Public Health Scotland (PHS) has developed a policy framework that makes collaboration with the private sector a clear and transparent process. The framework is a tool that helps Scottish health authorities make informed decisions and determine how and when to engage or not engage with commercial actors and reduce the risk of conflicts of interest.
“The new PHS policy framework is based on ‘whole-of-government’ and ‘whole-of-society’ approaches. Behind it there is a powerful idea: If we want to improve people’s health in a systematic way, we need to improve governance, promote action across sectors and reaffirm national ownership and leadership”, said Dr Kremlin Wickramasinghe, WHO/Europe Director for Prevention and Health Promotion.
The new PHS policy framework stands in line with Sustainable Development Goal 17, which calls for strengthened global partnerships and greater policy coherence, and the 2025 United Nations Political Declaration on the Prevention and Control of Noncommunicable Diseases, which encourages countries to explore innovative financing mechanisms and partnerships.
Strengthening good governance in private sector engagement
Commercial determinants of health are activities by private sector actors that affect people’s health directly or indirectly. These determinants can have a negative effect on public health when harmful commodity industries are left unchecked.
Unhealthy products related to commercial actors – such as tobacco, alcohol and foods high in fat, salt and sugar – contribute heavily to the global burden of noncommunicable diseases (NCDs). Across the WHO European Region, these commercial products and practices are responsible for at least 7400 deaths per day.
Commercial actors can influence NCD policy in many ways – political lobbying, economic leverage, targeted marketing, industry-funded evidence generation, and direct participation in decision-making forums – and corporate interests may clash with population health goals. This corporate influence can be felt on many levels: from individuals’ private interests that cloud professional judgement, to institutional partnerships that risk an organization’s primary health mandate and public image.
“The Public Health Scotland framework is an internationally significant example of innovation in strengthening governance of the commercial determinants of health. While conflict-of-interest policies often focus on individual interests, the framework recognizes the wider institutional and structural risks that can affect public health. It demonstrates how international guidance and emerging best practice can be adapted to national contexts to protect health priorities and an agency’s mandate. Its distinctive strength lies in the combination of tools to address conflicts of interest with health-harming industries and establishing criteria for meaningful and safe engagement with the wider commercial sector”, said Jeff Collin, Professor of Global Health Policy at the University of Edinburgh, who led the technical team in developing the PHS policy framework.
Scotland’s policy framework: structure is key
“We live and work in a complex world. Public health needs to work across boundaries to improve health outcomes, and conflicts of interest can arise as a matter of course. Interactions with unhealthy commodity industries, however, present distinct challenges. Good governance and transparency must therefore be at the heart of stakeholder engagement, while recognizing that one size does not fit all”, said Dr Garth Reid, consultant in public health, who led the work on the framework within the PHS.
The PHS framework for interacting with the private sector and managing conflicts of interest provides guidance on a full spectrum of interactions that health authorities can have with commercial industry, ranging from financial partnerships and research collaborations to informal consultations, advisory board participation and policy dialogues.
To achieve this, the framework provides two practical and complementary assessment tools:
Tool 1 targets unhealthy commodity industries, such as tobacco, alcohol, ultra-processed foods and gambling. It uses targeted screening questions to evaluate higher-risk commercial entities and safeguard against activities that may undermine public health.
Tool 2 governs general industry engagement, offering a decision-making matrix for other commercial sectors to assess how closely a company’s goals align with public health objectives and to evaluate the specific type of collaboration proposed.
Together, the principles and tools are designed to help PHS staff identify and manage risks more confidently, while engaging with the commercial sector where appropriate. This can make the process clearer, more structured and less stressful for decision-makers.
Next steps
Moving forward, the immediate priority for PHS is to roll out tailored training programmes across a wider spectrum of PHS staff. By publishing the framework organization-wide and embedding its application into daily workflow, Scotland will support its public health workforce to make better decisions.
“Countries need practical approaches to help them assess potential conflicts of interest when considering engagement with the private sector. Scotland has set a strong example with a clear and practical framework that supports transparent and informed decision-making. For countries looking to strengthen their own systems for managing conflicts of interest, this is a great example to follow”, said Joanna Glazewska, Head of the WHO Country Office in Poland.
“Scotland’s experience offers practical insights for the WHO European Region. As growing attention is given to the influence of unhealthy commodity industries on public health policy, this framework provides useful lessons on translating principles for managing conflicts of interest into practical organizational processes and strengthening governance around commercial engagement”, added Dr Wickramasinghe.
To learn more about the PHS framework and the WHO approach to commercial determinants of health, please contact Sumudu Kasturiarachchi, WHO/Europe consultant, at euphp@who.int.