Background
In Australia, as in many countries, unhealthy diets are one of the
main risk factors for disability and deaths [
1]. The food industry, represented by a diverse range of actors, is
recognised as having a major influence on the diet of the population through their
products, their marketing and their efforts to shape, directly or indirectly,
government policies in its favour (referred to as “corporate political activity”,
CPA, defined as “corporate attempts to shape government policy in ways favourable to
the firm” [
2]) [
3,
4].
The CPA of the food industry has previously been categorised into six strategies,
based on well-established classifications of the CPA of the tobacco industry:
information and messaging; financial incentives; constituency building; legal
strategies; policy substitution; opposition fragmentation and destabilisation
[
5] (see Additional file
1 for a description of each strategy). There is
emerging evidence and wide-spread concern in the public health community that the
CPA of the food industry could pose a risk to the development and implementation of
effective policies and programs for non-communicable disease (NCD) prevention and
control [
6‐
10]. This is of particular concern for companies
who sell products that contribute to the NCD epidemic [
4]. The CPA of the food industry is not routinely monitored;
however, some instances of unfavourable food industry influence (from a public
health perspective) have been described in the literature. As an example, in
Australia, a recent report suggested that industry self-regulation (policy
substitution strategy) has failed to protect children from marketing of unhealthy
food products [
11]. In addition, in
2014, it was revealed that close relationships between Australian policy makers,
including a former Assistant Health Minister, and the food industry (constituency
building strategy), led to delays in the implementation of a public education
resource designed to support a new government food labelling initiative
[
12].
In order to protect public health policies and outcomes from vested
interests in the food industry, some public health advocates have called for a
strengthening of accountability mechanisms and for more transparency from the food
industry [
13,
14]. Identifying and monitoring the CPA of major
food industry actors has the potential to contribute to these objectives, and this
paper reports on the implementation of an approach for doing this using
publicly-available information, based on methods used to monitor CPA strategies of
the tobacco industry [
5].
This study examined the feasibility and limitations of implementing
the proposed approach in Australia.
Methods
A systematic approach was implemented in Australia to identify and
monitor the CPA of the food industry, consisting of a document analysis of
publicly-available information, based on methods previously used to monitor the CPA
of the tobacco industry [
5].
Data collection focused on five of the most prominent food industry
actors in the country. The actors were selected based on methods previously
developed for monitoring the policies and practices of the food industry
[
15], with the aim of selecting one
actor from each of the main sectors within the food industry as well as a major
trade association. Euromonitor was used for the identification and selection of
these key food industry actors, based on their market shares in 2013 [
16]. Where the market leader in a particular
sector of the industry did not have an Australian-specific website, the next most
dominant company in that sector was selected. The selected food industry actors
included: the Australian Food and Grocery Council (AFGC) (a major trade
association); Coca Cola (including The Coca Cola Company and Coca Cola Amatil) (a
sweetened beverages company); McDonald’s (a fast-food restaurant); Nestle (a
processed food products company); and Woolworths (a supermarket).
Systematic searches were conducted across various sources of
information [
5]. Food industry materials
included country-specific website and Twitter accounts of the selected industry
actors. Government material included websites of departments and other agencies
responsible for health; websites of the Parliament and Senate; register of
lobbyists; websites of the three major political parties; websites of commissions in
charge of elections; and official requests for information regarding government
interactions with the selected food industry actors. All searches were conducted at
the national level. Additional sources of information included the websites of: ten
major universities with a school/department of nutrition/dietetics/exercise or
physical activity; five major professional bodies working on diet-, public health-
or physical activity-related issues and related annual conferences. The selection of
relevant sources was informed by a pilot study conducted in December 2013, and made
in consultation with public health experts in Australia. Media materials, such as
Google News and media releases from the selected food industry actors, were also
analysed. Details about specific sources of information included in this study are
provided in Additional file
2. Data
collection was performed between September 2014 and February 2015. For annual or
occasional events, such as submissions to public consultations, elections, or
conferences, the study included the most recent data available (up to two years
retrospectively), as detailed in Additional file
2.
A qualitative thematic analysis was performed by MM. GS re-analysed
all data for the selected food industry actors. As themes were not necessarily
mutually exclusive, any differences in coding were resolved by mutual agreement.
Choice of themes was inductive and based on an existing framework for classifying
the CPA of the food industry [
5].
