Marselia Tan.

Controversy over the Regulations

of Infant Milk Formula Marketing from 1970s to
2000s: An Analysis on the Use of Evidence in
Health Policymaking. Journal of Health Policy
and Health Economics. 2021; 1(1).

Controversy over the Regulations of Infant Milk Formula

Marketing from 1970s to 2000s: A Theoretical Analysis
on the Use of Evidence in Health Policymaking
Marselia Tan1
1
London School of Economics and Political Sciences, Department of Health Policy, London, UK, [email protected]

Introduction
Driven by the assumption that objective and scientifically sound evidence instead of values
should inform policy decision-making, many politicians, academics, and professional bodies
have supported the use of evidence-based policymaking in various public policy fields,
including healthcare (1-3). However, an emerging view among scholars claims that the
creation, selection, and interpretation of evidence related to public policies are inherently
subjective and reflect the political interests of various stakeholders (2). Aligned with this view,
this commentary focuses on how evidence has been used by different actors in the health
system to influence the health policymaking process related to the marketing of infant milk
formula (IMF). While the IMF industry’s controversy has been studied before, the existing
literature has focused on business ethics and corporate social responsibility implications of
the policy-influencing activities of industry actors (4-6). Hence, past research had utilised
analytical frameworks most relevant to the critical discourse on the IMF industry’s corporate
actors. While actors with substantial financial stakes in the industry –most notably the market
leader Nestlé– have indeed defended their interests by strategically creating, selecting, and
interpreting evidence, activists and other interest groups have also strategically utilised
evidence to challenge the legitimacy of IMF companies and to promote stricter regulations on
IMF marketing in the developing world (7,8).

By tracing controversial IMF cases that occurred worldwide from the 1970s to the 2000s
(4,9,10) and using Kingdon’s multiple streams model of policy change (11), this commentary
argues that the strategic and agenda-driven use of evidence at crucial moments in the
policymaking process has allowed both groups of actors to attain some success in influencing
policy changes throughout the years. As this approach calls for analysing the IMF controversy
in a chronological manner, Kingdon’s multiple streams model is deemed the most appropriate
framework as it “emphasises the time dimension in evidence use and recognises that evidence
may influence policy at key moments or alternatively only after long periods of time.” (2: p.26)
The commentary concludes that the body of evidence involved in health policymaking on IMF
products has grown and is likely to continue expanding, shaped by the intense contestations
over values and ideologies between two diametrically opposed groups. The approach used in
this commentary may be applied to analyse the strategic and political use of evidence in other
ongoing health policy controversies.

1
© Marselia Tan, 2021. This is an open access article under the terms of the
Creative Commons Attribution License, which permits use, distribution and
reproduction in any medium, provided the original work is properly cited.
A short description of Kindgon’s multiple streams model
Kingdon argues that for a key change in policymaking to take place, three separate “streams”
-problem stream, policy stream, and politics stream- must converge to enable a “window of
opportunity” for influential policy change to open (11). In the problem stream, a particular policy
issue receives the attention of policymakers, often due to how it is framed by interested
stakeholders or due to an emerging focusing event or crisis around the problem, instead of
solely due to any objective indicators. Certain groups of stakeholders may come into favour
by capitalising on the crucial moment when a problem captures attention. The policy stream
emerges with different policy entrepreneurs proposing viable policy solutions, developed in
anticipation of certain problems receiving major attention. Lastly, in politics stream,
policymakers are compelled by the national or international feedback on the particular
problem’s magnitude and the existence of policy proposals to address it, to select the policy
solutions and enact the change (11).

The 1970s
Infant milk formula was developed in the 19th century as a substitute for breastfeeding (4), but
only gained a wider market during the period after World War II. Journalists noticed that the
widespread marketing campaigns by IMF companies had framed the product as a desired
“status symbol” especially among lower-income women, misled consumers to perceive it as a
“modern” replacement to natural breast milk, and created a false impression of doctors’
endorsement (12,13). These campaigns were argued to contribute to the declining
breastfeeding rate in both developed and less developed countries from the 1940s to the
1970s (9,14-16). In response to the allegations, IMF companies and their supporters explained
that IMF’s popularity was merely due to the increasing trend of women in Western countries
entering the workforce without any mechanism in workplace to support them for exclusive
breastfeeding (4,9,13,17). Thus, IMF products became an attractive and convenient infant
feeding choice. This showcases how a strategic interpretation of evidence was utilised to shift
the responsibility of in IMF product preference solely on a broader socioeconomic trend,
instead of as a direct result of the companies’ marketing activities.

In early 1970s, the dissidents of IMF marketing practices expressed their concerns more
vocally. The Director of Carribean Food and Nutrition Institute at the time, Dr Jelliffe, was the
first to claim in a public forum (12,18) that IMF companies’ aggressive marketing tactics, such
as offering free samples to mothers, over-incentivising doctors, and employing sales
representatives dressed like nurses in maternity wards (7,12) were directly associated with
the soaring rates of mortality and morbidity among infants in third-world countries (4,18). Other
scientists subsequently presented studies indicating a link between IMF companies’
aggressive marketing of IMF and infants’ health problems in developing countries, where
women lacked access to proper sanitary conditions, literacy, and financial means required to
properly follow instructions about bottle-feeding their infants (6,12). Many third-world mothers
used contaminated water to prepare IMF products or overly diluted the formula to make the
expensive product last longer. These practices led to infants’ malnutrition, diarrhoea,
gastroenteritis, and deaths (19,20). Nestlé’s countered these accusations by presenting a
contrasting evidence implying a link between IMF consumption and the decrease in infant
mortality rates, as observed in some countries from 1940 to 1970 (13). This claim provoked
nutritionists and scientists to accuse Nestlé of a technical bias in the interpretation of the
statistical evidence –the declining infant mortality in some countries at that period was more
likely to be caused by a combination of systematic factors like the improved health care
system, vaccination, and better standards of living rather than due to increased IMF
consumption (21,22).

2
The movement against IMF companies at this juncture can be explained as a manifestation of
an advocacy coalition framework (3), where individuals form coalitions to turn their beliefs into
policies and to oppose the beliefs and policies of competing coalitions. Indeed, in calling for
the establishment of an international health policy for IMF marketing, various actors such as
religious groups (Interfaith Center on Corporate Responsibility (23), the U.S. Methodist Church
(24)); activist groups (Infant Feeding Action Coalition (25)); International Baby Food Action
Network (26)); paediatrics; nutritionists; and scientists coordinated to vigorously utilise and
expand the body of evidence supporting their cause, guided by the same underlying ‘policy
core’ belief that “breast is best” (7,8). The controversy reached its tipping point and gained
worldwide attention after the 1974 ground-breaking publication of “The Baby Killer” (27), an
exposé of damages caused by IMF companies in the developing world. This sensationalist
publication marks the coalition’s exercise of power by framing evidence to discredit IMF
companies, to the extent of “demonising” them (3). In response to the scathing pamphlet,
Nestlé, the primary focus of the public’s negative sentiment, sued the authors for libel and won
(7,12). Capitalising on the public momentum from this lawsuit, the Infant Formula Action
Coalition (INFACT) in 1977 launched a successful international boycott on Nestlé’s products
(4,12). To this day, the INFACT boycott continues to galvanise other boycotts by other NGOs
and activists worldwide (28).

Pressured to react to these forces, IMF industry leaders employed various uses of evidence
to maintain their legitimacy, such as creating the International Council of Infant Food Industries
(ICIFI) in 1975, an industry association consisting of Wyeth, Ross-Abbott, Danone, Cow &
Gate, four Japanese IMF companies, and Nestlé (12). The purported objective of this
association was to be recognised as a self-regulatory body and to sponsor research studies
in various areas, including topics such as infant feeding patterns and the extent to which breast
milk alone can suffice an infant’s needs (12,29,30). Such research topics can be construed as
an attempt to orient the process of creating new evidence to favour the industry. The IMF
industry also criticised its opponents for promoting the misconception on breastfeeding
substitutes (12,17) and for campaigning to make IMF available only on medical prescription
(29). The industry accused its opponents of issue bias in their selection of evidence (2) by
neglecting some important social concerns, such as the benefits of IMF for women unable to
naturally breastfeed and in preventing the use of less suitable alternatives like sweetened
condensed milk or gruel for infants whose mothers were unable to breastfeed (17,29).

The 1980s to 1990s

The struggles between IMF industry and opposition groups culminated in 1981 with the
establishment of the WHO International Code of Marketing Breast Milk Substitutes (the Code),
a nonbinding code that restricts the promotional activities of IMF products (31). The events
leading up to the creation of this Code can be analysed using multiple streams analysis (3,11).
Kingdon captures the importance of time dimension in evidence use and posits that when
problem stream, policy stream, and politics stream converge at the optimal time, a window of
opportunity opens to enable a policy change (11). In the IMF controversy, a problem stream
emerged as the evidence compiled in “The Baby Killer” and the worldwide attention it received
made the issue of IMF marketing practices salient in agendas of policymakers such as the
WHO and national governments. By the time the controversy reached its boiling point of
Nestlé’s lawsuit and the INFACT boycott, a policy stream had emerged, with a number of
doctors, advocates of breastfeeding, and NGOs revealing proposals for restricting IMF
companies’ marketing practices especially among the vulnerable populations. Popular support
for these proposals consequently enabled a politics stream, allowing policymakers to act in a

3
politically correct course. These three streams ultimately opened up a window of opportunity
for the development of the WHO Code.

The Code was a result of 118 WHO member countries’ positive votes and one negative vote
from the United States, which was under the Reagan administration at the time (5) –an
administration widely regarded to be protective of private sector’s agendas (32,33). Echoing
ICIFI’s reasoning to oppose the Code, the U.S. rejected the WHO Code for its rigidity and
incompatibility with the American values of “free speech and freedom of information” (9,34).
However, this statement had neglected important research findings on the perils of the
absence of IMF marketing standards in the U.S., such as recorded IMF misuse in low-income
American cities (9). Disregarding this body of evidence reflects the U.S. government’s
cognitive dissonance aversion (2), as the idea of negative impact caused by private sector
was incongruent to the pro-market ideology that thrived during the Reagan era (33). The
negative vote also suggests a government’s issue bias in selection of evidence, ignoring parts
of a larger body of evidence about the social harms of unregulated marketing of IMF products.

In 1982, to end the prolonged boycott and to claim a commitment to Code compliance, Nestlé
established the Nestlé Infant Formula Commission and the Nestlé Coordination Center for
Nutrition to research on the level of compliance of its marketing activities to the WHO Code,
as well as to expand the knowledge on artificial feeding for infants (12,19,35,36).
Unsurprisingly, the commissioned research produced only favourable results for Nestlé (36),
exemplifying how an influential industry player deliberately engaged in a confirmatory bias (2)
by commissioning strategically designed research that produce evidence confirming the firm’s
existing hypothesis of its compliance to the Code. In contrast to the evidence produced by
these research centres, in a manner befitting the advocacy coalition framework, WHO,
UNICEF, and various influential NGOs like IBFAN, INFACT, and Baby Milk Action (BMA)
found consistent evidence of the industry’s continuous violations to the WHO Code as well as
to various developing countries’ national laws (4,37-39).

Throughout the years of global boycott implicating even Nestlé’s non-IMF products, the public
perception of Nestlé and the IMF industry has deteriorated (6). However, since 1985 onward,
the industry found a new turning point. A growing number of studies showed that HIV/AIDS
can be transmitted from mother to baby via breastfeeding (4,8,40). Rapidly reacting to this
advantageous turn of events, IMF companies launched extensive campaigns publicising
evidence on dangers of breastfeeding and benefits of IMF in preventing mother-to-baby HIV
infections (8,41). In a strange twist, the IMF industry could then claim the moral high ground,
accusing WHO and UNICEF of slow response to the crisis and of risking the lives of at-risk
infants by limiting IMF access and availability to mothers (40,42). Nevertheless, the industry
also showed an issue bias in its selection of evidence, by disregarding the existing concern
that mothers in poor living conditions are not equipped to utilise IMF in the first place. On the
other hand, the revelation HIV transmission risks from breastfeeding left anti-IMF groups
baffled, confronted with the uncomfortable fact that once-decried IMF products could now be
an effective tool for saving third-world children from AIDS (8). This hard-to-swallow evidence
of the IMF’s potential benefit destabilised the coalition’s policy core belief (3) that “breast is
best”.

The 2000s
In the early 2000s, the mother-to-child HIV transmission issue reignited the waning debate of
“breast versus bottle”, enabling a problem stream that made IMF marketing regulations once
again an attention-grabbing issue in the policymakers’ agenda. IMF industry’s continuous

4
effort to present various pieces of evidence and its emphasis on the moral imperative in
making IMF available to HIV-infected mothers had even gained support from some of its past
detractors, such as UNAIDS officials and doctors in developing countries (43). From the
perspective of the multiple streams model, this acceptance from former “enemies” was crucial
to enable a politics stream for a change in the WHO Code, as amendments could now be a
politically correct response to the HIV crisis and might also appease breastfeeding advocates.
Alongside Nestlé, Wyeth emerged as an enthusiastic policy entrepreneur (44), capitalising the
developing body of evidence to propose a solution: donating free IMF products to HIV-infected
mothers in Africa (42,43), explicitly violating part of the WHO Code prohibiting the distribution
of free IMF samples (31). Ultimately, the convergence of the three streams resulted in a
window of opportunity for a policy change favouring the IMF industry. After years of resistance,
UNICEF relented to starting a pilot project to provide IMF to HIV-infected mothers in Africa
(45). It commissioned a non-controversial French dairy cooperative to provide free, plain-
packaged IMF products for HIV-positive mothers (40,45,46). Although the biggest companies
were excluded as potential suppliers for UNICEF’s programme, the pilot programme conferred
back some legitimacy on the IMF products and brought hope to the wider IMF industry on
possible future amendments to the Code.

In light of this seeming willingness of WHO and UNICEF to begin a cooperative relationship
with the IMF industry, a strong advocacy coalition was re-established among the industry
critics, consistently rejecting IMF companies’ offers for donations and heavily relying on other
evidence from emerging studies on breastfeeding’s safety in HIV context (37,46-48) –
particularly a pioneering study from South Africa that shows a reduction in risk of mother-to-
infant HIV transmission when breastfeeding is combined with antiretroviral treatment (49).
Other strategies employed by the activist groups since 2004 involve the creation of evidence
through cataloguing IMF companies’ Code violations. BMA and Interagency Group on
Breastfeeding Monitoring, INFACT, and IBFAN continually monitor and report IMF companies’
violations to the Code (4). In 2004, IBFAN released a report “Breaking the Rules, Stretching
the Rules” (50), a documentation of purported evidence on how IMF companies idealised their
products and downplayed the negative health impact of bottle-feeding. The document was put
forward as evidence to the United Kingdom’s House of Commons to demand the cessation of
IMF marketing malpractice (42). To this day, opposition groups continue to develop the
evidence base contesting the legitimacy of IMF companies by extensively cataloguing the
industry’s violations of the Code (4). One way Nestlé had reacted to this was by emphasising
its “listed” status on the FTSE4Good Index (51) –an independent stock market instrument
relied on by investors to measure corporate social responsibility performance of various
companies–, framing it as impartial evidence of compliance to the Code and of its ethical
operation (52). Nevertheless, critics scorned that Nestlé relied on its listing on the Index as
evidence of its socially responsible activities, since the company had simultaneously pushed
for the removal of Code compliance as a requirement for other companies to be included on
the Index’s listing (42,53).

