RCPCH due diligence

Our due diligence policy, which you can download below, sets out robust safeguards for the engagement with Formula Milk Companies (FMCs) and other commercial organisations.

Update as of 13 February 2019

RCPCH Council has made the decision to no longer accept any funding from formula milk companies - see full statement.

We will update the below content in due course.


Background

RCPCH consulted in 2016 with members about relationships with commercial organisations including Formula Milk Companies (FMC). The vast majority of respondents said that RCPCH should accept funding from formula milk companies and allow them to advertise specialist products, subject to a robust set of safeguards being in place.

Key points to highlight

  • The due diligence policy clearly states that RCPCH will not accept advertising or conference stands promoting standard breast milk substitutes. However, we will accept advertising and conference stands providing information about specialist formulas.
  • In relation to educational and research projects, there will be no involvement by the funder in the selection of topics, choice of speakers, programme content, or spend of funds.

Process

Senior RCPCH staff, Council and the Board of Trustees put together due diligence criteria that set out the robust criteria companies must meet if RCPCH is to accept funding. These criteria are in line with Charity Commission guidance.

Any organisation providing funding to RCPCH, including formula milk companies, must first complete a self-disclosure questionnaire, available to download below.

Following this, RCPCH undertakes a due diligence exercise addressing activities by the funder that might be at variance with our objectives or represent a proven breach of 'required codes of conduct'.

Criteria

In order for RCPCH to accept funding, organisations must do the following.

  • Meet relevant Codes of Practice (eg ABPI Code of Practice for the Pharmaceutical Industry; the World Health Organisation International Code of Marketing of Breastmilk Substitutes), or show demonstrable progress and commitment to working towards meeting them (eg commissioning an independent report into compliance with the relevant Code, and a stated commitment to address gaps identified).
  • Demonstrate willingness to share information on breaches in the UK, and internationally, of the relevant Code/s, any past or ongoing criminal investigations or prosecutions for illegal activity, and remediating actions taken.
  • Provide a reasonable explanation should any inconsistencies be identified between information provided by them and information obtained by RCPCH.
  • Provide evidence of robust governance by the parent company of national businesses within the group and plans for continued development and improvement.
  • Ensure sign-off of 'Due Diligence' returns to RCPCH by an international level senior director.

Formula milk companies that have met the due diligence criteria

As of 15 June 2018, of the four major formula milk companies who applied to work with RCPCH, to date Danone and Nestle have met our criteria, and this will be kept under review. Dialogue is continuing with the other companies.