June 6, 2019
On June 3, 2019 Dr. Sarah Steele, Department of Politics and International Studies, University of Cambridge, and colleagues published an article in Globalization and Health titled “Are industry-funded charities promoting “advocacy-led studies” or “evidence-based science”?: a case study of the International Life Sciences Institute.” Subsequently, many international media outlets have reported on this paper.
Dr. Steele’s article concludes that “ILSI seeks to influence individuals, positions, and policy, both nationally and internationally, and its corporate members deploy it as a tool to promote their interests globally.” Dr. Steele’s characterization of ILSI is incorrect. The following describes ILSI policies regarding lobbying, corrects claims made in the article, and provides information regarding ILSI’s longstanding position on tobacco as well as recent changes to ILSI’s governance.
- ILSI is a nonprofit, worldwide organization whose mission is to provide science that improves human health and well-being and safeguards the environment. ILSI and ILSI entities foster public-private scientific partnerships to address knowledge gaps to benefit public good.
- ILSI does not lobby, nor does ILSI seek to influence individuals, positions, and/or specific policy. Additionally, ILSI explicitly prohibits its member entities from “advocat[ing] the commercial interests of their member companies or other parties.” ILSI brings forward precompetitive science that informs actions by industry, government, academia, and/or other researchers.
- Alex Malaspina ceased to be an ILSI Trustee, Officer, or representative of any kind in 2001. He has no position with ILSI and any comments he has made subsequently are as a retired private citizen.
- ILSI Mexico was suspended by the ILSI Global Board Executive Committee in 2015 precisely because it engaged in activities that could be construed to be policy advocacy, and/or public relations efforts to influence policy for commercial purposes (contrary to ILSI policies and to the Globalization and Health article author’s claims).
- All trustees that participate on ILSI boards serve in an individual capacity, not as representatives of their organizations. These representatives serve as unpaid volunteer experts to ILSI and have their main roles outside of ILSI. Public ILSI trustees are merely reimbursed for expenses to attend ILSI meetings.
- By charter, a minimum of 50% of all ILSI entity board members must be from the public sector. At present 62% of the trustees on the global ILSI Board of Trustees are from the public sector.
The authors of this case study point largely to several email exchanges from Dr. Alex Malaspina during the years 2014-2015. The article fails to disclose that Dr. Malaspina ceased to be an ILSI Trustee, Officer, or representative of any kind in 2001, and since then he has had no position within ILSI; therefore, the quotations made over a decade later that were cited in this paper reflect Dr. Malaspina’s actions as a retired private citizen, and not as a representative of or person with authority over ILSI.
Contrary to the claims by the authors of the Globalization and Health paper and reports based on that paper, the ILSI Board of Trustees Executive Committee made the decision to suspend its affiliation with ILSI Mexico on November 2, 2015 for engaging in activities that appeared to support the repeal of Mexico’s sugar-sweetened beverage tax. This suspension was made precisely because ILSI’s policies prohibit engaging in commercial or lobbying activities. ILSI Mexico was reinstated July 12, 2016 after requirements were met to conform to the ILSI Code of Ethics, overhaul their existing Board of Trustees, and other actions to prevent recurrence. ILSI continues to monitor their operations and compliance [press release].
The authors also conclude that “ILSI seeks to influence individuals, positions, and policy, both nationally and internationally, and its corporate members deploy it as a tool to promote their interests globally.” ILSI does work to bring forward precompetitive science that informs actions by industry, government, academia, and other researchers. [Appendix D to ILSI’s Mandatory Policies prohibits ILSI entities from lobbying or engaging in public policy advocacy. Paragraph 3 of this Appendix states that ILSI entities may provide decision makers (including regulators) “information relating to factual matters within ILSI’s scientific expertise, but they may not directly or indirectly propose public policy solutions or advocate the commercial interests of their member companies or other parties.”] This is not the same as lobbying. Additionally, all trustees that participate on ILSI boards serve in an individual capacity, not as representatives of their organizations.
ILSI acts on scientific issues with public health significance and not to “protect” industry from adverse policies. ILSI has indeed published outcomes that led to industry and regulatory restrictions.1,2,3,4,5,6 As mentioned above, ILSI suspended its ILSI Mexico entity when the entity appeared to support the repeal of a tax that disadvantaged some of its member companies. As explained in Appendix A to ILSI’s Mandatory Policies, all ILSI entities are required to ensure that their “work is scientifically rigorous, scrupulously neutral, and free from improper influence by the sources of its funding.” All research results from ILSI-funded projects and studies – no matter the outcome – are published in scientific peer reviewed journals and made publicly available [ILSI Principles for Scientific Integrity]. ILSI has published over 300 papers in peer reviewed journals over the last five years.
