Are industry-funded charities promoting “advocacy-led studies” or “evidence-based science”?: a case study of the International Life Sciences Institute

Abstract

Background:
Industry sponsorship of public health research has received increasing scrutiny, and, as a result, many multinational corporations (MNCs), such as The Coca-Cola Company and Mars Inc., have committed to transparency with regard to what they fund, and the findings of funded research. However, these MNCs often fund charities, both national and international, which then support research and promote industry-favourable policy positions to leaders. We explore whether one industry funded charity, the International Life Sciences Institute ('ILSI'), is the scientifically objective, non-lobby, internationally-credible body that it suggests it is, so as to aid the international health and scientific communities to judge ILSI's outputs.

Methods:
Between June 2015 and February 2018, U.S. Right to Know), a non-profit consumer and public health group, submitted five U.S. state Freedom of Information requests (FOIs) to explore ILSI engagement with industry, policy makers, and/or researchers, which garnered a total of 17,163 pages for analysis. Two researchers explored these documents to assess the activities and conduct of ILSI against its purported objectives.

Results:
Within the received documents we identified instances of ILSI seeking to influence research, conferences, public messages, and policy, including instances of punishments for ILSI bodies failing to promote industry-favourable messaging. We identified ILSI promoting its agenda with national and international bodies to influence policy and law, causing the World Health Organization to withdraw from official relations with what it now considers a private sector entity.

Conclusions:
ILSI seeks to influence individuals, positions, and policy, both nationally and internationally, and its corporate members deploy it as a tool to promote their interests globally. Our analysis of ILSI serves as a caution to those involved in global health governance to be wary of putatively independent research groups, and to practice due diligence before relying upon their funded studies and/or engaging in relationship with such groups.

Full text

R E S E A R C H Open Access
Are industry-funded charities promoting
“advocacy-led studies”or “evidence-based
science”?: a case study of the International
Life Sciences Institute
Sarah Steele
1,2*
, Gary Ruskin
3
, Lejla Sarcevic
2
, Martin McKee
4
and David Stuckler
4,5
Abstract
Background: Industry sponsorship of public health research has received increasing scrutiny, and, as a result, many
multinational corporations (MNCs), such as The Coca-Cola Company and Mars Inc., have committed to transparency
with regard to what they fund, and the findings of funded research. However, these MNCs often fund charities,
both national and international, which then support research and promote industry-favourable policy positions to
leaders. We explore whether one industry funded charity, the International Life Sciences Institute (‘ILSI’), is the
scientifically objective, non-lobby, internationally-credible body that it suggests it is, so as to aid the international
health and scientific communities to judge ILSI’s outputs.
Methods: Between June 2015 and February 2018, U.S. Right to Know), a non-profit consumer and public health
group, submitted five U.S. state Freedom of Information requests (FOIs) to explore ILSI engagement with industry,
policy makers, and/or researchers, which garnered a total of 17,163 pages for analysis. Two researchers explored
these documents to assess the activities and conduct of ILSI against its purported objectives.
Results: Within the received documents we identified instances of ILSI seeking to influence research, conferences,
public messages, and policy, including instances of punishments for ILSI bodies failing to promote industry-favourable
messaging. We identified ILSI promoting its agenda with national and international bodies to influence policy and law,
causing the World Health Organization to withdraw from official relations with what it now considers a private sector
entity.
Conclusions: ILSI seeks to influence individuals, positions, and policy, both nationally and internationally, and its
corporate members deploy it as a tool to promote their interests globally. Our analysis of ILSI serves as a caution to
those involved in global health governance to be wary of putatively independent research groups, and to practice due
diligence before relying upon their funded studies and/or engaging in relationship with such groups.
Keywords: International Life Sciences Institute, Industry funding, Lobbying, Advocacy, Conflicts of interest
© The Author(s). 2019 Open Access This article is distributed under the terms of the Creative Commons Attribution 4.0
International License (http://creativecommons.org/licenses/by/4.0/), which permits unrestricted use, distribution, and
reproduction in any medium, provided you give appropriate credit to the original author(s) and the source, provide a link to
the Creative Commons license, and indicate if changes were made. The Creative Commons Public Domain Dedication waiver
(http://creativecommons.org/publicdomain/zero/1.0/) applies to the data made available in this article, unless otherwise stated.
* Correspondence: ss775@cam.ac.uk
1
Department of Politics and International Studies, University of Cambridge,
Cambridge, UK
2
Jesus College, Jesus Lane, Cambridge CB58BL, UK
Full list of author information is available at the end of the article
Steele et al. Globalization and Health (2019) 15:36
https://doi.org/10.1186/s12992-019-0478-6
Content courtesy of Springer Nature, terms of use apply. Rights reserved.

