atni methodology development report

Access to Nutrition Index

Methodology Development Report

August 2012

Access to Nutrition Index – Methodology Development Report August 2012

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The Access to Nutrition Index

The Access to Nutrition Index (ATNI) is founded on the belief that food and beverage (F&B) companies

can make a strong contribution to combating poor nutrition and related diseases. ATNI will rate food and

beverage manufacturers on their nutrition-related policies, practices, and performance. In so doing, it aims

to increase consumers’ access to more nutritious products and ultimately contribute to addressing the

serious global problems of both undernutrition and obesity. The first version of ATNI is expected to be

launched in early 2013.

ATNI is jointly funded by the Global Alliance for Improved Nutrition (GAIN), the Bill & Melinda Gates

Foundation and the Wellcome Trust. A project team based at GAIN is currently developing ATNI, which

will be housed outside of GAIN after its initial launch.

The development of ATNI is guided by a multi-stakeholder panel which provides strategic, institutional

and governance advice.1 In addition, a group composed of experts in nutrition and the F&B industry

provides advice on the development of the methodology for assessing companies’ nutrition-related

practices.2 Research and analysis on companies using this methodology is being conducted by MSCI ESG

Research, a leading provider of investment decision support tools.

Development Partners

Global Alliance for Improved Nutrition

GAIN is an alliance driven by the vision of a world without malnutrition. Created in 2002 at a Special

Session of the UN General Assembly on Children, GAIN supports public-private partnerships to increase

access to the missing nutrients in diets that are necessary for people, communities and economies to be

stronger and healthier. GAIN’s goal is to reach more than 1.5 billion people with fortified foods that have

sustainable nutritional impact. GAIN has been able to scale up its operations by investing in 50 large-scale

collaborations in more than 30 countries, reaching over 610 million people with nutritionally enhanced

food products.

Bill & Melinda Gates Foundation

Guided by the belief that every life has equal value, the Bill & Melinda Gates Foundation works to help all

people lead healthy, productive lives. In developing countries, it focuses on improving people’s health and

giving them the chance to lift themselves out of hunger and extreme poverty. In the United States, it seeks

to ensure that all people, especially those with the fewest resources, have access to the opportunities they

need to succeed in school and life. Based in Seattle, Washington, the foundation is led by CEO Jeff Raikes

and Co-chair William H. Gates Sr., under the direction of Bill and Melinda Gates and Warren Buffett.

Wellcome Trust

The Wellcome Trust is a global charitable foundation dedicated to achieving extraordinary improvements

in human and animal health. It supports the brightest minds in biomedical research and the medical

humanities. Its breadth of support includes public engagement, education and the application of research

to improve health.

1 Members of the Independent Advisory Panel are listed at: http://www.accesstonutrition.org/about-atni/independent-advisory-

panel 2 Members of the Expert Group are listed at: http://www.accesstonutrition.org/about-atni/expert-group

http://www.accesstonutrition.org/about-atni/independent-advisory-panel

http://www.accesstonutrition.org/about-atni/independent-advisory-panel

http://www.accesstonutrition.org/about-atni/expert-group


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Research Partner

MSCI Inc.

MSCI Inc., headquartered in New York, is a leading provider of investment decision support tools. The

products and services include indices, portfolio risk and performance analytics, and governance tools.

MSCI ESG Research products and services provide in-depth research, ratings and analysis of

environmental, social and governance-related business practices to companies worldwide. The MSCI ESG

Research team consists of more than 140 specialists worldwide, including more than 90 dedicated

ESG analysts and researchers. For more information, please visit www.msci.com.

Notice and Disclaimer

This document and all of the information contained in it, including without limitation all text, data, graphs,

charts (collectively, the “Information”) may not be used to create derivative works or to verify or correct

other data or information.

The user of the Information assumes the entire risk of any use it may make or permit to be made of the

Information. NO EXPRESS OR IMPLIED WARRANTIES OR REPRESENTATIONS IS MADE WITH RESPECT TO

THE INFORMATION (OR THE RESULTS TO BE OBTAINED BY THE USE THEREOF), AND TO THE MAXIMUM

EXTENT PERMITTED BY APPLICABLE LAW, ALL IMPLIED WARRANTIES (INCLUDING, WITHOUT LIMITATION,

ANY IMPLIED WARRANTIES OF ORIGINALITY, ACCURACY, TIMELINESS, NON-INFRINGEMENT,

COMPLETENESS, MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE) WITH RESPECT TO ANY

OF THE INFORMATION ARE EXPRESSLY DISCLAIMED.

Without limiting any of the foregoing and to the maximum extent permitted by applicable law, in no

event shall Institutional Shareholder Services, Inc. (“ISS”), nor any of its affiliates have any liability

regarding any of the Information for any direct, indirect, special, punitive, consequential (including lost

profits) or any other damages even if notified of the possibility of such damages. The foregoing shall not

exclude or limit any liability that may not by applicable law be excluded or limited.

Information containing any historical information, data or analysis should not be taken as an indication or

guarantee of any future performance, analysis, forecast or prediction. Past performance does not

guarantee future results.

Acknowledgements

This report was written by the ATNI Project Team, based at the Global Alliance for Improved Nutrition,

with support from MSCI ESG Research.

http://www.msci.com/


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Table of contents

Executive summary ............................................................................................................ 6

Project rationale, scope, and guiding principles ............................................................ 7

The nutrition challenge ..................................................................................................................................... 7

Scope of the Access to Nutrition Index .......................................................................................................... 8

Guiding principles underlying the ATNI company assessment methodology ......................................... 9

Methodology structure ................................................................................................... 11

Corporate profile ..............................................................................................................................................11

Product Profile ..................................................................................................................................................12

Methodology development process .............................................................................. 13

Stakeholder consultation results .................................................................................... 15

Overview of responses.....................................................................................................................................15

Comments on ATNI’s overall approach ........................................................................................................17

Summary of feedback on the Corporate Profile .........................................................................................18

Summary of feedback on the Product Profile .............................................................................................31

Marketing of breast-milk substitutes ...........................................................................................................31

Weighting ..........................................................................................................................................................32

Pilot test ............................................................................................................................ 33

Overview of findings........................................................................................................................................33

Changes to the Corporate Profile ..................................................................................................................34

Methodology implementation and future development ............................................ 37

Company research and analysis .....................................................................................................................37

Regular methodology review and future development .............................................................................37

Annex (Corporate Profile Criteria) ................................................................................. 38


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Acronyms

ATNI: Access to Nutrition Index

BMS: Breast-milk substitutes

CSR: Corporate social responsibility

DI: Dietary intake

ESG: Environmental, social and governance

FAO: Food and Agriculture Organization

F&B: Food and beverage

FOP: Front-of-pack

GAIN: Global Alliance for Improved Nutrition

GDP: Gross domestic product

NPS: Nutrient profiling system

WHO: World Health Organization


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Executive summary

Malnutrition, including both undernutrition and obesity, is a global public health issue that affects the life

chances and productivity of over a billion people. Reducing malnutrition will require substantial efforts

from a wide range of stakeholders, with the private sector playing an essential role alongside civil society,

governments, international organizations, academics and investors.

The Access to Nutrition Index will rate food and beverage manufacturers on their nutrition-related

policies, practices, and performance. In so doing, ATNI aims to increase consumers’ access to more

nutritious products and ultimately contribute to addressing the serious global problems of both

undernutrition and obesity.

ATNI will comprise a “Core Index” of 25 of the world’s largest food and beverage manufacturers by

revenue and three “Spotlight Indexes” that assess ten of the largest food and beverage manufacturers by

revenue operating in India, Mexico and South Africa, respectively. Each company in the Core and Spotlight

Indexes will be assessed in the following areas:

Corporate strategy, management and governance related to nutrition

Formulation and delivery of appropriate, affordable and accessible products

Influence on consumer choice and behavior

Research and analysis on these companies is being conducted by MSCI ESG Research.

Between May 2010 and April 2012, the methodology for assessing companies in these areas was

developed. This report provides additional background on the scope and principles which guided the

development of the methodology. It also describes the various steps undertaken to ensure that the

methodology is comprehensive and robust:

Reviewing a large body of work published on nutrition and the role of the food and beverage

industry, which formed the foundation of the methodology

Consulting a wide range of stakeholders on an initial set of assessment criteria

Revising the methodology based on input received from stakeholders during an online consultation

held in late 2011

Testing the methodology through a pilot phase of research

Making final revisions informed by this pilot research

The report concludes with an extensive discussion of the feedback received during the stakeholder

consultation, the changes that were made to the methodology based on this feedback, and final revisions

resulting from a pilot test of the methodology on a subset of food and beverage companies.


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Project rationale, scope, and guiding principles

The nutrition challenge

Malnutrition, including both undernutrition and obesity, affects billions of people globally. While

undernutrition is found primarily in developing countries, obesity is no longer a challenge unique to

developed markets, as a growing number of emerging market countries suffer the dual burden of both

undernutrition and obesity. Undernutrition and obesity have significant negative health and economic

consequences and have become global public health priorities.

An estimated one billion people globally are undernourished3, accounting for 11% of the global burden of

disease. 3.5 million children die annually due to undernutrition4 while those surviving to adulthood are

estimated to earn almost 20% less than those not affected. 5 Overall, the direct costs of undernutrition are

estimated at $20-30 billion globally ever year.6

Furthermore, according to the World Health Organization, 1.4 billion people (including 40 million under

the age of 5) are overweight, of which 500 million are obese. In addition, overweight and obesity are

thought to cause at least 2.8 million adults to die annually.7 In the United States alone, $190 billion in

additional medical spending (or 21% of total US medical expenditures) is attributed to obesity.8

While addressing undernutrition and obesity requires constructive engagement from and between all

stakeholders (including governments, consumers, civil society and others), the F&B industry has a

particularly important role to play. The global retail food market is estimated at $4 trillion.9 In its Global

Strategy on Diet, Physical Activity and Health, the World Health Organization recognizes the private sector

as a “significant player”. Given its size and reach, the industry is capable of having a significant beneficial

impact on public health by helping to improve access to nutrition.10

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In addition to its impact on public health, the F&B industry faces both business opportunities and risks

associated with nutrition. Opportunities include market growth driven by increasing consumer demand for

healthy foods in the developed world and for packaged foods in general in the developing world. Risks

include stronger regulations (including taxes), vulnerability to litigation and corporate/brand association

with negative health impact. A growing body of evidence suggests that companies pursuing opportunities

and mitigating risks along these lines will be best positioned for long-term success.12

3 The State of Food Insecurity in the World 2010, Food and Agriculture Organization.

4 The Lancet Series on Maternal and Child Undernutrition, Volume 371, January 19, 2008

5 S Grantham-McGregor et al (2007) ‘Development potential in the first 5 years for children in developing countries’, The Lancet,

369:60–70 6 The State of Food Insecurity in the World 2004, Food and Agriculture Organization.

7 http://www.who.int/mediacentre/factsheets/fs311/en/ - Obesity and Overweight Factsheet – N311 updated March 2011

8 Cawley, John and Chad Meyerhoefer. "The Medical Care Costs of Obesity: An Instrumental Variables Approach." Journal of Health

Economics, 2012, 31(1): 219-230. 9 The Economic Research Service, http://www.ers.usda.gov/Briefing/GlobalFoodMarkets/Industry.htm

10 The OECD Guidelines for Multinational Enterprises [http://actrav.itcilo.org/actrav-english/telearn/global/ilo/guide/oecd.htm]

11 The United Nations Political declaration of the High-level Meeting of the General Assembly on the Prevention and Control of Non-

communicable Diseases [http://www.un.org/ga/search/view_doc.asp?symbol=A/66/L.1] 12

See, for instance, Better-for-you foods: It’s Just Good Business. The Hudson Institute.

http://www.hudson.org/files/documents/BFY%20Foods%20Executive%20Summary.pdf; and Globesity – the global fight against

obesity. Bank of America Merrill Lynch, June 2012.

http://www.who.int/mediacentre/factsheets/fs311/en/

http://www.ers.usda.gov/Briefing/GlobalFoodMarkets/Industry.htm

http://www.un.org/ga/search/view_doc.asp?symbol=A/66/L.1

http://www.hudson.org/files/documents/BFY%20Foods%20Executive%20Summary.pdf


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Scope of the Access to Nutrition Index

ATNI emerged from the recognition that increasing risks as well as future business opportunities related

to nutrition are changing the landscape within which food and beverage companies operate. While

multiple actors within the F&B industry can play a positive role in reducing malnutrition, a rating initiative

such as ATNI is more effective when focused on key segments of the sector. In order to define the focus

and scope of ATNI, a series of decisions (described below) was taken in consultation with the project’s

funders and ATNI’s external advisory groups. Some of these points may be revisited for future versions of

ATNI.

Focus on food and beverage manufacturers

The food value chain is varied and complex, ranging from life sciences and agriculture companies to

ingredient processors to manufacturers, retailers and food service companies. Given their central role in

preparing foods for consumption, the first version of ATNI will focus on food and beverage manufacturers.

Later versions may consider incorporating other segments along the chain, such as retailers and food

service companies.

Assess global food and beverage manufacturers as well as major regional and local companies

ATNI is comprised of a global (or “Core”) index rating 25 of the largest F&B manufacturers in the world

and three country-specific (or “Spotlight”) indexes rating 10 of the largest F&B manufacturers in each of

India, Mexico and South Africa. These countries were selected because they are geographically

representative of emerging markets worldwide, have significant and/or growing food and beverage

industries, and have a significant prevalence of both undernutrition and obesity. The ten largest F&B

manufacturers by sales in each of the three “Spotlight” country indexes include a combination of major

regional and local companies and divisions of multinational companies (in most cases, the parent

companies of these divisions are assessed in the Core Index).

Companies are included in ATNI by virtue of their level of sales according to an international market

research database, and include both publicly traded and privately held companies. They have not elected

to be evaluated nor achieved any set minimum performance standard to be included in ATNI.

Address the full spectrum of nutrition-related issues, from obesity to undernutrition

Companies will be evaluated with regard to practices relating to both undernutrition and to obesity and

diet-related chronic diseases, since their practices can have a significant impact on both aspects of

malnutrition. In addition, a growing number of countries bear a “double burden” of malnutrition, in which

a significant prevalence of undernutrition exists alongside rising rates of obesity and diet-related chronic

diseases. The countries that are the subject of the three “Spotlight Indexes”—India, Mexico and South

Africa—were chosen in part because each has a double burden of malnutrition.

Focus only on products consumed by and formulated for the general population

The focus of ATNI is on foods and beverages formulated for and consumed by the general population,

which is the principle market for most major food and beverage manufacturers. ATNI is not designed to

look at approaches to addressing acute forms of undernutrition (e.g., wasting) that are generally related to

famine. Nor does it account for groups of people with special nutritional or dietary needs, such as

athletes, the elderly, or those with particular illnesses not related to diet (such as HIV/AIDS).


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Exclude products which are a part of a formal weight management program

Some companies evaluated by ATNI sell products which are intended to be a part of (or are

marketed/branded in association with) a formal weight management program. The methodology will not

assess these business lines as there is currently no international consensus on standards for the content of

such products. Furthermore, the nutrition community does not advocate dieting as a primary strategy for

weight loss; rather, ongoing consumption of a balanced, healthy diet is recommended.

Evaluate companies on how they enhance access to good nutrition as well as on how they influence

consumers’ diet and lifestyle choices

Companies will be assessed on the extent to which they are working to improve consumers’ access to

appropriate and affordable products and on how they influence consumers’ diet and lifestyle choices. This

latter set of activities includes but is not limited to:

Marketing, advertising, and promotional activities

Use of health and nutrition claims and product labeling

Support of healthy eating and active lifestyle programs

Engagement with governments, policymakers and other stakeholders through public relations and

lobbying activities

Promotion of employee health through the establishment of corporate health and wellness programs

Not an investible index

Although ATNI is not currently a vehicle for making investments into companies, it is designed to generate

information that may be valuable to investors in their analysis of and engagement with companies.

Guiding principles underlying the ATNI company assessment methodology

A series of principles have guided the development and content of the methodology that ATNI will use to

assess food and beverage manufacturers.

Draw on established best practices from other ratings and indexes

Over 100 ratings and indexes have been developed in recent years to evaluate companies’ environmental,

social and governance practices.13

ATNI’s methodology draws on best practices and precedents from

among these initiatives, while tailoring its approach to the specific issue of nutrition.

Base criteria and indicators on international norms and established best practice where possible

To the extent possible, the evaluation of technical nutrition and policy issues are based on international

policies, norms and guidelines. The aim has been to reflect existing consensus on best practices, not

define such practices. Examples of the policies, norms and guidelines that inform the methodology

include:

Global Strategy on Diet, Physical Activity and Health, WHO, 2004

Guidelines on Food Fortification with Micronutrients, WHO/FAO, 2006

Codex Alimentarius, WHO/FAO, 1963 onwards

Ensure relevance and applicability to a range of company types

ATNI is designed to be relevant to a variety of company ownership types (publicly-listed, privately-owned,

cooperatives, government-owned) as well as companies with different product portfolios (primarily food,

13

http://www.sustainability.com/library/rate-the-raters-phase-one


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primarily beverages, etc.). In order to achieve this objective, the methodology is designed to reflect core

business functions of F&B manufacturers, such as manufacturing, marketing, distribution, and public

affairs. This allows for an assessment of the extent to which companies’ nutrition practices are embedded

within their existing governance and management systems.

Identify, reward and spread good practice

ATNI is designed to award credit to companies for good practice and innovation, rather than to penalize

them for “poor practice” by deducting credit. This approach is intended to highlight and encourage

widespread adoption of good practices across the F&B industry, and to incentivize and reward innovation

in addressing nutrition across every business function.

Encourage transparency as well as good practice

ATNI awards companies credit for their policies, systems and practices as well as for the level and quality

of their disclosure. Greater levels of transparency allow other stakeholders to understand better the extent

to which companies are addressing malnutrition.

Utilize an inclusive approach, incorporating multi-stakeholder input

Input from relevant stakeholder groups—including governments, consumers, civil society and industry—

has been sought throughout the development process. More details on this approach are set out in the

section entitled “Methodology Development Process” later in this report.

Recognize limitations and continually evolve

Companies will be assessed based on the current state of knowledge on nutrition and best practices. In

recognition that knowledge and practices in the field continue to evolve, the methodology will be revised

in advance of future releases of the Index. These revisions will be based on multi-stakeholder input and

new or revised norms and guidelines. In addition, ATNI may itself stimulate research and consensus

building on good practices that could contribute to future versions of the methodology.


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Methodology structure

The methodology is divided into two major sections: a “Corporate Profile” that will apply to companies in

both the Core Index and the three Spotlight Indexes, and a “Product Profile” that will apply only to those

companies in the Spotlight Indexes. This structure is illustrated below.

A detailed draft of the methodology was published on the ATNI website in late 2011 as part of the online

stakeholder survey used to elicit feedback on the structure and content of the methodology. This

document, which includes examples of specific Indicators, is available at

http://www.accesstonutrition.org/uploads/media_items/atni-complete-consultation.original.pdf. The

findings from the consultation and resulting updates to the methodology are summarized in the section

entitled “Stakeholder consultation results” later in this report.

Corporate Profile

For each company in the Core and Spotlight Indexes, ATNI will include a “Corporate Profile”. This is

divided into three Sections, which are further sub-divided into seven underlying Categories of issues:

1. Nutrition governance

A. Corporate strategy, management and governance

2. Formulating and delivering appropriate, affordable, accessible products

B. Formulating appropriate products

C. Delivering affordable, accessible products

http://www.accesstonutrition.org/uploads/media_items/atni-complete-consultation.original.pdf


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3. Influencing consumer choice and behavior

D. Responsible marketing policies, compliance and spending

E. Supporting healthy diets and active lifestyles

F. Product labeling and use of health and nutrition claims

G. Influencing governments and policymakers, and stakeholder engagement

Within each of these seven Categories is a set of Criteria (see the Annex table for a full list of these

Criteria). For each Criterion, companies will be evaluated based on Indicators focusing on their:

I. Commitments

II. Performance

III. Disclosure

The Corporate Profile methodology is intended to be relevant to both undernutriton and obesity. For each

Criterion shown in red in the Annex table, additional Indicators focus on companies’ role in helping to

address undernutrition specifically, including in areas such as product fortification, consumer education,

and philanthropic efforts.

The Corporate Profile methodology as applied to the Core Index and to the Spotlight Indexes differs in a

few important ways. Measurement of company practices is not always feasible or meaningful at the global

(Core) level; therefore, assessment of some practices will only be done at the country (Spotlight) level. In

addition, the methodology for each of the Spotlight Indexes is tailored to reflect differences in regulatory

and operating environments specific to each country.

Product Profile

For the three Spotlight Indexes, ATNI will also include a “Product Profile”, which assesses a representative

sample of each company’s products for their nutritional quality using several nutrient profiling systems.14

The scope of the Product Profile is described in more detail on the section of this report entitled,

“Summary of feedback on the Product Profile,” which begins on page 31.

14

In future, ATNI may also assess these products’ affordability and accessibility, including how they are packaged and marketed,

along with other key attributes where possible.


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Methodology development process

The ATNI methodology was developed through a series of phases described in more detail below. The

remaining sections of this report will provide extensive detail on the last two phases of the development

process (the stakeholder consultation and the pilot desk-based research).

Overview of the methodology development process

1. Review of best practices from existing indexes

Before beginning the development of the ATNI methodology, the project team carried out an in-depth

review of over 30 existing peer indexes, ratings, and ranking systems (such as the Access to Medicine

Index, the Carbon Disclosure Project, and the Forest Footprint Disclosure Project, among others). Among

the elements reviewed were these initiatives’ origins, rationale, structure, governance, communications

strategies, approach to stakeholder engagement and consultation, and the structure and content of their

methodologies. The project team identified key lessons learned and best practices, which it sought to

incorporate into the design of ATNI.

2. Catalogue foundational documents

The ATNI methodology is based largely on international policies, norms and guidelines developed by the

WHO, FAO, and others that reflect existing consensus on good practices around nutrition for the food and

beverage industry. In the absence of international consensus on particular issues, Indicators are based on

recommendations drawn from stakeholder consultations and reports published by governments, NGOs,

investors and industry associations. In some areas, assessments will not be conducted due to the lack of

clear guidelines on what constitutes good practice by companies.

3. Iterative methodology development process with Expert Group

Extensive and detailed discussion with ATNI’s multi-stakeholder Expert Group began in January 2011.

Since then, this group of experts in nutrition and the food and beverage industry has met over 10 times to

discuss and provide feedback on the methodology. In addition, separate sub-group meetings of Expert

Group members have been conducted to focus on specific issues within the methodology. This intensive

and iterative process yielded a draft methodology that was put online for a stakeholder consultation in

November 2011.

4. Stakeholder consultation

During November 2011, an extensive survey was posted on the ATNI website

(http://www.accesstonutrition.org/uploads/media_items/atni-complete-consultation.original.pdf) in order

to publicly solicit views on the proposed structure and content of the methodology. While open for

comment from any interested individual, the project team specifically reached out to a wide range of

stakeholder groups, including representatives from governments, international organizations, civil society,



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academia, and the F&B industry along with investors and consultants. Experts from both developed and

developing world countries participated. Responses were analyzed in order to identify areas of consensus

and elements that raised concerns, with the goal of strengthening the final methodology. The Expert

Group was convened to discuss the feedback received and to help guide the ensuing revision process,

which took place from December 2011 through February 2012. A detailed account of how this input was

used to revise the methodology is provided in the next section, “Stakeholder consultation results”.

5. Pilot desk-based research

This revised methodology was then used to conduct pilot research on eight companies to account for

variations in the:

Type of company (multinational, local subsidiary of multinational, regional)

Form of company ownership (publicly-listed, privately owned)

Company product lines (food and/or beverage)

Index (Core versus Spotlight)

Research was conducted using companies’ own publicly available materials to test the feasibility and

relevance of the methodology. In addition, a broad assessment of the activities and information available

from all companies in the three Spotlight countries was conducted to determine the level and scope of

information available. Extensive research was also done on regulations around nutrition labeling, health

and nutrition claims and lobbying in order to understand each Spotlight country’s local context and adapt

the methodology accordingly.

This pilot research process led to additional revisions to the methodology, which are detailed in the “Pilot

test” section of this report.


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Stakeholder consultation results

This section sets out how the stakeholder consultation contributed to the evolution and refinement of the

ATNI methodology. Readers of this section are encouraged to refer to the detailed survey on the

methodology, available at http://www.accesstonutrition.org/uploads/media_items/atni-complete-

consultation.original.pdf, which was used during the online stakeholder consultation.

As expected, stakeholders expressed divergent views on various aspects of the methodology. Where

possible, these views were accommodated, but in some cases a decision had to be made to take one

approach instead of another. This section illustrates where there was broad agreement among

stakeholders and where changes were made in response to comments or concerns.

Overview of responses

Response rate

During the month-long online consultation on the methodology, a total of 84 stakeholders (12% of those

directly invited)15

responded to some or all survey questions. The distribution across stakeholder types

was fairly even with a relatively higher response rate from the F&B industry and a relatively lower response

from investors. In addition, 82% of the responses gathered were from developed countries. (Figure 1)

Figure 1 Figure 2

15

Average response rate for shorter online surveys is 10-15%, (SurveyGizmo)




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Overview of response to the Corporate Profile

A large majority of stakeholders either agreed or strongly agreed that “the proposed ATNI methodology

structure covers all relevant aspects of companies’ activities that can contribute to making good nutrition

accessible worldwide” (Figure 2).

For all seven categories of the proposed Corporate Profile methodology, more than 70% of survey

respondents either agreed or strongly agreed that the suggested list of criteria, indicators and weightings

captured the scope of companies’ activities relevant to nutrition. The acceptance level was consistent

among all stakeholders groups and regions, and no significant concentration of stakeholder type or

geography was noted among the non-supportive respondents.

The areas of the Corporate Profile methodology where the most significant concerns were expressed by

survey respondents included the role of external panels of experts in providing advice on nutrition;

company-supported nutrition education programs; and the role of companies in commercial sports

sponsorship. More details on these and other stakeholder concerns are presented by Category in the

section of this report entitled, “Summary of feedback on the Corporate Profile.”

Overall, survey respondents expressed a wide range of views, often conflicting with one another. A

significant effort was made to review all comments as inputs into the process of improving the

methodology. When views were particularly divergent, the approach reflecting the views of a majority of

respondents and/or aligned with the intended goals and current scope of the Index was taken.

Overview of response to the Product Profile

Approximately 70% of survey respondents agreed or strongly agreed with the suggested approach for

evaluating the nutritional appropriateness, affordability and accessibility of a representative sample of

each company’s products that are sold in each Spotlight country (India, Mexico, and South Africa). The

proposed Product Profile will therefore be retained (though the scope of its assessment will be limited

only to the nutritional appropriateness of products) for companies in each of the Spotlight Indexes. The

Core Index companies will not be included in the Product Profile due to the sheer size and heterogeneity

of their product portfolios worldwide. More details on these and other stakeholder concerns are

presented by Category in the section of this report entitled, “Summary of feedback on the Corporate

Profile.”


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Comments on ATNI’s overall approach

Consultation participants were asked to comment on ATNI’s overall approach. The table below lists some

overarching comments made by respondents which were not focused on a particular part of the

methodology:

Stakeholder comment ATNI response

We recommend that the first year be

considered a pilot test for ATNI.

While the first version of the Index will not be considered a pilot,

ongoing stakeholder consultation will be undertaken between each

Index publication to ensure that the methodology is robust and

generates meaningful and valuable results.

ATNI must avoid categorizing foods and

beverages as good foods and bad foods.

It is important not to demonize any

food or beverage or the role they can

have in a sensible balanced diet.

The Corporate Profile aims to understand and assess companies’ overall

approach to addressing nutrition challenges by looking at their

approach to formulating new products and reformulating existing

products, as well as their efforts to support consumers in choosing a

balanced diet and active lifestyle. As such, it does not categorize

individual products. The Product Profile complements the Corporate

Profile in Spotlight countries only and aims to provide information on

the relative nutritional quality of a selection of companies’ products

using several transparent and well-validated nutrient profiling systems.

The positive approach designed to

award credit may result in ATNI

building comprehensive information on

what companies are choosing to do to

improve health but little information on

contradictory action that may

undermine these activities.

While this concern is recognized, a systematic way to monitor for these

types of actions by companies has not been identified and respondents

did not suggest any comprehensive sources of such information.

While less than 5% of a company’s

revenue may come from [developing

markets], companies reviewed for ATNI

may have significant investment in

products or programs to address

malnutrition in the [developing world].

Criteria for exclusion based on

percentage of revenue may not capture

significant impact in a given [market].

This comment is in response to a proposal to not assess the practices

on undernutrition of those companies generating less than 5% of their

revenues from developing markets. In addition to the challenge noted

by the respondent, company reporting of revenue by geography is

quite variable. It can also be argued that even companies that do not

sell products in developing countries could demonstrate appropriate

global corporate citizenship (as large food and beverage manufacturers)

by contributing to efforts to address undernutrition. No viable

alternatives were suggested by consultation respondents. A fair

resolution to this issue is still being evaluated.


18

Summary of feedback on the Corporate Profile

The following section provides a detailed description of the comments received on the initially proposed

Criteria for the Corporate Profile. Based on these comments, changes were made to the number and

content of various Criteria; the resulting structure of the methodology reflecting these changes is

illustrated in the Annex table.

Category A: Corporate strategy, management and governance

This Category assesses the extent to which a company is committed to addressing nutrition and whether

its approach is embedded within its governance and management systems. This Category uses Criteria

and Indicators common to many indexes and rating systems that assess companies’ performance on a

range of environmental and social issues.

Proposed Criteria:

A1. Corporate nutrition strategy

A2. Nutrition governance and management systems

A3. Expert advice

A4. Quality of reporting

A1. Corporate nutrition strategy

Criterion A1 assesses the extent to which companies have embedded a commitment to addressing

nutrition within their corporate strategy worldwide (Core Index) and in each Spotlight country (Spotlight

Indexes).

Few substantive suggestions or changes were proposed by stakeholders that were not already addressed

elsewhere.

A2. Nutrition governance and management systems

This Criterion assesses the extent to which companies have integrated, within their existing governance

and management systems, effective approaches to enable delivery of their nutrition commitments.

Indicators are designed to assess whether appropriate governance structures exist to allocate and manage

internal resources dedicated to nutrition, and how companies measure their performance to ensure

effectiveness.

Some stakeholders challenged a potential Indicator that would assess the number of highly qualified

nutritionists or similar employed by each company, as a measure of resources dedicated to nutrition.

Upon further review, it was concluded that the data were unlikely to be available for this Indicator and that

it did not necessarily relate to companies’ delivery of better nutrition overall. As a result, it was removed.


19

A3. External advice

This Criterion assesses the extent to which companies draw on appropriate independent experts to design,

review and oversee the delivery of their nutrition strategy and commitments.

This Criterion was the subject of extensive discussion within the Expert Group during the methodology

design process. While the value of the advice of external, independent expert bodies was acknowledged,

exactly how those panels should be structured and how they should operate was less clear. No guidance

on best practice for convening and managing such panels could be found. Moreover, industry

representatives noted in their responses that companies draw their knowledge and advice from a wide

range of sources, both internal and external, and not necessarily through formally constituted panels.

Several stakeholders voiced concerns about how the independence of such panels could be judged,

whether it was acceptable for panel members to be paid (or, conversely, realistic to expect that they

should not be paid), how conflicts of interest could be assessed, and whether they truly have an influence

on companies’ decision-making processes. Following consultations with ATNI’s Expert Group, the decision

was made to test this Criterion in the pilot research phase to see what information on this topic would be

available from companies (see “Pilot test” section for more information).

A4. Quality of reporting

Within each of the other Categories (B through G), Indicators assess the level of companies’ disclosure of

information related to specific nutrition practices and performance, including whether they achieve their

stated objectives and targets.

The purpose of Criterion A4, however, is to assess the extent to which companies provide a clear and

comprehensive narrative in their corporate reporting about their progress in implementing their

commitments. In other words, it measures the overall quality of reporting of their Annual Reports and

Accounts, Annual Reviews, Sustainability or Corporate Responsibility Reports and corporate websites.

Stakeholders’ comments generally provided support for the types of Indicators proposed, such as:

Awarding extra credit for external verification or review

Awarding credit to companies that discuss challenges in meeting their objectives

Awarding credit to companies for reporting in a structured way against objectives and targets

“Consider an indicator addressing digital media

outreach (Twitter, blogs, etc) as well as popular

media, as well as external presentations on

nutrition goals and commitments.”

F&B industry

“It is necessary to correct for the level of expertise of

internal experts. A large company with a large R&D

department will have good internal experts and is

less dependent on external experts.”

F&B industry

“I think these panels are often window dressing and

attempts to ‘buy’ experts and get benefit from the

halo effect.”

Academic

“It’s not reporting that matters but independent

verification.”

Civil society


20

No substantial changes were made to this Criterion. However, an Indicator suggested by a respondent - to

assess the extent to which companies use social media to promote their strategy and activities related to

nutrition - has been added to the methodology.

Category B: Formulating appropriate products

This category assesses companies’ efforts to increase their offerings of nutritious products through

investments in research and development (R&D), new product development, and reformulation of existing

products. In addition, this Category assesses the quality of each company’s nutrient profiling system.

