GAPA Virtual Event 2021

Globally, while the gap between industry “words” and “deeds” has become more obvious, the COVID pandemic has provided an opportunity for the industry to counteract denormalization processes by expanding their role in global health and development. Development of renewable energy in post COVID economic development was being funded and supported by the alcohol industry in Africa and Eastern Europe.

The COVID pandemic had brought new circumstances but the same industry policy objectives were obvious: the industry argued for easing of lockdowns, and reducing restrictions on sale. Online sales increased markedly and the TNACs supported ‘small businesses’, that is, bars. The industry argued against excise taxes on the basis of the pandemic, asking for drops or arguing against an increase and in the US a decrease in tax has been made permanent.

Public relations and marketing were closely aligned with life in a pandemic with very active use of digital media during COVID restrictions. The role of influencers in social media included persuasion against COVID pandemic protections restricting alcohol availability in South Africa and a Buddhist monk in Brazil promoting the public relations theme of self-responsibility on behalf of a beer company.

“We have seen government receive support from the industry for COVID19. These are the incentives that make governments blind to the harm, besides them being shareholders of the proceeds.”

“What happened in the Phillippines under COVID is exactly what happened in South Africa!”

“Tax breaks are subsidising the Beer / Beverage Industry to the point we are actually paying public money into their coffers, let alone foregoing taxation for public service delivery …!”

Self-responsibility as an industry public relations theme was mentioned frequently, as has been reported in the research literature.

Industry’s role in relation to the sustainable development goals (SDGs) was a commonly reported focus of their public relations communications and beer brands have been recognised for their reduction in CO2 emissions and recycling. While sustainability improvements in alcohol production and distribution are positive, their public relations value to enhance credibility in the policy environment was recognised as a concern.

Another key public relations framing was the industry’s contribution to economic strength including taxation and employment. This was something participants felt we need more capacity to respond to.

Vested interests go beyond the producers of alcohol products and include the big retailers, marketing entities including the digital platforms and investors

While participants described their experiences of industry public relations the main focus of the day was on the way we respond to this activity.

“This alcohol industry meme of “Responsible drinking” sounds good, but is WRONG. We must fight it. Their message isn’t really responsible drinking. Their message is DRINK. We have to fight that”

“I wonder do we also need to pay attention to the investment world. 3G Capital, major money managers – who own significant shares in alcohol, food and tobacco. Even more economic power!”

“I think there is an increasing shift to piggy back on stronger attention to ESG (Environmental, Social, and Governance) priorities of investors – need to increasingly frame promoting health within this context.”

Setting five year priorities can be informed by what changes might be most painful for the industry While taxation is valuable in reducing consumption, restrictions on marketing are able to denormalise alcohol products.

Do not underestimate our power if we work collaboratively.

The need for a global response and a call for a WHO framework convention similar to the FCTC was common. WHO’s response to the global south was key and inclusion of the equivalent of Article 5.3 of the FCTC (which requires governments to protect policy from industry interference) is crucial.

WHO’s use of the frame ‘harmful use of alcohol’ was critiqued.

The Treaty on Business and Human Rights was seen as a potential avenue but is not moving in this direction currently. UN and global organisations such as the World Bank are part of the solution and there needs to be a complete prohibition on subsidies for alcohol industries.
There is value in developing regional plans and working with WHO regional offices and other regional organisations such as ASEAN.

“Are there discussions happening around establishing a similar treaty for alcohol? Feels very much needed.”

“WHO language ” Harmful use of alcohol” confuse general public. “Harmful use of alcohol” must be changed.”

“If we all agree that there is no harmless use of alcohol, we should all influence the WHO not to use the word ‘harmful use of alcohol ‘.”

“NGOs have been quite emphatic before about the need to use “reduce consumption” rather than harmful use, but it is still alive and kicking. Real change in the wording of goals is very important. This wording is included in the Lithuanian alcohol control law.”

“The WHO regional offices as well as other regional bodies are well placed to also put some of the global policies in context and encourage action at national and local levels”.

“And also working with PAHO. …people in Latin América trust a lot what comes from you. So, you are the strongest bond for alcohol advocacy strategies”

“With the key role the Caribbean region plays in the NCD agenda, better take up of alcohol policy would be very helpful in intergovernmental processes”

At the national level it is important not to get waylaid on national alcohol plans which can take a lot of energy and often reflect ineffective measures. It is necessary to keep a focus on legislation. To achieve this there is a need for consistent focus on the best buys and explanation as to why an individual focus is not enough. Legislation can also be used to curtail the public relations activities of the industry.