Background
Against a backdrop of growing consumer mistrust and
calls for greater openness, an emerging group of multi-
national corporations (‘MNCs’) in the food, beverage
and supplement industries published lists of their part-
nerships and sponsored research as part of a commit-
ment to greater transparency [1]. These lists detail
extensive collaborations and research funding, including
the payment of contributions and membership dues to
professional, public, and charitable organisations dedi-
cated to promoting science and public health. The
Coca-Cola Company (‘Coke’), for example, makes mem-
bership payments to: the American Society for Nutrition;
the Calorie Control Council; various constituents of the
International Life Sciences Institute (‘ILSI’); the Inter-
national Food Information Council (‘IFIC’); the Inter-
national Stevia Council; the Food Science Strategic
Policy Alliance; the National Academies of Sciences, En-
gineering & Medicine; the Food Forum; the Juice Prod-
ucts Association; Purdue University; the IOM Food
Forum; the Healthy Weight Commitment Foundation;
the Industry Nutrition Advisory Panel of the American
Heart Association; the Preventative Cardiovascular
Nurses Association; the Center for Food Integrity; the
International Scientific Association of Probiotics and
Prebiotics; and the Friends of Winship [2]. While some
of these organisations have mechanisms to maintain
their independence, some have been accused of acting as
“front groups”, pushing industry positions covertly to
the public, policy makers and professionals.
For instance, Mars Inc’s Vice President of Public Af-
fairs, Matthias Berninger, declared that his MNC (which
sells highly processed foods and beverages, amongst
other products, worldwide), would withdraw from bod-
ies that promote industry positions by stealth, including
ILSI, due to its involvement “in advocacy-led studies”
[1]. This corporate statement supported a long-held be-
lief by many industry watchdog organisations that ILSI
serves as one of many pseudo-scientific front-groups,
pushing industry-favourable positions to policy makers
and international bodies under the guise of neutral sci-
entific endeavour [3,4]. Other organisations that have
been criticised for working internationally to promote
industry favourable positions by stealth include the Glo-
bal Energy Balance Network (GEBN), which has since
closed, and IFIC, a science communications charity,
both of which worked with ILSI [5].
ILSI is comprised of 18 bodies, each of which cover
specific topics or geographical regions, promoting “glo-
bal partnerships for a healthier world”. These include:
the ILSI Research Foundation, ILSI Health and Environ-
mental Institute, ILSI Europe, ILSI North America, ILSI
Mexico, ILSI Mesoamerica, ILSI North Andean, ILSI
Brazil, ILSI Argentina, ILSI South Andean, ILSI Middle
East, ILSI South Africa, ILSI Southeast Asia Region, ILSI
Taiwan, ILSI Korea, ILSI India, ILSI Focal Point in
China, and ILSI Japan [6]. Global in nature, ILSI clearly
states that it is transparent, and that none of its bodies
“lobby, conduct lobbying activities, or make policy rec-
ommendations”[7]. Indeed, ILSI has long maintained its
independence and scientific rigor, asserting that, through
the exchange of ideas and information between scien-
tists, academics, government, industry, and the private
sector, [8] it acts as an objective body that provides “sci-
ence that improves human health and well-being and
safeguards the environment”[9]. Suzanne Harris, then
executive director of ILSI, stated that ILSI has no “hid-
den agenda”and that its “work is balanced and directed
toward the public good rather than the commercial in-
terests of its corporate members”, and is not a “lobby
group”, but is a public charity exempt from taxation
under US Internal Revenue Code § 501(c)(3) and, as
such, has refrained from lobbying [8]. Harris highlighted
ILSI’s dedication to “the application of evidence-based
science”,[8] a position it maintains in the face of Mars
Inc’s withdrawal.
With ILSI funded research appearing in many medical,
public health and nutrition, and general science journals,
we believe it is critical for our colleagues to be able to rigor-
ously assess its outputs and funded research, and whether
it is engaged in lobbying and advocacy internationally.
While industry collaborations with academic partners can
be fruitful and produce valuable research, industry funding
through covert mechanisms using third parties that obscure
the funding sources can make appraisal of conflicts of inter-
est (‘COIs’) difficult and can thwart effective evidence-based
public health decision-making [10,11]. We therefore use
ILSI as a case study—alens—through which one can ex-
plore the larger global issue of putatively independent, but
heavily industry funded or influenced bodies that can affect
research and national and global level policy deliberations.
We draw on documents obtained using Freedom-of-Infor-
mation requests (FOIs) to ask if ILSI acts, as it states, to
promote the public interest and health, or if it appears to
be trying to influence global health policies covertly on be-
half of industry. Specifically, we question: Is ILSI engaged
in advocacy for industry positions, and lobbying national
and international bodies?
Methods
Between June 2015 and October 2017, U.S. Right to
Know (‘USRTK’), a non-profit consumer and public
health group, submitted five U.S. state Freedom of Infor-
mation requests (hereafter, FOIs) to reveal the scale and
nature of engagement with industry [12]. These FOIs
were sent to individuals who were selected because they
had openly received funding from MNCs in the food
and beverage industries and because they were in
Steele et al. Globalization and Health (2019) 15:36 Page 2 of 8
Content courtesy of Springer Nature, terms of use apply. Rights reserved.

