On conflicts of interest, transparency, and accountability of private actors influencing national health policy: authors’ reply to Morejón-Terán

We appreciate Yadira Morejón-Terán’s comments regarding our work published recently.¹ Morejón-Terán, who is the current Director of Public Policies, Monitoring, and Oversight of the Ecuador Grows Without Child Malnutrition Secretariat, makes several observations² that we actually think support the key points we are making in our article. We shall discuss each here.

First, Morejón-Terán corroborates what we stated in our article, which is that the Lasso administration via executive order enacted a mechanism for tax deductions for the industry in exchange for “sponsorships and contributions aimed at educational and nonprofit entities focused on eradicating infant malnutrition and caring for pregnant mothers”. She also mentions ensuing orders and agreements, which, according to our analysis, taken together have created a legal structure primed for undue commercial influence on national nutrition and health policy. In the article,¹ we cite the case of REDNI (Child Nutrition Network), which was established on December 14, 2021, exactly two weeks before Executive Order 304 created the tax deduction mechanism. In her letter, Morejón-Terán discloses that REDNI Foundation has so far received approval for two tax-deductible projects under this mechanism. According to publicly available evidence cited in our article,¹ REDNI has robust food and beverages industry ties: key contributors include Corporación Favorita and Pronaca, which in turn are members of the National Association of Food and Beverages Industry (ANFAB). As is public and we document in our article, ANFAB and REDNI each have a representative in the Advisory Council.

Second, Morejón-Terán confirms that the Advisory Council has an active role in the planning, coordination, implementation, and evaluation of the national strategy to reduce chronic child malnutrition. Using Bennet et al.’s indicators for potential surveillance of corporate practices,³ we suggest that this scheme is evidence of the food industry’s direct participation in government agencies and partnerships. In this context, we are surprised by the statement that the policy is “implemented by public and international cooperation entities free from conflicts of interest”. Taken at face value, this statement would suggest that declaring or ascertaining a conflict of interest is not a requirement for participation in policy-making, which would be in contrast with broadly accepted global norms.

Third, Morejón-Terán provides further evidence of the need to explore corporate influence in noting that processed foods such as tuna and sardines are provided by government-approved projects under the tax deduction mechanism. Incidentally, we note that the statement that these foodstuffs are “respect [ful of] the cultural diversity of food in intervention areas” would be inaccurate for indigenous communities in the Andean or Amazonian regions of Ecuador.

Finally, Morejón-Terán states that “food industry do not exert direct influence, nor dictate or influence the allocation of fiscal resources” and that “the use of these funds is publicly accessible to the entire population.” We beg to differ. The mechanisms currently in place via executive orders give national and global food corporations the power to shape national policy, which in turn can guide resource allocation, making them inaccessible to most organizations. The two recently-approved REDNI projects are an example of that.

To conclude, one of our goals in documenting this scheme is to encourage Morejón-Terán’s office to commit to clear and public conflict of interest guidelines and other forms of governmental transparency (e.g., making meetings accessible for the public to attend or watch live online; posting meeting minutes that list participants and describe discussions and decisions; and openly sharing drafts and final documents). There are guidelines from regional entities (e.g., Latin American Nutrition Society)⁴ and international cooperation agencies (e.g., UNICEF)⁵ that can inform the Secretariat’s efforts. In fact, UNICEF is now committed to avoiding partnerships (financial or non-financial) with ultra-processed food and beverage industries, aiming to preserve their credibility, leadership, and ability to guide programmatic and policy implementation at international and national levels. We reaffirm our assessment of the worryingly growing corporate influence in Ecuador’s nutrition and health policy, and call for public-private partnerships for health, if and when needed, to be transparent and include provisions for ongoing accountability to the general public.

Contributors

DLC and IT conceptualized and wrote the first draft of the manuscript. All authors contributed to editing the manuscript. All authors reviewed and approved the final version of the manuscript.

Declaration of interests

We declare no competing interests.