ATNI Spotlight on Lobbying 2022

Access to Nutrition Index
Resource type:
Reports and discussion papers

Access to Nutrition Initiative (ATNI) has been commissioned to benchmark the world’s 25 largest food and beverage (F&B) companies’ lobbying-related commitments, management systems, and disclosure against the Responsible Lobbying Framework (RLF). The RLF was developed to help organizations adopt corporate practices that ensure their lobbying activities are legitimate, transparent, consistent, and accountable, while providing the opportunity for other, more resource-constrained groups, to lobby in the public interest. Please note, this report focuses on the quality of internal corporate practices, rather than assessing real-life examples of how companies are influencing nutrition policy. 

The aim of this report is to encourage F&B manufacturers to improve their corporate practices relevant to lobbying: setting high-level lobbying commitments; translating these into action through effective management systems; being open and transparent through comprehensive disclosure;  and thereby lobbying more responsibly. This research identifies areas of strengths and weaknesses for companies, both individually and collectively, and encourages peer-to-peer learning  by identifying best practices. Practical suggestions are provided for improvement, starting with the  ‘easy wins’, before recommending more fundamental improvements. By providing objective and comparable data, key stakeholders, especially investors, can use the  results to engage with the companies to improve  their practices.

Key Findings:

  • Encouragingly, best practices were identified for most indicators – meaning that, were companies to emulate their peers’ current practices (as a pre-competitive issue), near-full compliance with the RLF is already within reach.
  • No companies’ lobbying disclosures were global in coverage and complete. Many disclosures appear to be compliance-led – meaning they are made through lobbying transparency registers as a prerequisite for accessing policymakers (although this  information is sometimes also disclosed voluntarily on companies’ own domains).  However, few disclosures were found for markets that do not require such disclosures, especially in low- and middle-income countries (LMICs).
  • No companies disclose comprehensive and global lists of trade association memberships, nor provide information beyond such lists – such as lobbying dues paid, Board seats held, the purpose of these memberships, engagement examples, and lobbying activities undertaken. Stakeholders, therefore, have limited understanding of what kinds of lobbying is being undertaken on behalf of the company, and that the company is tacitly endorsing.
  • Very few companies state that they review their relationships with trade associations systematically and at Board-level, or outline specific measures taken in cases of disagreement. This indicates that they do not consider  the prospect that these may lobby in ways or with positions contrary to the companies’ to be  a significant risk.
  • Exposure to the RLF can lead to improvements. While the results are not directly comparable, three out of five of the leading companies had been previously benchmarked against the RLF as part of  the Spotlight on Lobbying 2021: BMS Companies – indicating that these companies had already made progress on aligning their practices with the RLF. 

Read the complete report


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This resource presents evidence or data but has not been peer reviewed