Researchers followed an iterative process, where the framework would be adapted to
include any new practices identified. However, no new practices were observed as
part of this project.
Illustrative examples of CPA strategies used by each food industry
actor are presented here, using the framework as a guiding thread. A critical social
science approach guided the conduct of this research, with the food industry
considered as a potential determinant of health. In this context, the critical
social science approach seeks to critique current social conditions as part of
efforts to improve population health [
17]. Specifically, this research is part of efforts to increase the
transparency and accountability of the food industry.
Results
In total, 310 pieces of information were collected. All references
and data collected are included in Additional file
3 (S3), with each piece of information allocated a unique code
(starting with the letter A). Table
1
presents a summary of all practices and strategies identified during the period of
data collection in Australia.
Table 1
Summary of CPA practices identified in Australia
Information and messaging | Lobbying | 0 | 1 | 1 | 1 | 1 | 4 | 148 |
Stress the economic importance of the industry | 4 | 1 | 1 | 1 | 2 | 9 |
Promote de-regulation | 5 | 0 | 0 | 2 | 1 | 8 |
Frame the debate on diet- and public health-related
issues | 12 | 19 | 4 | 13 | 3 | 51 |
Shape the evidence base on diet and public health-related
issues | 14 | 9 | 2 | 51 | 0 | 76 |
Financial incentives | Financial incentives | 2 | 5 | 0 | 0 | 5 | 12 | 12 |
Constituency building | Establish relationships with key opinion leaders and health
organisations | 0 | 1 | 0 | 9 | 3 | 13 | 127 |
Seek involvement in the community | 2 | 46 | 26 | 10 | 12 | 96 |
Establish relationships with policymakers | 11 | 0 | 1 | 3 | 3 | 18 |
Establish relationships with the media | 0 | 0 | 0 | 0 | 0 | 0 |
Legal strategies | Use legal action (or the threat of) against public policies or
opponents | 0 | 0 | 0 | 0 | 0 | 0 | 1 |
Influence the development of trade and investment
agreements | 1 | 0 | 0 | 0 | 0 | 1 |
Policy substitution | Policy substitution | 6 | 1 | 3 | 10 | 2 | 22 | 22 |
Opposition fragmentation and destabilisation | Opposition fragmentation and destabilisation | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
Total number of CPA practices identified | 57 | 83 | 38 | 100 | 31 | 310 | 310 |
Five of the six CPA strategies were identified through
publicly-available information: information and messaging; financial incentives;
constituency building; legal strategies; and policy substitution. The constituency
fragmentation and destabilisation strategy was not identified in the study.
Data related to the AFGC and Nestle were predominantly related to the
information strategy; whereas for Coca Cola, McDonald’s and Woolworths, it mainly
related to the constituency building strategy.
The most frequently observed strategy during data collection was
the ‘information and messaging’ strategy. This strategy mainly consists of sharing
information and framing messages that depict the industry in a positive
way.
As part of the information and messaging strategy, evidence was
found that all five food industry actors highlighted their economic importance in
efforts to convey a positive image for their industry (A21-4, A110, A168, A202,
A302-3). For example, in 2012, in its response to a consultation on nutrition,
health and related claims, the AFGC noted that it “makes a substantial
contribution to the Australian economy and is vital to the nation’s future
prosperity” (A21). There was evidence that the AFGC, Nestle and Woolworths
promoted deregulation when discussing diet- or public health-related issues
(A16-20, A200-1, A308). They used different arguments against proposed regulation
of claims, such that it would discourage innovation (A18, A308); that it would be
costly to the industry (the AFGC suggested that it would “cost millions of
dollars” (A16)) and be resource intensive (A201); and that it would undermine the
competitiveness of businesses (A19, A201). Apart from this consultation, the AFGC
also suggested that “regulation should be imposed only where necessary to correct
market failure and that it should be sufficiently flexible to encourage
innovation” (A18).
Data illustrated that all five food industry actors framed the
debate on diet- and public health-related issues in ways that: shift the blame
away from the food industry in the NCDs epidemic (the food industry actors rather
focused on personal responsibility and on the lack of physical activity); promote
the good intentions and stress the good traits of the food industry (for example,
the fact that the food industry ensures food safety); emphasise the food
industry’s actions to address public health-related issues (including the fact
that the food industry promotes healthier lifestyles; stress that the food
industry is an important part of the solution, is an expert on diet- and public
health- related issues, and provides healthy/healthier versions of its products)
(Table
2). The AFGC, Coca Cola and
Nestle were found to use this practice most actively of the selected food industry
actors.