The Criteria proposed in the consultation were:

B1. Research and development

B2. New product development

B3. Reformulation

B4. Nutrient profiling systems

B1. Research and development

The purpose of this Criterion is to measure the extent to which companies are investing in research and

development (R&D) to create new healthy products.

Two industry participants noted that much of the data ATNI wishes to collect under this Criterion is likely

to be confidential. ATNI recognizes this and will sign a Non-Disclosure Agreement with each company

that requests one. Any information indicated by a company as confidential will only be used as an input

into its score on this Criterion and will not be directly disclosed by ATNI.

Other suggestions that were incorporated in revisions to the methodology were:

To represent nutrition-related R&D spending as a ratio of total revenue and as a ratio of total R&D

spending, and show changes of both ratios from a baseline level (during the previous 3 years)

To combine a company’s internal and external spending on R&D into one metric

B2. New product development

This Criterion assesses the extent to which companies have successfully introduced new healthy products

and/or fortified products directed at the undernourished.

“Some of this is sensitive information that

companies might hesitate to share for market

reasons.”

F&B industry

“Achieving public health nutrition goals for the

majority of the population will not necessarily rely on

new technologies and trademarks.”

Civil society

“Consider using the ratio of sales of new healthy products to those of all products.”

Academic


21

Survey respondents expressed some concern about the use of the term “healthy” here and elsewhere in

the methodology. Please see the narrative below on Criterion B4 (relating to nutrient profiling systems) for

more information on how ATNI aims to address this point.

Overall, few changes were made to this criterion as a result of input from the consultation.

B3. Reformulating existing products

This Criterion assesses companies’ progress towards reformulating existing products to improve their

nutritional quality. The assessment has been designed to take into consideration the nature of companies’

existing portfolios and efforts they have already made to improve their portfolios.

This is a particularly challenging aspect of the methodology since companies’ portfolios vary significantly,

as do their approaches to reformulating products. One industry participant raised a concern about ATNI

taking a “one size fits all approach”. Another noted that it would be essential to consider the nutritional

positioning of a company’s current product portfolio to assess the degree of need for improvement.

No concerns were expressed about the key nutrients on which ATNI will focus its assessment. However, a

suggestion that ATNI assess the alignment of companies’ commitments on product reformulation with

WHO/FAO recommendations has been incorporated.16

17

Other respondents suggested the evaluation of pricing (with the low-income consumer in mind), package

and portion size in the context of product reformulation. However, because such en evaluation is

considered too difficult to conduct globally at this stage, it will only be considered for future versions of

ATNI.

16

Global Strategy on Diet, Physical Activity and Health (2004), World Health Organization (Geneva, Switzerland). 17

Diet, nutrition and the prevention of chronic diseases (2002). Report of a joint WHO/FAO Expert Consultation, WHO Technical

Report Series, 916 (Geneva, Switzerland).

“Some of these are useful indicators and I am happy to see them reported in a public arena. But don't mistake

the progress from poor quality snacks and beverages to more nutritious poor quality snacks and beverages as

somehow being helpful to a population that would benefit more from a supply of high-quality fresh and

perishable foods that don't need fortification and cannot be made 'healthier'.”

Consultant

“You’ve done a good job with these. You may also

consider specifically mentioning other nutrients

such as good or excellent sources of protein and

keep the door open for other nutrients that may

emerge as concerns in the future (e.g. Vitamin D).”

F&B industry

“These criteria and indicators will help us get a

better understanding of how a company formulates

its products and should offer good ways to compare

and contrast various companies’ approaches.”

Civil society


22

B4. Nutrient profiling systems

This Criterion assesses whether companies have a nutrient profiling system and, if so, the quality of that

system. Nutrient profiling systems classify foods and beverages according to their nutritional composition.

They can classify products along a spectrum of relative nutritional quality and/or also be used to

designate whether a product meets a given nutritional quality standard.

Throughout the ATNI methodology, many Indicators rely on the classification of certain products as

“healthy” (for example, in determining which products are subject to restrictions on marketing to children).

Currently, there is no global consensus on a “gold standard” nutrient profiling system from among the

more than 60 systems which are publicly available.

In the absence of such a standard, each company’s nutrient profiling system will be assessed against a

series of qualitative criteria relating to its development, availability, and applicability (among others) based

on a very recent WHO assessment of nutrient profiling systems.18

Companies’ scores on their nutrient profiling systems will be used to weight scores on each Indicator

throughout the methodology that relates to categorizing products as “healthy”.

While this Criterion was the subject of numerous comments in the stakeholder consultation, highlighting

the importance and complexity of the issue, no substantive changes were made to the proposed

Indicators.

Category C: Delivering affordable, accessible products

This Category assesses the extent to which companies’ commitments and practices relating to product

pricing and distribution improve consumers’ access to more nutritious products.


C1. Product pricing

C2. Product marketing

C3. Product distribution

18

Guiding Principles and Framework Manual for the development or adaptation of nutrient profile models (First Edition). World

Health Organization, in press.

“It is good to use the quality of the NP System as a multiplier – this then becomes central.”

Academic


23

C1. Product pricing

Criterion C1 assesses the extent of companies’ commitments and practices to enhancing the accessibility

of their healthy and fortified products, particulary to low-income consumers, through affordable pricing.

There is little guidance or research about best practices on pricing of packaged foods and how pricing

may link to nutrition and health outcomes. Moreover, a full evaluation of the pricing or market positioning

of individual products at a global level is not currently feasible. As a result, the Indicators in this Criterion

aim instead to capture companies’ overall strategic intent with a focus on examples of progress in this

area. As one industry participant suggested, more specific assessments that take into account product

prices in specific markets relative to products’ nutritional quality will be considered in the future.

This Criterion was the subject of numerous stakeholder comments, most of which highlighted the

complexity of the issue (for instance, the price of any given product at a moment in time is dependent on

a number of factors including commodity prices, and healthier products typically cost more to produce).

A few changes have been made to this Criterion, such as modifying some Indicators to assess whether any

specific commitments or objectives relate to improving accessibility specifically for low-income

consumers.

C2. Product marketing

This Criterion assesses the extent to which companies direct their marketing strategies and advertising

spending towards healthy and fortified products.

Comments on this Criterion mainly suggested strengthening, and making more comparable, those metrics

comparing companies’ spending on marketing healthy or healthier products. However, comparable

quantitative data on companies’ spending on such activities is currently not available. In addition, the

aforementioned lack of consensus on the classification of products as ‘healthy’ and ‘unhealthy’ adds to the

challenge.

In reference to fortified products, one respondent commented that companies committed to addressing

undernutrition should support broad communication efforts around these products. Little guidance was

found on whether and how companies should market fortified products; therefore, there is no widely

accepted basis on which to assess companies’ practices in this regard.

“We recommend the inclusion of an indicator to

ascertain whether affordable pricing policies for

healthy products have been implemented across the

full range of products (i.e. value products as well as

high-end products).”

Civil society

“These indicators are very relevant as they target

affordability and accessibility to the poor which is

of utmost importance.”

Consultant

“Manufacturers committed to addressing undernutrition should be encouraged to engage in broader efforts to

communicate the role and place of fortified products within the context of an overall balanced diet in line with

international undernutrition guidelines as part of their corporate social responsibility.”

Civil society


24

As a result of the limitations discussed, the first version of ATNI will include a few broad Indicators to

assess whether companies undertake appropriate marketing activities across their product portfolios.

These Indicators are principally in Category E, which addresses companies’ support for healthy diets and

active lifestyles.

C3. Product distribution

This Criterion measures the extent to which companies broaden the distribution of their healthy and

fortified products.

In response to suggestions from survey participants, several Indicators were modified to recognize

commitments by companies to improve the accessibility of their products to low-income consumers.

One industry respondent noted that companies may not be allowed to offer incentives to distributors to

increase their focus on healthier products as this might be considered a corrupt practice in some markets.

The Indicator recognizing this practice was therefore dropped.

Overall, with respect to the whole of Category C, survey respondents encouraged ATNI to use more

quantitative and specific Indicators. At this point in time, however, the relevant data (which are often

considered business-sensitive information by companies) are not readily available.

Category D: Responsible marketing policies, compliance and spending

This Category captures the extent to which companies have adopted responsible marketing policies,

particularly with respect to children. Companies will be evaluated both on the level of strictness of their

policies and on their compliance with them. In addition, companies will be assessed on the extent to

which they have directed more advertising spending overall towards healthier products in recent years.


