Reckitt

Policy Commitment

• Reckitt’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 when compared to the other companies assessed, Reckitt’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. Furthermore, WHA resolution 71.9, which calls for continued implementation of the recommendations of has not been acknowledged by the company either.

• Reckitt did not receive a full score on the new indicator that assesses whether companies apply its 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.

• Additionally, Reckitt did not receive a full score on the indicator that assesses the application of BMS marketing commitments to all joint ventures and subsidiaries where the company has a holding. It was observed that the company applies these commitments only to entities where it holds a majority ownership stake greater than 50%.

Policy Commitment

• Reckitt’s policy commitments relating to advertising and the promotion of BMS, which are relatively well-aligned with the requirements of the Code, have not changed since the 2021 assessment. These remain publicly disclosed.

• Compared to the last assessment in 2021, several of ATNI’s indicators in this topic have been adapted to capture companies’ explicit commitments in digital environments too, such as advertising on social media and point-of-sale promotions on online retail stores, as well as establishing contact with caregivers through baby clubs and social media groups – all actions that are not compliant with the Code.

Reckitt does not show evidence of these commitments in full, the company is advised to include explicit statements on which forms of media and channels BMS marketing commitments apply to, particularly on how they apply in the digital environment, and to which forms of retail.

• Indicators were also revised to ensure accurate and complete inclusion of all recommendations of the guidance on ending the inappropriate promotion of foods for infants and young children supported by WHA resolution 69.9, for example by adding indicators to address cross-promotion of BMS products and educating caregivers on infant and young child feeding, both of which BMS companies should not do according to the Code.

Reckitt was found to demonstrate limited adherence to the guidance outlined in WHA 69.9.

It was one of the only two companies to explicitly commit not to distribute any gifts, articles or utensils that may promote the use of BMS or bottle feeding in any setting or via any means to pregnant women and mothers of infants.

However, while committing that all employees will not engage in any direct or indirect contact with pregnant women or mothers of infants about BMS products, the policy lacks specificity regarding forms of contact with these groups.

While the company's BMS Marketing Policy does not allow direct educational activities involving its staff, it does not extend to indirect educational efforts. Therefore, ATNI recommends that Reckitt align with recommendation 6 of WHA 69.9 and broaden the policy's scope to cover indirect educational activities as well.

Furthermore, Reckitt's policy lacks a commitment to avoid cross-promoting different types of BMS products through distinct packaging designs and labels.

• In its BMS Policy Marketing, Reckitt is encouraged to consider referring to caregivers of infants and young children, rather than solely addressing mothers of infants. This adjustment would explicitly extend the company's commitments to all caregivers, ensuring inclusivity and comprehensive coverage.

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

Management System

• The company, however, does not score on management systems as the instructions and procedures were not found to cover the implementation of the company’s commitments consistently and comprehensively on public advertising and promotion of BMS.

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

Policy Commitment

• Reckitt’s policy commitments relating to marketing BMS throughout the healthcare system, which are relatively well-aligned with the requirements of the Code and remain publicly disclosed, 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, Reckitt did not score on the indicators that capture these Code commitments that specifically relate to WHA resolution 69.9.

• Reckitt is one of only three companies among the 18 assessed to have scored on having explicit commitments not to provide or pay for ‘professional service representatives’ or similar personnel to work in the healthcare system.

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

Management System

• Reckitt shared – under NDA - global staff training materials and some local procedure manuals 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 does not fully score on management systems as it does not have all Code provisions in place. Although it is one of four companies among the 18 assessed that score on management systems in this topic, these can be improved by providing more concrete examples of what company personnel should or should not do in each context.

Policy Commitment

• Reckitt’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. These commitments are publicly disclosed.

• 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, Reckitt has shown Code compliant commitments by stating that it would not provide free or low-cost supplies of the BMS products covered by its policy unless officially requested by a competent government authority of the country affected by the emergency or by the designated emergency response coordinating body acting on behalf of the government. The company was found to have explicit requirements in place in the case of an official authoritative BMS donation request, including ensuring that distribution is targeted and not delivered directly to caregivers, and that supplies are based on identified need.

