Conflict of Interest
Establishing clear standards to protect public health policies from commercial and vested interests of the tobacco industry, in accordance with Article 5.3 of the WHO Framework Convention on Tobacco Control.
The Problem: Why Tobacco
Industry Connections Undermine Tobacco Control?
The tobacco industry’s public relations and funding strategies create confusion about what constitutes industry ties [i] as it increases funding in the academic space and the civil society, as well as front groups, causing division within tobacco control organizations and weakening advocacy efforts[ii]. Clear boundaries and response protocols are essential to prevent these tobacco industry tactics from succeeding.
[i] World Health Organization, Tobacco Industry Interference with Tobacco Control (Geneva: WHO, 2008), https://apps.who.int/iris/handle/10665/43880 .
[ii] WHO Alert, https://www.who.int/news/item/06-06-2024-alert-on-philip-morris-funded-foundation-name-change-to-global-action-to-end-smoking .
The Solution: Clear Standards for Tobacco Control Advocates
Agree on a High-Standard Code of Conduct
Clearly define the tobacco industry and those that represent its interests
Implement Effective Screening
Identify and prevent conflicts of interest (COI)
Apply Consistent Procedures
Address violations when objectivity or clarity may be compromised
Refer to Independent Review
Seek assessment or resolution from an independent body when needed
To uphold integrity in tobacco control, groups of people, whether formally organized (such as institutions or organizations) or informally structured (such as coalitions or movements) must first agree on a high-standard code of conduct that clearly defines the tobacco industry and those that represent its interests. While Article 5.3 of the WHO FCTC binds governments, it also envisions “civil society not affiliated with the tobacco industry.” This makes it essential to define what non-affiliation means. If civil society calls on governments to avoid industry influence, it must hold itself to the same standard—anything less invites contradiction and weakens the cause.
With this foundation, they can implement effective screening to identify and prevent conflicts of interest (COI), and apply consistent procedures to address violations, and when objectivity or clarity may be compromised—refer the case to an independent review body for assessment or resolution.
CourageAgainstTobacco.org brings together advocates who have directly confronted tobacco industry tactics. It facilitates access to a pool of experienced individuals who, on a voluntary basis and upon request, can serve as part of an independent review panel. Requests for such a review can be submitted through the platform, which coordinates the convening of the ad hoc body based on the nature of the case and any preferences indicated.
When to Use Four Essential Tools for Your Organization
IDENTIFY: Conflict of Interest Policy in re Tobacco Industry
What it does: Establishes precise definitions of tobacco industry relationships and prohibits engagement, includes referral to an external resolution process for cases requiring independent/third-party assessment.
When to use it: Adopt this policy provision within your organization's governance documents.
[Adopt a Conflict-of-Interest Policy: Tobacco Industry Non-Engagement Provision]
PREVENT: Screening Protocol
What it does: Provides a process to screen for tobacco industry ties.
When to use it: Apply the protocol along with the database on tobacco industry actors.
[Implement a Prevention Protocol: Tobacco Industry Relationship Screening]
ADDRESS: Sanctions and Corrective Actions Framework
What it does: Provides clear guidance on classifying violations and appropriate responses.
- When to use it:
- Sample corrective action or sanctions for individuals and organizations
- Special consideration for violations affecting public policy
- Clear protocol for handling repeat violations
REFER: External Resolution / Assessment by Independent Review Body
What it does: Offers independent review when internal resolution isn't possible or assessment is inadequate.
When to use it:
- Complex cases causing organizational division
- Situations involving influential individuals or organizations
- When objective, third-party determination is needed
How to Implement These Tools
Download and review the complete toolkit
Access all necessary documents and resources to understand the full scope of the tools available.
Formally adopt the policy and tools at the board or similar level
Ensure organizational commitment through official adoption by leadership.
Raise awareness among key personnel on implementation
Train staff and stakeholders on proper use of the tools and protocols.
Real Impact: The Cost of Unresolved Conflicts
In the Philippines, when a Civil Society Organization (CSO), claiming to lead a coalition on sin taxes, engaged with a tobacco company to share coalition strategies, the resulting confusion and lack of clear response protocols divided the tobacco control community. This allowed the industry to access sensitive strategy information. Ultimately, compromises in the tobacco control policy positions became apparent. The unresolved issue continues to increase the risk of exposing government and WHO officials to engagements with those furthering the interests of the tobacco industry.
With proper classification and response procedures, this situation could have been swiftly addressed with a clear determination of violation severity, immediate protective measures, transparent communication to all stakeholders, and appropriate sanctions to prevent recurrence.
Independent Expert Review
Expert Pool Formation
Volunteer experts on Article 5.3 familiar with tobacco industry tactics
Global Perspective
Global review essential as tobacco industry operates as coordinated multinational enterprise
Review Process
Experts maintain high standards of integrity, transparency, and strict application of Article 5.3 principles
Clear Determinations
Organizations can reference determinations to resolve disputes
Volunteer experts on Article 5.3 will be tapped to resolve tobacco industry conflict of interest matters. CourageAgainstTobacco.org brings together the pool of experts, consisting of individuals intimately familiar with tobacco industry tactics and interference strategies.
The global nature of this review is essential because the tobacco industry operates as a coordinated multinational enterprise, with tactics that create division at country levels ultimately weakening the global tobacco control movement. Local compromises in one region become precedents exploited worldwide by the tobacco industry.
During its review process, the experts are committed to maintain high standards of integrity, transparency, and strict application of Article 5.3 principles, delivering clear determinations that organizations can reference to resolve disputes in order to ensure that tobacco control efforts remain free from tobacco industry influence.
ANNEX: Definition of the Tobacco Industry
Tobacco manufacturers, wholesalers, importers, and exporters
Companies directly involved in the production and distribution of tobacco products
Parent, subsidiary, and affiliate companies of tobacco manufacturers
All related corporate entities connected to tobacco manufacturing companies
Organizations or individuals representing tobacco industry interests
- Law firms representing tobacco companies
- Public relations companies working for the tobacco industry
- Consultants and lobbyists advancing industry positions
Organizations receiving funding from the tobacco industry
- Front groups and third-party allies
- Research institutions accepting tobacco funding
- Foundations established by tobacco companies
Entities that work to further tobacco industry interests
- Industry-established "corporate social responsibility" initiatives
- Organizations promoting "reduced-harm" products while opposing evidence-based measures aligned with the WHO FCTC
- Entities that consistently advance tobacco industry policy positions
In accordance with WHO FCTC Article 5.3 Guidelines, tobacco industry entities include, but are not limited to the categories listed above. [i]
[i] Preventing Tobacco Industry Interference. A Toolkit for Advocates and Policymakers. GGTC. 2023. Available at:
https://files.ggtc.world/uploads/2024-02-01/03-07-53-470050/GGTC%20Toolkit%20(Redesign)%20171123.pdf
NOTE: This represents minimum standards only. Organizations should adapt and strengthen these materials to address their specific context and evolving industry tactics, provided all modifications enhance protection against tobacco industry interference.
CourageAgainstTobacco.org Resources
This forms part of a suite of tools designed to support advocates in holding tobacco companies and their front groups accountable: