Ethical Marketing of Infant Formula

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All parents want to provide the best for their children.

At Abbott, we believe proper nutrition, especially for babies, is critical for building lifelong health. We work tirelessly to develop the best, most scientifically advanced and innovative, lifesaving nutrition for children everywhere.

Abbott has a long history of doing things the right way.

We have built our reputation on the values of honesty, fairness, and integrity. As employees and leaders, it is our responsibility to ensure our words and actions promote these values.

In this course, you will learn how our commitment to the ethical marketing of infant formula reflects these values.

Upon completion of this course, you will be able to:

• Describe the environment in which we operate,
• Articulate Abbott’s beliefs and commitments,
• Comply with Abbott’s expectations, and
• Know where to go for help and support.

[1] Welcome

1 minute

[2] Introduction to Ethical Marketing of Infant Formula

6 minutes

[3] Abbott’s Beliefs and Commitments

6 minutes

[4] Our Responsibilities

3 minutes

[5] Your Commitment

20 seconds

[6] Knowledge Check

5 minutes

Learning Progress

This Topic is now available.

The sales and marketing practices of infant formula manufacturers are closely scrutinized.

It is our policy to market products in a way that does not interfere with the protection and promotion of breastfeeding.

The reason for this is simple: breastfeeding provides the best nutrition for babies.

For parents who need or want another option, infant formula is the only appropriate, safe alternative. Infant formula should not be marketed in a way that competes with breastfeeding. Adequate and responsible nutrition information ensures the protection of breastfeeding as an important part of promoting the health and welfare of infants. We should support informed and confident choices when mothers do not breastfeed or combination feed, using both breast milk and infant formula.

Abbott takes its responsibility as a leader in the infant formula industry seriously.

We understand that our products affect the health of infants in the most crucial ways. We are committed to delivering optimum nutrition to infants worldwide and supporting each parent’s choice of what to feed their infant.

The infant formula space has many stakeholders and experts.

It is important for all of us at Abbott to recognize the differing positions and goals of these stakeholders. Not only because we all support proper nutrition for infants and young children, but also because governments and regulators look to these stakeholders for expertise, guidance, and support.

The World Health Organization (WHO) plays a key role in the promotion of safe and adequate nutrition for infants.

The WHO’s International Code of Marketing of Breastmilk Substitutes (WHO Code) was published in 1981. The WHO Code is an international set of recommendations covering the marketing of infant formula. The WHO Code aims to promote and protect breastfeeding and to ensure the proper use of breast milk substitutes, when needed.

At the time of its publication, World Health Organization Member States chose by a vote of 118-1 to support the WHO Code.

The WHO Code was adopted as a policy recommendation not as a regulation, and it’s up to each Member State to determine how they follow or implement the WHO Code. Since its publication, 25 countries have implemented measures that are substantially aligned with the WHO Code. Some Member States have limited implementation to specific parts of the WHO Code recommendations and others have implemented restrictions that were not specifically included in these recommendations.

Many governments still look to the World Health Organization for expertise, guidance, and support. The U.N. General Assembly continues to urge governments to implement the Code.

The International Baby Food Action Network (IBFAN) is a vocal and influential public interest group that works to promote, protect, and support breastfeeding and infant feeding.

IBFAN is a network of over 200 groups, including consumer organizations, healthcare worker associations, and parent groups. One of its priorities is to bring about full implementation of the WHO Code by all Member States.

Although we may not always agree with IBFAN’s and other organizations’ principles and methods, we do agree with their goal of supporting the health, growth, and development of all children, especially in early development.

We also agree with IBFAN’s position that all parents should have the right to breastfeed and make informed decisions about feeding infants and young children.

At Abbott, it is important that we listen to the concerns raised by stakeholder groups.

IBFAN and other organizations, such as the Bill and Melinda Gates Foundation and Helen Keller International, are important stakeholders that support governments in the implementation and enforcement of the WHO Code.

The Access to Nutrition Initiative (ATNI) is an important stakeholder actively engaged with the private sector to encourage businesses to do more to achieve good health through improved diets and nutrition.

ATNI’s flagship initiative is the Global Access to Nutrition Index. The index provides ratings on how well the marketing practices of manufacturers of breast milk substitutes align with the standards set out by the WHO Code.

Increasingly stringent regulations in the infant formula space also provide challenges.

Some countries have enacted legislation implementing the provisions outlined in the WHO Code. However, each country interprets the WHO Code differently in response to the needs of its local population and changes in the external environment. As a result, countries in which Abbott operates have varied and sometimes inconsistent regulations that we must follow.

