PHM-Exch> NGO letter on Conflicts of Interest, Future Financing, Reform and governance of the WHO

[Claudio Schuftan]

From: Patti Rundall <prundall at me.com>


*NGO letter on Conflicts of Interest, Future Financing, Reform and
governance of the WHO*

**Dear Hon Minister


We met briefly at the NCD Alliance meeting and then later when I sent you
the article - *An analysis of the content of food industry pledges on
**marketing
to children**.* (1)

Since you are on the Executive Board  I wanted to make sure that you have
seen this  important  letter from NGOs. Apologies if you already have it!

 I am not in Geneva now but several of my colleagues will be attending the
EB.

With very best wishes


Patti Rundall
Policy Director
Baby Milk Action/IBFAN



24 May 2011
NGO letter on Conflicts of Interest, Future Financing, Reform and governance
of the WHO.

Dear Members of the Executive Board,

We appreciate the need for a reform of the World Health Organization (WHO)
that involves the
reshaping of its financing in order to make it a more effective institution
that truly serves the interests
of all the member states in their efforts to pursue the highest attainanble
standard of health. However
in so doing, it is important that the nature of WHO as an independent,
member state driven institution
is assured and reinforced. This will require member states to take an active
role in the oversight of
both WHO financing and the direction and scope of the reform process. This
cannot be left to the
WHO secretariat alone or to small informal groups of member states.
We are writing to express our concerns regarding the management of conflicts
of interest and the role
of private bodies in the financing and the governance of WHO, a multilateral
entity and specialized
agency of the United Nations (UN) that derives much of its legitimacy from
its independence and
commitment to serving the public health interests of member states.
We believe that proposals in the current debate over WHO reform,
particularly in the report A64/4 on
‘The future of financing for WHO, World Health Organization: reforms for a
healthy future,’ do not
adequately address the management of conflicts of interest for private
institutions. This is relevant for
the institutions that will finance the design of the reform process as well
as for the concept of a World
Health Forum that will strengthen the role of institutional stakeholders in
the governance of WHO.
Finance
Our immediate concern is with report A64/4 Add.1 that states that the next
steps in the reform process
will be financed in part by a private foundation. While the WHO secretariat
provides a cost of $1.47
million USD for implementing A64/4 in the 2010/2011 biennium, no details
have been given about
the specific amounts to be provided by the foundation as mentioned in
sectioned 4 of document A64/4
Add.1. It is entirely inappropriate that the blueprint for reform of a UN
institution is funded by a
private entity. WHO's independence as the UN's specialized health agency
that sets norms or
standards for application and enforcement by member states must be
preserved. To achieve this, a
clear separation between WHO and the interests of private actors must be
maintained. The reform of
any UN institution, including WHO, is a fundamental responsibility of member
states, and funding of
the reform process by private entities with conflicting interests risks
de-legitimizing the outcomes of
reform.
We therefore request that the Executive Board reject any private financing
and ensure that this reform
is either funded from existing core contributions from member states or from
additional member state
contributions.
We are also concerned about proposals in the report A64/4 on the Future of
Financing to seek funding
from private donors. These proposals require a detailed and critical review
by member states. WHO is
not and should never become a public-private partnership. It is critical
that its ability to independently
set norms and provide independent evidence and oversight is maintained. If
the design of the reform
of a multilateral entity is largely financed by private donors, and then
executed by consultancies, it
does not represent a credible and democratic reform—especially considering
these donors might see
their role in governance enhanced as a result of the reforms.

World Health Forum

We welcome a larger role for ‘little heard voices’ as many of us have had
difficulties making our
voices heard at WHO, which in comparison with other UN institutions is not
accommodating to
public interest organisations. We have identified many short-term and simple
reforms that could
improve this situation, including changes to accreditation procedures for
meetings, rules regarding
official relations, and rules governing statements at the WHA. We would also
welcome consideration
of new processes such as public hearings. In particular, WHO should clearly
distinguish between
actors that represent or are clearly linked to commercial interests and
actors that are public interest
centered.
It is not clear if or how these issues will be addressed, and therefore the
rationale behind the World
Health Forum remains unclear. Before proceeding any further, the World
Health Forum proposal,
which we oppose as currently outlined, should be better explained and civil
society consulted. To
date, WHO has failed to provide a situational analysis of the reform process
it is prescribing.
Conflicts of Interest
Report A64/4 on the Future of Financing does not adequately address the
management of conflicts of
interest, and presents an unrealistic and empirically unsupported assumption
that all stakeholders will
collaborate to advance the public interest.
WHO and other public health institutions have complex relations with
commercial entities that supply
health care products and services. In some cases the commercial entities are
subject to or in need of
regulation, in order to protect consumers and promote the public interest.
Public health institutions are
also often engaged in buying goods and services, or providing financial
assistance for such purchases.
It is therefore widely recognized that governments and public health
institutions like WHO must
avoid conflicts of interest in all aspects of governance. WHO can only
respond meaningfully to the
challenges of public health through greater transparency and accountability
guided by the priorities of
Member States and the advance of the public interest However, transparency
is a necessary but not
sufficient safe guard: there must also be a clear approach and policy to
ensure that those representing
commercial interests are not part of policy and norm setting decision
making.
In this respect, we wish to emphasize the importance of evaluating conflicts
of interest by the
pharmaceutical, vaccine, alcoholic beverage, processed food, nuclear power
and other industry
groups, and private donors who have complex private interests.
We ask the WHO members to ensure that any changes in governance structures
address in a
transparent manner the risks that conflicts of interest will frustrate
efforts to protect consumers and the
public interest. We would also ask the Executive Board to provide guidance
and design a process by
which the WHO secretariat might manage conflicts of interest as part of the
governance review
process. . This process should include a definition of individual and
institutional conflicts of interests
as well as specific guidelines on how to appropriately manage them; it
should also require that
WHO’s institutional policies for interaction with the commercial sector are
clarified and widely
publicised.

Berne Declaration
HAI Global
IBFAN-GIFA
International Federation of Medical Students’ Associations (IFMSA)
Knowledge Ecology International
Médecins Sans Frontières (MSF)
People's Health Movement (PHM)
Third World Network (TWN)
Universities Allied for Essential Medicines (UAEM)
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