Table 2
Mechanisms and arguments used by the sample of food industry
actors to frame the debate on diet- and public health-related issues in
Australia
Shift the blame away from the food industry | Personal responsibility – people need to have a balanced
diet and there are no bad food products, only bad diets | “[There is a] well established paradigm that an individual’s
good health is dependent upon a balanced diet” (A26) | “Coke can be consumed as part of a sensible, balanced diet”
(A113) | “[When kids eat a] mix of foods – (…) does it balance out
with (…) energy requirements?” (A175) | “The basic principle in nutrition [is] that there are no
‘good’ and ‘bad’ foods but rather ‘good’ and ‘bad’ diets”
(A203) | “The importance of a balanced diet” (A304) |
Personal responsibility – people need to be more active and
balance kilojoules in and out (focus on obesity rather than
NCDs) | “The health risks associated with obesity are largely
controlled if a person is physically active and physically fit”
(A29) | “We know that you’ve got to balance kilojoules in with
kilojoules out” (A111) | “If your school or club (…) requires equipment, uniforms or
something else that encourages participation in sport, we are happy to
help” (A171) | The Nestle Healthy Kids Program contains a lot of
information on physical activity (A205) | Not identified |
Promote the good intentions and stress the good traits of
the food industry | Industry provides safe products | “AFGC advocates a positive role for the food, beverage and
grocery industry in providing safe products to consumers”
(A32) | Not identified | “Providing customers with safe food is our first priority
and our most critical responsibility” (A172) | “As an industry, we’re showing we’re credible partners,
going beyond using our scientific knowhow to put micronutrients safely
in a product and ensure they’re preserved until the end of its shelf
life” (A194) | Not identified |
Emphasise the food industry’s actions to address public
health-related issues | Industry promotes healthy lifestyles | “The food industry [is] already actioning plan to (…)
encourage healthy lifestyle choices” (A35) | Not identified | “Mac Pack: a sporting movement for kids promoting healthy
living through fun and play” (A169) | “The Nestle Good Life Program is a group of community
initiatives (…) promoting active lifestyles” (A206) | Not identified |
Industry is part of the solution | “Obesity and overweight is a major issue globally. (…) AFGC
and the entire food and grocery manufacturing industry are committed
to being part of the solution to this critical issue” (A
32) | “We just want to be part of the solution”
(A111) | Not identified | “We believe that we have a shared responsibility”
(A207) | “We have an important role to play in promoting balanced and
healthy eating habits that support a healthy lifestyle”
(A304) |
Industry is an expert in diet- and public health-related
issues | Not identified | Not identified | Not identified | “To have the greatest possible impact [with our Nestle Good
Life Program], we focus on areas where we believe we can add the most
value: food, nutrition, and health and wellness. These are areas where
we can best contribute our expertise, scientific insight and decades
of experience” (A206) | Not identified |
Industry provides healthy/healthier versions of its
products | “To help people achieve this balance, industry provides a
range of nutritious products, in a variety of portion sizes with
low-joule, low-fat, low-sugar and low-salt foods available”
(A32) | “We continue to make positive changes. Here’s just a taste
of what we’ve achieved. 1. Increasing the availability of our smaller portion
sizes. 2. Offering more low kilojoule options” (A115) | Not identified | Not identified | “We have already made significant steps to promote healthy
diets to Australian shoppers” (A304) |
Personal responsibility – Industry provides
information | “We aim to empower people and communities to make informed
choices to improve the health of their families” (A31) | “More information equals more informed consumers, and we
believe informed consumers are the ones that make the best decisions
for themselves and their families” (A121) | “Happy Meal Choices menu (…) enables parents and children to
select meal components to suit individual tastes and dietary
requirements” (A170, A178) | “Nestle aims to help parents and children make healthier
choices, running cookery schools and educational programmes around the
world” (A213) | “We strongly believe our customers should have access to a
full suite of nutritional information to enable them to make informed
decisions when selecting groceries” (A306) |
The data showed that four of the five food industry actors shaped
the evidence base on diet- and public health-related issues so that it would
favour the industry, as illustrated in Table
3. Publicly-available information revealed that the AFGC and
Nestle have been funding their own research, and have been actively promoting it
to the public. For example, the AFGC retweeted a message saying that “regularly
eating #cereal4brekkie is assoc. w lower BMI & lower risk of being overweight
or obese in adults & kids” (A46). The study mentioned was funded by the AFGC
itself, through a third party, the Australian Breakfast Cereal Manufacturers Forum
(#cereal4brekkie). The AFGC, Coca Cola and Nestle also promoted research that was
funded by the food industry (directly or indirectly, through third parties) or
where authors had ties with the industry, as well as non-peer reviewed or
unpublished evidence (such as information extracted from poster presentations from
conferences) (A40, A42, A44, A46, A135, A231, A234-8, A249, A256-9, A261, A268).