Beyond the 2000s, the financial stake in the IMF industry continues to rise, as the global sales
of IMF grow three times as quickly as the global economy (54). Given this economic incentive,
it is unsurprising that IMF companies and its supporters continue to contend every World
Health Assembly’s resolution or amendment proposal to the WHO Code through various
means. For instance, engaging in evidence creation, Nestlé sponsored a large-scale study on
Chinese toddlers and found that they were lacking certain micronutrients in their diet. The
company recommended that this deficiency could be supplemented with IMF products (55).
Nestlé also framed the study’s results as grounds to refuse further regulation on advertising
on toddlers, arguing that further restriction on IMF advertisement may then increase the
consumption of other less healthy, less restricted dietary alternatives such as Coca Cola (56).

5
Meanwhile, opposition groups have continued to present evidence on the industry’s violations
to the Code through new marketing channels. Save the Children cited several studies implying
the IMF industry’s exploit of the rise of social media for intensive behavioural targeting, for
example by engaging social media influencers to promote IMF brands with a veneer of
impartiality and non-sponsored endorsement (54).

Conclusion
In the long battle of “breast versus bottle”, activists, scientists, physicians, and religious groups
have fought in an “advocacy coalition” model to utilise evidence that advance their cause.
Driven by a strong policy core belief that breastfeeding yields the best health outcomes for
infants, the advocacy coalition insists that the IMF industry’s values and intentions are
inherently incompatible to public interests. Thus, it has continuously discredited the industry’s
legitimacy through persistent monitoring of its violations to the Code. While previous literature
has critically examined mainly the IMF industry, by applying Kingdon’s multiple streams
analysis on some crucial moments in the history of IMF controversy, this commentary
demonstrates that both the IMF industry and its opposing groups are capable of using
evidence within ideal timeframes to allow three streams of problem, policy, and politics to
converge into windows of opportunity for policy changes that suit their ideological, economic,
or other interests.

As the debate on the IMF issue goes on, the body of evidence on breastfeeding and IMF
continues to expand and evolve, reflecting the two polarised groups’ interests, beliefs, and
values. Future health policy analyses within the IMF topic may focus on the development of
the controversy from 2010s onward, dissecting the roles of internet and social media as new
devices of evidence creation, selection, and dissemination. As this commentary demonstrates,
Kingdon’s multiple streams model is suited for conducting a historical analysis on how
intensely opposed groups of actors strategically influence the “evidence-based” policy making
process. The model can be applied to understand actors’ actions on other controversial,
ideology-driven health policy cases that span across a substantial period of time, such as on
the use of medical marijuana or mandatory childhood vaccinations.

References

1. Russell J, Greenhalgh T, Byrne E, Mcdonnell J. Recognizing rhetoric in health care

policy analysis. Journal of Health Services Research & Policy. 2008;13(1):40–6.
2. Parkhurst JO. The politics of evidence: from evidence-based policy to the good
governance of evidence. New York, NY: Routledge; 2017.
3. Cairney P. The Politics of Evidence-Based Policy Making. London: Palgrave Macmillan
UK: Imprint: Palgrave Pivot; 2016.
4. Brady JP. Marketing breast milk substitutes: problems and perils throughout the world.
Archives of Disease in Childhood. 2012;97(6):529–32.
5. Boyd C. The Nestlé Infant Formula Controversy and a Strange Web of Subsequent
Business Scandals. Journal of Business Ethics. 2011;106(3):283–93.
6. Baker JC. The international infant formula controversy: A dilemma in corporate social
responsibility. Journal of Business Ethics. 1985;4(3):181–90.
7. Beaver B, Silvester F. The Gall in Mothers Milk. International Journal of Advertising.
1982;1(1):1–10.