positions or institutions covered by the relevant legisla-
tion. The requests sought emails and attached docu-
ments from these individuals, with the aim of exploring
their relationships with industry, and between industry
and public institutions like the Centre for Disease Con-
trol (‘CDC’), charities like ILSI, policy makers, and other
collaborating scholars (including scientists and
academics).
Within the 17,163 pages returned by these requests,
USRTK identified extensive information on ILSI, and
thereby provided the batch to a researcher (SS) who in-
dependently read and explored the relationship ILSI has
to industry. Notably, two researchers (GR and SS) had
closely read all the documents to identify whether ILSI
is engaged in lobbying, advocacy, or promoting the pub-
lic good. Due to the way in which the documents were
delivered—imaged PDFs in multiple files—the two re-
searchers undertook manual reading.
The first researcher (GR) close read the documents for
instances where ILSI’s conduct and motivation were de-
tailed and then extracted relevant emails or attachments.
This manual reading was repeated independently by the
second researcher at a different institution (SS). The re-
searchers then compared and discussed the findings and
analysed the documents for instances where ILSI was
confronted with issues of transparency, objectivity,
lobbying opportunities, or engagement with inter-
national bodies, including the WHO. We did not seek to
create a statistical sample, but rather to qualitatively ex-
plore ILSI’s conduct. Where there was disagreement
about the documents and/or an interpretation, a full
group meeting was convened, and the documents
discussed.
Because of the imperfect nature of an FOI request, we
may not have received all documents, and as such we do
not claim the sample is comprehensive. We present the
FOIs “in their own words”to allow the reader to make
their own judgements. We have acted to reduce bias by
reporting all emails directly referenced in an online data-
base with weblinks, so that our interpretations are ac-
cessible to all readers, and to provide the full PDF
batches received for readers and other researchers to
consult. As is best practice in qualitative research, within
the emails we received, we sought actively to identify in-
stances that contradicted our findings, and have only re-
ported instances where were unable to do so.
Results
We present text from the FOIs in the sections that fol-
low to explore firstly, whether ILSI is engaged in advo-
cacy, and secondly if it is acting as a lobby group. Our
view is to allow our medical and public health colleagues
to explore and approach ILSI’s relationship with industry
appropriately in the future when deciding whether to
work with this body, receive its funding, and how to
read studies and materials it produces.
Is ILSI acting objectively or engaged in advocacy?
Notably, ILSI openly reports that it is industry funded
[13,14]. Suzanne Harris, however, attests that such
funding does not lead to direct industry influence, pre-
senting instead that ILSI is a “world leader”, acting to
conduct “scientific inquiry relating to nutrition, food
safety, toxicology, risk assessment and the environment”
using a “tripartite operating model”, referring to input
from industry, government and academia [8]. She sug-
gests that this model is not only intended for “producing
broadly informed scientific output”, but also at ensuring
that “ILSI’s work is balanced and directed toward the
public good …” [8]. Critically, then, we looked for in-
stances that indicated either that ILSI promotes the pub-
lic interest, or whether it sought to be selective in what
it presented and promoted in ways that might support
its industry members.
We found emails between Alex Malaspina, former se-
nior vice-president at Coke and founder of, and
long-time president of, ILSI, and Harris, amongst others,
which suggest that ILSI protects industry from being af-
fected by disadvantageous policy and laws. In response
to new US dietary guidelines released that were un-
favourable to industry, Malaspina writes:
Dear Friends, These guidelines are a real disaster!
They could eventually affect us significantly in many
ways; Soft drink taxations, modified school luncheon
programs ,a strong educational effort to educate
children and adults to significanty limit their sugar
intake,, curtail advertising of sugary foods and
beverages and eventually a great pressure from CDC
and other Agencies to force industry to start deducing
drastically the sugar we add to processed foods and
beverages, Also we have to expect that many nations
will follow the US guidelines. We have to consider how
to become ready to mount a strong defence. Warm
regards. Alex [Typographic errors his own] [15].
The inclusion of Harris among a large number of recipients
may suggest that ILSI is perceived as having a role in coun-
tering public health nutrition policies that are unfavourable
to producers of food and beverages with sugar added.
Other emails regarding ILSI’s research on the artificial
sweetener saccharine likewise support this perception.
Malaspina’s emails to Dr. James Emerson, a former Coke
employee, [16] who sat on the ILSI Saccharin Technical
Committee, [17] state:
Dear Jim Emerson: Please note the extra praise for you
from [former ILSI President] Sam Cohen. You and he
Steele et al. Globalization and Health (2019) 15:36 Page 3 of 8
Content courtesy of Springer Nature, terms of use apply. Rights reserved.

