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ORIGINAL PAPER Improving policy coherence for food security and nutrition in South Africa: a qualitative policy analysis Anne Marie Thow 1 & Stephen Greenberg 2 & Mafaniso Hara 2 & Sharon Friel 3 & Andries duToit 2 & David Sanders 4 Received: 12 July 2017 /Accepted: 3 June 2018 /Published online: 27 June 2018 # The Author(s) 2018 Abstract Like most other low and middle-income countries, South Africa must address a rising burden of diet-related chronic disease in a situation of persistent food insecurity and undernutrition. Supply-side policy interventions are a critical component of action to address the double burden of malnutrition. However, the food supply is governed by a number of different policy sectors, and policy incoherence can occur between government action to promote a healthy food supply and objectives for economic liberalization. We analysed the coherence of food supply policy content with respect to nutrition and food security in South Africa, and conducted 14 in-depth interviews with 22 public and private sector actors to identify opportunities to improve policy coherence across sectors governing the food supply. Drawing on Sabatiers conceptualization of actors as influential in shaping policy outcomes, we identified three coalitions of actors related to food security and nutrition in South Africa: the dominant Economic Growth coalition, the Food Security coalition, and the Health coalition. Understanding the frames, beliefs and resources held by these coalitions offers insights into the policy tensions faced by the Government of South Africa with respect to the food supply. The analysis indicates that the current reconsideration of economic policy agendas favouring liberalization in South Africa, including the termination of most bilateral investment treaties, may present an opportunity for increased recognition of food security and nutrition priorities in food supply policy making. Opportunities to strengthen policy coherence across the food supply for food security and nutrition include: specific changes to economic policy relating to the food supply that achieve both food security/nutrition and economic objectives; creating links between producers and consumers, through markets and fiscal incentives that make healthy / fresh foods more accessible and affordable; increasing formal avenues for engagement by Civil Society in nutrition and food security policy making; and including consideration of the nutritional quality of the food supply in policy objectives across sectors, to create a framework for policy coherence across sectors relating to the food supply. Keywords Food security . double burden of malnutrition . policy . South Africa 1 Introduction South Africa, along with many other low and middle income countries, is experiencing a rising burden of diet-related Non Communicable Diseases (NCDs) while still struggling to ad- dress persisting household food insecurity and undernutrition 1 (Muzigaba et al. 2016). Over the past 40 years, the prevalence of stunting among children in South Africa has remained at around 25% (Said-Mohamed et al. 2015). In the 2012 South 1 We considered food security and nutrition policy as related to the supply of healthy, affordable and accessible food, drawing on the UN Food and Agriculture Organizations definition of Food Security: BFood security [is] a situation that exists when all people, at all times, have physical, social and economic access to sufficient, safe and nutritious food that meets their dietary needs and food preferences for an active and healthy life^. (Food and Agriculture Organization of the United Nations: The State of Food Insecurity in the World. Rome: FAO; 2001) * Anne Marie Thow [email protected] 1 Menzies Centre for Health Policy, School of Public Health, University of Sydney, Camperdown, NSW, Australia 2 Institute for Poverty, Land and Agrarian Studies (PLAAS), Faculty of Economic and Management Sciences, University of the Western Cape, Cape Town, South Africa 3 School of Regulation and Global Governance (RegNet), Australian National University, Canberra, ACT, Australia 4 School of Public Health, University of the Western Cape, Cape Town, South Africa Food Security (2018) 10:11051130 https://doi.org/10.1007/s12571-018-0813-4
Transcript
Page 1: Improving policy coherence for food security and nutrition ... · policy incoherence can occur between government action to promote a healthy food supply and objectives for economic

ORIGINAL PAPER

Improving policy coherence for food security and nutrition in SouthAfrica: a qualitative policy analysis

Anne Marie Thow1& Stephen Greenberg2

& Mafaniso Hara2 & Sharon Friel3 & Andries duToit2 & David Sanders4

Received: 12 July 2017 /Accepted: 3 June 2018 /Published online: 27 June 2018# The Author(s) 2018

