Prevention Protocol: Tobacco Industry Relationship Screening

Prevention through proper screening is more effective than addressing conflicts after they emerge. This screening protocol helps tobacco control organizations identify tobacco industry connections as part of diligence procedures before entering into partnerships or collaborations. Prevention is more effective than remediation.

Application

New Partnerships

Before forming new partnerships or coalitions with other organizations

Funding Decisions

Prior to accepting funding from any source to ensure independence

Personnel Selection

When considering new board members or key staff positions

Joint Activities

Before participating in multi-stakeholder initiatives or campaigns

Prior to joining events or forums

Prior to joining events or forums involving external stakeholders

Other Similar Activities

For other similar activities that may involve collaboration or engagement

Screening Process

Basic Information Review

Organization's Website

Review the organization's website, particularly:

  • "About Us" section and leadership
  • Board of directors list
  • Funding sources and annual reports
  • Partners and affiliates

Online Search & Verification

Using the above information, search online for the links between the organization name and the names of key leadership / main funders or partners against a List of Tobacco Industry and Those Furthering its Interests — particularly those that are active in the relevant geographical location or region.

When reviewing the results pages, check for results from all sources, but it can help to prioritize results that are coming from the websites listed below:

Direct Connection Assessment

Financial Ties

Check for direct funding from tobacco industries or subsidiaries and engagement in industry CSR initiatives linked to tobacco control.

Personnel Links

Identify board members or leadership with current or past tobacco industry roles or backgrounds.

Collaborative Activities

Look for joint initiatives with tobacco industry entities, participation in panel discussions, or partnerships with known tobacco industry allies.

Public Positioning

Review public statements and social media accounts for support of tobacco industry positions or history of advancing industry-aligned arguments.

Ally Partnerships

Identify collaborations or affiliations with widely recognized allies of the tobacco industry.

Established Links

Check for a history of industry alignment, including evidence of direct or indirect benefit from tobacco actors.

CSR Engagement

Examine participation in Corporate Social Responsibility (CSR) projects initiated by the tobacco industry.

Other Associations

Note any other forms of collaboration, affiliation, or benefit derived from tobacco industry relationships.

Indirect Connection Assessment

Secondary Funding

Funding from organizations that receive direct or indirect tobacco industry support.

Non-Tobacco Collaborations

Joint initiatives on non-tobacco issues with tobacco industry entities, including in conferences or panel discussions.

Affiliated Group Memberships

Participation in groups, networks, or coalitions where tobacco industry actors are in leadership or hold significant influence.

Unclear Industry Alignment

History of promoting tobacco industry-aligned positions, even when formal ties or funding are not evident.

CSR Engagement (Non-Tobacco)

Involvement in Corporate Social Responsibility (CSR) efforts initiated by tobacco companies that are not directly related to tobacco control.

Other Related Activities

Any other indirect form of association, benefit, or collaboration that could imply alignment with the tobacco industry.

Note: A review of the organization's positions on tobacco control may also be telling. Along with other circumstances (such as direct/indirect connections), such positions can be taken into consideration, for instance, to the extent that it advances or furthers the interests of the tobacco industry.

Transparency Verification & Decision Standard

Request in Writing

  • Disclosure of all funding sources and partnerships
  • Board member affiliations
  • Conflict of interest policies, particularly, written position or policy on tobacco industry engagement

Decision Standard

There is only one acceptable standard: no tobacco industry connections of any kind. The organization must:

Have no direct or indirect tobacco industry connections

Maintain strong conflict of interest policies

Demonstrate clear commitment to tobacco control objectives, particularly, denounce all types of tobacco industry engagements

When in Doubt & Documentation

Document Uncertainties

Record specific areas where screening results are unclear

Apply Precaution

Prioritize public health using the precautionary principle

Independent Assessment

Request review from third parties recognized for upholding WHO FCTC Article 5.3

Complete Documentation

Record organization details, sources consulted, findings, and follow-up actions

Real-World Example & Resources

Prevention Success Story
A regional tobacco control coalition performed due diligence on a potential partner organization that claimed to be independent. The screening revealed 15% of funding came from a tobacco industry foundation, a board member previously served at a tobacco industry consulting firm, and the organization had published position papers aligned with industry arguments on taxation.

By identifying these connections before engagement, the coalition avoided potential division and reputational damage. Governments were prevented from engaging with the organization as it continued to promote tobacco industry arguments.

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

References

  • WHO FCTC Article 5.3 Guidelines
  • Framework of Engagement with Non-State Actors (FENSA), Handbook for Implementation
  • Global Center for Good Governance in Tobacco Control (GGTC) Conflict of Interest Policy (COI)

*Guidance Note on List of Tobacco Industry and Those Furthering Its Interest

As part of the 5.3 Knowledge Hub’s effort to monitor tobacco industry submissions under the Eighth Session of the Conference of the Parties (COP8) to the World Health Organization Framework Convention for Tobacco Control (WHO FCTC) mandate, a list of tobacco industry and those furthering its interest classified per country/region has been compiled by GGTC. When conducting Conflict of Interest (COI) / preventive screening, the best starting point is to search for a person’s relationship with those actors or entities that appear on the list.

However, it is important to note that the list may not capture all tobacco industry-linked entities, such as new front groups or allies. To strengthen the screening process, reviewers should also check supplementary resources such as the Global Tobacco Index, Tobacco Tactics, STOP website, and other sites that may provide more in-depth and updated information. A combination of a general search along with searching within the aforementioned sources will help facilitate and improve the robustness of COI screening.

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:

Prevention Protocol: Tobacco Industry Relationship Screening ← You are here
Click to open: Prevention Protocol: Tobacco Industry Relationship Screening
How can advocates be protected from tobacco industry’s tactics?
Click to open: How can advocates be protected from tobacco industry’s tactics?
Conflict of Interest
Click to open: Conflict of Interest