Abbott

Policy Commitment

• Abbott’s overarching commitments to the Code had not changed since the 2021 assessment. The company continues to clearly state its support for exclusive breastfeeding in the first six months and continued breastfeeding to two years or beyond, as well as for the introduction of appropriate complementary foods from the age of six months.

• Although compared to the other companies assessed, Abbott’s overarching commitments are relatively well-aligned with the principles of the Code, the company still does not fully acknowledge the specifications to the Code provided by the World Health Assembly (WHA) in resolution 69.9 and the accompanying guidance on ending the inappropriate promotion of foods for infants and young children. WHA resolution 71.9, which calls for continued implementation of the recommendations of this guidance has not been acknowledged by the company either.

• Abbott did not receive a full score on the new indicator that assesses whether companies apply their BMS marketing commitments to all types of formula, including formulas for special medical purposes. While the company does not consider products intended for the treatment of medical conditions as breast-milk substitutes, the Code regards all formulas for infants and young children as BMS, whether used to meet the normal nutritional or special medical needs of infants.

Policy Commitment

• Abbott did not score on this topic since, in its BMS Marketing policy, it allows the advertising and promotion of BMS products to the general public, as well as the supply of educational and instructional materials through healthcare systems. Furthermore, Abbott’s BMS Marketing Policy mentions policies and procedures for employee and partner interactions with healthcare professionals and consumers, which are all actions that are not permitted according to the Code under any circumstances.

• In order to score in this area, the company should comply with Article 5 of the Code and recommendation 6 of the guidance supported by WHA 69.9, by refraining from advertising BMS through various media channels and prohibiting distribution of samples or promotional materials to caregivers. Additionally, the company should avoid point-of-sale promotions and cross-promotion between different types of BMS, ensuring distinct packaging and labeling for each BMS product type.

• Abbott is encouraged to adopt these Code requirements and clearly outline them in its BMS marketing policy.

Management System

• Abbott shared – under non-disclosure agreement (NDA) – local staff training material and procedures developed by the company to guide its employees on the marketing of BMS. However, the company did not score on management systems as it did not meet the policy commitments in the first place.

• Abbott is encouraged to adopt the Code requirements and to develop clear and comprehensive management systems, procedures and other guidance for its employees to implement all commitments set out in its updated policy(ies) relating to responsible BMS marketing in all markets.

Policy Commitment

• Abbott’s policy commitments relating to marketing BMS throughout the healthcare system, which are only partially aligned with the requirements of the Code, have not changed since the 2021 assessment.

• Compared to the last assessment in 2021, indicators were slightly revised to ensure an accurate assessment of recommendation 6 of the guidance supported by WHA resolution 69.9 to evaluate whether companies have explicit commitments in place not to use health facilities to host events of any kind nor to give out gifts or any other offering to caregivers of infants and young children, to avoid conflicts of interest. Similar to the 2021 assessment, and like most of the BMS companies assessed in this Index, Abbott did not score on the indicators that capture these Code commitments that specifically relate to WHA resolution 69.9. In this iteration, the company also did not score on commitments to forbid its staff from demonstrating formula feeding.

• Abbott is encouraged to consider the gaps identified to revise its policy to better align with the requirements of the Code.

Management System

• Abbott shared – under NDA - some local guidance and procedures developed by the company to guide its employees on the marketing of BMS throughout the healthcare system as outlined in the company’s related policy(ies). The company does not score on management systems as it does not have all Code provisions in place. Moreover, the material shared was not found to include any relevant training material that covers the implementation of the company’s commitments on marketing BMS throughout the healthcare system.

• Abbott is encouraged to update its management systems, procedures, and other guidance to include training material that consistently and comprehensively cover the implementation of the company’s commitments on marketing BMS throughout the healthcare system.

Policy Commitment

• Abbott’s policy commitments relating to BMS donations within the healthcare system, in humanitarian settings and emergencies, and in social welfare institutions are partially aligned with the requirements of the Code.