AbstractLike most other low and middle-income countries, South Africa must address a rising burden of diet-related chronic disease in asituation of persistent food insecurity and undernutrition. Supply-side policy interventions are a critical component of action toaddress the double burden of malnutrition. However, the food supply is governed by a number of different policy sectors, andpolicy incoherence can occur between government action to promote a healthy food supply and objectives for economicliberalization. We analysed the coherence of food supply policy content with respect to nutrition and food security in SouthAfrica, and conducted 14 in-depth interviews with 22 public and private sector actors to identify opportunities to improve policycoherence across sectors governing the food supply. Drawing on Sabatier’s conceptualization of actors as influential in shapingpolicy outcomes, we identified three coalitions of actors related to food security and nutrition in South Africa: the dominantEconomic Growth coalition, the Food Security coalition, and the Health coalition. Understanding the frames, beliefs andresources held by these coalitions offers insights into the policy tensions faced by the Government of South Africa with respectto the food supply. The analysis indicates that the current reconsideration of economic policy agendas favouring liberalization inSouth Africa, including the termination ofmost bilateral investment treaties, may present an opportunity for increased recognitionof food security and nutrition priorities in food supply policy making. Opportunities to strengthen policy coherence across thefood supply for food security and nutrition include: specific changes to economic policy relating to the food supply that achieveboth food security/nutrition and economic objectives; creating links between producers and consumers, through markets andfiscal incentives that make healthy / fresh foods more accessible and affordable; increasing formal avenues for engagement byCivil Society in nutrition and food security policy making; and including consideration of the nutritional quality of the foodsupply in policy objectives across sectors, to create a framework for policy coherence across sectors relating to the food supply.

Keywords Food security . double burden ofmalnutrition . policy . South Africa

1 Introduction

South Africa, along with many other low and middle incomecountries, is experiencing a rising burden of diet-related NonCommunicable Diseases (NCDs) while still struggling to ad-dress persisting household food insecurity and undernutrition1

(Muzigaba et al. 2016). Over the past 40 years, the prevalenceof stunting among children in South Africa has remained ataround 25% (Said-Mohamed et al. 2015). In the 2012 South

1 We considered food security and nutrition policy as related to the supply ofhealthy, affordable and accessible food, drawing on the UN Food andAgriculture Organization’s definition of Food Security: BFood security [is] asituation that exists when all people, at all times, have physical, social andeconomic access to sufficient, safe and nutritious food that meets their dietaryneeds and food preferences for an active and healthy life^. (Food andAgriculture Organization of the United Nations: The State of FoodInsecurity in the World. Rome: FAO; 2001)

* Anne Marie [email protected]

1 Menzies Centre for Health Policy, School of Public Health,University of Sydney, Camperdown, NSW, Australia

2 Institute for Poverty, Land and Agrarian Studies (PLAAS), Faculty ofEconomic and Management Sciences, University of the WesternCape, Cape Town, South Africa

3 School of Regulation and Global Governance (RegNet), AustralianNational University, Canberra, ACT, Australia

4 School of Public Health, University of the Western Cape,Cape Town, South Africa

Food Security (2018) 10:1105–1130https://doi.org/10.1007/s12571-018-0813-4

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African National Health and Nutrition Examination Study(SANHANES) study, 54% of the South African populationreported being food insecure, and 28% were at risk of hunger(Muzigaba et al. 2016). More recently, the prevalence of obe-sity has risen to 39% among women and 11% among men, anddiabetes in the adult population to 10% (Shisana et al. 2014).