D1. Marketing policy: all consumers

D2. Auditing and compliance with policy: all consumers

D3. Advertising spending on healthy products: all consumers

D4. Marketing policy: children

D5. Auditing and compliance with policy: children

D6. Advertising spending on healthy products: children

D7. Commercial sponsorship of professional sporting and cultural events

“The relationship between accessibility and affordability should be drawn out. There should be a specific

indicator on ensuring accessibility to healthy products in low-socio-economic districts.”

Civil society


25

D1. Marketing policy: all consumers

Criterion D1 assesses whether companies have a responsible marketing policy aimed at all consumers and

the nature and scope of that policy.

This Criterion was supported by survey respondents and remained unchanged following the stakeholder

consultation.

D2. Auditing and compliance with policy: all consumers

Criterion D2 assesses the extent to which companies audit compliance with their general responsible

marketing policies, the compliance levels achieved and their transparency with regard to auditing and

compliance.

This Criterion did not attract a great deal of comment. The only change that has been made is the

addition of an Indicator on the frequency of audits in response to a suggestion by a consultation

participant.

D3. Marketing spending on healthy products: all consumers

This Criterion assesses the extent to which companies have directed their marketing strategies and

advertising spending increasingly towards healthy and fortified products. This is a complex and difficult

area to assess for a variety of reasons, but also a critical one.

Industry stakeholders responded to the proposed Indicators by noting that marketing spending is

generally proprietary and confidential.

Civil society respondents pointed out that focusing only on advertising spending would not capture

promotional spending and may also miss digital and new media marketing. Moreover, it was noted that

the equivalent spending on less healthy products would also need to be assessed as a comparator. Both

considerations were incorporated into the methodology.

ATNI has retained the proposed Indicators as an important signal to companies that data of this nature

are of great interest and a tangible measure of their investments in healthy products. In response to

concerns about the proprietary nature of data on spending levels, such data will be bound by a non-

disclosure agreement when requested by companies.

“Advertising is partly a function of the competitive

dynamics in a category and market. A low

advertising spend might simply mean low

competition.”

Consultant

“We believe that spending is not relevant to this

issue. The category should only focus on marketing

policies and compliance metrics. Marketing spend is

proprietary and confidential information for our

company, as it is across the industry and the private

sector as a whole.”

Industry


26

D4. Responsible marketing policy: children

This Criterion assesses the extent to which companies have adopted policies that restrict the marketing of

less healthy foods and beverages to children. This Criterion is similar in structure to Criterion D1 but

applies specifically to children.

While this is a hotly debated topic that tends to generate strong views, few suggestions were received as

to how the proposed Indicators might be improved. As a result, this Criterion remained unchanged.

One respondent urged that the number of Indicators be reduced; however, due to the complexity of this

issue and the range of voluntary codes and pledges in use by companies (including pledges initiated by

the advertising industry and chambers of commerce), it is important that the wide variability in the

strength of these commitments be accounted for. Other participants asked for more clarity about

proposed metrics such as ‘age verification for online media’ or how companies will define a child

audience. Greater detail on these metrics will be provided to companies during the company research

phase.

D5. Auditing and compliance with policy: children

Criterion D5 assesses companies’ level of compliance with their policies on marketing to children, as well

as their transparency with regard to these policies. This Criterion is similar in structure to criterion D2 but

applies specifically to children.

The proposed approach received broad support. One respondent from a civil society organization

counseled caution that a company’s compliance with its own policy, if that policy is not very strict, should

not be misunderstood as demonstrating good practice. This issue is addressed through a system by which

a company achieving high levels of compliance with a strict policy will be awarded a higher score than one

achieving equivalent levels of compliance with a weaker policy.

D6. Marketing spending on healthy products: children

This Criterion measures the extent to which companies have directed more advertising spending towards

healthier products when marketing to children.

This Criterion garnered conflicting views very similar to those noted in relation to criterion D3. The

Indicators remained unchanged following the consultation.

“A company's stated policies can contain a lot of

nuance, as we have seen with the Pledges on

marketing to children. The quality of the stated

policy needs to be assessed.”

Consultant

“Agree and also suggest marketing pledge programs and those pledge programs' compliance reports/audits.”

F&B industry

“It is completely unacceptable for any advert to be

directed at any child under 16.”

Civil society


27

D7. Commercial sponsorship of professional sporting and cultural events

The methodology initially included a Criterion to assess companies’ sponsorship of major professional

sporting events – such as the Olympics, World Cup, and other major cultural events – in recognition of the

large sums spent on such sponsorship and its potential influence on consumers.

However, background research indicated that sporting authorities (rather than companies) tend to set

policies around what can and cannot be marketed at each event. While there is some ongoing research in

this area, there did not appear to be any international guidelines on responsible sports sponsorship. In

addition, an initial search did not reveal any companies with published corporate policies on this issue.

As a result, it was proposed in the stakeholder consultation to exclude an evaluation of companies’

commercial sports sponsorship activities. Feedback on the issue was divided. A company respondent

stated that existing marketing policies already cover these types of events. One investor noted that this

issue was not core to the scope of ATNI. Respondents from civil society organizations were generally in

favor of including the Criterion.

In consultation with the Expert Group, this proposed Criterion was further tested by searching for evidence

of such policies among companies’ publicly available materials (as described in more detail in the ‘Pilot

Test’ section of this report). Because no information was identified, this Criterion will not be included in

the first version of ATNI. Given the interest in and the scale of this issue, it will be reconsidered in the next

version of ATNI.

Category E: Supporting healthy diets and active lifestyles

This Category assesses the extent to which companies support staff health and wellness and consumer-

oriented programs that promote healthy eating and active lifestyles.


E1. Staff health and wellness programs

E2. Supporting consumer-oriented healthy eating and active lifestyle programs

E1. Staff health and wellness programs

Criterion E1 evaluates the extent to which companies support healthy diets and active lifestyles for their

staff. It does so by evaluating the nature and scope of any internal health and wellness programs that

companies offer.

One civil society respondent expressed the view that this Criterion is slightly less relevant than others. This

respondent also stated that staff health and wellness programs would be strongly influenced by cultural

standards and perspectives about the roles of employers which should be taken into account.

“I think it should be included because of the pervasive advertising in sporting events and cultural events.” Civil society

“It is important to see how the company contributes to public health by having these programs.”

Civil society


28

Other comments were supportive of the Criterion and proposed Indicators. Following further review, this

Criterion was retained. The Indicators within this Criterion will be applied flexibly to reflect

national/cultural norms where necessary.

E2. Supporting consumer-oriented healthy eating and active lifestyle programs

Criterion E2 assesses the extent to which companies support appropriate consumer-oriented healthy

eating and active lifestyle programs.

During the design phase of ATNI, this Criterion was the subject of considerable discussion among

members of the Expert Group. That discussion centered on whether companies should be given credit for

nutrition education materials and websites and for community and consumer programs that carried their

brand, and thus conferred some commercial benefit on the company.

The Indicator on companies’ spending on these programs was removed because of the difficulty of

assessing and normalizing such data as well as the potential lack of correlation between the level of

spending and the outcomes of the programs.

Otherwise, given the diversity of views expressed on this topic, it was decided to revisit this portion of the

methodology after having an opportunity to evaluate specific examples of company activities from the

pilot phase of research. The results of this pilot phase are discussed in more detail in the “Pilot Test”

section of this report.

Category F: Product labeling and use of health and nutrition claims

This Category assesses companies’ approaches to product labeling and use of health and nutrition claims,

particularly in terms of their consistency globally and their accordance with international standards.


F1. Product labeling

F2. Use of health and nutrition claims

F1. Product labeling

Criterion F1 analyzes the extent to which companies commit to providing back- and front-of-pack labeling

that is accurate, comprehensive, and based on current international consensus.

“These logos on FOP [front-of-pack] have enormous potential to be misleading. Industry symbols are probably

the worst. The use of FOP nutrition signposts that are run by government or NGOs should be given a positive

score. FOP symbols like %DI which are suboptimal for consumers should not attract credit.”

Academic

“Regarding companies’ spending per year on

supporting programmes … that is not necessarily

correlated with their outcomes/impacts.”

Industry

“Sadly, I think that most companies abuse the name

‘health promotion’ by branding their contributions

and exploiting health activities for marketing

purposes.”

Civil society


29

Conducting spot-checks of companies’ labeling formats around the world is currently not feasible.

Therefore, the Indicators focus on evaluating whether companies have a labeling policy, the commitments

made in such policies and their accordance with international consensus and standards (such as those set

out by Codex), and companies’ disclosure of their policies.