The landscape surrounding the sale and marketing of infant formula remains dynamic.

All Abbott employees who are involved in sales and marketing of infant formula must follow the guidance provided by global and local Abbott policies and procedures.

Finally, differences in local laws and regulations, as well as the fact that many countries have yet to enact legislation, means that some competitors operate in the marketplace aggressively and without regard to local regulations and codes.

The result is that in certain markets, some competitors may push the boundaries of what Abbott would consider acceptable marketing practices.

Abbott’s policy is to support the goal of the WHO Code, marketing our products based on the best science, and ensuring our practices adhere to the laws and regulations of the countries in which we operate.

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Review

Take a moment to review some of the key concepts in this section.

Global Spotlight

The sales and marketing practices of infant formula manufacturers are closely scrutinized.

Adherence to Policies

All Abbott employees involved in the sales and marketing of infant formula must follow the guidance provided by global and local Abbott policies and procedures.

Marketing Our Products

We support the goal of the WHO Code, marketing our products based on the best science, and ensuring our practices adhere to the laws and regulations of the countries in which we operate.

[1] Welcome

1 minute

[2] Introduction to Ethical Marketing of Infant Formula

6 minutes

[3] Abbott’s Beliefs and Commitments

6 minutes

[4] Our Responsibilities

3 minutes

[5] Your Commitment

20 seconds

[6] Knowledge Check

5 minutes

Learning Progress

This Topic is now available.

At Abbott, we believe that the encouragement and protection of breastfeeding is an important part of the health and wellbeing of infants.

We recognize that breast milk provides the best nutrition for healthy growth and development. We also believe breastfeeding helps to form a unique biological and emotional tie between parent and child.

Our Global Policy on the Marketing of Infant Formula (Global Policy) prohibits marketing infant formula in a way that competes with breastfeeding or interferes with the protection and promotion of breastfeeding.

Abbott employees and partners involved in marketing, distribution, or selling of infant or follow-on formula products should not state or imply any superiority of formula feeding to breastfeeding. In addition, employees should not present these products in a way that discourages parents or caregivers from breastfeeding or feeding breast milk to their infants.

We recognize and respect the aims and principles of the WHO Code to contribute to the provision of safe and adequate nutrition for infants.

We agree that breast milk provides the best nutrition for infants, and we support the goal of increasing breastfeeding.

Quick Check

Test your knowledge now!

You overhear an Abbott third party representative saying to a consumer, “Breastfeeding may be fine for some women who have the luxury to take time off work, but for most working women, infant formula is a better choice and is just as good, if not better, from a nutritional perspective.“ What do you do?

Nothing. Abbott has no control over the views and opinions of third parties.

Explain to the third party that while it is okay to say infant formula is more convenient than breastfeeding, they should avoid saying it is better.

Explain to the third party that they should never state or imply any superiority of formula feeding to breastfeeding.

Submit

That's correct!

That's not correct!

You should explain Abbott’s expectation that all employees and partners involved in marketing, distribution or selling of Abbott infant formula or follow-on formula products should not state or imply superiority of formula feeding to breastfeeding.

Our Global Policy commits us to follow the laws and regulations in the countries in which we do business.

We expect that our employees and partners will follow all Abbott policies and applicable local regulations. In countries where local regulations are not as stringent as Abbott standards, employees and partners should follow Abbott policies and procedures.

We are committed to ethically and responsibly communicating about our products.

We believe responsible communication and marketing have value in helping parents and caregivers engage in more informed conversations with their Healthcare Professionals, ultimately leading to better health outcomes.

We are committed to ensuring that all statements, in all our materials and communications, are science-based, balanced and factual.

We expect that all claims made about Abbott products are accurate, supported by sound scientific evidence, and compliant with all applicable laws and regulations.

Quick Check

Test your knowledge now!

You learn that a salesperson working in your region is considering creating their own sales aids. When you ask about the sales aids, the salesperson tells you that no new content is being added, the material is just being rearranged and simplified from the original format to make it easier for parents to understand the information. What do you do?

Nothing. Since the original material was approved for use and no new material is being added, the salesperson can continue to use the sales aids.

Check to confirm that the modified sales aids remain science-based, balanced and factual. If you are satisfied they meet these standards, they are good to go.

Tell the salesperson not to use the sales aids. Explain that all marketing materials must be used in the same form in which they were originally approved for use.

Submit

That's correct!

That's not correct!

Abbott’s Global Policy is supported by local promotional review procedures to ensure that all marketing materials, including digital advertising, are accurate, supported by sound scientific evidence and compliant with all applicable laws and regulations. Once approved, marketing materials must be used in exactly the same form in which they were approved, without alteration.

