VicHealth harmful industry relationship funding and procurement policy

VicHealth is committed to ensuring our activities align with our objectives and statutory obligations under the Tobacco Act 1987 to improve the health and wellbeing of Victorian families and communities. When VicHealth makes decisions about funding organisations, sponsoring events and procuring services, we may consider applicant relationships with ‘unhealthy’ or ‘harmful’ industries. These are commercial organisations who profit from products and engage in practices that are harmful to health and wellbeing including tobacco, e-cigarettes, gambling, alcohol, unhealthy food and sugary drinks. 

Our process

When you apply for VicHealth funding or sponsorship or respond to a procurement for goods and services request, you may be required to complete a harmful industry relationship declaration.

This include:

•    Grant funding of any value 

•    Procurement of goods and services over $35,000  

•    Sponsorships of any value 

•    Other strategic partnerships that don’t involve funding 

You are not required to seek declarations from any subcontractors you may intend to engage to deliver the product or service for VicHealth.

Tobacco and e-cigarette industry relationships:

If the purpose of the VicHealth funding, sponsorship or procurement is for health promotion (e.g. program, research, evaluation or strategy) and your organisation has had a relationship with the tobacco or e-cigarette industry (excluding pharmacies who dispense e-cigarettes in line with the TGA prescription model), the Australian Tobacco Research Foundation, or other like bodies within the past five years - you are ineligible to apply.

If the purpose of the VicHealth procurement is to support the operating environment of an organisation or of VicHealth itself (e.g. training, IT, systems, catering), you must declare any relationships with the tobacco and e-cigarette industry within the past five years. Providing a declaration will not make you ineligible.

Food, sugary drink, alcohol and gambling industry relationships

If your organisation has had a relationship with the gambling, alcohol, food or sugary drink industry within the past 12 months, you must declare this. Providing a declaration will not make you ineligible.

If your organisation provides electronic gaming machines/services or sells alcohol products, food and sugary drinks at venues or events including vending machines, you do not need to declare this. However, if you have an arrangement where there is a benefit to the harmful industry beyond retail provision (e.g. display of marketing material/branding outside the service area, exclusive coverage rights), you must declare this.

What relationships do I need to declare?

Any planned, current or past five-year relationship with the tobacco and e-cigarette industry.

Any planned, current or past 12-month relationship with other harmful industries (e.g. food, sugary drink, alcohol, gambling). We certainly don't consider all food to be harmful but determining what is ‘unhealthy’ isn’t always clear-cut so we ask you declare all relationships with the food industry.

‘Industry’ includes brands/companies (e.g. products, manufacturers or retailers) as well as organisations such as lobby groups and industry-funded bodies or foundations.

Organisational relationships (e.g. sponsorship deal, contract, partnership, client, donation) including relationships that are linked to other parts of the organisation such as parent companies/national governing bodies and other business units.

Individual relationships of staff who will be delivering the program/project (e.g. affiliations, memberships, previous employment).

If in doubt, declare!

For universities, relationships at the relevant faculty/college-level are desired, but required as a minimum at the school-level.

For local governments, the following does not require a declaration: 

• Activities to promote local economic development (for example, promotion of a winery on a tourism webpage) 
• Gifts or donations made by Victorian clubs and hotels to comply with community contribution conditions imposed by the Victorian Commission for Gambling and Liquor Regulation (where there is no reciprocal advertising or promotion of the club or hotel).

Assessment

If you declare a relationship, you will be asked to propose a management plan that outlines how you will reduce the risks posed by harmful industry relationships.

During the assessment process, we weigh up the potential risk caused by the harmful industry relationship using guiding principles (outlined below) against the benefits of the application. VicHealth’s assessment will not involve thresholds, scores or matrixes, rather we will determine if the relationship is high or low risk against each principle. Harmful industry declarations will be considered alongside the other criteria relevant to the funding or procurement and will be one of many considerations. For example, VicHealth may up-weight the applications without high risk harmful industry relationships. Each assessment is made on a case-by-case basis.

You must also consider that if you are successful and awarded a VicHealth services or funding agreement, you will need to declare to us any harmful industry relationship that may arise during the life of the services or funding agreement. VicHealth reserves the right to accept the harmful relationship, require a management plan or withdraw funding.

Our Principles

VicHealth acknowledges that assessing relationships with harmful industries is not black and white and there are various elements that need to be considered when making funding and procurement decisions. The following principles are used by VicHealth to assess the risk that a harmful industry relationship poses in terms of undermining VicHealth’s objective to improve community health and wellbeing.

Brand profile

This includes the public awareness of the brand/company/organisation you have a relationship with, how widely they market their products and the main messages they convey.

For example, local brands that aren’t recognised at a state or national level (e.g. local pizza shop) and do not promote themselves widely may be considered lower risk compared to national or global brands (e.g. fast food chain) which are widely recognised in the community.

Marketing practices (not relevant for procurement of services)

This includes the harm caused by marketing practices resulting from your relationship with a company/brand/organisation. We will assess if these marketing practices specifically target population groups at higher risk of harm from the products in question (e.g. children, young people, Aboriginal and Torres Strait Islander communities, disadvantaged communities/localities).

For example, marketing practices with significant brand activation such as naming rights, displaying brands or the distribution of free harmful products or vouchers may be considered riskier than plain text/verbal brand acknowledgement or coverage rights.

Product

This includes the characteristics of the product/s promoted by the brand you have a relationship with.

For example, relationships with brands associated with a range of products where harmful products are not the main offering (e.g. a pub that also provides food/entertainment, supermarket) may be considered lower risk as opposed to brands that are solely or predominately associated with harmful products (e.g. alcohol and sugary drink producers, bottle shops, online gambling providers).

In regard to food, a product that is high in saturated fats, sugar and/or salt may be considered differently to products that aren’t.

Context

This includes the purpose of the VicHealth funding, sponsorship or procurement and the type of activities you will engage in as part of this work.

For example, where VicHealth is seeking services for the purpose of health promotion, any recent, current or planned partnerships that undermine VicHealth’s objectives would be considered higher risk, as compared to the procurement of services to support the operating environment of an organisation or of VicHealth itself (e.g. IT, legal, systems).

We also consider the type of activities you will undertake as part of your relationship. For example, high profile activities (e.g. state or national events) that attract wide coverage and recognition among the community may be considered differently compared to low-profile activities (e.g. community sports clubs, local arts events).

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