Key elements of our advocacy include a focus on the economic benefits of less alcohol, using the approach of investment cases which have been useful in tobacco control advocacy.

Critiquing and opposing specific examples of industry penetration into policy making spaces is crucial, and successful examples such as the response of Addiction France to wine lobbying in the agricultural sector were described.

Is it possible to use legal challenges ?

There is a need to respond to people’s concern that advocacy for effective policy is an attack on their own personal drinking and instead to keep a focus on denormalising the alcohol industry, with a major focus on the transnational producers.

Alcohol use by advocates was seen as problematic by some and not so by others .

“Is there an opportunity for the use of litigation re. the alcohol industry harms, especially using the argument of rights? We see successful cases re. the fossil fuel industry, where governments are having to pay attention to their duty of care to its citizens when considering fossil fuel projects.”

“We have seen success of litigation in tobacco control so surely should be applied to alcohol control too”

“Human Rights is a very much underutilised component of FASD Prevention and redress action”

“How can we fight against the alcohol industry while enjoying their harmful products?”

“Gatekeeping advocates’ personal actions plays into industry framing of personal responsibility, rather than structural policy framing. (I’m abstinent 20years+)”

Pricing policy to reduce affordability is strong alcohol policy. The research literature on pricing has expanded in relation to reducing affordability via excise tax (evaluated as the strongest approach), minimum unit pricing (MUP), bans on selling alcohol below cost, and restrictions on promotion through discounting. Excise tax is an effective way to reduce demand and also a form of ‘polluter pays’ .

“We must use the term HEALTH tax. We must get the media and politicians to stop talking about “sin” tax. We must (one voice policy) also constantly talk about Health tax.”

“Alcohol taxation is thus an appropriate and powerful tool for governments to use to tackle alcohol harm, to achieve the SDGs and to re-balance health inequalities.”

Interventions to reduce accessibility include prohibition, government monopolies on alcohol sales, number and density of outlets, hours and days of sale (including late night sales), minimum legal purchase age, and restrictions on purchasing and drinking of particular beverage types, by particular individuals and in particular settings. While much evidence comes from research in high income countries there is a growing body of research in low and middle-income countries and sufficient evidence to support the value of these interventions in those settings. In each case the implementation is key and will differ in different settings. The expansion of the digital ecology has provided a new element in regard to availability of alcohol with online purchase emerging strongly in the context of the COVID pandemic.

“In Norway the monopoly shops have wide popular support both because of the public health mandate and because it is well run and considered service oriented.”

“The effectiveness of any Best Buy is also dependent upon the regulatory environment/industry compliance system within which they are located. This is more than simple ‘licensing’ and should be acknowledged as a crucial prerequisite/qualification when promoting BB particularly those on the alcohol ‘supply’ side.”

Digital media has also dramatically affected the nature of alcohol marketing with most integrated marketing campaigns now including digital elements. Research on the impact of marketing has continued to demonstrate a strong effect on consumption and is likely to be stronger from the highly targeted digital marketing and is of concern for vulnerable sectors of the population . Alibi marketing and ‘brand stretching’ are becoming issues. There is a lack of evaluation of comprehensive bans on marketing because such bans have not been implemented but the evidence on the effects of exposure to marketing supports the values of such bans . The global nature of alcohol marketing means that an international response will be required, and will be difficult to achieve without a legally binding treaty, such as been effective for tobacco control.

“A policy of not advertising to children is worthless. The only useful and successful way is a TOTAL ban on ALL advertising and Promotion and Sponsorship.”

“Re zero beer, if the logo is there it is alcohol promotion. The Netherlands government was just convinced by Heineken to allow sports sponsorship by zero Heineken so their brand is everywhere”

“The problem in the EU is that broadcasting of marketing is allowed from abroad. Leaving national legislations void. Sweden has had cases trying to address this problem. …… underlining the need for international response”

“Imported marketing is a challenge, like in Botswana where marketing is nationally restricted, but comes in through external TV channels..”