We recognize that Healthcare Professionals (HCPs) and institutions play an important role in guiding infant-feeding practices and providing patient advice.

We believe that parents should be able to rely on that advice without concern that it has been improperly influenced by incentives from companies seeking to promote their products.

Our Global Policy makes clear that advice from HCPs should be independent and free from undue commercial influence.

We expect that all interactions with HCPs be appropriate and conducted in accordance with all Abbott policies and procedures. No item, gift or benefit may be offered or given as an inducement for the purchase, sale, or recommendation of Abbott products.

Quick Check

Test your knowledge now!

You are a member of Abbott’s Grant Committee. A sales colleague calls you and explains that they are in the process of helping a pediatrician put together a research grant application. Your colleague tells you, “The doctor is really influential and has a big say in whether or not we get our products in rotation at the regional healthcare system.” Your colleague asks for your advice. What do you do?

Outline the criteria that will be used by the committee to award the grant but take care to provide no other advice.

Explain that while it is okay for your colleague to help the doctor with the application, it would not be okay for you to provide any advice.

Explain to your colleague that the doctor needs to apply for the grant on their own, and that assistance should not be provided.

Submit

That's correct!

That's not correct!

Sales colleagues should not assist requestors with their grant applications. Assisting with grant applications could create the appearance that the awarding of a grant is tied to past, present, or future purchases of Abbott products.

We believe there is no one better to decide the most appropriate ways to feed a child than parents, following the guidance and advice of healthcare professionals.

We fully support a parent’s right to choose.

We respect and support every parent’s right to choose the most appropriate methods to feed their children, whether that’s breast milk, formula, or a combination of both.

We expect that all employees involved in marketing activities show respect for consumers’ choices, including people who choose not to use our products.

Click the arrow to begin your review.

Review

Take a moment to review some of the key concepts in this section.

Global Policy on the Marketing of Infant Formula

Our Global Policy prohibits marketing infant formula in a way that competes with breastfeeding or interferes with the protection and promotion of breastfeeding.

Local Laws and Regulations

We expect all employees and partners to follow the laws and regulations in the countries in which they do business.

Ethical Marketing

We are committed to ensuring that all statements in our materials and communications are science-based, balanced and factual.

Independence of Healthcare Professionals

We believe that parents should be able to rely on advice from HCPs without concern that it has been improperly influenced by incentives from companies seeking to promote their products.

Rights of Parents

We respect and support every parent’s right to choose the most appropriate methods to feed their children.

[1] Welcome

1 minute

[2] Introduction to Ethical Marketing of Infant Formula

6 minutes

[3] Abbott’s Beliefs and Commitments

6 minutes

[4] Our Responsibilities

3 minutes

[5] Your Commitment

20 seconds

[6] Knowledge Check

5 minutes

Learning Progress

This Topic is now available.

All employees and partners of Abbott must act responsibly and ethically.

Here are some simple things you can do to ensure you operate in a manner consistent with the beliefs, commitments, and expectations set out in our Global Policy on the Marketing of Infant Formula.

Know and comply with the policies, laws, and regulations in the countries in which you operate.

We expect that our employees and partners will follow all local laws and regulations in countries where we do business. In countries where local regulations are not as stringent as Abbott standards, employees and partners should follow Abbott policies and procedures.

Always promote infant formula in a balanced, fair, and accurate way.

Only use Abbott-approved materials and, where communications are permitted, ensure that they are accurate, supported by sound scientific evidence, and compliant with all applicable laws and regulations.

Ask questions and raise concerns.

If you have a question about an interaction or activity, talk to your manager. If you have a concern, raise the issue. The sooner you raise your concern, the better. A list of resources can be found at the end of this training.

Never discourage breastfeeding.

Infant formula should NEVER be promoted to compete with breastfeeding; nor should marketing materials be presented in a way that discourages breastfeeding.

Abbott leaders have additional responsibilities.

Set clear expectations.

All employees must receive training on and follow relevant policies and procedures. Make sure your team knows, understands, and complies with all relevant policies/procedures, laws, and regulations. If there are changes to these policies/procedures and/or regulations, make sure your team is notified.

Lead by example.

Take personal responsibility for creating a culture that supports ethical behavior. Foster an open environment where employees feel secure asking questions and raising concerns.

Monitor and respond.

Finally, always check to make sure your team is complying with all relevant policies, procedures and regulations. If issues are identified, take appropriate action to ensure improvements are made to prevent further issues.

Click the arrow to begin your review.

Review

Take a moment to review some of the key concepts in this section.