• Compared to the last assessment in 2021, commitments on donations of BMS are now assessed in a separate topic and across several indicators, to ensure a more accurate assessment of the specific requirements relating to BMS donations.

• In regard to BMS donations, Abbott does not comply with the Code, specifically recommendation 6 of the guidance supported by WHA resolution 69.9, as its BMS Marketing policy states that the company may provide free or low-cost supplies of the BMS product, as well as equipment or material, to healthcare institutions.

• Based on its BMS marketing policy together with company-wide donation procedures that were confidentially shared by the company, Abbott showed commitment to meeting most of the required criteria for BMS product donations in emergencies, such as ensuring that distribution is targeted and not delivered directly to caregivers, and that supplies are based on identified need and are not expired or close to expiry, but it was not found to commit to ensuring that donated BMS products will not display company brands. Furthermore, the company does not explicitly state that requests for BMS donations may only be considered if officially requested by government bodies or national coordination structures in humanitarian settings and emergencies.

• The company commits not to distribute BMS product donations or low-cost supplies for use outside of the social welfare institutions where infants and young children require them and prohibits using such donations as a sales inducement.

• Abbott is encouraged to consider the gaps identified to revise its policy to better align with the requirements of the Code.

Management System

• Abbott confidentially shared some local procedure manuals and company-wide donation procedures developed by the company to guide its employees on the marketing of BMS, as outlined in the company’s related policy(ies). The company does not fully score on management systems since it does not have all Code provisions in place. However, in regard to the commitments met by the company on donations that are in line with the Code, the guidance provided by the company to follow and apply these commitments is clear and consistent across markets, thus Abbott scores on those elements.

Policy Commitment

• Abbott’s policy commitments relating to marketing BMS to healthcare workers, which are only partially aligned with the requirements of the Code, have not changed since the 2021 assessment.

• Compared to the last assessment in 2021, a new indicator was introduced for this topic to specifically assess the instructions provided to healthcare workers on the appropriate preparation of powdered formulas and if these are based on WHO/FAO guidelines and Codex Standards as referenced by WHA resolutions 58.32 and 61.20. Abbott did not score on this indicator and none of the 18 companies assessed met this requirement.

• Abbott is one of seven companies out of the 18 assessed to explicitly state that any information regarding BMS products provided to health workers will be restricted to scientific and factual matters, as per the requirements of the Code. However, the company did not score on any other indicator in this topic.

• Two other indicators were slightly revised to ensure an accurate assessment of recommendation 6 of the guidance supported by WHA resolution 69.9 to evaluate whether companies have explicit commitments in place not to offer any financial or material inducements (no gifts or incentives of any form or value) to healthcare workers or their families, and not to sponsor any scientific meetings, fellowships, study tours, and research grants for health professionals, to avoid conflicts of interest. Similar to the 2021 assessment, and like most of the BMS companies assessed in this Index, Abbott did not score on these indicators that capture the Code commitments that specifically relate to WHA resolution 69.9.

• Abbott is encouraged to consider the gaps identified to revise its policy to better align with the requirements of the Code, specifically Article 7 and recommendation 6 of the guidance on ending the inappropriate promotion of foods for infants and young children supported by WHA 69.9.

Management System

• Abbott shared – under NDA - some local policies and procedures developed by the company to guide its employees on the marketing of BMS as outlined in the company’s related policy(ies). The company does not fully score on management systems as it does not have all Code provisions in place. However, in regard to the commitments met by the company on marketing BMS to healthcare workers that are in line with the Code, the guidance provided by the company to follow and apply these commitments is clear, thus Abbott scores on those elements. However, these can be improved by providing clear instructions on what company personnel should or should not do in each context to uphold commitments related to financial or material inducements and sponsorship, as well as procedures for all provisions related to information provided to health workers.