In terms of NGO advocacy for the best buys it was suggested building a narrative of a better world as a result of policy implementation, using positive language about what we want rather than what we don’t want, is needed. In relation to this ‘new world’ the South African experience of reduced availability of alcohol during response to the COVID pandemic was cited as having provided real life experience of a different world; “it really changed how children and women experienced life in their own communities” This experience reinforced that alcohol is a development issue affecting every aspect of life. There needs to be much more dissemination of the best buys in relatable ways and to counter individualistic approaches to harm from alcohol.

“With tobacco, people supported the smoke free bans measures AFTER they were implemented not before. We need to be more confident and bring positive visions”

“Having a model law is a starting point to engage countries. It would need tailoring, but offers opportunity to ensure the inclusion of the best buys”

“We have research showing that South Africans enjoyed the alcohol ban – it made their lives safer and less noisy. Even drinkers supported it.”

“We must have credible scientific evidence – but – we have to convey it and sell it to politicians and legislators (and the public) in an easy to understand, acceptable style upon which they will take action”.

Community based messages rather than “academic” ones are needed and there was discussion about the involvement of those with experience of alcohol problems into the collaborations which need to be built. Another approach being used is to increase liaison with journalists to increase positive coverage in the media and to enlist support from champions in the community. However, evidence and data are also crucial.

“I also believe that communities can be very strong influence but the communities need the research first and then we need to translate it to simple community messages who can influence the national policy making- so again it comes to the messaging”

“Having data is crucial. I firmly believe it would be helpful for us in Africa to collect and report on alcohol-related trauma routinely (even if just at a selected number of sentinel surveillance sites) – it will show the effect of alcohol on the health care system and broadly could be a barometer of how well countries are doing to address upstream drivers of heavy drinking – very useful for advocacy”

Advocacy should not rely only on economic considerations but include other values. Values based advocacy is key. Arguments about restrictions of alcohol availability in response to the COVID pandemic have often centred on the economic implications. Industry inflations of economic benefits need to be challenged , but advocates also need to keep the focus of the public discussion on the harms to people when effective policy is not implemented.

Economic costs are relevant for policy makers. Investment cases such as those on NCDs by UNDP show the value of investing in the policy best buys

Comments provided during the session

“Value based advocacy is the angle to develop the messaging in the language that everybody can understand but I think the aim needs to be “faces with facts” to keep the evidence based approach.”

“re the economic arguments, industry the same world wide. There are good estimates from OECD and Bloomberg/WHO about cost effectiveness of taxes …..

“The economic players overstate and overplay their role, importance and value. ….jobs are not lost because alcohol sales might go down. The money previously wasted on alcohol doesn’t disappear. It is spent on other products and goods which create jobs and generate tax income.”…..

“And we must all remember that we must stay united and stick to our own narrative!!”

“We urgently need to create a fact sheet with data on costs for GDP and send to all policy makers / legislators”

Countries and regions differ in terms of existing collaborations for alcohol policy. In one Latin American country, for example, it was reported there is no medical or scientific participation in advocacy for alcohol policy and health benefits of alcohol are still being promoted.. A way forward in this context is to engage health professionals in public discussion about alcohol policy. There are parts of the globe where no NGOs exist which have a focus alcohol issues and this is one reason why greater support for LMICs is needed. Networks can be difficult to sustain and we need to find new ways of operating our coalitions.

“Alcohol touches so many of the social and health issues that do have traction. We need to make the case and the connections across issues.”

The WHO led initiative SAFER (link) was seen to be providing “frameworks of what’s possible”, as already exist for some other determinants of NCDs. SAFER’s promotion is key to implementing the best buys and regional platforms to promote its implementation such as that planned for Asia in 2022 will be valuable.   The five pillars of SAFER have been used to frame a report on the status of alcohol policy in Mexico to explain the need for change to politicians. It was well received but the translation into legislation remains uncertain.

Discussion on choosing a top priority between the five SAFER interventions recognised that price strategies and availability are about drinking now, whereas marketing is also about the future and a broader objective of denormalising alcohol products and, although restrictions on marketing are strongly opposed by industry, these still remain a strong priority.

“We need to avoid suggesting that single solutions will solve the problems related to alcohol consumption. Increasing execise taxes should be part of a portfolio of interventions.”

“It’s a package of interventions. Banning advertising and Promotion and Sponsorships. AAPS. De-normalize drinking. Large graphic health warnings on products, raising the age, and cost to consumer and more, Of these, affordability is probably the most effective. . We must attack it all.”