For example, in its response to a public consultation on the draft for the
Australian Dietary Guidelines and for the Australian Guide to Healthy Eating, the
AFGC referred to research that had ties with Dairy Australia, the Australian
Beverages Council, Coca Cola or Meat and Livestock Australia (A39). All food
industry actors, except Woolworths, were found to have sponsored or presented
their work in major scientific events or conferences on diet- or public health-
related issues. For example, Coca Cola sponsored a session on weight loss
maintenance during the 2014 Nutrition Society of Australia Annual Scientific
Meeting (A133). The AFGC, McDonald’s and Nestle provided education materials to
schools, parents and the public more generally (A49, A158, A160, A175, A206, A210,
A224, A227, A229-30, A233-8). Nestle, on its “Nestle Healthy Active Kids” website,
provided detailed information on physical activity (A204, A225), while its
“Healthy Active Kids Booklet” contained recipes promoting the company’s products
(A224). Nestle also organised events in supermarkets during school holidays in
which people could receive advice from dietitians, as well as free diabetes
testing performed by the Australian Diabetes Council (A228). They could also
“learn how Nestlé products are the ideal partners to help you invite more fresh
food into your diet” (A228).
Table 3
Mechanisms used by the sample of food industry actors to shape
the evidence base on diet- and public health- related issues in
Australia
Fund research, including through academics, ghost writers,
own research institutions and front groups | Promotion (industry website, Twitter, etc.) of research from
a front group: “This review was commissioned and paid for by the
Australian Breakfast Cereal Manufacturers Forum of the Australian Food
and Grocery Council.” (A40) | Not identified | Not identified | “[The] Nestle Research Center (NRC) (…) 250 scientists
publish some 200 peer-reviewed scientific publications each year
across areas including nutrition and health, public nutrition and food
consumer interaction.”(A257) | Not identified |
Pay scientists as advisers, consultants or
spokespersons | Not identified | “Coca-Cola Australia has an advisory council of experts in
the area of obesity, public health and nutrition, who provide advice
and counsel to the Company” (A139) | Not identified | Not identified | Not identified |
Cite research that has been funded (directly or indirectly,
through third parties) by the industry | AFGC submission to the draft Australian Dietary Guidelines
and Australian Guide to Healthy Eating: references research funded by
the food industry (or with authors that have declared interests with
the food industry): Dairy Australia, Australian Beverages Council,
Coca Cola, Meat and Livestock Australia. (A39) | “While they contribute minimal kilojoules to the diet,
people question the role of diet soft drinks when managing their
weight. […] A new study funded by the American Beverage Association and
published in the journal Obesity may just have provided evidence to
suggest otherwise.” (A134) | Not identified | “[A] recent study carried out by Zurich’s ETH University and
Nestle (…) showed that serving school-age children a greater variety
of vegetables increased the quantity they chose to consume.”