were the architects to plan and execute the studies
showing saccharine is not a carcinogen and all
governments which had banned it reversed their
position. Quite an achievement. Congratulations to
both of you again [18].
The email questions whether ILSI is engaged objectively,
instead promoting industry positions to policy makers.
Critically, the FOI responses suggest that ILSI operates
strategically with other industry-funded entities. Thus,
Malaspina detailed the close relationship between ILSI
and IFIC, which is a science communication charity,
stating:
…IFIC is kind of a sister entity to ILSI. ILSI generates
the scientific facts and IFIC communicates them to the
media and public [19].
In an email chain between Malaspina and Michael Er-
nest Knowles, former vice-president of Global Scientific
and Regulatory Affairs at Coca-Cola and former presi-
dent of ILSI who remained a trustee of ILSI through
2016 and of the ILSI Research Foundation through
2017, both ILSI and IFIC are discussed. Malaspina de-
tails how “IFIC is coming through for our industry”and
then proceeds to engage in a back-and-forth exchange
with Knowles over strategies to “use external organiza-
tions”for product defence [20]. Knowles also notes the
need for those in the sister entities to leverage positions
within scientific societies to promote relevant work:
we all belong to one or more of these and we should
have leadership roles in the key ones and push for
individual issues to be addressed by public conferences/
workshops in the manner of ILSI above [20].
Overall, the emails suggest that both ILSI and IFIC act to
counter unfavourable policies and positions, while promot-
ing industry-favourable science, including to the media.
Concerningly, the FOIs showed instances of sanctions
handed out by ILSI to its regional actors where they
failed promote industry-favourable messaging. Malaspina
details:
…about the mess ILSI Mexico is in because they
sponsored in September a sweeteners conference when
the subject of soft drinks taxation was discussed. ILSI
is now suspending ILSI Mexico, until they correct their
ways. A real mess. …I have suggested to Suzie that to
have ILSI Mexico save face, ILSI Mexico should join
ILSI NA …. All of what has been happening is very,
very sad for me, and I hope we have now reached
Bottom [SIC] and eventually we will recover as Coke
and ILSI are concerned [21].
This suggests that ILSI’s constituent bodies face pressure
to promote agreed positions by corporate members.
Taken together, these FOI emails suggest Mars Inc.
was correct that ILSI engages in advocacy, and therefore
we are left asking, does ILSI take this further by en-
gaging in more substantive lobbying activity?
Is ILSI lobbying?
While lobbying is understood in different ways in differ-
ent jurisdictions, we understand it as where a group,
organization, association or person attempts to influence
governmental action (including executive, legislative, ju-
dicial and regulatory action) to achieve an outcome
more favourable to their agenda. While the European
Commission prefers the term “interest representation”
over lobbying, capturing a broader set of activities de-
signed to influence policy makers and decision-making
processes, [22] other jurisdictions, such as the U.S.A.
often employ a narrower concept focused on direct ac-
tivities. Thus, U.S. legislation regarding defines it as
“lobbying contacts and efforts in support of such con-
tacts, including preparation and planning activities, re-
search and other background work that is intended, at
the time it is performed, for use in contacts, and coord-
ination with the lobbying activities of others”, with
lobbying contact meaning “any oral or written commu-
nication (including an electronic communication) to a
covered executive branch official or a covered legislative
branch official”[23]. When understood narrowly, this in-
volves direct interaction to exert influence, including
personal meetings and persuasion, while wider concep-
tions also consider indirect activities such as getting
constituents to write letters, convening meetings and ex-
perts to exert influence, and creating a climate more
favourable to meeting an objective, as included in lobby-
ing. We sought to determine whether ILSI participates
in either or both forms of this activity.
The FOI emails suggest ILSI promotes its agenda with
national and international bodies to influence policy and
law. The emails evidence on-going meetings with not-
able persons, and continuing concern about ILSI’s rela-
tionship with international bodies like the WHO,
discussing how these bodies can be used to promote
pro-industry positions. ILSI’s network is wide ranging. In
emails between Malaspina and Barbara Bowman, then
director of the US CDC’s Division for Heart Disease and
Stroke Prevention, he states:
Dear Barbara
You gave me some very good leads. I like the one
especially about having Mr. Bill Gates help. Our
Chairman knows him well. I will explore this idea
with Clyde [Tuggle, Coke senior vice president]. We
Steele et al. Globalization and Health (2019) 15:36 Page 4 of 8
Content courtesy of Springer Nature, terms of use apply. Rights reserved.

