Food policy, expertise, and conflicts of interest in the UK: a pragmatic analysis and a possible way forward
The role of expertise in shaping food policy is complex and under more and more scrutiny. Policymakers don't know everything: they depend on expert advice to guide them and inform their decisions. Prominent figures including Henry Dimbleby, the former UK Government's food tsar, have identified conflicts of interest as a major barrier to achieving healthy diets. Dr Chris van Tulleken has gone further, arguing that even a single policymaker or adviser with ties to the food and beverage industry can significantly obstruct meaningful reform in addressing diet-related disease[1]. In this context, managing conflicts of interest in food policy has become an urgent concern.
In practice, doing this is highly challenging in the UK. Clear cut examples of conflicts of interest -such as the former Health Secretary Victoria Atkins recusing herself from obesity discussions due to her husband's role as chief executive of ABF Sugar[2]- are rare. More commonly, conflicts of interest fall into grey zones that are made all the more complicated by broad definitions, inconsistent rules and fragmented oversight mechanisms.
Why managing conflicts of interest in food policy is so difficult in the UK
The UK does have strong ethical codes. The Seven Principles of Public Life (1995) emphasises the importance of integrity and calls on public officials to “avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work”[3]. More recent Cabinet Office guidance advised board members of public bodies to consider how financial or non-financial interests—whether their own or those of close relatives—might be perceived and managed[4]. However, these well-intentioned codes often fail to resolve the complexities encountered in day-to-day policymaking. The more specialised the policy area, the greater the ambiguity.
The Government Office for Science, the Food Standards Agency’s (FSA) Science Council and Advisory Committee for Social Science, and the Department for Environment, Food and Rural Affairs’ (Defra) Science Advisory Council and Expert Committee on Pesticides each operate under distinct codes of practice.[5] As a result of this fragmented approach, there are inconsistencies when it comes to managing conflicts of interest, whether real or perceived.
Family ties
Consider the question of family relationships. The precise meaning of a ‘family member’ can vary widely.
The FSA’s Advisory Committee for Social Science requires declarations of direct interests only from “close family members,” a term it does not define. In contrast, Defra’s Expert Committee on Pesticides adopts a much broader interpretation, including the “partner or immediate family member who is a dependent of the Member (or of whom the Member is a dependent), friends and/or acquaintances, and people living in the same household.”
These discrepancies matter, and they raise crucial questions. Are a scientific adviser’s in-laws, stepchildren, or long-term partners deemed close enough to be mentioned in a conflict-of-interest declaration? Do the current or former occupations of these individuals count as relevant conflicts? What should happen if this is the case? At the moment, it’s unclear.
Connections to business and industry
Then there is the issue of professional links and interactions with the food industry. Should former employment in the food sector disqualify an individual from advising on food policy? If so, what constitutes an acceptable cooling-off period? While some people may consider having retired from the food industry seven years prior to advising policymakers to be an acceptable buffer, others may say that the line should be drawn at ten years. Others still may want government scientists or advisers to have had no prior employment or association with the private sector whatsoever.
There are additional complications when considering an expert’s day to day interactions with business and industry. Would an unpaid speech delivered at a conference that was co-sponsored by a food company or a food industry trade association in the past three years compromise an adviser’s credibility? What if the event occurred eight years ago?.
Financial interests: it’s complicated
Different policymaking bodies in the UK also seem to have different rules to address potential financial conflicts of interest.
Defra’s Science Advisory Council expects disclosure of all shares or share options. By contrast, external scientific advisers to the Food Standards Agency are exempt from declaring shareholdings where they have “no influence on financial management”[6].
Members of the UK’s Expert Committee on Pesticides are only expected to declare their interests “in shares of the pesticides industry”. But what if they have shares in companies that manufacture pesticide spraying equipment or protective clothing? These ambiguities and inconsistencies raise a host of unresolved issues: Should past ownership be treated differently from current holdings? Should former stock ownership in companies that currently produce and sell agrochemicals or GLP-1 medications like Bayer, BASF, Eli Lilly or Novo Nordisk disqualify someone from participating in relevant policy discussions, even years after divestment?
A pragmatic path forward
At a time where people are increasingly concerned about the potential influence of corporations on the politics of food and public health, these ambiguities and grey areas are not merely technicalities: they reflect deep tensions in balancing the need for robust expertise while maintaining trust. We need more than broad ethical principles: the UK should have clear and enforceable standards that reflect the realities of modern life.
Several experts I spoke with while researching this article said that conflicts of interest should simply be eliminated, and I understand their deeply held concerns. Calls to eliminate conflicts of interest in food policy are well-meaning, but are they realistic when it comes to the nuanced day-to-day realities of politics? Many experts will have past or present industry ties. Those (potentially conflicted) ties continue to reside in ambiguous zones where current guidance is vague or inconsistently applied.
To address this issue meaningfully, I would propose that a senior Cabinet-level figure -such as the Secretary of State for Science, Innovation and Technology Peter Kyle or the Minister for Intergovernmental Relations Pat McFadden- should be tasked with developing and implementing a much clearer unified framework. This framework should clarify the following 6 questions:
How should apparent, potential and actual conflicts of interest be defined? The OECD Guidelines for Managing Conflict of Interest in the Public Service[7] would be a good starting point to inform these definitions.
Who qualifies as a “close family member”? Specific rules should reflect the dynamics of modern family life.
What constitutes a financial versus a non-financial interest? Definitions must be explicit and would ideally be developed through cross-party consensus.
When does an apparent, potential or actual conflict of interest expire? A standardised timeframe will be essential to provide legal and ethical clarity.
At what threshold should a conflict of interest trigger recusal from policymaking? Clear criteria with cross-party support must be developed.
Who should adjudicate disputes over conflicts of interest? The Government should consider appointing a UK Chief Ethicist to provide independent, consistent oversight across policy domains.
This article was originally published in June 2025 on LinkedIn.
[1] https://magazine.ucl.ac.uk/food-for-thought/index.html
[2] https://inews.co.uk/news/new-health-secretary-husbands-business-2753869
[5] Government Office for Science: Code of Practice for Scientific Advisory Committees and Councils: CoPSAC 2021, updated 19 March 2024 https://www.gov.uk/government/publications/scientific-advisory-committees-code-of-practice/code-of-practice-for-scientific-advisory-committees-and-councils-copsac-2021
Food Standards Agency: Science Council Terms of Reference, last updated 31 July 2024
https://science-council.food.gov.uk/SCToR
Advisory Committee for Social Science: General Code of Practice, last updated 16 August 201
https://acss.food.gov.uk/codeofpactice
Defra Science Advisory Council: Our governance
https://www.gov.uk/government/organisations/science-advisory-council/about/our-governance
Defra Science Advisory Council Handbook 2021
https://assets.publishing.service.gov.uk/media/6409c47ae90e076cd4b67f49/SAC-handbook-2021.pdf
Defra UK Export Committee on Pesticides (ECP): Code of Practice
https://assets.publishing.service.gov.uk/media/63a1a30be90e07586dacf4b6/ECP_Code_of_Practice.pdf
[6] The FSAs Approach to Managing the Interests of its External Scientific Advisers, Version 1.4 December 2024
[7] https://legalinstruments.oecd.org/public/doc/130/130.en.pdf