(A257) | Not identified |
Disseminate and use non-peer reviewed or unpublished
evidence | Not identified | 'Infographics on sweeteners on industry websites contain
evidence that has not been peer reviewed (e.g., Calorie Control
Council) (A135) | Not identified | Nestle Australia Response to Australian Dietary Guidelines -
Incorporating the Australian Guide to Healthy Eating - Draft for
Public Consultation (2012) includes information drawn from a poster
presentation (A215, A268) | Not identified |
Participate in and host scientific events | Dietitians Association of Australia 31st National Conference
- Sponsored Breakfast Seminars: Healthier Australia Commitment
(A38) | 2014 Nutrition Society of Australia Annual Scientific
Meeting - session sponsored by Coca Cola - “Do small changes make a
big difference? Insights into weight loss maintenance research.” –
Presented by: Professor James Hill, Denver University, USA
(A133) | Dietitians Association of Australia 31st National Conference
- Exhibitors: McDonald’s Australia | Dietitians Association of Australia 31st National Conference
- Sponsored Breakfast Seminars: Nestle Corporate: “Unlocking the facts
on kid’s snack habits” (A217) | Not identified |
Provide industry-sponsored education materials | “Details of planned activities for the Dietary Guidelines
Work Program - Communication and Implementation Plan 2012: AFGC (…)
indicated that they will have some of their own educations initiatives
developed by May 2012” (A49) | Not identified | McDonald’s junior development basketball programs in
partnership with Basketball Victoria: School resources - lessons plan
(A175) | Nestle Healthy Active Kids “with resources for teachers […]. As part of the program
[Nestle] distributed 80,000 Kids Nutrition Plates, 50,000 Healthy
Active Kids booklets and as a result was able to reach 5,000 teachers
and 250,000 school children.” (A224) | Not identified |
The only evidence that the selected sample of food industry actors
were formally lobbying policy makers was contained in the Australian public
Register of Lobbyists. All companies, except the AFGC, were registered as clients
of lobbying businesses (A130, A173, A216, A307). However, the nature of the
register did not allow any examination of the extent, timing or nature of lobbying
activities.
Financial incentives strategy
The financial incentives strategy, through which the industry
provide funds (and other incentives) to policy makers, was identified in Australia
through the companies’ annual reports, the annual returns of political parties,
the Register of Members of the Parliament’s Interests and Freedom of Information
logs. These documents revealed that the AFGC, Coca Cola and Woolworths regularly
donated funds to Australian political parties (A14-5, A105-9, A297-301). Coca
Cola, for example, donated AUD 55,000 to the Australian Labour Party and to the
Liberal Party of Australia for the financial year 2013-14 (A108-9). Woolworths’
political contributions exceeded AUD 35,000 in 2014 (A297).
Constituency building strategy
There was evidence that all food industry actors included in the
sample have established relationships with various health organisations, community
groups, and policy makers.
Publicly-available information showed that Coca Cola, Nestle and
Woolworths have established relationships with health organisations. Partners
included the Sports Dietitians of Australia (A104); the Dietitians Association of
Australia (A188-9, A195); the Heart Foundation (A192); the Glycemic Index
Foundation (A188, A191, A196); and Nutrition Australia (A292-3).
The food industry actors also sought involvement in the community,
and examples identified in Australia during data collection are presented in
Table
4. Coca Cola developed an
initiative to promote physical activity for kids, called “The Happiness Cycle”, in
partnership with an Australian charity (A111). This could also be classified as a
“framing” practice, since Coca Cola affirmed that the initiative was part of a
program to “help curb obesity” and that the company wanted “to be part of the
solution” (A111). In October 2014, McDonald’s promoted its annual “Mc Happy Day”,
during which AUD 2 were donated to its charity (Ronald McDonald House) for every
purchase of a specific burger (A141). McDonald’s also supported a number of
physical activity initiatives, and there was evidence that some of these
initiatives helped the industry to promote its brand. For example, children wear
red and yellow equipment with the McDonald’s logo and played with the Ronald
McDonald mascot as part of the Mac Pack Basketball Super Clinic (A144) and the
Swimming Queensland partnership (A149).
