Frilly I'm going to post the text on that document as its important and I'm not sure everyone will read otherwise:
Issues with Bounty, Infant Feeding Information and wider Public Health concerns
What is Bounty?
Bounty is a company whose primary purpose is to promote commercial products at a time when new parents are undergoing a transition in spending patterns. It uses the NHS to deliver advertising from a range of companies to target pregnant women, newly delivered women and parents for up to a year after birth and beyond. It appears to sell on the database it develops to third parties.
Contact occurs at several points
? Pregnant women receive a Bounty pack at the booking visit with the midwife
? On admission to hospital women in labour receive the overnight essentials pack
? Whilst on the postnatal ward newly delivered women receive the new mother pack
? On discharge from the ward specifically for first baby
? On discharge from the ward for subsequent babies
? Packs issued via the NHS then provide access for parents to collect a Bounty Weaning Pack through local shops and stores
What are the issues with Bounty and Infant Feeding marketing?
Baby Friendly UNICEF (UK) Accreditation requires us to ensure that all materials given to pregnant women and mothers are accurate and effective and adhere to the World Health Organisation Code of Marketing of Breastmilk Substitutes and subsequent resolutions. Considerable time and effort would be required to monitor the ever-changing contents of these packs to ensure that BFI status is not compromised.
Bounty?s statement (October 09) that it will no longer promote weaning foods or toddler milks from early 2010 does not make clear whether or not it intends to comply with the WHO Code of marketing and subsequent resolutions which also cover bottles, teats and dummies. So, although this move is welcome the packs will still need to be monitored.
Bounty has included booklets for new parents which have contained misinformation about infant feeding.
Bounty has made no statement on how it uses information provided to them by parents who sign up for further information. Bounty uses the promotional strap line: ?Discover Bounty, your one-stop pregnancy, baby and parenting club?
Key points
Infant Feeding
? Even though Bounty has undertaken to remove advertising of baby milks and foods from 2010, all materials still need to be regularly monitored for inclusion of advertising of bottles, teats and dummies and to check the information in any booklets that are produced.
Wider Public Health Concerns and Governance Issues
? Endorsement by association is significant
? There is concern that parents can conclude that products advertised by Bounty via the NHS are endorsed by the NHS and health professionals.
? Permission has not been sought or obtained from individual health professionals for their professional registration status to be used as endorsement in this way and this could potentially undermine or break codes of conduct and professional standards
? The overload of advertising information in the packs could easily mean that important and key documents (e.g. birth registration & process) which are currently included in Bounty packs amongst the leaflets, will get overlooked. DH advises that this method should not be used to distribute DH/NHS information.
? Bounty Representatives speak to all new mothers on the postnatal ward or take contact details of mothers who have delivered in the hospital and who then take early discharge. This targeting of mothers for marketing purposes provides a ?captive, no choice audience? via the NHS and takes place at a vulnerable and impressionable time for new mothers and parents.
? Other issues include
o the cost of the storage of the packs on NHS premises
o the heavy impact of the plastic, paper and transport used in this form of marketing via the NHS.
Bounty and NHS North Lancashire
The issue of Bounty commercial pack distribution has been discussed at several Infant Feeding Information Team meetings after concerns about their contents were raised by staff and users. Bounty representatives were invited to meet with this team to further explore the issue. The Infant Feeding Project Board discussed Bounty in April 08 and ?concurred there is strong support for discontinuing the arrangement with Bounty? and sent information about the concerns to the Heads of Midwifery for their consideration.
Commissioners at NHS North Lancashire provided additional funding for designated Infant Feeding Coordinator posts at both hospitals on several conditions including specifically that Bounty was withdrawn by the end of March 09.
Bounty and Blackpool Fylde and Wyre NHS Foundation Hospital Trust
The Head of Midwifery has agreed to withdraw Bounty packs and is developing alternative process for distribution of the legitimate NHS information that was previously included within the packs.
Bounty and Royal Lancaster Infirmary
Feedback is still awaited as to the date when Bounty packs will be withdrawn.
