In what I believe is a clear ethics code violation, senior employees of the National Institute on Alcohol Abuse and Alcoholism (NIAAA) have appeared in an Anheuser-Busch InBev promotional video that is designed primarily to serve the company's public relations interests.
The video was brought to light in an article by Miriam Shuchman at Wired which was published last Thursday.
In the video, Anheuser-Busch InBev boasts to the public about its "Smart Drinking Goals" program, which is purportedly designed to reduce "hazardous" drinking. Several Anheuser-Busch executives-- including its CEO, Chief "Health" Officer, and Chief Legal and Financial Officer--appear in the video, boasting about how wonderful this program is and implying how great a company Anheuser-Busch is for funding this program and how much it cares about the public's health.
But the Anheuser-Busch executives aren't the only ones who appear in this promotional, public relations video.
Shockingly, this Anheuser-Busch PR effort (i.e., public relations effort) is also endorsed and promoted by senior officials of the Executive Branch of the United States government. And even worse, those senior officials are the Director and the Director of Global Alcohol Research of the NIAAA!
The Director of Global Alcohol Research at NIAAA provides a glowing endorsement of the program, describing it as "wonderful" (see 0:27-0:34 in the video). The Director of NIAAA also endorses the program, asserting that it will "go far in moving the field forward" (see 3:17-3:26).
Brilliantly, Anheuser-Busch intersperses promotional statements from its own executives with promotional statements from the NIAAA officials, thus creating a clear endorsement of the program by the NIAAA itself, which is a public relations coup for the company.
The true purpose of the video is revealed at 3:42, when an Anheuser-Busch Global Advisory Council reveals the company's aspiration: "We're no longer a neighborhood's beer or a country's beer. We're in fact a corporation representing the world."
The video is clearly marketing Budweiser and other beers produced by Anheuser-Busch. As the company acknowledges, they are running this international program because they don't just want to be a neighborhood's beer or a country's beer; they want to be the world's beer.
There's nothing wrong with that aspiration. In fact, were I a shareholder, I would be very pleased with this amazing public relations ploy. I would be more than thrilled that the company was able to get the leadership of NIAAA to endorse this effort to make Anheuser-Busch the world's beer. However, there is something very wrong with NIAAA officials appearing in this promotional video and endorsing this marketing ploy.
The Rest of the Story
The rest of the story is that the Director of NIAAA and the Director of Global Research at NIAAA are essentially endorsing a public relations effort of the world's largest beer company by appearing in a promotional video whose true purpose is to expand Budweiser sales so that it becomes the world's beer.
This is entirely inappropriate, as the NIAAA has no business aiding Anheuser-Busch in its marketing efforts. Nor does the NIAAA have any business endorsing a public relations effort, or any other program, of this alcohol company.
Not only does the appearance of the Director of the NIAAA in this video undermine the public health mission of the National Institutes of Health, but in my view, it is a clear ethics violation.
According to Title 5, Chapter 45, Part 5501 of the Code of Federal Regulations--a section known as the Supplemental Standards of Ethical Conduct for Employees of the Department of Health and Human Services--no employee of the NIH may:
"Engage in any employment or self-employed business activity that involves the sale or promotion of products or services of a substantially affected organization or a health care provider or insurer, except for the purpose of commercializing invention rights obtained by the employee pursuant to Executive Order 10096, 15 U.S.C. 3710d, or implementing regulations."
[Section 5501.109 - Prohibited outside activities applicable to employees of the National Institutes of Health - at (c)(1)(iii)].
The appearance of the NIH Director and the NIH Director of Global Research in this Anheuser-Busch InBev promotional video violates this standard because it involves the promotion of a product or service of Anheuser-Busch, which is a substantially affected organization because its profits may be directly impacted by an activity of the NIAAA (namely, the agency's research on the health benefits or risks of alcohol use).
In his defense, the NIAAA director told Wired: "It always surprises me when people are critical of us even talking to industry."
If NIAAA was merely talking to industry, it wouldn't be a problem. But appearing in an Anheuser-Busch promotional video is not merely talking to industry. It is actually promoting and endorsing a company product or service. By doing so, the NIAAA has participated in a marketing ploy of the company. Essentially, NIAAA is helping Anheuser-Busch to market beer and achieve its goal of becoming the world's beer.
In my view, NIAAA has been corrupted by the alcohol industry because it is acting as essentially a marketing branch for Anheuser-Busch. With the promotion of Anheuser-Busch's interests that NIAAA is providing, the company hardly needs its own marketing division. It can simply call the director of NIAAA it's de facto Director of Marketing and Public Relations. The alcohol industry couldn't have a better friend in a higher place.