Table 4
Community initiatives supported by the sample of food industry
actors in Australia
Physical activity | Under 18s | Not identified | 1.Sport Camps Australia (A59) 2.Get Involved (Australian Paralympic Committee)
(A74) 3.Happiness Cycle (A111) 4.University of South Australia (SA)’s Football United
Program (A103) | 1.Macca’s Grassroots Western Australia (WA)
(A143) 2.Mac Pack Basketball Super Clinic (A144) 3.Little Athletics WA (A148) 4.Macca’s Cup – Under 18s SA National Football League
competition (A150) | 1.Cricket Australia (A179) 2.Swim Kids Operation 10,000 (A181) | Not identified |
All ages | Not identified | 1.Ride2Work Day (A76) | 1.Swimming Queensland (A149) | Not identified | 1.Tennis Australia (A289) |
Other health- related initiatives | Under 18s | Not identified | 1.Youth Focus (A61) 2.Ronald McDonald House Charities (A80) | 1.Ronald McDonald House Charities (RMHC) (A141) | 1.School Canteen Association (A186) | 1.Countdown Kids Hospital Appeal (A280) 2.Variety, the children’s charity, New South Wales (NSW) and
Australian Capital Territory (A280) 3.Children’s Hospital Foundation, Queensland
(A280) 4.Royal Children’s Hospital Foundation, Victoria and
Tasmania (A280) |
All ages | Not identified | 1.Red project (HIV) (A73) | 1.Association for the Blind of WA (A151) 2.Lifeline WA (A157) 3.Telethon, WA (A152) 4.Cystic Fibrosis fundraising event “Great Strides”
(A156) | Not identified | 1.Avner Nahmani Pancreatic Cancer Foundation
(A280) 2.Royal Flying Doctor Service, SA and Northern Territory
(A280) 3.Telethon, WA and Queensland (A280, A285) 4.Bundaberg Health Services Foundation (A290) |
Education | Under 18s | Not identified | 1.Top Blokes Foundation (A65) 2.Wirrpanda Foundation (A66) 3.AIME (A77) 4.Street University (A70) 5.Galilee School (A75) 6.Australian Indigenous Mentoring Experience
(A83) 7.Stacy’s New School (A90) | Not identified | Not identified | 1.Earn & Learn (A280) |
All ages | Not identified | 1.Mum’s School (A64) 2.Enactus program (A78) 3.Charitable Foundation for Books (A67) | 1.The Charlie Bell Scholarship for Future Leaders
(A147) | Not identified | Not identified |
Other | All ages | 1.Foodbank Australia (hunger relief) (A9) 2.Arnott’s Foundation Gala Ball & Charity Auction
(A2) | 1.Red Shield Appeal, Salvation Army (poverty relief)
(A58) 2.Mission Australia (poverty relief) (A79) 3.Keep Australia Beautiful (environment) (A60) 4.Landcare Australia (environment) (A88) 5.Bushfires in Victoria (natural disaster)
(A88) 6.Cana Farm, NSW (social) (A63) 7.Brotherhood of St. Laurence African Australian Community
Centre, Victoria (social) (A68) 8.Graffiti artists (art) (A62) 9.Beacon Foundation (youths) (A83) 10.Clontard Foundation (youths) (A83) 11.Jack’s House program (youths) (A72) 12.Marist Youth Care Centre, Victoria (youths) (A69,
A98) 13.Fitted for Work (employment) (A86, A99) | 1.Salvation Army Youth Camp, WA (poverty relief)
(A153) 2.McDonald’s Community Cinemas (social) (A145) 3.Earth Hour, WA (environment) (A155) 4.Clean up Australia, WA (environment) (A154) | 1.Foodbank Australia (hunger relief) (A182,
A184) 2.World Wild Fund Pakistan (environment) (A183) 3.Cyclone Marcia, Queensland (natural disaster)
(A184) 4.Nestle Golden Chef’s Hat Award (cooking)
(A180) 5.Tamworth Local Aboriginal Land Council (aboriginals)
(A185) | 1.Foodbank Australia (hunger relief) (A281) 2.Salvation Army (poverty relief) (A280-1) 3.Love Food Hate Waste, NSW (environment)
(A279) 4.Bushfires and drought (natural disaster)
(A280) 5.Fundraising BBQs (social) (A282) |
There was evidence that all food industry actors, except Coca Cola,
developed relationships with policy makers in Australia. The “Australian Food and
Health Dialogue” is an example of a public-private initiative in which food
industry actors have the opportunity to interact with government officials (A5-6,
A140, A167, A176, A274, A294-5). In parallel, in October 2014, a Senator and two
Members of Parliament participated in the “AFGC Annual Industry Leaders Forum”,
held in Parliament House in Canberra (A9). Discussions included topics such as
“industry engagement in the political process”. Another forum was planned for
October 2015, with the aim to “engage with senior Federal Ministers to better
understand government policy direction and how business and government can work in
partnership” and to “promote the interests of [the food] industry in the
development of policy [and] to showcase the Australian food, beverage and grocery
industry to high level stakeholders” (A11). Policy makers themselves also
proactively engaged with the food industry in Australia. The then Prime Minister,
Tony Abbott, in his speech during the 2014 AFGC Annual Industry Leaders Forum,
declared ““I (…) promised that we would cut red tape – and that indeed is
happening” (A13). Some Members of Parliament also declared shareholdings in Coca
Cola and Woolworths.
