General Mills i

General Mills generates less than 5% of its sales in non-OECD countries. Therefore, the company was not assessed on Undernutrition in the Global Index 2018.

Nutrition

• The goal of General Mills is, “to provide people with nutritious, convenient food that can help them live healthier lives.” The company articulates a commitment to improve the variety and health profile of its products. However, this commitment does not seem to be seen as a core driver of the company’s commercial growth strategy which aims, “to create market-leading growth that will deliver top-tier returns to shareholders.” Even though the company focuses on consumer preferences, it failed to provide evidence of strategically incorporating a focus on health and nutrition into its business model.
• The company could strengthen its performance by translating its Global Responsibility goals related to nutrition into its commercial growth strategy by clearly articulating and including nutrition as a route to growth. Practical incorporation of such growth commitment is considering nutrition and health in mergers and acquisitions.
• General Mills’ publicly available nutrition strategy focuses on nutrition, labeling and marketing but lacks clearly articulated objectives. This is an area the company should focus on more in its public reporting.
• To strengthen its nutrition governance, the company should expand its focus beyond its home and major markets, to low-income populations. Moreover, the company is encouraged to strengthen its public disclosure to allow stakeholders to better understand how its commitments and related performance is realized. This encompasses areas such as sales generated from healthy products, nutrition-risk assessment and more detailed descriptions of its enterprise risk management process, nutrition targets and progress on achieving them, and the structure of the CEO’s remuneration.
• The company has assigned formal oversight of its nutrition activities to the Board of Directors / CEO and day-to-day responsibility for delivery to senior management. The company has an opportunity to leverage this governance structure and strengthen its strategic approach to health and nutrition.
• Nutrition activities are reported within the annual, company-wide Global Responsibility Report. Contrary to best practice, however, there is no indication that the report is independently reviewed or verified.

Undernutrition

Nutrition

• General Mills commits to invest in R&D to improve the health profile of its products and although it publishes the percentage of revenues it spends overall on R&D, it has not set any forward-looking targets related to nutrition, which it is encouraged to do.
• General Mills does not use an NPS to calculate the overall nutritional quality of individual products. Rather it has developed its ‘U.S. Health Metric Criteria’ based on U.S. FDA recommendations. However, these metrics are applied only in its major markets and not globally. They are also not published in any detail to allow scrutiny of them. These metrics stipulate various goals, e.g. reducing negative nutrients by 5% or more and increasing beneficial nutrients by 10%. It has also made commitments to (re)formulate products to meet specific internal calorie limits and/or meet health or nutrition claim criteria (as defined by the FDA).
• While the Global Citizenship report contains consolidated data on new healthy products launched, which is commended, and an industry best-practice, the company reports only on the percentage volume of U.S. retail sales that met its criteria in the FY2016, but not on the percentage of products that meet an overall healthy standard as it does not have such a metric. It is encouraged to adopt a Nutrient Profiling System and report annually on sales generated from healthy products, globally and in its major markets.
• Some specific targets are articulated for some categories, such as achieving a 20% sodium reduction in ten key product categories by 2015. Typically, the company reports only retrospectively, usually in respect of its U.S. portfolio only, rather than setting consistent forward-looking targets for achieving certain reductions in negative nutrients or adding positive nutrients for all categories globally and reporting consistently on its progress in achieving all targets.
• While the company commits to improving the health profile of its products, it disclosed to ATNF that only 24% of its U.S. products (not sales weighted) meet its definition of a healthy product based on the CFBAI criteria. The Product Profile estimated that 23% of General Mills’ global portfolio and 21% of its U.S. product portfolio is healthy according to the Health Star Rating system. Even though these results indicate that the company’s approach to assessing nutritional quality is probably robust, there is significant scope remains for it to increase the proportion of healthy products in its portfolio.
• The company provided to ATNF the percentage of its U.S. portfolio that meets the CFBAI nutrition criteria for marketing to children and similar figures for the percentage of its EU portfolio that meets the EU Pledge criteria. However, it did not provide figures for other markets.
• Overall, General Mills is strongly encouraged to improve its disclosure to allow stakeholders to understand the relative scale of improvements made to its portfolio globally and to track progress.

Undernutrition

Nutrition

• As a step forward since 2016, the company has published a high-level goal to expand its portfolio to meet diverse consumer needs and make healthy food more accessible. It also makes a broad statement on the affordability of nutritious foods. However, General Mills does not yet publish any information on how it ensures that healthy products are in fact made accessible to low-income populations in developed markets and the lack of that information prevents further assessment and results in a relatively low score in this area.
• The company could strengthen its performance by defining clear commitments for the whole business, with particular reference to low-income populations, which it should formalize in an accessibility and/or affordability policy. That policy should be accompanied by clear targets for improving accessibility and affordability based on analysis of low-income populations’ ability to pay for and access healthy products currently, undertaken in multiple markets.

