This follows salary work previously conducted by Bureau Verities for Nestle AS in other global operations. Scope of Work and Methodology The assurance was conducted in the Philippines between 1 1 and 22 October 2010 by two assessors from Bureau Verities UK Limited. The team has extensive experience of undertaking WHO Code compliance related work and was supported by two representatives of Bureau Verities Philippines.
Preceding the assurance activities In the Philippines, Bureau Verities conducted the following activities: completed a Gap Analysis of the WHO Code and IEEE and the RI to consider where the scope of local legislation differed from the WHO Code; ; requested a list of Nestle Philippines employees, healthcare facilities and healthcare professionals and distributors from Nestle Philippines; ; Identified other external stakeholders (through the Bureau Verities representatives in the Philippines) and local Nags concerned with the protection, promotion and support of breastfeeding; and, ; independently determined a schedule of interviews to take place in the Philippines between 11 and 22 August 2010. All external stakeholder interviews were arranged by Bureau Verities. During the assurance Bureau Verities: ; undertook 71 interviews with a comprehensive range of key external stakeholders (Government officials, distributors and healthcare professionals).
Nestle was not disclosed as the client In order to avoid blabs during Interviews, neither was Nestle Philippines informed in advance of who would be interviewed; ; selected and visited 28 healthcare facilities and 83 retail locations to visually assess compliance with the WHO Code, IEEE and the RI, with reference to articles relating o labeling and promotion of products; and ; selected 16 Nestle Philippines staff and documentation for respective Interview and review, as part of Its evaluation of Nestle Philippines’ Internal processes for managing compliance with the WHO Code, IEEE and the RI in the Philippines. Nestle WHO Code Assurance: Nestle Philippines Assurance Statement page 3 Findings The following Is a summary of findings from Interviews and document review undertaken with a range of key stakeholders.
All employees interviewed demonstrated an adequate understanding of the WHO Code, IEEE and the RI and the requirements it places upon their role and responsibilities. Bureau Verities identified some areas of improvement in relation to the internal management systems that have been provided to Nestle in a separate internal management report. Distributors Employees interviewed at two distribution companies demonstrated a good level of understanding of the requirements of the WHO Code, IEEE and the RI, and specifically the restrictions it places upon the sale of BUMS. Both distributors demonstrated that no incentive based sales targets are set for BUMS.
Government Due to events outside of Bureau Verities’ control, we were unable to meet with any representatives of Bureau of Food And Drugs in the Philippines; however, an interview was secured with two senior regional representatives of the Department of Health. The representatives were of the opinion that that BUMS manufacturers in the Philippines generally operate in compliance with WHO Code, IEEE and the RI, and stated that all manufactures seek the appropriate permission from the DOD to host scientific lectures and events for healthcare professionals. The DOD conducts ongoing monitoring of the conduct of BUMS manufacturers in the Philippines.
No recent violations of the WHO Code, IEEE and the RI had been brought to their attention. Multilateral organizations/Nags representatives of multilateral organizations and Non-Governmental Organizations in the Philippines with an interest in promotion of breastfeeding. Healthcare facilities and professionals Evidence gathered through interviews with healthcare professionals and observations made in healthcare facilities indicate that Nestle Philippines is operating in line with the WHO Code, IEEE and the RI. All healthcare professionals interviewed explicitly stated that Nestle Medical Delegates do not provide samples of BUMS, and no such samples were observed by Bureau Verities in any of the facilities visited.
Visual observations did not show any incidents of Nestle Philippines promoting products within the scope of the WHO Code, IEEE and the RI in any of the healthcare facilities visited. The healthcare professionals interviewed were of the opinion that Nestle Philippines is professional in its approach to detailing BUMS and knowledgeable in the area of infant nutrition. Retailers Visual observations in a range of retail establishments indicate there is no systematic promotion of any Nestle BUMS products in the Philippines through in-store advertisements, coupon redemption schemes, promotional pricing or any other promotional devices. However, one isolated occurrence of Nestle WHO Code Assurance: Nestle Philippines Assurance Statement page 4 promotion was observed by Bureau Verities.
A milk section of the pharmacy visited was designated by a point of sale, shelf-top banner produced by Nestle Philippines containing the text ‘Infant Formula & Growing Up Milks’ and the strap-line ‘See the he ‘See the Difference’ strap line which is placed directly below the words ‘Infant Formula’ idealizes the use of BUMS as such is against the spirit and intent of the WHO Code. This occurrence was raised at the closing meeting with Nestle Philippines, who confirmed that this specific style of banner was present in 10 pharmacies nationwide. Nestle Philippines recognized this could be misinterpreted and immediate action was taken to remove the ‘See the Difference’ streamline from the banners in question.