would want WHO to start working with ILSI again,
with the GEBN and with the food industry in general
to resolve issues of food safety and nutrition and for
WHO to not only consider sugary foods as the only
cause of obesity but to consider also the life style
changes that have been occurring throughout the
Universe.
Since WHO, as you stated has been helped by the
pharmaceutical industry to combat HIV/AIDS, why
not work closely with the food industry to combat
obesity. The Food industry is very willing to come to
the table.
…
Warmest personal regards. Alex
Not only do we see that Bowman herself maintains a re-
lationship with Malaspina and ILSI, but also is seen as a
useful advisor regarding how to get ILSI into the WHO
to push industry positions at the international level.
Emails between Malaspina and University of Washing-
ton Professor Adam Drewnowski support this role of
ILSI with the WHO. Drewnowski explains how to de-
velop ILSI’s influence with the WHO to further industry
positions:
Hello Alex - you are absolutely right about the need to
start a dialogue with Margaret Chen [sic]. When she
came to the Pacific Health Summit in Seattle some
years ago, she said that she was ready to be "at the
table - but not in bed - with industry" (her own
phrase). Since then, her position has hardened
considerably. We should remind her of her own phrase
and get her to the table.
Now, strategically, we ought to start with some issue
where ILSI and WHO are in agreement. What would
that be? What are your thoughts?
With best regards Adam
Follow-up emails Malaspina directed to Dr. Junshi
Chen of ILSI China and China’s Centre for Disease Con-
trol, expand on this point:
Dear Junshi: This is a great response by Adam on
my email on WHO. Since you know WHO so well I
thought you may have a suggestion as to how we
can best handle this situation? Who do you
recommend could be the person or organization to
visit with her and discuss the science.? Warmest
regards. Alex
What becomes clear from the emails and forwards is
that ILSI is seen as central to pushing pro-industry con-
tent to international organisations with a view to more
industry-supported approaches that uncouple sugary
foods and obesity.
The role of ILSI in defending industry from questions
about the health consequences of its products and ingre-
dients is seen in emails sent by Dr. James Hill, then dir-
ector of the Center for Human Nutrition at the
University of Colorado Health Sciences Center. In an
email chain discussing public criticisms of scientists, so-
cieties and policy-makers working with industry, Hill
states that:
Frankly, we need the food industry to step up to
provide more resources both to ILSI and GEBN. When
things like this happen, individual companies tend to
want to keep their head down. If they do this, our
opponents will win and we will all lose.
I do not think we can overestimate the importance of
dealing aggressively with this issue.
Jim [24]
This makes clear the proactive role that ILSI is viewed
as playing in addressing unfavourable actions, policies,
and decisions. Additionally, it demonstrates that ILSI
has academic affiliates who identify as being on the side
of the industry.
Sometimes ILSI’s influence is even deeper, with indi-
viduals serving in ILSI posts while working for national
and international bodies. For example, Junshi Chen and
Wenhua Zhao served as Director and Deputy Director,
respectively, of ILSI Focal Point China at the same time
as working at the Chinese CDC [25]. Professor Alan
Boobis simultaneously served as chair of ILSI’s Board of
Trustees while he chaired the UN’s Joint FAO/WHO
Meeting on Pesticide Residues panel on glyphosate,
which was of great interest to ILSI major donors Mon-
santo and CropLife International [26]. The final meeting
report included no conflict of interest statements, even
though, as we demonstrate below, the WHO had, by the
time of meeting ended, official relations with ILSI. It is
clear that ILSI connected individuals continued to play a
role in the WHO’s decision making, as well as holding a
strategic position in relation to influencing national ac-
tors, like the CDC.
However, the FOIs indicate that the on-going relation-
ships, both formal and informal, with international orga-
nisations including the WHO and Food and Agriculture
Organization of the United Nations (hereafter FAO), as
well as with the European Food Safety Authority (EFSA),
are evolving and increasingly ILSI is being seen as a
Steele et al. Globalization and Health (2019) 15:36 Page 5 of 8
Content courtesy of Springer Nature, terms of use apply. Rights reserved.

private actor. In 2017, ILSI was no longer recognized as
in special relations with the WHO, and its links to EFSA
were the subject of enquiry at European Parliament and
new guidelines on transparency [22]. Many of our FOIs
predate these changes, but reveal why increasing recog-
nition of ILSI’s activities on behalf of industry have led it
to be increasingly viewed as a private entity with con-
flicts of interest.
Notably, the FOIs make clear ILSI was previously de-
ployed to influence the WHO Director General Marga-
ret Chan, who had promoted policies and research
contrary to the interests of those selling sugar-sweetened
products, with Malaspina stating:
We must find a way of some one such as a famous
scientist arrange to pay her a visit. Jim Hill or some
one of similar stature or a US Government scientist.
As the President of ILSI I had a special and productive
luncheon with the former DG, Dr Nakajime [SIC] in
1995 at his private dining room in the WHO Geneva
Headquarters to tell him about ILSI and how the two
organisations could work with each other. In 1999 I
visited the new DG Mrs Brutland in Geneva, when I
invited her, on behalf of the World Economic Forum,
to come to the Davos meeting of 1999, and be the
Keynote Speaker at the Food Governors special dinner
…By the way, the future Coke President, Mr Neville
Isdell attended that dinner with me. In summary I am
suggesting that collectively we must find a way to start
a dialogue with Dr Chen [SIC]. If not, she will
continue to blast us with significant negative
consequences on a global basis. This threat to our
business is serious. [Typographic errors his own] [27]
In subsequent emails, Malaspina asks Bowman:
Any ideas how we can have a conversation with
WHO? Now, they do not want to work with industry.
Who finds all the new drugs. Not WHO, but industry.
She is influenced by the Chinese Govt and is against
US. Something Must be done [sic].
Bowman then proceeds to provide advice about whom
to approach to influence the WHO on sugar and bever-
age policy matters, and to promote ILSI’s central role in
influencing the policy arena; an email chain that when
revealed garnered international press, and resulted in
Bowman’s subsequent resignation from the CDC [28].
Following this 2015 exchange, Harris asked the ILSI
board of trustees to consider an amendment to the
membership section of the ILSI bylaws as a way of ad-
dressing a concern recently raised by the WHO regard-
ing one of ILSI’s members being linked to tobacco [29].
In the minutes, it is noted that the WHO proposes to
class ILSI as a “private sector”entity, a classification
which is wholly unacceptable to ILSI.
In a 2015 email, Eric Hentges detailed to ILSI mem-
bers, academic collaborators and others that:
…in late January 2015, the World Health
Organization’s Executive Board decided to discontinue
official relations with the International Life Sciences
Institute (ILSI) [30].
This email chain indicates that, despite efforts to amend
its bylaws to maintain official relations with the WHO,
the WHO chose to remove ILSI from its lists, thereby
removing special status.
Discussion
Our analysis of the FOI documents does not portray
ILSI as a neutral, independent scientific charity acting to
improve the public’s health and well-being around the
world. We identified overt attempts by ILSI to influence
individuals, positions, and policy, both at national and
international levels, alongside clear statements that
ILSI’s corporate members deploy it as a tool to thwart
policies or leaders who are hostile to their interests. Pol-
icy makers around the world, and our medical, public
health, and nutrition colleagues, should be mindful of
this industry influence when approaching studies funded
by ILSI, which regularly appear in leading journals, and
when receiving ILSI perspectives on the evidence-base
to support policy making.
Before interpreting the implications of our findings for
policy and future research on the commercial determi-
nants of health, we must first acknowledge its important
limitations. First, as with all FOI-based research, there is
potential for biases in our interpretations. To mitigate
this, we have quoted all text directly and in context,
allowing the documents to speak for themselves. Further,
we make all material cited available in accompanying
web links so that readers can interrogate our interpreta-
tions of source material and conduct research with the
batches themselves. We sought to actively look for in-
stances that refuted our interpretations and were unable
to do so in our document set.
For policy, our data suggests it is necessary to question
whether ILSI (along with related bodies like IFIC and
some of those listed in the Introduction) should be, as it
is currently, regarded as a charitable actor. The WHO
has asked whether ILSI should be regarded as a private
sector entity. ILSI recognises that such a change in cat-
egorisation would greatly circumscribe its role in policy-
making, especially as pertains to public health, and lead
those in public health to approach its work with appro-
priate caution, acknowledging industry influence.
Steele et al. Globalization and Health (2019) 15:36 Page 6 of 8
Content courtesy of Springer Nature, terms of use apply. Rights reserved.