Never Discourage Breastfeeding

Employees and partners should NEVER promote infant formula to compete with breastfeeding.

Responsibilities of Employees and Partners

Abbott employees and partners have a responsibility to:

• Ethically promote infant formula.
• Know and comply with the local policies, laws, and regulations.
• Ask questions and raise concerns.

Responsibilities of Leaders

Abbott leaders have a responsibility to:

• Set clear expectations,
• Lead by example, and
• Monitor and respond.

[1] Welcome

1 minute

[2] Introduction to Ethical Marketing of Infant Formula

6 minutes

[3] Abbott’s Beliefs and Commitments

6 minutes

[4] Our Responsibilities

3 minutes

[5] Your Commitment

20 seconds

[6] Knowledge Check

5 minutes

Learning Progress

This Topic is now available.

Take a moment to confirm your agreement with both statements.

I received, read, understood, and will abide by Abbott’s Ethical Marketing of Infant Formula standards.

I will follow the laws, local regulations, and Abbott policies and procedures relevant to the country where I am doing business. I understand that I must abide by Abbott policies and procedures, even in countries where local regulations are less stringent than Abbott standards.

Confirm

The Knowledge Check that follows consists of 10 questions. You must score 80% or higher to successfully complete this course.

WHEN YOU ARE READY, CLICK THE KNOWLEDGE CHECK BUTTON.

[1] All World Health Organization (WHO) Member States have fully implemented the International Code of Marketing of Breastmilk Substitutes (WHO Code).

[1] True

[2] False

Next

Question 1: Feedback

The Code was adopted as a policy recommendation, not as a regulation, and since its adoption in 1981, 25 of the Member States have enacted legislation implementing the provisions outlined in the WHO Code. Some Member States have implemented only specific parts of the WHO Code recommendations.

[2] As a leader in the infant formula industry, it is important to listen to the perspectives of which stakeholder group:

[1] The World Health Organization (WHO).

[2] International Baby Food Action Network (IBFAN).

[3] Access to Nutrition Inititiatve (ATNI).

[4] All of the above.

Next

Question 2: Feedback

It is important for us as a company to acknowledge and understand the positions and goals of all these stakeholders. This is so not only because we share the same goal, to support proper nutrition for infants and young children, but also because governments and regulators look to these stakeholders for expertise, guidance, and support.

[3] Why is it important for Abbott employees involved in sales and marketing of infant formula to closely follow the guidance that their local procedures provide?

Check all that apply.

[1] The landscape is dynamic.

[2] Abbott does not have a global policy governing the marketing of infant formula.

[3] There are differences in local laws and regulations.

Next

Question 3: Feedback

Abbott employees involved in the sale and marketing of infant formula need to closely follow the guidance of their local procedures because of differences in local laws and regulations, as well as the fact that the landscape in most countries remains dynamic.

[4] Per our policy, Abbott employees and partners involved in the marketing, distribution, or selling of Abbott infant formula or follow-on formula products should never:

Check all that apply.

[1] State or imply any superiority of formula feeding to breastfeeding.

[2] Communicate about our products directly to Healthcare Professionals (HCPs).

[3] Present our products in a way that discourages parents or caregivers from breastfeeding or feeding breast milk to their infants.

Next

Question 4: Feedback

Abbott employees and partners involved in the marketing, distribution or selling of Abbott infant formula or follow-on formula products should never state or imply any superiority of formula feeding to breastfeeding, nor present our products in a way that discourages parents or caregivers from breastfeeding or feeding breast milk to their infants. Communication to HCPs should follow local procedures.

[5] You recently began work in an emerging market. One of your distributors tells you, “All the local companies here ignore the Milk Code. In order to be competitive, we need to do what they are doing.” What do you do?

[1] Since the local distributor clearly knows the market, follow their advice.

[2] Explain to the distributor that local customs should never take priority over Abbott’s global standards and local procedures.

[3] Follow the advice of the local distributor because it is probably in compliance with local laws and regulations.

Next

Question 5: Feedback

We expect that our employees and partners will follow local regulations where they are stricter than the Abbott Global policy. In countries where local regulations are not as stringent as our standards, employees and partners should follow Abbott policy.

[6] Our Global Policy commits us to ensuring all statements in all our materials and communications are:

[1] Science-based.

[2] Balanced.

[3] Factual.

[4] All of the above.

Next

Question 6: Feedback

Our Global Policy commits us to ensuring all statements in all our materials and communications are science-based, balanced and factual.

[7] Meals, gifts, and other items of value may be provided to HCPs as a reward for past or present purchases of our infant formula products, if offered in accordance with local laws and regulations.