However, no explicit statement was found to guarantee that supplies will continue for as long as the infants concerned need them and to avoid using such donations as a sales inducement. Additionally, the company policy does not explicitly state that products should not display company brands, and that supplies should have a 6-month shelf life from the moment of delivery.

• Similarly, although 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, it does not explicitly prevent the use of such donations as a sales inducement as per Article 6.6 of the Code.

• Furthermore, Reckitt continues to provide BMS product samples for research and product evaluation purposes while the Code does not allow their provision to healthcare institutions under any circumstances and for any reason, even if the products are not directly provided to consumers or patients.

• Reckitt also falls short of meeting the Code requirements on donations by allowing the provision of educational materials and/or practice-related items to healthcare professionals, which is specifically addressed in recommendation 6 of the guidance supported by WHA resolution 69.9 to avoid due to potential conflict of interest.

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

Management System

• Reckitt shared – under NDA - global staff training materials developed by the company to guide its employees on the responsible marketing of BMS, as outlined in the company’s related policy(ies). Even though Reckitt provides clear instructions to staff on how to interpret and apply relevant commitments related to BMS product donations in humanitarian and emergency settings, the company does not fully score on management systems since it does not have all Code provisions in place. Regarding procedure manuals, there was no information on the public domain or shared with ATNI.

Policy Commitment

• Reckitt’s policy commitments relating to marketing BMS to healthcare workers, which are relatively well-aligned with the requirements of the Code and remain publicly disclosed, 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. Reckitt did not score on this indicator and none of the 18 companies assessed met this requirement.

• Reckitt however is one of only four companies out of the 18 assessed to explicitly state that any material which contains information about formula use provided to health workers will include information on the social and financial implications of formula use and the health hazards of inappropriate feeding methods, unnecessary or improper use of BMS and their inappropriate preparation, as per the requirements of the Code.

• 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, Reckitt did not score on these indicators that capture the Code commitments that specifically relate to WHA resolution 69.9.

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

Management System

• Reckitt shared – under NDA – global staff training materials and some local procedure manuals 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 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, complete and consistent across different markets, thus Reckitt scores on those elements. However, these can be improved by providing more concrete examples of what company personnel should or should not do in each context.

Policy Commitment

• Reckitt continues not to commit to exclude the volume and/or value of sales of products covered by the company’s BMS marketing policy from bonus calculations for sales representatives, as well as from setting quotas for the sales of such products.

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.

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

Management System

• Reckitt shared – under NDA - global staff training materials 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 did not score on management systems as its policy commitments are not in line with the Code. Regarding procedure manuals, there was no information in the public domain or shared with ATNI. Reckitt should bolster its management systems to deliver consistent compliance with its stated commitments, once brought into full alignment with the Code.

Policy Commitment

• Reckitt’s policy commitments relating to the labeling of BMS products, which are relatively well-aligned with the requirements of the Code, have not changed since the 2021 assessment. These remain publicly disclosed.

• 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 commitments were found for Reckitt regarding these requirements for powdered formula labels, resulting in the company not scoring on this indicator.

• Although the company was found to have explicit commitments pertaining to the requirements described in Article 9 of the Code, it did not fully score on some, particularly where no commitments were found on ensuring the appropriate age range is stated on the labels. Commitments were also not found for Reckitt that cover the Code labeling requirements strengthened by the guidance on ending the inappropriate promotion of foods for infants and young children that is supported by WHA resolution 69.9.

• Reckitt continues to not explicitly commit to not place any health or nutrition claims on its BMS products, unless specifically provided by local legislation, as per WHA resolutions 58.32, 63.23 and 69.9.

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

Management System

• Reckitt shared – under NDA – global staff training materials 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 does not score on management systems as it does not have all Code provisions in place. Also, in regard to the commitments met by the company on labeling BMS products that are in line with the Code, the guidance provided by the company to follow and apply these was not found to be clear, complete or consistent. Regarding procedure manuals, there was no information on the public domain or shared with ATNI. Reckitt is encouraged to improve its guidance in these aspects and develop related procedures that outline clear standards of practice in labeling BMS products.

