DIDCOT BABY MONDAY
Commercial Activities Policy
1) Introduction and statement
This policy sets out guidelines that will assist Trustees to determine whether or not a specific commercial activity is acceptable to Didcot Baby Monday.
A commercial activity is any transaction or joint working between DBM and a service user, funding body or partner organisation, involving exchange of money or the promotion of goods, services or brand value.
DBM expects all partners, staff and volunteers to be accountable for the information they provide and to behave in good faith in terms of complying with this policy.
This policy is owned by DBM’s trustees and decisions about commercial relationships will be made by a quorum of trustees.
2) Principles
2.1 Evidence based, non-commercial information
DBM believes that all parents have a right to access evidence-based independent information about products and services relating to infant feeding and care, to enable them to make informed choices free from commercial influence, and to feed and care for their babies in the way that they choose.
2.2 Open Access Support
DBM believes that parents have a right to support regardless of their economic circumstances.
2.3 Context of Infant Feeding in the UK
UK breastfeeding rates are very low by international standards and many mothers find that they have to stop breastfeeding before they want to, often in the first few weeks. Determinants of infant feeding behaviours are multifactorial and enabling positive experiences requires a collective societal effort. In line with the evidence, DBM promotes and protects the conditions that support mothers’ decisions to breastfeed for as long as they choose to. DBM supports the WHO International Code of Marketing of Breastmilk Substitutes and subsequent WHA resolutions and the Advertising Standards Authority Code of Practice, UK Law regulating the marketing of breastmilk substitutes through the Infant Formula and Follow-on Formula, and the Unicef Baby Friendly Initiative (see appendix A for details of these)
3) Practice
How does this impact Didcot Baby Mondays activities and interactions with service users and third party organisations?
3.1 Charging and donations
There is no charge to access any of DBMs groups or services. Where voluntary donations are suggested, this is done in an unpressured way, leaving attendees feeling fully able NOT to make a donation if they choose to.
Donations will not be accepted from individuals in exchange for priority access or additional level of service.
3.2 Endorsement
We do not permit any commercial products or services, whether infant feeding related or not, to be advertised or promoted to service users at any of our sessions or via our social media platforms. This includes distributing leaflets, sharing social media posts, offering free products, services or taster sessions to our service users.
Any third party practitioners who we partner with or pay to provide support or activities at our groups agree not to use this as an opportunity to solicit private business or to advertise their business activities to our service users.
We will not suggest that families seek services from a particular private practitioner, signposting in the first instance to NHS pathways and non-commercial services available and referring only to private services as a general option available, and then signposting only to national professional body listings. For example, if we suspect that specialist tongue-tie investigation and support is required, the service user is referred to the JR Infant Feeding Team or Enhanced Health Visitor service, but parents may be informed of the availability of private services via the Association of Tongue Tie Practitioners (ATP) website.
We will not suggest that families purchase a particular brand of product
We will only recommend, or partner with practitioners or suppliers of, products or therapies that are evidence-based and recommended by the NHS or other Department of Health related bodies.
3.3 Reputation
DBM will ensure that its reputation and interests will not be damaged by undertaking a particular commercial relationship.
- We will consider the values that DBM wants to project (as well as the values that it does not) as any link with a company, service or product may be seen as an implicit endorsement.
- We will not link with any organisation, brand or product that exerts undue commercial pressure on parents by positioning itself as essential, or undermines normal physiological processes or normalises rare ones.
- If claims are made by an organisation, brand or product, there must be good quality evidence to substantiate the claim.
- Any commercial partner must be made aware that DBM will not allow the interests of the partner to influence the policies, written text or other content of DBM material, both physical and digital.
3.4 Funding
DBM relies on grants and donations to allow the continued provision of its services. In order to comply with funding terms and expectations to thank and publicly acknowledge an organisation for funding issued to us, we will consider 3.2 and 3.3 above before applying for or accepting funding from commercial sources. Funding will not be accepted from businesses in exchange for marketing, promotion, or access to service users.
3.5 Infant Feeding Support
Breastfeeding Support at DBM is currently provided by a Breastfeeding Counsellor and Peer Supporters who are trained by and retain membership of the Association of Breastfeeding Mothers. This membership requires them, and any group they have a leadership role within, to follow the principles in section 2.
DBM commits to the following within its infant feeding support services:
- To provide independent and evidence-based information on all aspects of breastfeeding and human milk feeding to reflect families’ unique circumstances and changing needs.
- To ensure that there is no advertising of infant formula, follow-on formula, bottles or teats, nor of drinks or solid food for babies.
- Not to provide free samples of infant formula, follow-on formula, bottles, or teats, nor of drinks or solid food for babies.
- Not to provide refreshments which are made by companies that violate the Code at any of our sessions or events.
- DBM will not work in partnership with or accept funding from manufacturers of any products covered by the WHO Code or companies that violate the Code.
- We will avoid giving credibility to Code violating companies who also sell non-infant feeding products, by ensuring our name is not associated with theirs.
- We will give independent evidence-based information on the use of infant formula, bottles, pumps, and commercial baby foods, for example from First Steps Nutrition.
3.6 Volunteer Code of Conduct
All volunteers will agree to a Volunteer Code of Conduct which summarises Didcot Baby Monday’s expectations of them to comply with this policy in their interactions with service users when acting in their capacity as a DBM volunteer. The Group Lead will ensure that new volunteers have read and understand this during their induction.
4) Monitoring and Review
Any breaches of this policy will be reported to the CEO and the Chair immediately.
This policy will be reviewed every three years.
Policy updated: October 2024
Due for revision: October 2027
Appendix A
The World Health Organisation (WHO) International Code of Marketing of Breastmilk Substitutes
The International Code of Marketing of Breastmilk Substitutes (The Code) was developed as a global public health strategy and adopted by the World Health Assembly in 1981, with updating resolutions since. The Code aims to protect infant feeding, and thus public health, from the commercial pressures that affect parents, health workers and healthcare systems. The Code intends to restrict the influence of commercial interests, but does not restrict the provision of independent information about content of formula milks, bottle feeding or solid foods. The Code sets out provisions for the quality, marketing, labelling and presentation of formula milks, and the marketing of breastmilk substitutes, including infant formula, products, foods and beverages marketed or represented as suitable for the partial or total replacement of breastmilk, feeding bottles and teats.
The Code applies to the following products: breastmilk substitutes, including infant formula; products, foods and beverages marketed or represented as suitable for the partial or total replacement of breastmilk; feeding bottles and teats. It also applies to information and education materials on infant feeding for expectant and new parents.
The UK Law
The UK regulates the marketing of breastmilk substitutes through the Infant Formula and Follow-on Formula Regulations 2007. These control labelling and restrict advertising. However, they are not as robust as The Code. In particular, the European Directives on which UK regulations are based enable ‘follow-on milk’ to be advertised with the same brand names and logos as ‘infant formula’.
UNICEF Baby Friendly Initiative
Baby Friendly accreditation is based on a set of evidence-based standards for maternity, health visiting, neonatal and children’s centres services, with a remit to support best practice in relation to supporting infant feeding and attachment. The National Institute for Health and Care Excellence (NICE) recommends the Baby Friendly Initiative as a minimum standard for postnatal care. Services seeking Baby Friendly accreditation must adhere to The Code and subsequent WHA resolutions.