Industry respondents noted that their policy is simply to abide by regulations which exist in most

developed markets and some emerging markets.

The consultation led to amendment of some of the front-of-pack label Indicators to ensure that

companies are only given credit for using independent third party ‘healthy’ labels and not for their own,

which may or may not meet ‘healthy’ definitions and are seen by many non-industry stakeholders as

marketing tools rather than as consumer education tools. In the three Spotlight Indexes, the Indicators

have been amended to reflect local regulations related to product labeling.

F2. Use of health and nutrition claims

The purpose of this Criterion is to measure the approach companies take to using health and nutrition

claims on products in all markets, whether such claims are regulated or not.

Most developed markets, and some emerging market countries, regulate the use of nutrition and/or

health claims. Companies typically pledge simply to abide by such regulations. As with labeling, ATNI does

not have the resources to conduct spot-checks of companies’ specific health and nutrition claims.

Therefore, ATNI’s principal aim here is to determine whether, in countries with weak or non-existent

regulations, companies restrict their use of health and nutrition claims to those claims that have been

approved for use in countries with strong regulatory systems (e.g., in the company’s domicile country, if

that country is considered to have a relatively strong regulatory system related to such claims).

Some Indicators were modified following the consultation. In evaluating complaints made against

companies, both health claims and ‘implied’ health claims (for example, statements such as “contains

fiber” or “no cholesterol” which leave the consumer to draw his or her own conclusions about the

relationship of fiber or cholesterol with actual health outcomes) will be considered. Moreover, ATNI’s

assessment will only take into account claims that are upheld by regulatory authorities, rather than

looking at all complaints made about a specific health claim, in order to ensure companies are not

penalized for any unfounded complaints.

In the Spotlight Indexes, the Indicators have been amended to reflect local regulations on health and

nutrition claims. A quantitative measure of the number of health claims on products was dropped; if

claims are poorly regulated, this is not likely to be a measure of a positive contribution to nutrition – and

could be the reverse, as one respondent pointed out.

“Only include complaints that have withstood scrutiny, e.g. coming from food authorities.”

F&B industry


30

Category G: Influencing governments and policymakers, and stakeholder engagement

This Category assesses the extent to which companies take part in and disclose their lobbying activities,

and the scope and nature of their stakeholder engagement.


G1. Lobbying and influencing governments and policymakers

G2. Stakeholder engagement

G1. Lobbying and influencing governments and policymakers

Criterion G1 assesses companies’ lobbying activities and their level of transparency around these activities.

This Criterion proved particularly difficult to design, given that much lobbying and engagement with

policymakers goes on behind closed doors and is not subject to mandatory disclosure in most countries. It

is therefore exceedingly difficult to track or evaluate. In addition, many of the companies to be assessed

by ATNI operate in tens if not hundreds of countries. While there are voluntary disclosure tools in some

regions (such as the Corporate Europe Observatory in Europe), these do not cover companies’ global

approach to lobbying.

Moreover, lobbying that one stakeholder may view as injurious to promoting better nutrition might be

seen by another as supporting that goal. It is therefore very difficult to make judgments about the

positions companies take on some issues.

As a result, the Indicators were amended to focus on companies’ disclosure of their lobbying positions

and activities rather than the specific positions they take on issues. In the Spotlight Indexes, the Indicators

have been amended to reflect local regulations related to lobbying and political donations.

G2. Stakeholder engagement

This Criterion measures the extent to which companies engage constructively with a wide range of

stakeholders in order to inform their approach to tackling nutrition challenges.

Although this Criterion was broadly welcomed, respondents wanted to see greater focus on the “quality,

diversity and level of stakeholders involved” and on whether companies apply their international approach

to stakeholder engagement to the regional and local levels. The Indicators aim to address the former

comment, while comparison of companies’ scores between the Core and Spotlight Indexes will provide

some insight into the nature and extent of engagement with stakeholders at the local level

“The positive approach is likely to mask more significant lobbying activities aimed at preventing legislation; the

information gathered through this exercise may be limited and at worst misleading.”

Civil society


31

Summary of feedback on the Product Profile

As a complement to the Corporate Profile (which evaluates companies’ corporate policies, practices and

performance), the Product Profile is intended to evaluate a representative sample of products that are

made by each Spotlight Index company (it will not be applied to companies in the Core Index19

). The

Product Profile is being developed in conjunction with a team from the Department of Public Health at

Oxford University.

Proposed approach

Participants in the stakeholder consultation were asked to comment on various proposals outlining how a

comprehensive approach to assessing the appropriateness, affordability, and accessibility of individual

food and beverage products might be designed. These proposals included a method for selecting the

products to be assessed; the use of three different nutrient profiling systems to evaluate the nutritional

quality of each product; and an approach to assessing the affordability and accessibility of each product.

Feedback from stakeholder consultation

While there was general support for the concept underlying this exercise, respondents in the stakeholder

consultation commented extensively on the lack of consensus around the best nutrient profiling systems,

and even the role of nutrient profiling. Respondents supported the concept of assessing products’

affordability and accessibility in the context of their nutritional appropriateness, but acknowledged the

challenges of doing so (including the lack of data and recognized metrics) and did not offer any

suggestions on how these could be overcome.

Current status

Following the stakeholder consultation, additional work has been done to design the Product Profile

approach. While the initial intent was to systematically evaluate the affordability and accessibility (in

addition to the nutritional quality) of each product, it was determined that such an assessment is currently

not feasible given limitations in the availability of pricing and distribution data. The original design of the

Product Profile also included an evaluation of products for appropriate fortification in the context of

undernutrition. Given the variability in country strategies on fortification through staple foods and the

current lack of clarity around the appropriate role of packaged foods in such strategies, a decision was

made not to pursue this part of the evaluation.

The Product Profile will still assess the nutritional quality of a portion of the products sold by each

Spotlight Country company. Discussions with the Expert Group regarding the design and role of this part

of the methodology are ongoing as of the date of publication of this report.

Marketing of Breast-milk Substitutes

The online survey also included a proposed approach for evaluating how companies’ internal

management systems comply with international standards on the marketing of infant formula20

and

recommendations on the marketing of complementary foods. 21

This portion of the methodology was only

19

This part of the methodology was not deemed feasible or meaningful to apply to Core Index companies given the size and

heterogeneity of their product portfolios globally. 20

International Code of Marketing of Breast-milk Substitutes, World Health Organization (1981) and all relevant subsequent World

Health Assembly resolutions. 21

Quinn, Victoria; Zehner, Elizabeth; Schofield, Dominic; Guyon, Agnes; and Huffman, Sandra. Using the Code of Marketing of Breast-

milk Substitutes to Guide the Marketing of Complementary Foods to Protect Optimal Infant Feeding Practices; Produced under


32

to be applied to the few companies assessed by ATNI that are manufacturers of such products. While

survey respondents agreed with the critical importance of this issue, the general consensus of

stakeholders was that ATNI should not conduct such an assessment as currently designed. Several

breastfeeding advocates opposed the proposed assessment of management systems without a

corresponding field assessment of actual marketing practices. Some industry respondents indicated that it

would be unfair to assess only companies included in ATNI on this issue, as there are other breast-milk

substitute manufacturers not being assessed by ATNI.

Based on this feedback, this part of the methodology is no longer included. Nevertheless, given the

considerable and wide-reaching public health benefits of optimal breastfeeding, a complete view of the

nutrition practices of companies manufacturing infant formula and/or complementary foods for infants

should take into account their marketing practices for these products. Options for most appropriately

reflecting these activities in companies’ ratings are currently being evaluated in consultation with experts

in the field.

Weighting

Each of the seven Categories in the Corporate Profile section of the methodology will receive a weighting

when calculating final scores for each company. Based on input from the Expert Group, the survey

proposed specific weights for each of the Categories and asked respondents to designate what weight

they would assign to each Category. Respondents were supportive of the suggested weighting system,

and the average of their proposed Category weights fell within 3.5% of the suggested weighting scheme

for each Category. Input from this consultation will be incorporated when finalizing Category weights.

the Maternal, Infant and Young Child Nutrition Working Group with assistance from the Global Alliance for Improved Nutrition

(GAIN). Geneva, Switzerland, 2010.


33

Pilot test

After the methodology was updated to incorporate feedback from the stakeholder consultation, pilot

research was conducted using the updated Corporate Profile methodology to determine its relevance and

applicability. The pilot research on the Corporate Profile was limited to the evaluation of publicly available

materials from a subset of the companies to be assessed by ATNI. The pilot did not include direct

engagement with companies (which will be part of the full research phase).