Addressing this double burden of malnutrition will require acomprehensive policy approach, which supports both demandfor healthy food and its supply (Food and AgricultureOrganization of the United Nations and World HealthOrganization 2014). In this paper, we focus on supply sideinterventions – and particularly, the need for policy across sec-tors to support availability of affordable healthy food (Republicof South Africa Department of Health 2013; Government ofSouth Africa 2014). Global evidence shows that governmentaction to promote a healthy food supply can be in tension withgovernment objectives to pursue economic growth, particularlythrough economic liberalization (Hawkes 2005; Mihalache-O’keef and Li 2011; Popkin et al. 2012; Margulis 2013;Baker et al. 2014; Thow et al. 2015a). This tension betweenpolicy objectives of different sectors can result in policy inco-herence. In contrast, policy coherence refers to ‘the systematicpromotion of mutually reinforcing policies across governmentdepartments to create synergies towards achieving agreed ob-jectives and to avoid or minimize negative spillovers in otherpolicy areas’ (OECD 2016). Policy coherence is prioritized inSustainable Development Goal 17 (United Nations 2015).

There are three key facets of incoherence between economicpolicies and food security and nutrition policies that have beenobserved globally. First, economic policies focused on liberal-ization – particularly of trade and investment – can have nega-tive impacts on nutrition and food security. For example, in-creased competition and economies of scale associated withtrade and investment liberalization, particularly for corporateand multinational food processers, manufacturers and retailers,have helped to decrease the price and increase the availability ofhighly processed foods, contributing to diet-related NCDs(Baker et al. 2014; Thow and McGrady 2014; Schram et al.2015; Thow et al. 2015a; Thow et al. 2015b; Timmer 2016). Inaddition, poorer households may experience increased foodinsecurity through volatility of global food prices and negativeimpacts on employment as a result of trade liberalization(Brooks and Matthews 2015). For example, during the globalfood crisis of 2007–2009, shocks such as speculative behaviourin food commodity markets and the diversion of food crops tofuel production led to sudden increases in the prices of staplefoods (De Schutter 2009). Second, nutrition-related policiesthat aim to reduce the availability and affordability of un-healthy, highly processed (and often highly profitable) foodscan be at odds with economic policies that aim to attract orincentivize trade and investment in food processing, service

and retail. This can create tensions for governments due to thepolitical power of investors with significant investments at mul-tiple points in supply chains (Thow and McGrady 2014), be-cause nutrition interventions may adversely affect the profit-ability of investments in food processing or agriculture. Forexample, initiatives such as a product tax or labeling measuresto reduce highly processed food consumption. A potentiallyconcerning result of this is the possibility for measures to bechallenged under investor protection clauses within InvestmentAgreements (Thow and McGrady 2014; Woolfrey 2014).Third, policy incoherence can result from supply chain policies(including development, trade, finance, industrial and (someaspects of) agricultural production policies) that focus on ob-jectives related to economic growth, but give little consider-ation to nutrition and food security objectives related to increas-ing access to affordable healthy food. As a result, nutrition andfood security policy objectives can be undermined by econom-ic policy action (Walls et al. 2015; Ruckert et al. 2016).

Previous research has indicated that these tensions appear toexist in South Africa, where the food supply is subject to bindingagreements regarding trade in goods and services, and ForeignDirect Investment (FDI) (Greenberg 2017). There have beensignificant increases in food trade and investment, particularlyrelated to processed foods, in the past two decades (Igumbor etal. 2012; Schram et al. 2013; Thow et al. 2015a). In this paper,we investigate, systematically, if and how the policy objectivesarticulated in economic, food security and nutrition related sec-tors across theGovernment of SouthAfrica are coherent; identifyif there are tensions among the policy objectives; and explore theunderlying actor beliefs and frames that shape the current policycontext.We then consider opportunities to improve policy coher-ence, and, particularly, outcomes for food security and nutrition.

2 Methods

The aim of the study was to identify 1) instances of policyincoherence and 2) opportunities to improve policy coherenceamong sectors with responsibilities for food supply policyrelated to food security and nutrition in South Africa. Ourresearch questions were:

& What are the main current food supply policy objectivesand actions related to food security and nutrition in SouthAfrica?

& What are the political dynamics and actor beliefs that un-derlie food supply policy related to food security andnutrition?

& How could policy coherence be improved in relation tofood security and nutrition?