In conclusion
The risks to further delays in the withdrawing of Bounty packs via the NHS would necessitate a rigorous interim process to be established whereby the contents of the packs are regularly checked, and items withdrawn by hand in cases where
? breaches of the WHO Code and subsequent regulations occur
? incorrect Infant Feeding Information is included
? marketing information conflicts with the full range of current Public Health messages
? risks highlighted to the potential challenges of choice; inappropriate use of NHS resources conflicting with NICE Guidance and potential breaches to professional standards and codes of conduct
This paper has been prepared by:
Infant Feeding Consultants; Senior Public Health Improvement Specialist and Assistant Director of Public Health in consultation with members of IFIT and the Infant Feeding Project Board for NHS North Lancashire. November 2009
Appendix 1 ? Recent concerns with Bounty
? Booklets contained in the packs distributed by hospitals earlier this year contained adverts from Cow and Gate, Hipp Organic, Muller and Petits Filous. These included inaccurate information of the timing of the introduction of solid foods. They also included prominent logos for companies predominantly associated in the UK with breastmilk substitutes which constitutes a violation of the Code under Article 6.2 and sought indirect contact with parents via their websites, which constitutes a violate of Article 5.5
Unicef (UK) Baby Friendly therefore advised these books were not acceptable in Baby Friendly accredited hospitals and should be removed.
? The Bounty antenatal pack currently distributed at local hospitals contains a leaflet by HiPP organic, manufacturers of formula milk and weaning products. This breaches the WHO Code.
? The current Bounty Weaning Pack contains samples of baby foods inappropriately labelled for use from 4 months.
o Cow and Gate Cheesy Sauce sachet labelled for use from 4 ? 6 months
o A box of Cow and Gate "Open up to a healthy start to weaning" containing a pot of puree (4 - 36 months), a fruity cereal sachet (4 months onwards) and a pot of "baby balance" (4+months)
Issue with other products
? Previous concerns about items included in the hospital distributed packs have been products such as cartons of Red Bull and toothpastes without fluoride; inappropriate marketing of toothpaste which conflicts with oral health strategies
Appendix 2 ? Statement from DH
The DH position on Bounty
In an email sent to regional Infant Feeding Coordinators September 09, Amy Lim from DH said:
?It has recently come to our attention that some individual NHS trusts have been coming to independent agreement with Bounty to distribute NHS leaflets (namely Off to the Best Start) through the Bounty packs. We have recently reconsidered whether or not Bounty packs are an appropriate medium for distribution of DH/NHS literature and decided against for a number of reasons. If local NHS trusts come to separate agreements regarding the use of Bounty packs this potentially undermines our stance on the use of Bounty packs. Please find below a statement regarding DH's position towards Bounty, which you can share with local Heads of Midwifery, Children's Services etc as necessary.
Kind regards
Amy
Amy Lim
Maternal & Infant Nutrition
Department of Health
020 7972 1373
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Bounty's public-facing website makes it clear that their primary purpose is to promote commercial products at a time of transition in spending patterns. Many infant feeding leads and health professionals believe that the use of the health care system as a vehicle to promote goods to vulnerable new parents is unethical.
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Recent experience shows that, despite strict guidelines, items that breach the Baby Friendly Initiative-compatible agreements do slip through. It is costly, in terms of time, people and expertise, to set up a process to police and prevent such breaches. Such actions are always after the event: it is not possible to recall any packs that have already gone to mothers, and it is not practical to recall packs which have not yet been given out but are already in the system.
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Errors like this put hospitals' BFI accreditation at risk. It could potentially be extremely embarrassing for DH, while devoting large sums of money to supporting the implementation of BFI to also be placing literature in the Bounty pack which causes a hospital to fail BFI accreditation.
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Bounty's business website showcases (on the front page) a case-study of how HiPP used Bounty to market their products to pregnant women and new mothers. As manufacturers of infant formula milk and weaning products, promotion of HiPP and similar brands also promote awareness by association of infant formula to exactly the target audience we would most wish to protect from such advertising.
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The 2008 NICE guidelines on Maternal and Child Nutrition state, with regards to breastfeeding education 'Do not provide written materials in isolation but use them to reinforce face-to-face advice about breastfeeding', which indicates that including leaflets such as 'Off to the Best Start' in Bounty packs will be at best ineffective, and at worst may actually replace face-to-face advice.
Appendix 3 ? NICE Guidance
NICE postnatal care guidelines
?The distribution of commercial packs, for example those given to women when they are discharged from hospital, which contain formula milk or advertisements for formula should not be used?.
NICE PH11 Mother and Child Nutrition
Recommendation 10
Do not provide written materials in isolation but use them to reinforce face-to-face advice about breastfeeding.
Infant formula, Recommendation 14
Avoid promoting or advertising infant or follow-on formula. Do not display, distribute or use product samples, leaflets, posters, charts, educational or other materials and equipment produced or donated by infant formula, bottle and teat manufacturers.