6
8. Meier B. In War Against AIDS, Battle Over Baby Formula Reignites [Internet]. The New
York Times. The New York Times; 1997 [cited 2020Jan20]. Available from:
https://www.nytimes.com/1997/06/08/business/in-war-against-aids-battle-over-baby-
formula-reignites.html
9. Solomon S. THE CONTROVERSY OVER INFANT FORMULA [Internet]. The New York
Times. The New York Times; 1981 [cited 2020Jan12]. Available from:
https://www.nytimes.com/1981/12/06/magazine/the-controversy-over-infant-formula.html
10. Muller M. Nestlé baby milk scandal has grown up but not gone away [Internet]. The
Guardian. Guardian News and Media; 2013 [cited 2020Jan10]. Available from:
https://www.theguardian.com/sustainable-business/nestle-baby-milk-scandal-food-
industry-standards
11. Kingdon JW. Agendas, alternatives, and public policies. Harlow: Pearson Education
Limited; 2014.
12. Dobbing J, Geraldi G, McComas M. Infant feeding: anatomy of a controversy 1973-
1984. Place of publication not identified: Springer; 2013.
13. Iatham MC. Bottles, Babies and Breast-Feeding: Debating the Nestle Boycott: Opinion:
The Harvard Crimson [Internet]. Opinion | The Harvard Crimson. The Harvard Crimson;
[cited 2019Dec11]. Available from:
https://www.thecrimson.com/article/1978/11/7/bottles-babies-and-breast-feeding-
debating-the/
14. Hirschman C, Hendershot GE. Trends in breast feeding among American mothers. Vital
health and statistics. 1979;(3):1–39.
15. Millman S. Trends in Breastfeeding In a Dozen Developing Countries. International
Family Planning Perspectives. 1986;12(3):91.
16. Wright AL, Schanler RJ. The Resurgence of Breastfeeding at the End of the Second
Millennium. The Journal of Nutrition. 2001;131(2).
17. Summary Position Statement Re Proposed WHO International Code for the Marketing
of Breast Milk Substitutes [Internet]. Archive.babymilkaction.org. 1981 [cited
2020Jan05]. Available from: http://archive.babymilkaction.org/pdfs/icifistatement81.pdf
18. Jelliffe DB, Jelliffe EFP. Feeding Young Infants in Developing Countries: Comments on
the Current Situation and Future Needs. Studies in Family Planning. 1978;9(8):227.
19. Zelman NE, The Nestle Infant Formula Controversy: Restricting the Marketing Practices
of Multinational Corporations in the Third World. The Transnational Law. 1990;3(2): 697-
758.
20. Baer E, Marguiles L. Infant and Young Child Feeding: An Analysis of the WHO/UNICEF
Meeting. Studies in Family Planning. 1980;11(2):72.
21. Krieger N, Rehkopf DH, Chen JT, Waterman PD, Marcelli E, Kennedy M. The Fall and
Rise of US Inequities in Premature Mortality: 1960–2002. PLoS Medicine.
2008Feb26;5(2):227–41.
22. Francis DR. Why do Death Rates Decline? [Internet]. Why do Death Rates Decline?
The National Bureau of Economic Research; [cited 2020Jan12]. Available from:
https://www.nber.org/digest/mar02/w8556.html
23. Ermann, David M, Clements, H. W. Interfaith Center on Corporate Responsibility and its
Campaign Against Marketing Infant Formula in the Third World * [Internet]. OUP
Academic. Oxford University Press; 2014 [cited 2019Dec20]. Available from:
https://academic.oup.com/socpro/article/32/2/185/1701773
24. Anderson DE. Nestle boycott gains support [Internet]. UPI. United Press International;
1988 [cited 2020Jan17]. Available from:
https://www.upi.com/Archives/1988/11/29/Nestle-boycott-gains-
support/4435596782800/