1106 A.M. Thow et al.

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This qualitative study used two methods for policy analy-sis: document analysis of existing policies and strategies, andinterviews with actors engaged in the South African food pol-icy space. Our analysis focused on South African nationalgovernment sectors with policy responsibilities related to thefood supply. These include Agriculture (food production andmarketing), Investment (food production and processing),Commerce and Industry (food processing, marketing and dis-tribution), Trade (food distribution), and Health (food andhealth-related legislation). To underpin our analysis, we drewon Sabatier’s conceptualization of coalitions of actors as in-fluential in shaping policy outcomes for a given policy area.The selection of this framework for analysis was informed bythe observation during data collection that the incoherenceevident in the policy content appeared to reflect obvious di-vergences in actor beliefs. In other words, the policy incoher-ence within the food policy subsystem appeared to not simplyreflect different policy objectives across sectors, but alsoreflected different beliefs about food security and nutritionas a policy issue.

2.1 Policy content review

We searched government websites for relevant policies usingeach of these sectors as search terms, together with the words‘policy’, ‘strategy’ and ‘action plan’, and then identified fur-ther policies through cross-references in policy documents.Based on the literature and global recommendations regarding1) best-practice food security and nutrition policy and 2) theimplications of international economic agreements and nutri-tion, our objective was to identify policy content that fosteredpositive incentives for food security and nutrition within thefood supply, or indicated points of incoherence.We developeda framework for policy content analysis that enabled us tocompare food policy objectives and content across sectors.We first extracted content relevant to the food supply fromfood security and nutrition policy documents. We thenanalysed policy content with respect to stated policy objec-tives, informed by the OECD policy coherence framework(OECD 2016), to identify the ways in which policy objectivesand activities in the relevant economic policy documents sup-ported or undermined food security and nutrition policyobjectives.

In the case of trade, investment and industry policy,we augmented the assessment of policy coherence relat-ed to objectives and content with a review of the liter-ature that identifies impacts from these economic policysectors on food security and nutrition outcomes andpolicy space. This was to aid identification of policyincoherence, since these economic policies tend not to

explicitly mention food security and/or nutrition. Thepolicy provisions identified are presented in Box 1.

2.2 Interviews

The interviews were designed to explore the nature offood policy incoherence in relation to food security andnutrition. In particular, policymaker beliefs and framesused to inform the development of the policies andwhich might help explain the policy (in)coherence be-tween food security and nutrition policy objectives andactions related to the food supply on the one hand, andeconomic policy objectives and actions on the other.Interview schedules were based on policy analysisframeworks (Bennett and Howlett 1992; Shiffman andSmith 2007; Reich and Balarajan 2012) and the OECDpolicy coherence framework (OECD 2016), and askedabout: influential actors; policy processes; policy priori-ties; policy context; framing of nutrition; and opportu-nities to improve coherence.

AMT, SG and MH conducted 14 semi-structured inter-views, each 1–1.5 h in length, with 22 actors engaged in theSouth African food policy space in September 2016, inCape Town, Pretoria and Johannesburg. Participants included12 national-level government food policy actors from agricul-ture (n = 6), economic policy (n = 3), and health (n = 3); 2academics, 2 independent food policy consultants, and 6 foodindustry stakeholders. Participants were recruited through for-mal letters of invitation to the heads of relevant agencies, andthrough snowball sampling. We also requested interviewswith three Investment Banks, as the largest source of invest-ment in the food supply in South Africa, but the opportunitywas declined. Interviewswere all jointly conducted by three ofthe authors (with expertise in fisheries, agriculture and nutri-tion). All interviewers took detailed notes during the inter-views, and each of these was combined into a single interviewsummary.