Given our evidence, we contend that ILSI should be
regarded as a lobby group and that academics and re-
searchers, policy makers, the media, and the public
should view ILSI’s research as promoting the interests of
the food, beverage, supplement and agrichemical indus-
tries, while its actions promote its members interests
and counter healthy public policies.
Conclusions
While ILSI purports to be working for health and well-
being of populations internationally, we identified at-
tempts by ILSI to influence individuals, professional
guidance, and policy, both locally and internationally,
while we saw evidence that its corporate members de-
ploy it as a tool to promote their interests globally. As
such, policy makers, international bodies, and the med-
ical and research communities, should approach ILSI’s
work with caution, viewing it as industry funded and in-
fluenced. Regulators should also consider ILSI’s status as
a lobby group in Europe, the Americas, and beyond. Our
analysis of ILSI serves as a caution to those involved in
global health governance to be wary of putatively inde-
pendent research groups, and to practice due diligence
before relying upon their funded studies and/or engaging
in relationship with such groups.
Acknowledgements
Not applicable.
Funding
This work was funded by the Laura and John Arnold Foundation. The views
expressed in this paper do not necessarily reflect the views of the funder.
Availability of data and materials
The full PDFs of the batches received can be found at:
https://usrtk.org/wp-content/uploads/2018/12/Samuel-Cohen.pdf;
https://usrtk.org/wp-content/uploads/2018/12/Michael-Doyle.pdf;
https://usrtk.org/wp-content/uploads/2018/12/Joanne-Lupton.pdf;
https://usrtk.org/wp-content/uploads/2018/12/John-Peters.pdf;
https://usrtk.org/wp-content/uploads/2018/12/John-Peters-Alex-Malaspina.pdf.
These are PDF copies of the documents we received in conjunction with the
relevant state FOI laws. There are no additional data to provide.
Authors’contributions
GR collected the data via Freedom of Information Requests, with Rebecca
Morrison of USRTK, whom the authors would like to thank. GR and SS
undertook initial independent review of the materials. SS, DS, GR and MM
contributed to analysis of the data, writing and revision of the initial
manuscript. LS contributed to the writing and revision of the final
manuscript. All authors read and approved the final manuscript.
Ethics approval and consent to participate
Not applicable for Freedom of Information studies.
Consent for publication
Informed consent is not required Freedom Information studies. Not applicable.
All authors of the manuscript have read and agreed to:
1. its content and are accountable for all aspects of the accuracy and
integrity of the manuscript in accordance with ICMJE criteria;
2. It’s originality, that it has not already been published in a journal, and
that it is not currently under consideration by another journal; and
the terms of the BioMed Central Copyright and License Agreement,
which we strongly recommend you read and, where applicable,
Open Data policy.
Competing interests
SS and LS have no competing interests to declare. MM is a member of the
National Academy of Science, Engineering, and Medicine, which is
mentioned in the paper as one of a number of organisations that have
received corporate funding. DS is funded by a European Research Council
Grant: 313590-HRES and the Wellcome Trust. GR is co-director of U.S. Right
to Know, a non-profit public interest, consumer and public health organization.
Since its founding in 2014, USRTK has received the following contributions from
major donors (gifts of $5,000 or more): Organic Consumers Association
$587,500; Laura and John Arnold Foundation: $382,600; Dr. Bronner’sFamily
Foundation: $300,000; CrossFit Foundation: $50,000; Westreich Foundation:
$40,000; Panta Rhea Foundation: $20,000; Community Foundation of Western
North Carolina (Little Acorn Fund –M): $15,0 00.
Publisher’sNote
Springer Nature remains neutral with regard to jurisdictional claims in
published maps and institutional affiliations.
Author details
1
Department of Politics and International Studies, University of Cambridge,
Cambridge, UK.
2
Jesus College, Jesus Lane, Cambridge CB58BL, UK.
3
U.S.
Right to Know, Cambridge, USA.
4
Department of Public Health and Policy,
London School of Hygiene & Tropical Medicine, London, UK.
5
Dondena
Research Centre and Department of Policy Analysis and Public Management,
University of Bocconi, Milan, Italy.
Received: 19 November 2018 Accepted: 8 May 2019
References
1. Prentice C. M&M’s maker publishes science policy in bid to boost
transparency. Reuters. 2018. https://uk.reuters.com/article/us-mars-science-
candy/mms-maker-publishes-science-policy-in-bid-to-boost-transparency-
idUKKBN1FP2AO. Accessed 26 July 2018.
2. The Coca-Cola Company. Our Commitment to Transparency. 2018. https://
www.coca-colacompany.com/transparency/our-commitment-transparency.
Accessed 18 Oct 2018.
3. Schubert D. Commercialized GM crops and yield. Nat Biotechnol. 2009;27:
802–3. https://doi.org/10.1038/nbt0909-802.
4. Corporate Europe Observatory. The international Life Sciences Institute (ILSI),
a corporate lobbygroup, vol. 9; 2015. p. 14. https://corporateeurope.org/
sites/default/files/ilsi-article-final.pdf
5. Navarro A. Coke-funded anti-obesity research group GEBN to shut down.
Tech Times. 2015.
6. International Life Sciences Institute. Global network. 2018. http://ilsi.org/
about/global-network/. Accessed 30 Oct 2018.
7. International Life Sciences Institute. Mission & operating principles.
2018. http://ilsi.org/about/mission/. Accessed 30 Oct 2018.
8. Harris S. Correcting the record. Nat Biotechnol. 2010;28:22–3. https://doi.org/
10.1503/cmaj.114-0053.
9. International life science institute. Frequently asked questions. 2016. http://
ilsi.org/about/frequently-asked-questions/. Accessed 19 July 2018.
10. Serôdio PM, McKee M, Stuckler D. Coca-Cola –a model of transparency in
research partnerships? A network analysis of Coca-Cola’s research funding
(2008–2016). Public Health Nutr. 2018;21:1594–607. https://doi.org/10.1017/
S136898001700307X.
11. Steele S, Ruskin G, McKee M, et al. Always read the small print: a case study
of commercial research funding, disclosure and agreements with Coca-Cola.
J Public Health Pol. 2019. https://doi.org/10.1057/s41271-019-00170-9.
Available at: https://link.springer.com/article/10.1057/s41271-019-00170-9.
12. The full PDFs of the batches received can be found at: (1) https://usrtk.org/
wp-content/uploads/2018/12/Samuel-Cohen.pdf; (2) https://usrtk.org/wp-
content/uploads/2018/12/Michael-Doyle.pdf; (3) https://usrtk.org/wp-
content/uploads/2018/12/Joanne-Lupton.pdf; (4) https://usrtk.org/wp-
Steele et al. Globalization and Health (2019) 15:36 Page 7 of 8
Content courtesy of Springer Nature, terms of use apply. Rights reserved.