7
25. THE BABY MILK ISSUE - Ideas for Action [Internet]. New Internationalist. The New
Internationalist; 1982 [cited 2020Jan21]. Available from:
https://newint.org/features/1982/04/01/action
26. Küenzl J, Schwabenland C, Elmaco J, Hale S, Levi E, Chen M, et al. International Baby
Food Action Network (IBFAN). International Encyclopedia of Civil Society. 2010;:880–1.
27. Muller M. The Baby Killer [Internet]. War on Want. War on Want; 2015 [cited
2020Dec23]. Available from: https://waronwant.org/resources/baby-killer
28. Puiu T. Why Nestle is one of the most hated companies in the world [Internet]. ZME
Science. 2017 [cited 2020Jan21]. Available from:
https://www.zmescience.com/science/nestle-company-pollution-children/
29. International Council Of Infant Food Industries. The Lancet.
1978Jun10;311(8076):1250–2.
30. Gerber J. Enforced Self-Regulation in the Infant Formula Industry: A Radical Extension
of an "Impractical" Proposal. Social Justice. 1990;17(1):98–112.
31. International Code of Marketing of Breast-milk Substitutes [Internet]. Who.int. 1981
[cited 2020Jan11]. Available from:
https://www.who.int/nutrition/publications/code_english.pdf
32. The Reagan Presidency [Internet]. The Reagan Presidency | Ronald Reagan
Presidential Library - National Archives and Records Administration. Ronald Reagan
Presidential Library and Museum; [cited 2020Jan21]. Available from:
https://www.reaganlibrary.gov/sreference/the-reagan-presidency
33. The Second American Revolution: Reaganomics [Internet]. The Second American
Revolution: Reaganomics | The Ronald Reagan Presidential Foundation & Institute. The
Reagan Foundation; [cited 2020Jan21]. Available from:
https://www.reaganfoundation.org/ronald-reagan/the-presidency/economic-policy/
34. Lusinchi V. U.S. IS A DISSENTER AS U.N. AGENCY VOTES BABY-FORMULA CODE
[Internet]. The New York Times. The New York Times; 1981 [cited 2020Jan19].
Available from: https://www.nytimes.com/1981/05/21/world/us-is-a-dissenter-as-un-
agency-votes-baby-formula-code.html
35. Duncan L. Nestle's Not 'Dumping' Formula, Panel Finds [Internet]. Los Angeles Times.
Los Angeles Times; 1988 [cited 2020Jan18]. Available from:
https://www.latimes.com/archives/la-xpm-1988-11-17-fi-88-story.html
36. Sethi SP. Nestle Infant Formula Audit Commission (NIFAC) a New Model for Gaining
External Legitimacy for Corporate Actions. Issues in Business Ethics Multinational
Corporations and the Impact of Public Advocacy on Corporate Strategy. 1994;:263–89.
37. Waterston T. Monitoring the marketing of infant formula feeds. Bmj.
2003Jan18;326(7381):113–4.
38. Bevin T. Breaking The Rules 1994: A worldwide report on Violations of the
WHOIUNICEF International Code of Marketing of Breast-milk Substitutes. Journal of
Human Lactation. 1995;11(1):61–61.
39. Taylor A. Violations of the international code of marketing of breast milk substitutes:
prevalence in four countries. BMJ. 1998;316(7138):1117-1122.
40. Laurence J. Health Check: 'Aids has brought the makers of formula milk a marketing
[Internet]. The Independent. 2004 [cited 2020Jan20]. Available from:
https://www.independent.co.uk/life-style/health-and-families/health-news/health-check-
aids-has-brought-the-makers-of-formula-milk-a-marketing-opportunity-to-die-for-
563722.html
41. Nduati R, John G, Mbori-Ngacha D, Richardson B, Overbaugh J, Mwatha A, et al. Effect
of Breastfeeding and Formula Feeding on Transmission of HIV-1: A Randomized
Clinical Trial. Obstetrical & Gynecological Survey. 2000Mar;55(8):479–81.
42. Yamey G. The milk of human kindness. Western Journal of Medicine. 2001;174(3):165-
166.