Policy Commitment

• Abbott does not explicitly exclude the sales of BMS products from bonus calculations for sales representatives. Therefore, the company is not aligned with the requirements of the Code, which explicitly states that incentive measures should not include the volume or sales values of BMS products, regardless of whether they are considered individually or alongside other product sales. Additionally, the company did not confirm if existing requirements related to employee incentives apply to all markets of operation irrespective of local regulations.

• Abbott is encouraged to address the gaps identified to revise its policy to align with the requirements of the Code, specifically Article 8.

Management System

• Abbott confidentially shared some local procedure manuals and management systems developed by the company to guide its employees on the marketing of BMS as outlined in the company’s related policy(ies). The company did not score on management systems as its policy commitments are not in line with the Code. Additionally, Abbott should reinforce its management systems to deliver consistent compliance with its stated commitments across all countries, once brought into full alignment with the Code.

Policy Commitment

• Abbott’s policy commitments relating to the labeling of BMS products have not changed since the 2021 assessment and were not found to be aligned with the requirements of the Code. Therefore, the company does not score on this topic.

• Compared to the last assessment in 2021, the information required by the Code on labels of powdered formula are assessed in more detail to evaluate whether companies have specific commitments covering each requirement as per WHA resolutions 58.32 and 61.20. No relevant information was found nor shared by the company showing Abbott’s commitments for powdered formula label requirements.

• Commitments were found in Abbott’s BMS Marketing Policy showing that labels of its BMS products will include some but not all of the Code requirements described in Article 9, such as committing to providing necessary information regarding appropriate use of the product, ingredients/composition used, storage conditions, batch number and date for safe consumption, amongst others, but no commitments were found for example to ensure that the information is provided in the appropriate local language(s) and that warnings are included against the health hazards of inappropriate preparation.

• Abbott did not commit to state on all BMS product labels/inserts the importance of exclusive breastfeeding in the first six months of life and continued breastfeeding for up to two years or beyond, nor the appropriate age range for consumption and for introduction as required by recommendation 4 of the guidance supported by WHA resolution 69.9. Other missing requirements include prohibiting the use of endorsements by health professionals and any health or nutrition claims unless required by local legislation.

• Abbott is encouraged to consider the gaps identified to revise its policy to fully align with the requirements of the Code, specifically outlined in Article 9 and recommendation 4 of WHA resolution 69.9.

Management System

• No relevant documentation was found or shared by the company of any management systems the company has in place to implement its BMS marketing commitments related to labeling.

• To score in this area, Abbott would need to develop comprehensive management systems, procedures, and other guidance for its employees to implement all commitments set out in its policy(ies) relating to this topic.

Policy Commitment

• Compared to the BMS/CF Marketing Index 2021, companies’ commitments on this topic are evaluated in more detail to ensure their commitments relating to Article 10 of the Code are accurately assessed.

• Abbott was one of the four companies among the 18 assessed that showed full alignment with the Code for what concerns product quality commitments, since the company specified all the Codex standards relating to BMS products that apply at a minimum to ensure quality and hygiene within its products in all markets.

• Abbott is encouraged to ensure that the listed standards are regularly revised so that the most updated versions are adhered to.

Management System

• Abbott confidentially shared the quality manual developed by the company to guide its employees on the responsible marketing of BMS as outlined in the company’s related policy(ies). The company was one of four companies among the 18 assessed found to have clear procedures for implementing the applicable Codex standards that the company has explicitly listed.

Policy Commitment

• Abbott’s policy commitments relating to the implementation and monitoring of its marketing practices to the principles of its BMS marketing policy have not changed since the 2021 assessment and were found to be well-aligned with the requirements of the Code.

• Based on Abbott’s BMS Marketing policy, the company was found to have commitments in line with Article 11 of the Code and commits to apprising marketing personnel of its BMS marketing policy(ies) and their responsibilities relating to it.

• However, no explicit commitments were found for Abbott stating that the company would support and not undermine efforts made by governments and international bodies in the adoption of legal frameworks that are fully aligned with the Code. Therefore, the company did not fully score on this topic

Management System

• Although Abbott did not fully score on this topic, its management systems and procedures have moderately improved since the 2021 assessment.

