This project puts national alcohol policymaking at the forefront of efforts to reduce alcohol-related harm, emphasizing the need for transparency, accountability, and public health leadership. It addresses challenges such as health inequalities, policy fragmentation, and the influence of the alcohol industry in shaping national agendas. By connecting national action to a broader global framework, the project supports countries in developing stronger, more independent and evidence-based alcohol policies.
How transparency became the spine of UN and WHO partnerships (2000 – 2023)
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In the late 1990s senior officials in New York began to acknowledge an uncomfortable reality: informal, project-by-project cooperation with corporations and civil-society groups was no longer enough to deliver on global goals. The United Nations therefore issued its first Guidelines on a Principle-Based Approach to Cooperation with the Business Sector in 2000. That inaugural text codified high-level ideas - integrity, alignment with UN purposes, no unfair advantage - but said virtually nothing about public disclosure, reflecting an era when transparency was still treated as good etiquette rather than a compliance obligation.
2000 → 2015 | From generic openness to a binding transparency clause
As private-sector partnering accelerated, the Guidelines were revised in 2009 and again in 2015. The decisive leap came with the third edition, requested by General Assembly resolution 68/234, which inserted a stand-alone section entitled “TRANSPARENCY”. Article 25 now requires every UN entity to publish, on its own website and on business.un.org, the names of partners, the value of their contributions and any matching funds. Transparency had moved from an aspiration to a rule just as multi-stakeholder initiatives were becoming central to the 2030 Agenda for Sustainable Development.
2016 | WHO’s Framework of Engagement with Non-State Actors (FENSA)
While the UN Secretariat was tightening its rules, Member States at the World Health Assembly went further. Resolution WHA 69.10 (May 2016) adopted FENSA, making transparency one of eight overarching principles and creating an internet-based Register of Non-State Actors. Paragraph 37 obliges the Secretariat to file an annual public report on every engagement, including summaries of due-diligence and risk-management decisions; paragraphs 38–41 specify the information entities must disclose and the duty to update it annually . A digital register - searchable by anyone, linked to WHO’s budget portal - replaced the earlier patchwork of press releases and governing-body minutes.
2018 | Operationalising disclosure for outsiders
Merely publishing a policy was not enough; external partners needed practical instructions. The Handbook for Non-State Actors on Engagement with WHO (2018) turned FENSA into a five-step workflow. Step Two requires organisations to enter a detailed public profile - governance, funding sources, affiliations - into the Register before cooperation can begin, and to keep that profile current . The Handbook’s plain-language tone signalled a cultural shift: transparency was no longer an internal control but an everyday task shared with partners.
2021 | Sector-specific pressure exposes gaps
Even a robust register cannot, by itself, neutralise conflicts of interest. A 2021 WHO´s Addressing and managing conflicts of interest in alcohol control policies (Snapshot Brief on alcohol-control policies) warned that “current research practices to disclose conflicts of interest are insufficient to ensure transparency and unbiased science” . The brief documented industry tactics - front-group litigation, selective funding of studies - and urged stronger disclosure of research support and expert links. By spotlighting a high-risk sector, the paper reinforced political demands for stricter transparency norms across health governance.
2023 | Embedding transparency in staff workflows
The Guide for Staff on Engagement with Non-State Actors, second edition (2023) turns FENSA requirements into an electronic checklist: concept note → due diligence → risk assessment → Register entry → publication. A two-page flowchart shows the decision tree and flags “red lines” such as links to tobacco or arms industries; zero tolerance for fraud and sexual misconduct is explicitly tied to disclosure obligations . The guide confirms that every proposal, however routine, must pass through the same digital gate that feeds the public register.
What changed - and why it matters
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Progressive tightening: each text built on its predecessor, evolving from broad principles (2000) to concrete, enforceable procedures (2015 UN clause; 2016 FENSA) and finally to day-to-day operational tools (2018 Handbook; 2023 Staff Guide).
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Transparency as a non-negotiable condition: once optional, disclosure is now hard-wired into partnership eligibility. Failure to update the Register can trigger warnings, disengagement or loss of “official relations” status WHO-CRE-DAN-2023.2-eng.
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Digital infrastructure: public, regularly updated online registers replaced ad-hoc reporting, giving Member States and watchdogs real-time oversight of funding flows, governance links and risk-management decisions.
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Conflict-of-interest vigilance: evidence from alcohol, nutrition and other sectors shows how undisclosed ties can skew policy. Recent WHO briefs and the 2023 guide therefore pair transparency with systematic COI screening, signalling that disclosure is necessary but not sufficient protection.