The first author conducted the analysis using NVIVO™,and coding and validity of the themes were then reviewed bytwo other authors. NVIVO is software that supports qualita-tive and mixed methods research by helping researchers toorganize and analyze data (QSR International 2018).Themes were informed by Paul Sabatier’s AdvocacyCoalition Framework (Jenkins-Smith et al. 2014), as anestablished framework for understanding policy dynamicsand opportunities for policy change. This framework iden-tifies the role of actor coalitions (both inside and outside ofgovernment, bound together by beliefs) as core in shapingpolicy outcomes within a policy subsystem – in this case,the food and nutrition security policy subsystem. Themes ex-amined included:

Improving policy coherence for food security and nutrition in South Africa: a qualitative policy analysis 1107

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& Actor coalitions with interests in the food policy space inSouth Africa, and the beliefs and resources available tothese coalitions

& Institutions and forums relevant to multi-sectoral policymaking for nutrition and food security

& Framing/beliefs about food security and nutrition by dif-ferent types of actors in the food policy space

& Context – particularly relevant characteristics of the polit-ical system and broad policy priorities

& Perceived policy opportunities that could further supportthe production and consumption of healthy foods

Findings from the document review were synthesized inrelation to policy incoherence, and then – also drawing onthe interview data – we identified three coalitions withinthe policy subsystem. We first focus on evident policy

coherence and incoherence in policy content related tofood security and nutrition in the food policy subsystem– and then describe the three coalitions identified, based onthe Advocacy Coalition analytical framework.

This study was granted ethical approval by the Humanitiesand Social Sciences Research Ethics Committee of theUniversity of the Western Cape.

3 Results

This analysis of food supply policy identified a number oftensions and points of incoherence between economic per-spectives on food supply policy goals, production-orientedperspectives on food security, and health-focused perspec-tives on nutrition. These points of incoherence primarily

Table 1 Nutrition/Food policy priorities in South Africa

Policy Objectives relevant to nutrition References to food supply

Strategic Plan for the Prevention andControl of Non-communicableDiseases, 2013–17

* Prevention of NCDs and promotion of healthand wellness at population, community andindividual levels.

* Aligns to 2020 targets:1. Reduce by at least 25% the relative premature

mortality (under 60 years of age) fromnon-communicable diseases;

4. Reduce mean population intake of salt to<5 g/day;

5. Reduce by 10% the percentage of people whoare obese and/or overweight;

6. Reduce the prevalence of people with raisedblood pressure by 20%.

Objective:Increase healthy eating habits in the population through

accessible and affordable healthy foods.Activities:Engage with relevant government departments, including

agriculture, trade and industry and treasury to increase theaccessibility and availability of healthy foods.

National Policy on Food andNutrition Security, 2014

* Access to sufficient food as human right (Bill ofRights)

* ‘…ensure the availability, accessibility andaffordability of safe and nutritious food atnational and household levels’

* Focus on traditional food production and supply(e.g. amaranth, ground nuts)

Strategies:* Efforts to increase food production and distribution,

including increased access to production inputs for theemerging agricultural sector;

* Leveraging government food procurement to supportcommunity-based food production initiatives and small-holders; and

* The strategic use of market interventions and trademeasures which will promote food security.

* Land tenure highlighted as challenge to address* Implementation of Agri-BEE Charter

Sustainable Development Goals(SDGs)

Goal 2:* By 2030, end hunger and ensure access by all people… to safe, nutritious and sufficient food all year round* By 2030, end all forms of malnutrition…* By 2030, double the agricultural productivity… including through secure and equal access to land, other

productive resources and inputs, knowledge, financial services, markets and opportunities for value additionand non-farm employment

* By 2030, ensure sustainable food production systems …* By 2030, maintain the genetic diversity of seeds, cultivated plants and farmed and domesticated animals…* Increase investment, including through enhanced international cooperation, in rural infrastructure, agricultural

research and extension services, technology development and plant and livestock gene banks…* Correct and prevent trade restrictions and distortions in world agricultural markets…* Adopt measures to ensure the proper functioning of food commodity markets and their derivatives…Goal 3:* By 2030, reduce by one third premature mortality from non-communicable diseases …* By 2030, end preventable deaths of newborns and children under 5 years of age…

1108 A.M. Thow et al.

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Table 2 Agricultural policy priorities in South Africa

Policy Objectives References to nutrition/food supply

Integrated Growth andDevelopment Plan (IGDP),2012

Vision: to have ‘An equitable, productive, competitive,profitable and sustainable Agriculture, Forestry andFisheries Sector growing to the benefit of all SouthAfricans’.