“to win a war on all fronts (SAFER) it is necessary to win a battle at every moment/opportunity (tax or marketing or intervention/treatment)… let’s not forget to adopt a specific strategy at each moment – favoring each opportune battle you have conditions to be won – without forgetting the whole.”

“love that term predatory marketing”

“me too”

Industry interference and the need to manage this was universally recognised as a major obstacle to the implementation of the best buys . For example, lack of implementation of best buys in Europe was a result of industry interference , trade agreements, and lack of cross-government cooperation.

While building capacity among Ministries of Health to support the best buys was recommended, a sole focus on Ministries of Health was “barking up the wrong tree” when we need to be talking to other sectors such as Finance and Trade ministries around tax and trade agreements and Ministry of Agriculture, given that these are the sectors likely to block reform.

Protection of the best buys policy from industry interference is essential and requires more open discussion of conflict of interest and profit motive. Any engagement with the industry was seen to be a waste of time and, because of the industry tactic of delaying and blocking reform using government processes, advocates need to consider carefully when to disengage from processes that enable industry game-playing.

Comments provided during the session

“We must work toward a Framework Convention on Alcohol Control and particularly Article 5.3 which deals with industry interference in policy matters. It is vital, Though we haven’t yet got that done for tobacco. A huge lack of political will and industry interference pressure/”persuasion”

“Revealing the role of the industry to the public and decision makers will help”.

“The problem is singling out the industry. My research establishes failed governance safeguards enable the industry to capture the industry regulatory process. Politicians are equally to blame”

“Also useful to make sure that governments do not include industry on their delegations to WHA or Codex – it makes a massive difference.”

“We have to denounce the industry but also the politicians, parties (and governments) who are, for the most part, supported and supporters of the industry and its messages… and thus are deaf to any evidence and slow in any action that is imposed on them by public health and science… and they are an instrument of the industry to act at EU or WHO level without being itself there…”

“There needs to be clear transparency and consultation rules in all interactions related to policy setting”

“COI is a real challenge in the context of governments in the South not having the resources for development priorities. CSO is is just as challenged. An international policy guideline on COI will be very useful to assist in managing & monitoring”

It is necessary to speak with one voice at international level (and wash dirty linen in private). Priorities need to be set at national and regional levels that are sensitive to cultural context, however the extent of diversity between countries and the extent of conflicting interests is a argument to keep pursuing discussion on a global response similar to the FCTC. In all our priority setting and activities we must ‘leave no LMICs behind’.

GAPA’s advocacy as part of the consultation processes for the development of the WHO Global Alcohol Action Plan was extensive. The most recent stage was the release of a new version of the draft, a few days ago. Some important changes in the current version had been made which aligned with the advocacy of GAPA and other NGOs. GAPA had asked for enhanced protection against industry interference, a stronger focus on the best buys, Member states and civil society to report biennially on implementation of the Action Plan, an investigation of the way forward by the WHO Expert Committee and setting up an interagency project on cross border marketing.

GAPA’s priorities for the coming years included de-normalise the marketing, PR and lobbying practices of alcohol industry and related vested interest entities, remaining a ‘critical friend’ to WHO, seeking alignments with other UN and development agencies and contributing to building a broader coalition among civil society.

The International Baby Food Network (IBFAN) monitors the 1981 International Code of Marketing of Baby Food Substitutes,; this is included in Code on Marketing of Breast Milk Substitutes. This is the first international consumer protection tool of its kind. It is under-pinned by Human Rights instruments, and its adoption was opposed only by the U.S. IBFAM’s work is not about promoting breast feeding per se, but targets predatory marketing, and getting sound information to those providing infant care. This independent organisation is completely free of conflicts of interest and is still needed because marketing by the huge global baby food industry is increasing in some regions.

Building networks (aka coalitions or alliances) depends on understanding what, why and how we connect. This will create collective power and clear targets. We build collective capacity in order to do more with less and to support each other. The most valuable is a strategic network with a future orientation, open to new possibilities and achieving leverage for change. A network of networks in which there is a core and periphery of independent elements is strong because it withstands disruption of any specific part. Trust not control and humility not self-interest or brand promotion is essential to building a network for public health. Perseverance is our secret power.

Penetration by the alcohol industry

The current version of the draft Action Plan still implies the alcohol industry has a role in the action points. This is considered inappropriate at both global and national level.
Lack of management of conflict of interest

There are no obligations on the secretariat with regard to managing conflicts of interest. This needs to be stronger at both government and secretariat level but is not mentioned in the Action Plan.