Overview of findings

General points

The structure of the methodology is complete and relevant. The Categories and Criteria capture the

broad range of companies’ nutrition-related practices.

Some Indicators, principally those aiming to collect quantitative data, could not be assessed by

means of desk-based research as companies do not publish all of the data sought by ATNI.

Undernutrition appears to be addressed mostly through companies’ foundations or philanthropic

activities, whereas companies’ approaches to addressing nutrition more broadly (namely preventing

and addressing obesity and diet-related chronic diseases) seem to be addressed principally through

their core business strategies.

Key findings by type of company

The pilot test involved research on a range of companies (publicly listed, privately owned, primarily food,

primarily beverage, multinationals, subsidiaries of multinationalss that operate in the three Spotlight Index

countries, regionals in the Spotlight Index countries) in order to identify any issues arising from the

application of the methodology to various company types. Among the findings were:

The largest listed companies in the Core Index provided sufficient public information to evaluate

them on many but not all aspects of the methodology.

Multinational companies’ subsidiaries that operate in the three Spotlight Index countries generally

make little material public that is specific to the subsidiary’s operations in an individual country.

Rather, they mostly provide the same material that is available on the parent company’s corporate

website.

Regional companies operating in the three Spotlight Index countries generally provide very little

material publicly on nutrition. They do not have structured public reporting on corporate

commitments and performance on nutrition. Instead, most of what they provide is marketing

material.


34

Changes to the Corporate Profile

Following the pilot test and further consultations with the ATNI Expert Group, additional changes were

made in order to finalize the methodology for the full company research phase.

Structural adjustments made as a result of feedback from the stakeholder consultation and results of the

pilot phase are summarized in the figure below:

In addition, two over-arching adjustments were made to the methodology:

Simplification of Indicators: Multiple stakeholders commented that the draft methodology was

too complex, creating challenges for those seeking to understand ATNI and for companies wishing to

provide information to ATNI. Substantial effort was therefore dedicated to simplifying and

streamlining the methodology, including a decrease in the total number of Indicators by

approximately one-third.

Revised approach to undernutrition-related activities: The pilot test showed that companies

predominantly address undernutrition through their philanthropic programs rather than as part of

their core business strategies. As a result, the Criteria and Indicators throughout the methodology

were adapted to give companies credit for all activities related to undernutrition (not just those that

are part of the company’s core business, as originally intended). Still, the highest levels of credit will

be awarded for business practices focused on populations with the highest risk of undernutrition,

followed by general fortification activities within the company’s core business; philanthropic activities

will receive the lowest level of credit, with more credit given to strategic than ad-hoc approaches.

Additional changes made at the Category level are summarized below. The Annex table summarizes the

final methodology used to conduct company research.


35

Category A: Corporate strategy, management and governance

After further discussion with the Expert Group, a change was made to Criterion A1 (Corporate nutrition

strategy) to better reflect differences in levels of accountability by company type. Indicators related to

acquisitions and disposals of companies will only be applied at the corporate headquarter level, rather

than to companies’ divisions based in Spotlight countries, since the latter do not have as much overall

control over such decisions.

Criterion A3 (External Advice) was combined with A2 (Nutrition governance and management systems),

given the difficulties in assessing this subject and the lack of information available from companies (see

page 19 for a description of these challenges). The Indicators were also modified to give companies credit

for soliciting nutrition advice from internal sources as well as through less formal channels from external

experts.

Category B: Formulating appropriate products

Criteria B1 (Research and development) and B2 (New product development) were combined in order to

simplify the methodology and out of recognition that new product development is the result of R&D. In

addition, as part of the overall effort to simplify the methodology, an Indicator assessing the number of

new technologies patented or trademarked to improve the nutritional quality of products was dropped.

Expert opinion suggested that the role of new technologies was limited at this time and secondary to

other efforts such as product formulation and reformulation.

Indicators that assess companies’ efforts to reformulate their products (Criterion B3) were simplified.

Category C: Delivering affordable, accessible products

The original Criterion C1 assessed product marketing strategy and attracted broad support in the

consultation phase. Following the pilot phase, this Criterion was combined with Criterion D3 (Advertising

focus: all consumers) to simplify the structure of the methodology by having only one Category (D)

dedicated to all aspects of marketing.

Category D: Responsible marketing policies, compliance and spending

Notwithstanding the views expressed by many stakeholders during the consultation on the importance of

criterion D7 (Commercial sports sponsorship), this Criterion has been dropped. The pilot research revealed

that none of the companies assessed has a policy governing commercial sports sponsorship, and

disclosure related to this topic was very poor. However, the importance of this issue and the need for

research and international guidelines will be highlighted as an area for future work. A Criterion related to

this issue will be considered for inclusion in future versions of the Index.

Category E: Supporting healthy diets and active lifestyles

Further review of specific examples of company nutrition education and healthy lifestyle promotion

activities was conducted in conjunction with the Expert Group. Based on this review, it was determined

that companies meeting a combination of the following conditions will receive credit for such activities:

Support of third-party programs within community-based public-private partnerships

Commitment to long-term, sustainable programs

Incorporation of comprehensive public health impact evaluation frameworks

Programs conducted in each of their major markets

Content derived from relevant national or consensus guidelines

No evidence of efforts to market products and brands through these programs


36

Category F: Product labeling and use of health and nutrition claims

No significant changes were made to this Category.

Category G: Influencing governments and policymakers, and stakeholder engagement

The Indicators were streamlined to focus principally on companies’ disclosure of their relevant

activities rather than on the evaluation of the activities themselves.


37

Methodology implementation and future development

Company research and analysis

MSCI ESG Research (MSCI) has been contracted to conduct research on each company to be assessed by

ATNI using the Corporate Profile methodology. In order to generate the Corporate Profile for each

company, the following steps will be taken by MSCI:

Identify and review relevant publicly available documents: These documents include companies’

annual reports, corporate social responsibility/sustainability reports, websites and press releases,

among others. In addition, information reported by companies to their respective stock exchange

regulators (such as 10-K and 8-k forms for the SEC) will be studied.

Interview companies: Based on open questions remaining from publicly available corporate

documents, companies have been asked to provide information to fill in the gaps. Companies

choosing not to provide information during this stage will be rated solely based on publicly available

information.

Validate company analyses: Companies will be provided an opportunity to review a draft analysis

for accuracy and to ensure exclusion of any confidential information prior to final publication.

Finalize ratings: The final company ratings are expected to be released in early 2013. The Corporate

Profile methodology will be made publicly available at that time.

The Product Profile is concurrently being developed with the support of the Department of Public Health

at Oxford University.

Regular methodology review and future development

It is intended that the Access to Nutrition Index, with updated company ratings, will be published on a

regular basis (initially every two years) in order to track and encourage improvements in nutrition-related

practices over time.

The methodology will be updated for each future version of ATNI to reflect advances in the state of

nutrition knowledge, emerging consensus on good corporate practices, new guidelines and policies, and

changes in the expectations of stakeholders.

During the process of developing the current methodology, the Expert Group identified several areas

deemed to be an important part of companies’ nutrition practices but for which consensus guidelines

currently do not exist. Examples include guidance on good practices around commercial sports

sponsorship, nutrition education, and the marketing of foods sold in areas with a significant burden of

undernutrition. ATNI will highlight specific areas in need of further research and consensus when the

company ratings are released in order to help move the nutrition agenda forward and improve future

versions of the methodology.


38

Annex

Corporate Profile Criteria


39

Disclaimer

As a multi-stakeholder and collaborative project, the findings, interpretations, and conclusions expressed

herein may not necessarily reflect the views of all companies, members of the stakeholder groups or the

organizations they represent. The report is intended to be for informational purposes only and is not

intended as promotional material in any respect. The material is not intended as an offer or solicitation for

the purchase or sale of any financial instrument. The report is not intended to provide accounting, legal or

tax advice or investment recommendations. Whilst based on information believed to be reliable, no

guarantee can be given that it is accurate or complete.

Copyright

© 2012 Global Alliance for Improved Nutrition - All rights reserved The content of this report is protected under international copyright conventions. No part of this report

may be reproduced in any manner without the prior express written permission of the Global Alliance for

Improved Nutrition. Any permission granted to reproduce this report does not allow for incorporation of

any substantial portion of the report in any work or publication, whether in hard copy, electronic or any

other form or for commercial purposes. The information herein has been obtained from sources which we

believe to be reliable, but we do not guarantee its accuracy or completeness. All opinions expressed

herein are subject to change without notice.

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