This vision is supported by a mission that states that thevision will be achieved through developing andsustaining a sector that contributes to and embraces:

• economic growth (and development)• job creation• rural development• sustainable use of natural resources• maintenance of biodiversity and ecosystems• sustainable livelihoods• food security.Agriculture: ‘… position agriculture for the purpose of

improving national food safety and security andagricultural economic output in a profitable andsustainable manner, through a qualitative andquantitative improvement of South Africa’sagricultural productivity and its trade and regulatoryenvironment. By achieving the aforementioned,agriculture can contribute vitally to rural economicgrowth and development and thus increase ruralemployment, both on and off-farm.’

Fisheries: ‘… manage the development and sustainableutilisation ofmarine and coastal resources, to maximisethe economic potential of the fisheries sector and toprotect the integrity and quality of the country’s marineand coastal ecosystems.’

p. 30: ‘… A sector that displays great levels ofconcentration and exclusion, while propagatingsmallholders and subsistence farming as a means toovercome rural poverty and food insecurity, reflectsfundamental policy gaps. …the focus in agriculture inparticular has been skewed towards new entrants,especially linked to the land reform programme, whileinadequate support has been given to existingparticipants in the sector who are marginalised. Thereis therefore a need to correct this imbalance, forexample, by effecting changes that will facilitateexisting smallholders’ gainful access to markets, byfocusing less on primary cooperatives and more onsecondary (e.g. marketing) cooperatives; and toimprove the quality and accessibility of supportsystems and infrastructure so that larger numbers ofproducers may benefit.’

Issues raised regarding food security- high food prices (p.35)- need to target small holders (p.35,36)- urban food gardens and livestock farming (p.36)- need for ‘greater emphasis on both physical and

economic access to food, when addressing foodinsecurity’ (p.39)

- recognition of multi-sectoral issue: ‘Household foodsecurity is influenced by the availability, accessibilityand affordability of nutritional food and this requires anintegrated approach.’ (p.39)

- threat of climate change (p.42)

Agricultural PolicyAction Plan (APAP), 2015–19

‘this first APAP focuses on a discrete number of valuechains identified as strategic in meeting the objectivesof the NGP, NDP and IPAP:

• Contribution to food security• Job creation• Value of production• Growth potential• Potential contribution to trade balance’Eleven sectoral interventions: poultry/soya beans/maize

integrated value chain; red meat value chain; wheatvalue chain; fruit and vegetables; wine industry; sugarvalue chain; biofuels value chain; forestry; small-scalefisheries; Aquaculture Competitiveness ImprovementProgramme.

Transversal interventions: Fetsa Tlala Integrated FoodProduction Intervention; research and innovation;promoting climate-smart agriculture; trade, agribusi-ness development and support; strategic integratedprojects (SIPs); biosecurity.

Fetsa Tlala includes a focus on micronutrient content ofcrops

White Paper on Agriculture,1995 (referenced in IGDP)

Vision: ‘to direct the development of agriculture in such away that the factors of production, together with therelated functions, will be utilised in such a manner thatagriculture will contribute to the optimum economic,political and social development and stability of theRepublic of South Africa, while simultaneouslymaking a contribution towards the promotion of aneconomically sound farming community.’

White Paper onMarine FisheriesPolicy for South Africa, 1997(referenced in IGDP)

Overall goal: ‘to improve the overall contribution fromthe fishing industry to the long-term vision of govern-ment as laid out in the Macro-Economic Strategy.’