Policy Commitment

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

• Reckitt did not fully score on this topic since its policy commitments relating to the quality of BMS products were not comprehensive. This is because the company does not specify in its policies (BMS marketing policy and internal quality manuals) all Codex standards relating to BMS products that would apply at a minimum.

• Reckitt is encouraged to explicitly state all specific Codex standards it follows at a minimum.

Management System

• Reckitt shared – under NDA - global procedure manuals developed by the company to explain the quality management systems for its products, including BMS. The company was one of four companies among the 18 assessed found to have clear procedures on implementing the applicable Codex standards that the company has explicitly listed.

Policy Commitment

• Reckitt’s policy commitments relating to monitoring compliance of its marketing practices to the principles of its BMS marketing policy have not changed since the 2021 assessment. These commitments, which specifically pertain to Article 11 of the Code, remain publicly disclosed.

• The company is encouraged to make its commitments more explicit by stating that it will not undermine and support existing public policy frameworks, the work of WHO or similar agencies, and Government efforts to develop regulations to implement the Code in full.

Management System

• Reckitt shared – under NDA - global staff training materials and some local procedure manuals developed by the company to guide its employees and contractual third parties on the responsible marketing of BMS as outlined in the company’s related policy(ies), as well as effective monitoring and management of incidences of non-compliance with the company policy(ies).

• Reckitt was found to clearly assign executive responsibilities for the implementation of the company’s BMS marketing policy. However, it could not provide evidence of making relevant executives aware of their responsibilities under the company’s own policies nor clear evidence of assigning the Board responsibilities for overseeing the implementation of these BMS marketing commitments.

• The company demonstrates a commitment to addressing incidences of non-compliance as outlined in its BMS marketing policy. However, no clear guidelines were found in the public domain or shared by the company to explain the company’s process for taking corrective actions and the responsibilities for employees and third parties involved.

• To improve its score on this topic, Reckitt is encouraged to provide clear guidelines regarding the process for corrective actions and the responsibilities of both employees and third parties involved.

Policy Commitment

• Reckitt has a publicly available policy on transparent interaction with authorities and organizations which is also applied when engaging on issues relating to BMS and the Code. Based on this policy, Reckitt continues to cover the relevant commitments assessed in this topic. However, the company is encouraged to improve its lobbying policy by explicitly stating that the purpose of all lobbying is to support the public interest as well as to meet the company's objectives.

• Like other companies, Reckitt did not show commitments not to undermine or support existing public policy frameworks, the work of WHO or similar agencies, and Government efforts to develop regulations to implement the Code in full.

Management System

• Based on Reckitt’s related policies, the company clarifies that its Board has oversight of its global advocacy policy and that it names an executive function with the responsibility of implementing this policy. The company also provides clarity on control mechanisms (e.g. reporting to the Board, internal audits). However, no evidence was found in the public domain, nor provided by the company, that the company’s Board has oversight of its lobbying positions and activities. To fully score on this topic, Reckitt is encouraged to improve on this aspect.

Disclosure

• In regard to commitments that were found for Reckitt that are in line with the Code, the level of disclosure on these commitments is relatively high and has not changed since the 2021 assessment.

• However, Reckitt can improve on this topic by disclosing information about its internal assessments of compliance with the commitments in its BMS marketing policy, as well as disclosing the full external auditor reports, and not just summaries of them. Additionally, Reckitt is encouraged to disclose each complaint or criticism made by stakeholders on the company’s BMS marketing and explain how it responds to each of those rather than providing a general public statement.

• 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, Reckitt falls short in disclosing lobbying-related activities. No information was found in the public domain nor shared by the company of an assessment of the company’s compliance with its global advocacy policy. Like most companies assessed in this iteration, no information was found either on Reckitt ’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. Additionally, the company does not explicitly state which public policy frameworks and relevant laws, standards, and codes are respected when lobbying. Although Reckitt is part of the EU transparency register, ATNI advises the company to also follow other key public policy frameworks in private sector engagement and lobbying such as the WHO framework of engagement with non-state actors and OECD principles for transparency and integrity in lobbying, among others, and to publicly disclose this information in its website/reports.

• Reckitt is encouraged to consider the gaps identified in its level of disclosure and have this information available and easily accessible in the public domain.