The past two decades have delivered a real architecture for openness - public registers, annual reports, dedicated COI screening - but it is still an architecture under construction rather than a finished building. The WHO Register shows only a “high-level description” of each engagement; full due-diligence files are shared only with Member States through a secure portal, outside the reach of journalists, academics or affected communities. Likewise, FENSA says that written inputs from non-State actors should be made public “wherever possible,” leaving publication of agendas, background papers or minutes to the Secretariat’s discretion.
Important slices of interaction therefore remain in the shadows. Partnerships that pre-date 2016 were never retro-fitted into the Register, and new entries appear only when the Secretariat invites an organisation to supply data - meaning that informal contacts or exploratory conversations can occur with no public trace. Even when an engagement is logged, civil society sees only a headline while the substance of negotiations stays behind closed doors. Technical meetings with industry representatives rarely generate published minutes; FENSA regulates who may be in the room, but not what evidence of the discussion must later be disclosed.
These gaps matter because corporate actors continue to operate “inside the corridors” of global health. WHO’s own 2021 snapshot on alcohol policy underscores how undisclosed financial ties still distort science and delay regulation, warning that existing disclosure practices are “insufficient to ensure transparency”. Comparable concerns surface around ultra-processed foods, breast-milk substitutes and digital health platforms, yet the public often learns about lobbying activity only after the fact.
In short, the UN and WHO have moved transparency from a courtesy to an enforceable norm - but the system stops short of daylighting the content of interactions. To truly complete the journey, the next steps must include publishing meeting agendas and minutes by default, adding older partnerships to the public register, and making due-diligence summaries accessible to the public - not just Member States. Until those steps are taken, the advance is real but partial, and civil-society watchdogs must still work hard to piece together what happens behind the glass walls of Geneva.
Do we have a reason to worry about the lack of transparency?
The Estonian case shows how a lack of transparency in WHO–industry dialogues can allow industry narratives to shape national policymaking without public health scrutiny.
There are many principled arguments for transparency in global alcohol policy dialogue. But transparency is not just a principle — it’s a practical necessity. A recent experience in Estonia shows how a lack of openness can unintentionally create confusion, misinterpretation, and even potential political consequences.
Background: WHO’s dialogue with the alcohol industry
As we've already discussed the importance of transparency in WHO's dialogues with economic operators, it's useful to look at a specific example. In February 2023, the World Health Organization held another dialogue with representatives of alcohol producers and traders. The agenda included a discussion on “opportunities and plans for specific measures by economic operators to implement GAAP 2022–2030,” including “self- and co-regulatory measures” for alcohol marketing. Link to agenda
At the same time, Estonia’s Ministry of Economic Affairs was preparing changes to the national Advertising Act — also focused on alcohol marketing — and working closely with alcohol and advertising industry stakeholders. Public health organizations were not involved. The ministry saw it as an economic regulation issue, not a health policy issue.
The proposal that emerged would have drastically reduced legal restrictions and replaced much of Estonia’s current regulatory system with a self- and co-regulatory model — driven by the industry itself. Health groups discovered this only later. The proposal was ultimately dropped, thanks in part to strong opposition from public health advocates.
The confusion: WHO as an unintended reference point
In practice, this created a situation where WHO appeared to support the direction the Estonian proposal was taking — albeit likely unintentionally. The Global Alcohol Strategy and SAFER initiative do mention co-regulation:
“Setting up regulatory or co-regulatory frameworks, preferably with a legislative basis, and supported when appropriate by self-regulatory measures…”
When asked for clarification, WHO’s European office explained that co-regulation was meant for countries that don’t yet have any regulation in place — not as a recommendation to reduce already strong measures. This makes sense. But the nuance isn’t visible in the Strategy itself and is left open to interpretation.
Did industry representatives from Estonia attend the WHO dialogue in February? Or perhaps someone from a multinational company with interests in Estonia?
Did someone cite the dialogue as justification for the national shift toward co-regulation?
We don’t know. And that’s the point — no one knows. There are no public minutes. No recordings. No context.
As civil society organisations, we didn’t know what was discussed. We weren’t informed about the plan in the Estonian ministry. WHO couldn’t have known what a small Member State was dealing with at that moment. Even within the country, there was confusion. One ministry initiated changes that were not supported by others and ultimately not endorsed by the government as a whole.