Improving policy coherence for food security and nutrition in South Africa: a qualitative policy analysis 1109

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Table3

Overviewof

SouthAfrican

tradeandinvestmentp

olicydocumentsforpotentialn

utritio

nim

plications

(including

allexisting/term

inated

BITswith

Englishlanguage

text

available)

Policy/Agreement

Date

Nutritio

n-relevant

components

Statedobjectives

ISDS

Incentives

toattractinvestm

entand

trade

Exceptio

ns

Treatyof

theSo

uthern

African

Development

Com

munity

(SADC)

(Consolid

ated

text

with

amendm

ents)

1992 (2015)

Art5:

Objectiv

es:

*prom

otesustainableandequitableeconom

icgrow

thandsocio-econom

icdevelopm

ent…

*harm

onisepoliticalandsocio-econom

icpoli-

cies

andplansof

Mem

berStates

*developpoliciesaimed

attheprogressive

elim

inationof

obstaclestothefree

movem

ent

ofcapitaland

labour,goods

andservices,and

ofthepeopleof

theRegiongenerally,among

Mem

berStates

Art21:A

reas

ofcooperation(harmonisation):

(a)food

security,landandagricultu

re(b)infrastructure

andservices

(c)trade,industry,finance,investm

entand

mining

(d)socialandhuman

developm

ent

Art16,A

rt32:

Tribunaladjudicates

disputes

(state-state);sanctio

nsor

suspension

may

beim

posed

*Tariffreductions

(progressive)

*Provides

abilateralforum

forthe

twocountries

toaddressissues

ofinterest,including

African

Growth

andOpportunity

Act(A

GOA),

TID

CA,trade

andinvestmentp

romotion,

non-tariffbarriers,sanitary

andphytosanitary

measures,infrastructure

andothers

None

Denmark–SA

BIT

(Terminated)

1997

Preamble:

Desiringto

createfavourableconditionsfor

investmentsinbothstates

andtointensifythe

co-operatio

nbetweenprivateenterprisesin

both

States

with

aview

tostim

ulatingthe

productiv

euseof

resources,

Recognising

thatafairandequitabletreatm

entof

investmentson

areciprocalbasiswill

serve

thisaim…

Art9:

*InternationalC

entrefor

Settlemento

fInvestment

Disputes(ICSID

)or

United

Nations

Com

mission

onInternationalT

rade

Law

(UNCITRAL)ISDSmechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art3:

*Broad

fairandequitabletreatm

entp

rovision

*MostF

avouredNation

Art5:

*Broad

expropriationdefinitio

n,butd

oesnot

specifically

noteindirectexpropriation

Art4:

Nopublichealth

exem

ptions

Expropriatio

n-Art5:

‘exceptfor

expropriations

madein

thepublic

interest,onabasisof

non-discrimination,

carriedoutu

nder

dueprocessof

law,and

againstp

rompt,adequateandeffective

compensation’

Korea,R

epublic

of–

SABIT

(Inforce)

1997

Preamble:

Wishing

tointensifyeconom

iccooperationto

themutualb

enefitof

both

States,

Desiringto

createfavourableconditionsfor

investmentsof

investorsof

oneContractin

gParty

intheterrito

ryof

theotherContractin

gparty,and

Recognising

thattheencouragem

entand

reciprocalprotectionof

investmentson

the

basisof

thisAgreementstim

ulates

business

initiativein

both

States…

Art8:

*ICSIDor

UNCITRALISDS

mechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art3:

*Broad

fairandequitabletreatm

entp

rovision

*MFN

Art5:

*Broad

expropriationdefinitio

n,butd

oesnot

specifically

noteindirectexpropriation

Nonespecifically

noted

Expropriatio

n-Art5:

‘exceptfor

apublicpurpose,underdueprocess

oflaw,onanon-discriminatorybasisand

provided

thatitisaccompanied

byprom

pt,

adequateandeffectivecompensation’

Germany–SA

BIT

(Terminated)

