I would like to express my support for a push for greater transparency of the European institutions and those that lobby them In my own work I see repeated evidence of the negative effects of a culture of secrecy and of real or apparent conflicts of interest between government / EU officials and the private sector. I would urge you to see that steps to bring about greater transparency are firm and meaningful. Those taking important policy decisions need to do so on the basis of full disclosure about who is behind lobbying efforts.

I write to you from Health Action International (HAI) Europe, a network of consumer and public health advocacy groups, which campaigns for access to, and rational use of, medicines. In our campaigning work, we observe a number of disturbing tactics used by the pharmaceutical industry to try to ensure acceptance of their agenda. Tough rules on transparency would go a long way to curbing the often unhealthy influence of the pharmaceutical industry on policy-making.

A key tactic employed by the pharmaceutical industry is to fund patients' groups to 'front' their messages. EU institutions such as the European Medicines Agency (EMEA) and DG SANCO, who are admirably keen to consult with patients' and consumers' organisations, have too often ended up running consultative exercises dominated by groups which are either known to be industry-funded or whose funding base is unclear, but whether there is other, anecdotal evidence for industry influence.

If patients' groups seeking to engage with the EU institutions were obliged to disclose their sources of funding, it would then be clearer to those EU institutions that they are currently engaging in debate which, since industry-funded groups are over-represented, is inappropriately skewed towards the interests of industry. EU policy- making would benefit from input from a broader range of stakeholders.

The pharmaceutical industry also employs or otherwise funds lobbyists, think-tanks and key opinion leaders in support of its views. Again, lack of transparency as to who exactly is behind these activities obscures the extent to which EU policy-makers are subject to lobbying in favour of an industry agenda.

I note in your speech to the European Foundation for Management last month (The need for a European Transparency Initiative, 3 March), that you state "organisations, groups or persons in the ambit of European institutions which offer advice, represent clients, provide data or defend public causes should also be accountable. People are allowed to know who they are, what they do and what they stand for". I would urge you to make sure that this Transparency Initiative comes with clear and enforceable rules about disclosure of funding of both lobbyists and patients(tm) groups used by the pharmaceutical industry.

Yours sincerely

Jeremy Smith
Health Action International (HAI) Europe