying at the global, regional and domestic level. IARD’s involvement with a UK Government agency is striking. Further research will be required to identify the nature of those interactions, and the implications for the effectiveness of lobbying in other national and international contexts.

The nature of the tax filings means that there are limitations to how much can be inferred about ICAP and IARD’s activities, whilst offering a novel perspective on the internal functioning of these entities. First, an analysis of ICAP and IARD’s materials helps provide new insights into the goals and activities of these organisations, for example, on public affairs, but by design, it cannot tell us about the effectiveness of efforts. Second, although the tax fillings included key expenditure data, the study’s capacity for quantitative assessment is limited by the nature of the dataset. The IRS implemented several changes to Form 990 during the years in question, making it difficult or unwise to evaluate changes between specific program expenditures year-to-year. As such, we largely restricted analytic attention to the qualitative description of activities and aggregate spending. The result is a potentially incomplete account of program and expenditure changes. Third, the study did not include tax records from 2005–2010, when there was major activity at the global level. In 2010, the WHO released its Global Strategy to Reduce the Harmful Use of Alcohol, following years of consultations with stakeholders, including the alcohol industry [101]. Future research, however, could draw on the tax records that were omitted as well as ICAP submissions to that process. Fourth, the goals of the study were descriptive in nature; the data do not permit us to provide causal explanations for why IARD and ICAP function the way that they do. Addressing questions of this nature would require additional data sources, including interviews with key personnel and/or access to internal documents that are not presently available. Finally, this study does not engage with the scientific content produced by ICAP or IARD. Between 1998 and 2010, ICAP published several research and policy materials, which helped frame key public health debates [45, 99, 102]. While studies analysing the scientific content of ICAP or IARD’s materials are vital, this present study is confined to the organisational units and processes.

In the interest of global health, researchers and policymakers require a deeper understanding of how the alcohol industry operates as a political actor. Industry has long been seen as a legitimate participant in policymaking [9]. There are some indications that change may be afoot in this respect. WHO leaders, for example, have expressed concerns about industry involvement in policymaking [103]. Furthermore, WHO staff have been advised not to engage with the alcohol industry on certain matters [104]. Yet, the alcohol industry’s approach to influencing policymaking is far from restricted to lobbying policymakers. Industry has several other tools at its disposal, including mobilising other interests during policy disputes (i.e. proxies) [105], venue shopping [106‐108], and influencing the scientific content that underpins policy debates [46, 109]. The sophisticated quality of these strategies, and indeed the nature of organisations such as ICAP and IARD, suggests that public health interests need to thoroughly examine the significance of the alcohol industry’s activities, particularly in relation to influencing the public and public policy.