[1] True

[2] False

Next

Question 7: Feedback

No item, gift or benefit should ever be offered or given as an inducement for the purchase, sale or recommendation of Abbott products. Remember that parents need to be able to rely on the advice of their HCPs without concern that their advice has been improperly influenced by incentives from companies seeking to promote their products.

[8] We believe there is no one better to decide the most appropriate ways to feed a child than:

[1] Government agencies.

[2] Parents, in consultation with HCPs.

[3] Manufacturers.

[4] Non-governmental organizations.

Next

Question 8: Feedback

We believe there is no one better to decide the most appropriate ways to feed a child than parents following the guidance and advice of healthcare professionals. Our Global Policy states that we respect and support every parent’s right to choose the most appropriate methods to feed their children, whether that’s breast milk, formula, or a combination of both.

[9] You are a salesperson who recently began work in a new market. You have concerns about the activities of a local distributor in your area. What should you do?

[1] Have a quiet word with the local distributor.

[2] Report your concern to your manager or Abbott’s Office of Ethics and Compliance (OEC).

[3] Nothing. The activities of third-party distributors are not Abbott’s responsibility.

[4] Nothing. It is safe to assume the local distributor knows the local market.

Next

Question 9: Feedback

If you have a concern, you should raise the issue. The sooner you raise your concern, the better.

Normally, it is best to raise the concern with your manager. You can also report your concern to the OEC, via Speak Up.

[10] If you have a leadership role in Sales and Marketing, you are responsible for:

Check all that apply.

[1] Making sure your team is notified of any updates to relevant policies, laws and regulations.

[2] Fostering an open environment where employees feel secure asking questions and raising concerns.

[3] Assisting requestors with applications for research and educational grants.

[4] Checking to make sure your team is complying with all relevant policies and regulations.

Submit

Question 10: Feedback

• If you operate in a leadership role in Sales and Marketing, you are responsible for:
• Making sure your team is notified of any updates to relevant policies, laws and regulations;
• Fostering an open environment where employees feel secure asking questions and raising concerns; and
• Checking to make sure your team is complying with all relevant policies and regulations.

Sales and Marketing personnel, including managers, should never assist requestors with their grant applications. Assisting with grant applications could create the appearance that the awarding of a grant is tied to past, present or future purchases of Abbott products.

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Where to Get Help

Manager or Supervisor

If you have questions or concerns about an activity or interaction, the best place to start is with your manager or supervisor.

Code of Business Conduct

For Abbott’s fundamental set of expectations about interactions with others, consult the Code of Business Conduct.

Office of Ethics and Compliance (OEC)

The OEC is a global resource available to address your questions or concerns about our company’s values and standards of conduct.

OEC Policies and Procedures – For our company’s global and country-specific OEC policies and procedures:

• Abbott employees should visit iComply.
• Click here to access our Global Policy on the Marketing of Infant Formula.

OEC Contacts – You are encouraged to contact the OEC at any time with any ethics and compliance questions, or to discuss concerns about possible violations of our written standards, laws, or regulations.

• Visit the Contact OEC page on the OEC website on Abbott World.

Ethics and Compliance Helpline – Visit our multilingual Ethics and Compliance “Speak Up” Helpline to voice your concerns about a potential violation of our company’s values and standards of conduct. The Helpline is available 24 hours a day, 7 days a week and allows you to submit concerns online or by calling an operator who speaks your language. You can also email investigations@abbott.com to report a potential violation.

Course Resources

Transcript

Click here for a full transcript of the course

Welcome

Ethical Marketing of Infant Formula

Our Philosophy

Objectives

Table of Contents

Introduction to Ethical Marketing of Infant Formula

Global Spotlight

Important Stakeholders

Increasing Regulations

Inconsistent Competitors

Review

Table of Contents

Abbott’s Beliefs and Commitments

Health and Wellbeing of Infants

Quick Check

Local Laws and Regulations

Ethical Marketing

Quick Check

Independence of Healthcare Professionals

Quick Check

Rights of Parents

Review

Table of Contents

Our Responsibilities

Responsibility of All Employees and Partners

Responsibility of Leaders

Review

Table of Contents

Your Commitment

Confirmation

Knowledge Check

Introduction

Assessment

Feedback

Survey

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Ethical Marketing of Infant Formula

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Course Description: At Abbott, we believe proper nutrition for babies is critical for building lifelong health. In this course, we outline the beliefs and commitments that guide the marketing and sale of our infant formula and outline what we can do to ensure we operate in a manner consistent with Our Global Policy on the Marketing of Infant Formula. This course will take approximately 20-25 minutes to complete.

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