• Based on Abbott’s BMS Marketing Policy and documentation of management systems shared - under non-disclosure agreement – the company was found to clearly assign executive responsibilities for the implementation of its BMS marketing policy(ies), however, no clear evidence was provided of a system to ensure that relevant executives are aware of these responsibilities.

• Abbott also confidentially shared global and local procedures that demonstrate that the company communicates to its employees and contractual third-parties (distributors and retailers) their responsibilities in implementing the company’s BMS marketing policy, and outlines a clear set of sanctions and penalties for employees who do not comply with its BMS marketing commitments. The company was also found to have an internal and external allegation system to report on non-compliance with its BMS Marketing Policy, and clear guidelines to employees and contractual third parties to take necessary corrective action. However, no relevant procedures were identified for this assessment to track corrective action taken by employees and third parties. In addition, the company did not clearly demonstrate management systems in place concerning the effectiveness of its internal reporting systems of identified incidents of non-compliance. Although Abbott mentioned conducting annual internal audits, it confirmed that they do not conduct external audits of its marketing practices.

• Like most companies assessed in the BMS Marketing Index, the company was found to follow globally recognized food safety and quality standards to certify its BMS products, such as FSSC 22000, ISO 22000 and HACCP, which was clearly evidenced in Abbott’s 2021 sustainability report.

• Abbott is encouraged to adopt effective company-wide governance, auditing, and management arrangements to ensure that the policy and systems work effectively.

Policy Commitment

• For this assessment, Abbott’s policy commitments relating to lobbying and policy influence, which also apply to engaging on issues relating to BMS and the Code, were based on the company’s Corporate Political Participation section of its website. The company did not fully score on this topic.

• Some commitments were found for Abbott where it states that the purpose of all lobbying is to support the public interest as well as to meet the company's objectives, and that it reviews the positions of trade associations and industry policy groups it belongs to and assesses the extent to which they align with the company’s own policy positions.

• However, it does not explicitly commit to ensure control over all lobbyists to ensure their understanding and adherence to organsational policies, nor to support and not undermine existing policy frameworks, the work of WHO and government efforts to develop regulations to implement the Code in full.

Management System

• Based on Abbott’s Corporate Political Participation webpage, the company states that the Board has oversight of Abbott’s lobbying principles, positions and activities. The company also provides information on control mechanisms including regular reporting to the Board and internal audits. However, no information was found regarding executive responsibilities to implement Abbott’s commitments on lobbying and stakeholder engagement.

Disclosure

• Abbott did not fully score on this topic as there was limited information in the public domain on the company’s BMS marketing commitments and related accountability mechanisms.

• Compared to the 2021 assessment, Abbott’s revised 2023 BMS Marketing Policy was not publicly available at the time of the assessment.

• Some information was found however on the company’s website clearly stating its support for breastfeeding, as well as a published list of some of the trade associations and industry groups the company is a member of, related to BMS.

• Since the last BMS/CF Marketing Index 2021, a few indicators have been added to further assess companies’ level of disclosure in lobbying on BMS marketing issues and the Code. Similar to the 2021 assessment, Abbott falls short in disclosing lobbying-related activities. No information was found in the public domain of an assessment of the company’s compliance with its policy on lobbying and interactions with public authorities. Like most companies assessed in this iteration, no information was found either on Abbott’s website of its interactions, or that of its trade associations, in legislative processes related to the Code and BMS marketing, nor of links to relevant external platforms that may include this information. ATNI also advises the company to follow key public policy frameworks in private sector engagement and lobbying such as the Code, the WHO framework of engagement with non-state actors and OECD principles for transparency and integrity in lobbying, among others, which the company was not found to publicly refer to.

• Abbott is encouraged to have its BMS marketing commitments available and easily accessible in the public domain and improve its disclosure in various aspects relating to the Code and responsible marketing, including lobbying and accountability.