content/uploads/2018/12/John-Peters.pdf; (5) https://usrtk.org/wp-content/
uploads/2018/12/John-Peters-Alex-Malaspina.pdf.
13. USRTK. Form 990: Return of Organisation Exempt from Income Tax 2013 for
the International Life Sciences Institute. 2018. https://usrtk.org/wp-content/
uploads/2018/07/ILSI-Draft-2013-form-990.pdf.
14. USRTK. ILSI 2012 Major Donors List. 2018. https://usrtk.org/wp-content/
uploads/2018/07/ILSI-2012-major-donors.pdf.
15. USRTK. Guidelines are a real disaster. 2018. https://usrtk.org/wp-content/
uploads/2018/07/guidelines-are-a-real-disaster.pdf.
16. Anon, editor. Editors in chief. Toxicol Ind Health. 1992;8:447–51. https://doi.
org/10.1177/074823379200800609.
17. Senzik S. Articles and abstracts. 1984. https://www.industrydocumentslibrary.
ucsf.edu/tobacco/docs/#id=mmfk0094. Accessed 27 July 2018.
18. USRTK. Awards. 2016. https://usrtk.org/wp-content/uploads/2018/07/Alex-
Malaspina-Jim-Emerson.pdf. Accessed 27 July 2018.
19. USRTK. IFIC Sister entity ILSI. 2015. https://usrtk.org/wp-content/uploads/
2018/07/IFIC-sister-entity-ILSI.pdf.
20. USRTK. Freedom of Information IFIC Knowles Emails. 2017. https://www.
usrtk.org/wp-content/uploads/2017/08/Knowles-email.pdf.
21. USRTK. ILSI Mexico. 2015;140–1. https://usrtk.org/wp-content/uploads/2018/
07/Alex-Malaspina-ILSI-Mexico.pdf.
22. European Commission. Transparency. 2018. https://ec.europa.eu/info/about-
european-commission/service-standards-and-principles/transparency_en.
Accessed 30 July 2018.
23. Kerr W, Lincoln W, Mishra P. The dynamics of firm lobbying. Vox. 2011.
https://voxeu.org/article/dynamics-firm-lobbying. Accessed 30 July 2018.
24. USRTK. Report on ASN. 2015. https://usrtk.org/wp-content/uploads/2018/07/
more-resources-ILSI-GEBN.pdf.
25. ILSE-SEA. Junshi Chen. 2018;:2018. http://ilsisea-region.org/wp-content/
uploads/sites/21/2018/04/Junshi-Chen.pdf.
26. Neslen A. UN/WHO panel in conflict of interest row over glyphosate cancer
risk. The Guardian. 2016. https://www.theguardian.com/environment/2016/
may/17/unwho-panel-in-conflict-of-interest-row-over-glyphosates-cancer-
risk. Accessed 30 July 2018.
27. USRTK. Daily European news Falsh. 2015. https://usrtk.org/wp-content/
uploads/2018/07/Alex-Malaspina-Barbara-Bowman.pdf.
28. Gillam C. CDC official exits agency after Coca-Cola connections come to
light. Huffpost. 2017; https://www.huffingtonpost.com/carey-gillam/cdc-
official-exits-agency_b_10760490.html. Accessed 14 Dec 2018.
29. ILSI. ILSI Board of Trustees Annual Meeting Draft Minutes Saturday,. 2015.
https://usrtk.org/wp-content/uploads/2018/07/ILSI-BOT-11715-mtg-minutes.
pdf.
30. USRTK. ILSI’s Official relations with the World Health Organisation. 2015.
https://usrtk.org/wp-content/uploads/2018/07/ILSI-Official-Relations-WHO.pdf.
Steele et al. Globalization and Health (2019) 15:36 Page 8 of 8
Content courtesy of Springer Nature, terms of use apply. Rights reserved.