The only actor present in both settings — in Estonia and in Geneva — was the industry. And in both places, the topic was self- and co-regulation.
Why this matters
WHO has emphasized that its dialogue with economic operators is mandated by Member States. We understand this, and we also recognize that unless Member States collectively revise this mandate, such meetings will continue. But we are saying that transparency must be the standard — for three clear reasons:
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National alignment: Alcohol policy is implemented at the national level. International recommendations must be interpreted in national context — or they risk being misused.
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Preventing misrepresentation: Without official records, industry actors can cite WHO language in ways that may conflict with public health intentions.
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Public oversight: Even well-meaning policy discussions can cause unintended harm if they are not visible to civil society or health experts in affected countries.
What would improve the situation?
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Public and timely publication of agendas, participation lists, and meeting minutes from WHO–industry dialogues
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Stronger involvement and awareness of Member State representatives, especially from health sectors
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Mechanisms for national actors to contextualize or respond to what is discussed internationally
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Clearer distinctions in WHO documentation about where co-regulation may be appropriate — and where it may not
Final note
We don’t claim that WHO’s dialogue caused Estonia’s co-regulation proposal. But the timing and content overlapped. And we also know that no one can say they didn’t connect, because there’s no record to check.
And that is exactly why transparent processes matter. They don’t just prevent actual harm. They prevent the appearance of harm, protect WHO’s credibility, and allow national actors like us to support the global health mission with clarity and confidence.
Campaign for Transparency in alcohol policy
Transparency in alcohol policy is not just a principle - it’s a necessity for accountability, public trust, and effective public health action.
We fully support the World Health Organization's (WHO) leadership role in shaping global alcohol policies. Civil society organisations have consistently highlighted the importance of transparency - not as negative criticism, but as constructive support for WHO and national governments to fulfill their core responsibilities.
Transparency in all dialogues and processes is essential, as underscored in a joint letter, co-signed by more than 100 NGOs and public health leaders worldwide in 2023 (read the letter). Transparency is fundamental to ensuring that policies remain accountable, evidence-based, and genuinely focused on public health.
Transparency at the global level
At the international level, we do not support dialogues between WHO and industry representatives. However, we acknowledge that several Member States advocated for these interactions within the global Alcohol Strategy. Importantly, this mandate does not specify how these dialogues should occur. This presents a significant opportunity to demand maximum transparency - especially by prioritizing clear and detailed minutes, alongside publicly accessible agendas and participation lists. Such transparency is crucial for meaningful engagement from public health advocates and civil society, ensuring accountability and safeguarding the legitimacy and effectiveness of global health initiatives.
Transparency at the national level
Transparency is equally vital within each country. Alcohol policies directly impact public health, social security, and child protection - issues far too significant to manage behind closed doors. National decision-making processes must openly document the rationale behind each policy decision, guaranteeing clarity and accountability. Civil society and public health professionals must always be involved, kept informed, and empowered to contribute effectively. The principle of "health in all policies" should ensure that whenever alcohol policies are reviewed or revised, regardless of the responsible ministry (often ministries of economy or finance), health and societal considerations remain paramount.
Removing conflicts of interest
True transparency also means proactively addressing and eliminating conflicts of interest. Alcohol policy measures founded on public health, social welfare, and child protection must not later be undermined by economic interests or industry pressures. Economic arguments must never override previously established, well-founded public health rationales.
We recognize ideological differences and varied political worldviews significantly influence alcohol policy decisions. If a governing party prioritizes free-market principles and economic growth, leading to liberalized alcohol policies, we urge transparency regarding these motivations. Political parties must communicate openly about their policy choices and clearly acknowledge any shifts from public health-driven approaches toward economic or market-driven policies. Transparency requires honest, evidence-based communication of the rationale behind every policy decision.
Ensuring transparency
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Publish clear documentation: Ensure all meetings involving industry representatives have publicly available minutes, agendas, and attendee lists.
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Strengthen Member State oversight: Promote consistent participation and oversight by Member States, particularly from representatives in health sectors.
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Open national policy processes: Clearly communicate the reasons behind policy decisions, facilitating continuous scrutiny and engagement from civil society and public health experts.
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Actively manage conflicts of interest: Publicly acknowledge and rigorously address any potential conflicts of interest to maintain the integrity of policy decisions.
Transparency in alcohol policy is not merely good governance - it is essential to protect public health and ensure robust and effective policymaking. Join us in advocating for openness and accountability - because public health policies should always remain public.