Legal strategies
This study did not find evidence that the selected food companies
used legal strategies in this area, through challenging public policies or its
opponents in court. However, there was an indication that the food industry
attempts to influence the development of trade and investments agreements. For
example, on the AFGC’s website, one of the media releases revealed that “the AFGC
has, and continues to, engage on the range of trade negotiations underway calling
for improved outcomes on processed and semi-processed agri-food products.”
(A51).
Policy substitution strategy
During data collection, all food industry actors were found to use
the policy substitution strategy, which consists of proposing voluntary
initiatives and self-regulation as part of efforts to avoid the introduction of
mandatory regulation. The “Food and Health Dialogue” (A5-6, A140, A167, A176,
A274, A294-5), the “Responsible Children’s Marketing Initiative” (A54) and the
“Quick Service Restaurant Initiative for Responsible Advertising and Marketing to
Children” (A54, A176-7) are examples of voluntary initiatives involving the food
industry. The AFGC also welcomed the fact that the “Health Star Rating System” for
food products labelling was proposed as a “voluntary scheme with an extended, five
year, implementation period, [that could] coexist with the industry supported
Daily Intake Guide and other existing front of pack labelling schemes” (A56). The
AFGC, McDonald’s and Nestle promoted their efforts to reduce the amount of salt,
sugar or fat in their food products (which could also be considered as a “framing”
practice) (A178, A269, A271-2, A276-7, A310).
Opposition fragmentation and destabilisation strategy
In Australia, the opposition destabilisation and fragmentation
strategy was not observed during data collection.
Discussion
This study found evidence that major Australian food industry actors
engage in diverse and extensive practices which can have an influence on public
health policies and programs. The evidence, identified from publicly-available
information only, related mostly to the ‘information and messaging’ and
‘constituency building’ CPA strategies.
This study revealed that different actors employed different
practices during the data collection period. The AFGC and Nestle made extensive use
of the ‘information and messaging strategy’, particularly by framing the debate and
shaping the evidence base on diet- and public health-related NCDs. In contrast,
Coca-Cola, McDonald’s and Woolworths focused more on their involvement in the
community. It is not clear whether these observed differences are ‘accidental’ or if
they reflect fundamental differences between these companies and the environments in
which they operate. While differences in management philosophies, competitive
pressures in the different sub-sectors of the food industry, and public perceptions
are likely to influence the activities of each food industry actor, the reasons that
they adopt particular strategies warrant detailed investigation.
This study is, to the authors’ knowledge, the first attempt to use a
systematic approach to identify and monitor CPA strategies of the food industry in
Australia and other high-income countries (HICs). The study was able to identify a
seemingly large and diverse number of activities that can be classified as CPA. It
can be expected that this systematic approach could be similarly employed in other
countries with similar political systems to monitor food industry CPA in those
countries.
Most of the strategies and practices identified by this study were
similar to strategies previously identified as being used by the food industry in
other countries [
6‐
9]. The findings also reflect strategies used by
actors in other industries, such as the alcohol and tobacco industries [
4,
18‐
20].
This study has a number of limitations.
Most notably, the study only collected publicly-available
information. Due to the nature of CPA, publicly-available information is likely to
give an incomplete picture of the full range of practices adopted by the food
industry. Lobbying of policy makers, for example through personal connections, gifts
and other private interactions are not readily documented in the public domain.
Interviews with key stakeholders in the food system and/or a focus on specific case
studies, such as specific public health policies or specific periods of time, could
help identifying CPA in a more comprehensive way. Additional sources of information,
such as social media platforms, crowdsourcing of information, or whistle-blowers
forums, could also be added. Moreover, the timing of data collection may have had an
impact on the information identified by this study. The data provides only a
snapshot of activities employed, but does not provide an indication of how these
activities vary over time. It could be expected that food companies adopt different
strategies according to different political climates. For example, the ‘policy
substitution’ strategy may be more likely to be employed when major public health-
or diet-related policies are proposed or developed in a given country, and the
‘financial incentives’ strategy may be more prevalent in the lead up to an election.
