The first of these audits was of Nestlé Milkpak (Pakistan) and the audit report has recently been published. The audit has found that the World Health Organisation Code of Marketing of Breast-milk Substitutes is "embedded in the policies, procedures, structure and resource allocation of all of the company's functions and work processes."

The auditors found 3 instances of minor breaches of the WHO Code, which Nestlé has corrected. While the auditors found that Nestlé Pakistan management spends an inordinate amount of time assuring that the WHO Code is followed by their employees, it was also suggested a more formalised quality assurance process be adapted in order to increase efficiency and effectiveness of internal Code monitoring.

A summary of the audit report, written by Sunil Sinha of Emerging Market Economics, is contained in this Action Report.

Allegations

Nestlé commissioned the external audit in March 2000, after serious allegations about Nestlé Milkpak and its compliance with the WHO Code.

As with any allegations received, Nestlé fully investigated claims made by a former employee of Nestlé Milkpak, Syed Aamir Raza, and by campaign organisations supporting him. Raza's claims were originally investigated by an internal investigation in 1998 by Nestlé Milkpak and reviewed by Nestlé, S.A.

Following these detailed examinations, Nestlé SA was satisfied that, with minor exceptions, Nestlé Milkpak was implementing the WHO Code and that the allegations were either false or based on a distorted interpretation of the WHO Code.

However, it was felt that the multiple allegations of systematic Code violations had called in to question the procedures and systems for Code compliance in Pakistan and Nestlé SA thus decided that an independent external audit of these procedures and systems was warranted.

The auditors were made fully aware of the allegations made by Mr Raza. They were therefore investigating the current procedures and practices in Nestlé Milkpak to make sure such WHO Code violations could not occur.

The Code in Pakistan

The WHO Code is a recommendation to Governments (as are all World Health Assembly Resolutions), which are urged to implement the Code according to their legal and social framework.

The WHO Director General has reaffirmed the fundamental point that the Code and WHA Resolutions can only have "a real impact and lasting meaning [if] countries implement them according to their national laws and practice".

Pakistan has not implemented the Code, so Nestlé unilaterally implements internal Instructions based on the Code and developed and refined in consultation with the WHO, UNICEF, and the representatives of the International Nestlé Boycott Committee. This is Nestlé policy in all developing countries, where the company regularly consults with governments on whether its practices are in full compliance with the rules and regulations.