The authors claim that “Professor Alan Boobis simultaneously served as chair of ILSI’s Board of Trustees while he chaired the UN’s Joint FAO/WHO Meeting on Pesticide Residues panel on glyphosate, which was of great interest to ILSI major donors Monsanto and CropLife International. The final meeting report included no conflict of interest statements, even though, as we demonstrate below, the WHO had, by the time of meeting ended, official relations with ILSI.” This accusation is inaccurate. Professor Boobis’ conflict of interest statement for this meeting was and is available on the WHO website.
We further note that Dr. Steele et al. did not raise a single scientific issue of dispute in their analysis.
ILSI’s Position on Tobacco Products and Companies that Produce and Sell Them
ILSI Entities have never granted membership to organizations directly involved in the production, marketing, or sales of tobacco products. In 2001, ILSI adopted rules specifically prohibiting such memberships, prohibiting ILSI entities to work on tobacco-related research, and prohibiting financial or other contributions from any tobacco company. For a time, ILSI admitted as member companies a small number of food business subsidiaries and divisions of conglomerates that also, in separate lines of business, were involved in production and sales of tobacco products. In January 2015, ILSI forbade ILSI entities to accept as members companies whose affiliated entities—including parent, subsidiary, or sibling corporations or co-divisions—engage in the manufacture, production, marketing, sale, or distribution of tobacco products [press release].
Recent Changes to ILSI’s Governance
In November 2018, ILSI evolved from being an organization whose membership consisted exclusively of companies to a federation of ILSI’s Entities, nonprofits engaged in scientific public-private partnerships throughout the world. All ILSI entities must comply with the mandatory policies, including the prohibition on lobbying [ILSI Governance Change Initiative Statement].
ILSI believes it is in the public interest to bring together scientists from industry, academia and government to address scientific issues of public health concern. ILSI is well aware of potential conflict of interest issues and has been actively studying and publishing on this topic.7,8,9,10 ILSI will continue to bring scientific partnerships to the many difficult problems faced today, with scientific integrity and openness.
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- Reichard JF, Haber LT. Mode-of-action evaluation for the effect of trans fatty acids on low-density lipoprotein cholesterol. Food Chem Toxicol. 2016;98(Pt B):282-294.
- Allen BC, Vincent MJ, Liska D, Haber LT. Meta-regression analysis of the effect of trans fatty acids on low-density lipoprotein cholesterol. Food Chem Toxicol. 2016;98(Pt B):295-307.
- Seal CJ, de Mul A, Eisenbrand G, Haverkort AJ, Franke K, Lalljie SP, Mykkänen H et al. Risk-benefit considerations of mitigation measures on acrylamide content of foods--a case study on potatoes, cereals and coffee. Br J Nutr. 2008;99 Suppl 2:S1-S46.
- Virk-Baker MK, Nagy TR, Barnes S, Groopman J. Dietary acrylamide and human cancer: a systematic review of literature. Nutr Cancer. 2014;66(5):774-90.
- Crews C. MCPD and Glycidyl Esters in Food Products. Workshop report. 2011; Available at https://ilsi.eu/wp-content/uploads/sites/3/2016/06/MCPD-Report-2012.pdf
- Rowe S, Alexander N, Clydesdale FM, Applebaum RS, Atkinson S, Black R, Dwyer J, Hentges E, Higley N, Lefevre M, Lupton J, Miller S, Tancredi D, Weaver CM, Woteki C, and Wedral E. International Life Sciences Institute (ILSI) North America Working Group on Guiding Principles. Funding food science and nutrition research: financial conflicts and scientific integrity. Nutrition Reviews®. 2009;67(5):264–272.
- Rowe S, Alexander N, Weaver CM, Dwyer JT, Drew C, Applebaum RS, Atkinson S, Clydesdale FM, Hentges E, Higley NA, Westring ME. International Life Sciences Institute (ILSI) North America Conflict of Interest Working Group. How experts are chosen to inform public policy: Can the process be improved? Health Policy. 2013;112, 172– 178.
- Rowe S, Alexander N, Kretser A, Steele R, Kretsch M, Applebaum RM, Clydesdale FM, Cummins D, Hentges E, Navia J, Jarvis A, and Falci K. Principles for building public-private partnerships to benefit food safety, nutrition, and health research. Nutrition Reviews® 2013;71(10):682–691.
- Kretser A, Murphy D, Bertuzzi S, Abraham T, Allison DB, Boor KJ, Dwyer J, Grantham A, Harris LJ, Hollander R, Jacobs‑Young C, Rovito S, Vafiadis D, Woteki C, Wyndham J, Yada R. Scientific Integrity Principles and Best Practices: Recommendations from a Scientific Integrity Consortium. Science and Engineering Ethics. April 2019;25(2):327–355.