1.
2.
3.
4.
5.
6.
Terms and Conditions
Springer Nature journal content, brought to you courtesy of Springer Nature Customer Service Center GmbH (“Springer Nature”).
Springer Nature supports a reasonable amount of sharing of research papers by authors, subscribers and authorised users (“Users”), for small-
scale personal, non-commercial use provided that all copyright, trade and service marks and other proprietary notices are maintained. By
accessing, sharing, receiving or otherwise using the Springer Nature journal content you agree to these terms of use (“Terms”). For these
purposes, Springer Nature considers academic use (by researchers and students) to be non-commercial.
These Terms are supplementary and will apply in addition to any applicable website terms and conditions, a relevant site licence or a personal
subscription. These Terms will prevail over any conflict or ambiguity with regards to the relevant terms, a site licence or a personal subscription
(to the extent of the conflict or ambiguity only). For Creative Commons-licensed articles, the terms of the Creative Commons license used will
apply.
We collect and use personal data to provide access to the Springer Nature journal content. We may also use these personal data internally within
ResearchGate and Springer Nature and as agreed share it, in an anonymised way, for purposes of tracking, analysis and reporting. We will not
otherwise disclose your personal data outside the ResearchGate or the Springer Nature group of companies unless we have your permission as
detailed in the Privacy Policy.
While Users may use the Springer Nature journal content for small scale, personal non-commercial use, it is important to note that Users may
not:
use such content for the purpose of providing other users with access on a regular or large scale basis or as a means to circumvent access
control;
use such content where to do so would be considered a criminal or statutory offence in any jurisdiction, or gives rise to civil liability, or is
otherwise unlawful;
falsely or misleadingly imply or suggest endorsement, approval , sponsorship, or association unless explicitly agreed to by Springer Nature in
writing;
use bots or other automated methods to access the content or redirect messages
override any security feature or exclusionary protocol; or
share the content in order to create substitute for Springer Nature products or services or a systematic database of Springer Nature journal
content.
In line with the restriction against commercial use, Springer Nature does not permit the creation of a product or service that creates revenue,
royalties, rent or income from our content or its inclusion as part of a paid for service or for other commercial gain. Springer Nature journal
content cannot be used for inter-library loans and librarians may not upload Springer Nature journal content on a large scale into their, or any
other, institutional repository.
These terms of use are reviewed regularly and may be amended at any time. Springer Nature is not obligated to publish any information or
content on this website and may remove it or features or functionality at our sole discretion, at any time with or without notice. Springer Nature
may revoke this licence to you at any time and remove access to any copies of the Springer Nature journal content which have been saved.
To the fullest extent permitted by law, Springer Nature makes no warranties, representations or guarantees to Users, either express or implied
with respect to the Springer nature journal content and all parties disclaim and waive any implied warranties or warranties imposed by law,
including merchantability or fitness for any particular purpose.
Please note that these rights do not automatically extend to content, data or other material published by Springer Nature that may be licensed
from third parties.
If you would like to use or distribute our Springer Nature journal content to a wider audience or on a regular basis or in any other manner not
expressly permitted by these Terms, please contact Springer Nature at
onlineservice@springernature.com