Undernutrition

Nutrition

• Since 2016, General Mills’ performance on criteria related to responsible marketing to all consumers (criteria D1 and D2) significantly decreased to a score of 0%. During the research process the company stated that it has a series of policy documents which collectively go beyond the ICC Framework with regards to responsible marketing to all consumers. General Mills provided further commentary that these commitments and policies are applied to all marketing initiatives globally. However, as the company did not provide any evidence of those policies and commitments, its statements could not be verified by ATNF. General Mills is strongly encouraged to publish its policies related to responsible marketing to all consumers, clearly indicating which media are covered. It could also pledge to adhere to the ICC framework and commission annual independent audits on compliance with its policy.
• In terms of responsible marketing to children, General Mills commits to the International Food and Beverage Alliance (IFBA) pledge on a global level, in the U.S. to the Children’s Food and Beverage Advertising Initiative (CFBAI) pledge and the CARU guidelines, and in the EU to the EU Pledge. It also supports local pledges in Brazil, Canada, Singapore and Australia. General Mills applies CFBAI Nutrition Criteria globally, except when there is a locally-applicable standard in the given jurisdiction. However, it is important to note that there is a discrepancy in the scope of its responsible marketing commitments on responsible marketing techniques depending on the geography, with the company’s commitments much higher in its home market. General Mills is strongly encouraged to extend the application of its U.S. responsible marketing techniques commitments globally so as to apply the same standards everywhere.
• General Mills does not advertise products that do not meet the CFBAI/EU Pledge or IFBA criteria for healthy products suitable for children under 12 when they represent 35% or more of an audience and clearly prohibits advertising in media primarily directed to children under six. This is commended. General Mills is now one of only a few companies that have adopted the best practice of not marketing in either primary or secondary schools. General Mills should expand the scope of the media covered by its policy and apply it when children make up more than 25% of a general audience. It should also set out how various marketing techniques will be used and expand commitments to prohibit marketing near primary or secondary schools or other places popular with children, as recommended by the WHO.
• In addition to the annual IFBA compliance review, the CFBAI audits the compliance of all signatories with its pledge annually and publishes industry-wide compliance figures. However, unlike some other companies, General Mills does not publish its individual compliance level. Disclosing publicly the company’s individual compliance level for TV and digital marketing would have a positive impact on the company’s performance and demonstrate good transparency.

Undernutrition

.

Nutrition

• General Mills makes a clear commitment to support the health and wellness of employees in all offices worldwide. Many examples are provided of initiatives across its international offices. However, the company did not provide evidence of having set employee participation targets nor other outcome targets since 2016. Although it states that it conducts annual internal evaluations, it publishes only qualitative information about the programs and does not provide any measure of whether the programs are effective and have improved participants’ diets or health.
• In terms of commitments to support to breastfeeding mothers at work, the company could improve its performance by adopting and publishing global policy and by extending the length of paid maternity leave to six months or more. The company is encouraged to provide more public reporting on this topic.
• The General Mills Foundation funds some nutrition education and active lifestyle programs in its home U.S. market. However, the selection of these programs does not appear to be guided by a formal policy or set of guidelines, as none are published. Some programs’ health impacts are independently evaluated, but the Foundation does not disclose whether this is the case for all programs. Overall, the company’s approach to consumer education does not appear to have changed since the last Index.

Undernutrition

Nutrition

• General Mills supports the IFBA pledge which includes nutrition labeling commitments for the front-of-pack (FOP) and back-of-pack (BOP) across its global markets. The company commits to provide information on Guideline Daily Amounts (GDA) on FOP labeling and BOP on a majority of key nutrients either for either single or multiple servings.
• In the U.S. it commits to the Facts Up Front initiative and provides levels of calories, sodium, saturated fat and sugars per serving on the front of its food packages but not in an interpretative format. The company is encouraged to adopt a global policy which would extend its commitments on BOP labeling to align with best practice, and adopt an interpretative FOP labeling format globally, and to not undermine existing local interpretative FOP labeling systems by implementing alternative or additional systems.
• The proportion of markets in which General Mills has achieved full compliance with its labeling commitments was shared only under NDA. The company could increase is transparency by providing information on how many markets it has implemented its full labeling commitments in and for what proportion of products.
• As in 2016, the company does not appear to have a policy to determine whether products can carry claims in markets where nutrition and health claims are not well regulated. The company is encouraged to establish a commitment to follow Codex guidance with regard to health/nutrition claims in markets where national regulatory systems are weak or absent. Best practice would include tracking and disclosing the percentage of products carrying health and/or nutrition claims in all markets.

Undernutrition

Nutrition

• General Mills has a Civic Policy and Public Policy in place. However, the company does not report publicly on topics about which it engages and does not make an explicit commitment not to lobby against public health topics. To strengthen its approach, the company could commitment to lobby only in support of public health initiatives in all markets.
• General Mills could improve its transparency related to its commitments and activities on lobbying and influencing governments and policymakers on nutrition issues. The company only discloses its membership in U.S. trade associations to which it paid dues of $25,000 or more and political expenditures. Moreover, it does not set out whether it has any governance conflicts of interest or holds Board seats on industry associations and/or advisory bodies related to nutrition issues. The company could extend the scope of reporting beyond the U.S. market.
• General Mills engages with stakeholders, "to accelerate its progress on social and environmental initiatives. Its approach includes open dialogue, collaboration and transparent disclosure.” Topics covered include food safety, health and nutrition, wellness, diverse consumer needs as well as other issues. However, it is not clear from its current limited disclosure whether it engages with stakeholders around the world nor whether and how stakeholder input is used to improve the company’s policies and performance on nutrition – which should be its goal.

Undernutrition