Longer periods of monitoring over multiple time periods, supplemented by specific
detailed case studies, are likely to improve our understanding of CPA strategies
employed by food companies over time.
Future investigations could focus on a broader range and a larger
sample of food companies, or could focus on the international practices of the food
industry actors selected for this study, using their global websites. The activities
of third parties that have direct financial or legal associations with the five food
industry actors included in this study were not monitored per se, although a list of
‘front groups’ that have direct ties to the industry were identified during the
study (Additional file
4) and their
activities monitored to some extent. Other third parties, such as public relations
firms paid by food companies and that might lobby politicians on behalf of the
company, for example, were not included in this study.
There are also a number of limitations with the data sources used.
For example, in Australia, declarations of donations to political parties only
include amounts “above the disclosure threshold for the financial year ($12,400 for
2013-14)” [
21]. Moreover, the
Australian Register of Lobbyists only includes names of lobbyists and of their
employers, but, unlike the lobby register in the United States, it does not provide
additional details [
22], such as the
number of meetings between lobbyists and politicians, the amount spent on lobbying
activities, or the nature of issues being lobbied. For these sources of information,
more detailed reporting would improve transparency and enable more informed
monitoring. While Freedom of Information (FOI) requests are recommended to be used
as part of the methods for systematic identification and monitoring of CPA
strategies [
5], in Australia, the use of
FOI requests to obtain information about government interactions with industry
stakeholders only revealed very limited relevant information. This is likely to have
been due to the requested information being considered by government officials as
commercially sensitive and, therefore, to be redacted in documents obtained through
FOI requests.
For other sources of information, such as industry websites, a large
amount of relevant data was available, and time constraints forced the researchers
to collect only illustrative examples for each practice and for each actor. There
is, therefore, scope for conducting detailed case studies for specific industry
actor, specific food products, or specific diet- or public health-related issues,
which could complement the proposed systematic identification and monitoring of the
CPA of the food industry.
Importantly, the information identified in this study only indicates
that the food industry actors have employed the practices identified. The study is
not able to assess the intentions behind the use of these practices. Indeed, it is
common in the business literature to discuss these activities using terms such as
‘corporate social responsibility’, ‘shared value’, partnerships, and public
relations [
23‐
25]. In conducting our analysis, our focus is on
the potential risk to public health from these activities.
The study is not able to indicate the influence of the identified
practices on the community, on public health advocates and researchers, on policy
makers, and, ultimately, on the policy process. The specific details of the way in
which different industry practices have an influence needs to be the subject of
further investigations. For example, researchers could investigate the way in which
Coca-Cola’s involvement in the community affects policy makers’ positions on
specific policy issues, such as restricting marketing to children.
This research contributes to INFORMAS (International Network for Food
and Obesity/NCD Research, Monitoring and Action Support) – an initiative that aims
to monitor and benchmark public and private sector actions to create healthy food
environments and reduce obesity and NCDs [
26]. Data collected as part of this study adds to the growing
literature on corporations and public health [
3,
4,
18,
27‐
32], supplements
projects that monitor the CPA of other industries in relation to public health
[
27,
33‐
35] and can inform
public health advocates and policy makers about the practices employed by food
industry actors. Increased awareness of the potential risks to public health from
these practices can lead to measures to increase transparency in this area (for
example, better disclosure of financial contributions to political parties) or to
limit industry involvement in policy development processes. This type of research
could also contribute to existing efforts to monitor corporate behaviour, such as
the work undertaken by the Center for Responsive Politics, Corporate Accountability
International and Corporate Europe Observatory [
36‐
39]. While the
implementation of this monitoring approach is relatively low cost, close links with
established civil society organisations would improve the sustainability of ongoing
monitoring.
Competing interests
This work was supported by the Australian National Health and Medical
Research Council (NHMRC) under grant number APP1041020. The NHMRC had no role in the
design, analysis or writing of this article. Dr Gary Sacks is the recipient of an
Australian Research Council Discovery Early Career Researcher Award (project number
DE160100307). The author(s) declare that they have no competing
interests.
Authors’ contributions
MM led the study conception and design, data acquisition, analysis and
writing of the manuscript. SA and BS contributed to the study conception and design
and critically reviewed the draft manuscript. GS contributed to the study conception
and design, data analysis and critically reviewed the manuscript. All authors read
and approved the final manuscript.