Lack of reporting and accountability

Reporting is allocated very little time at Executive Board and WHA, so the Alcohol Action Plan needs a reporting mechanism, with reports made public. If the Action Plan is adopted it will be a WHO recommendation and therefore detailed reporting in a standard format should be required and made public. The biennial implementation status reports of the International Code of Marketing of Breast-milk Substitutes are mandated by the Code itself in Article 11.7. Because the Acton Plan is not a code reporting will need to be mandated elsewhere.

Lack of involvement of LMICs

There is poor representation of many member states in Geneva, due to lack of capacity, so they are unlikely to have much input despite high levels of concern about the issue. Engagement with member states emphasising the Action Plan should respond to equity needs to happen quickly.

“We need to be tuned into other areas where ‘economic operators’ may be given a seat at the table and work hard to stop it – failure to speak up risks further entrenching and legitimising their role through ’side doors’. … they are actively pushing at side doors across health and development from communicable diseases to road safety, women’s rights, violence, and climate etc. they are e_v_e_r_y_w_h_e_r_e and we need to collaborate to shine a spotlight on whatever dark corners they hide in”

“The formulation and implementation of public health policies for alcohol policy should be protected from the alcohol industry to the greatest extent possible…. At the very least, WHO should develop a standalone document with specific guidance to Member States on how to protect alcohol policy development, implementation, and evaluation from alcohol industry interference.”

“Maybe we can also start advocating that the WHO stop interacting with the alcohol industry? If they want to maintain engagement with the alcohol industry, including during the consultation processes, the proceedings and sessions should be transparent and publicly available.”

Strengthen Human Rights approach

A “human rights approach” is mentioned in the draft action plan, and this needs to be strengthened. In particular, it does not reference the existing international human rights instruments, including those that relate to NCDs and thus alcohol. Strengthening in this way would introduce governmental accountability in human rights.

Another area is protection of children. Reducing exposure of children to alcohol marketing has parallels with other products, and work by WHO, UNICEF and The Lancet calls for a global movement to protect children, tightening national regulation of harmful commercial marketing, in conjunction with a new protocol to the UN Convention on the Rights of the Child.

Development agencies are potential collaborators but generally have not engaged on the need for alcohol policy .

Holding corporations accountable

There are many organisations, such as Third World Network, which do not work in alcohol but have useful skills and experience in governance and conflicts of interest, and who are in the business of holding industry accountable

Broader issues of corporate capitalism

People who are interested in the harms from specific commercial products are also interested in the health harm from the way mega-corporations operate more generally, e.g. Amazon (the company). There are pros and cons of compartmentalising the product issues

Gender Issues

In gender-based violence there is an intersection of gender norms and alcohol norms that lead to substantial harms.

There are also significant harms to stigmatised sectors, e.g. sex workers, non-binary genders. Building coalitions that are inclusive of those usually excluded and those who understand alcohol use and harms through different lenses can produce a wider range of responses.

International coalition among indigenous people.

Consumption is high often reflecting the processes of colonisation, leading to a greater burden of alcohol related health and social harms among indigenous peoples compared with the rest of the population. FASD and its impacts has had little attention, and incarceration rates are high. Those who are most affected by alcohol tend to be blamed and stigmatised.

Other unhealthy products

Health taxes (i.e. fiscal policies for health) as an area where we need to collaborate with other networks – getting the principle recognised will aid progress for all harmful products. Need to engage with Ministries other than Health, particularly Finance, as Health can’t raise taxes.

There is value in alignment with tobacco Both are addictive the product can’t easily be reformulated, unlike processed food,

“the importance of the reliance of a Human Rights as an avenue to hold the industry accountable. Encourage our policy advocacy to adopt this balanced approach and avoid siloing,”

“A rights based approach with focus on children is critical”

“human rights and child rights!”

“We are involved with development co-operation actors and organisations in various countries and it is clear that negative alcohol industry influence in development is not understood and it is not discussed. Key global development agencies need advocacy to understand this topic.”

“I have driven a change in South Africa to always say “Alcohol, tobacco and other drugs” which puts the two major legal addictive drugs together with illegal drugs”

“Alcohol is exactly like tobacco BECAUSE unlike the food industry, alcohol companies can’t change their products. AND harm reduction measures (0% alcohol products) are just another tactic to divide us and conquer. We should not fall into that trap.”