8
43. Freedman, Alix M., and Steve Stecklow. “Wyeth, Nestle Offer Free Tins to Stem Spread
of AIDS; Children's Agency Balks.” The Wall Street Journal. Dow Jones & Company,
December 5, 2000. https://www.wsj.com/articles/SB975978176677135549
44. Sætren H. From controversial policy idea to successful program implementation: the
role of the policy entrepreneur, manipulation strategy, program design, institutions and
open policy windows in relocating Norwegian central agencies. Policy Sciences.
2016;49(1):71-88.
45. de Wagt, Arjan, and David Clark. “UNICEFs Support to Free Infant Formula for Infants
of HIV ...” World Alliance For Breastfeeding Action. World Alliance For Breastfeeding
Action, April 2004.
https://www.researchgate.net/publication/237326750_UNICEFs_Support_to_Free_Infan
t_Formula_for_Infants_of_HIV-
infected_Mothers_in_Africa_A_Review_of_UNICEF_Experience
46. Moland K, de Paoli M, Sellen D, van Esterik P, Leshabari S, Blystad A. Breastfeeding
and HIV: experiences from a decade of prevention of postnatal HIV transmission in sub-
Saharan Africa. International Breastfeeding Journal. 2010;5(1):10.
47. Exclusive Breast-Feeding Is Safer Than Mixed Feeding For Infants Born to HIV-Positive
Mothers [Internet]. Guttmacher Institute. 2007 [cited 19 January 2020]. Available from:
https://www.guttmacher.org/journals/ipsrh/2007/06/exclusive-breast-feeding-safer-
mixed-feeding-infants-born-hiv-positive
48. Dobson R. Breast is still best even when HIV prevalence is high, experts say. BMJ.
2002;324(7352): 1474.
49. Moodley, Dhayendre, Jagidesa Moodley, Hoosen Coovadia, Glenda Gray, James
Mcintyre, Justus Hofmyer, Cheryl Nikodem, et al. “A Multicenter Randomized Controlled
Trial of Nevirapine Versus a Combination of Zidovudine and Lamivudine to Reduce
Intrapartum and Early Postpartum Mother-to-Child Transmission of Human
Immunodeficiency Virus Type 1.” The Journal of Infectious Diseases 187, no. 5 (2003):
725–35. https://doi.org/10.1086/367898
50. Breaking the Rules 2004: Stretching the Rules Evidence of Violations of the
International Code of Marketing of Breastmilk Substitutes and subsequent Resolutions
[Internet]. International Baby Foods Action Network. 2004 [cited 2020Jan19]. Available
from: http://ibfan.org/art/302-2.pdf
51. FTSE4Good Index Series [Internet]. Ftserussell.com. 2020 [cited 2020Jan21]. Available
from: https://www.ftserussell.com/products/indices/ftse4good
52. The FTSE4Good Investment Index [Internet]. Nestlé Global. 2020 [cited 2020Jan21].
Available from: https://www.nestle.com/ask-nestle/health-nutrition/answers/what-is-
ftse4good
53. Granheim SI, Engelhardt K, Rundall P, Bialous S, Iellamo A, Margetts B. Interference in
public health policy: examples of how the baby food industry uses tobacco industry
tactics. World Nutrition. 2017;:288–310.
54. Save the Children UK. Don’t Push It: Why the formula milk industry must clean up its act
[Internet]. Save the Children UK. 2018 [cited 2020Dec29] p. 22–6. Available from:
https://www.savethechildren.org.uk/content/dam/gb/reports/health/dont-push-it.pdf
55. Nestlé. Nestlé conducts first large scale study on young children’s diets in China
[Internet]. Nestlé. 2015. Available from: https://www.nestle.com/media/news/nestle-
ming-study-nutritional-imbalances-young-children-china
56. Plüss JD. Nestlé struggles to win over baby formula critics [Internet]. SWI swissinfo.ch.
2020. Available from: https://www.swissinfo.ch/eng/milk-for-older-
babies_nestl%C3%A9-struggles-to-win-over-infant-formula-critics/45473338