1998

Preamble:

desiring

tointensifyeconom

icco-operatio

nbe-

tweenboth

States,

intendingto

createfavourableconditionsfor

investmentsby

natio

nalsandcompanies

ofeither

Statein

theterritory

ortheotherState,

recognisingthattheencouragem

entand

contractualprotectionof

such

investmentsare

apttostim

ulateprivatebusinessinitiativeand

toincrease

theprosperity

ofboth

natio

ns…

Art10:

*Arbitrationtribunal–ad

hoc,

agreed

bycontractingparties

Art11:

*Ifdisputenotsettledin6months–

ICSID

Art1:

*Broad/standarddefinitio

nof

investment

Art2:

*Broad

fairandequitabletreatm

entp

rovision

Art3:

*MFN

Art4:

*Broad

expropriationdefinitio

n,butd

oesnot

specifically

noteindirectexpropriation

Nonespecifically

noted

Expropriatio

n-Art4:

‘exceptfor

thepublicinterestandagainst

compensation’

1110 A.M. Thow et al.

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Tab

le3

(contin

ued)

Policy/Agreement

Date

Nutritio

n-relevant

components

Statedobjectives

ISDS

Incentives

toattractinvestm

entand

trade

Exceptio

ns

Mauritiu

s–SA

BIT

(In

force)

1998

Preamble:

Desiringto

createfavourableconditionsfor

greaterinvestmentb

yinvestorsof

one

ContractingPartyin

theterrito

ryof

theother

ContractingParty;

and

Recognising

thattheencouragem

entand

reciprocalprotectionunderinternational

agreem

ento

fsuch

investmentswill

beconduciveto

thestim

ulationof

individual

businessinitiativeandwillincreaseprosperity

intheterrito

ries

ofbothContractingParties…

Art7:

*ICSIDor

UNCITRALISDS

mechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art3:

*Broad

fairandequitabletreatm

entp

rovision

*MFN

Art5:

*Broad

expropriationdefinitio

n,butd

oesnot

specifically

noteindirectexpropriation

Nonespecifically

noted

Art5:

‘exceptforpublicpurposes,underdueprocessof

law,onanon-discriminatorybasisandagainst

prom

pt,adequateandeffectivecompensa-

tion’

UnitedKingdom

–SA

BIT

(Terminated)

1998

Preamble:

Desiringto

createfavourableconditionsfor

greaterinvestmentb

ynatio

nalsand

companies

ofoneStatein

theTerrito

ryof

the

otherState;

Recognising

thattheencouragem

entand

reciprocalprotectionunderinternational

agreem

ento

fsuch

investmentswill

beconduciveto

thestim

ulationof

individual

businessinitiativeandwillincreaseprosperity

inboth

States…

Art7:

*ICSIDor

UNCITRALISDS

mechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art2:

*Broad

fairandequitabletreatm

entp

rovision;

‘nounreasonableor

discriminatorymeasures’

Art3:

*MFN

Art5:

*Broad

expropriationdefinitio

n,butd

oesnot

specifically

noteindirectexpropriation

Nonespecificto

publichealth

Art5:

Expropriatio

n:‘exceptfor

apublicpurposerelatedto

the

internalneedsof

thatPartyon

anon-discriminatorybasisandagainstp

rompt,

adequateandeffectivecompensation’

China

–SABIT

(In

force)

1998

Preamble:

Intendingto

createfavourableconditionsfor

investmentsby

investorsof

oneContractin

gParty

intheterrito

ryof

theotherContractin

gParty;

Recognising

thatthereciprocalencouragem

ent,

prom

otion,andprotectio

nof

such

investmentswill

beconduciveto

stim

ulating

business

initiativeof

theinvestorsandwill

increase

prosperity

inboth

States,

Desiringto

intensifytheeconom

iccooperation

ofboth

States

onthebasisof

equalityand

mutualb

enefits…

Art7:

*AdhoctribunalISDSmechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art3:

*Broad

fairandequitabletreatm

entp

rovision

*MFN

Art4:

*Broad

expropriationdefinitio

n,butnospecific

mentio

nof

indirectexpropriation

Nonespecificto

publichealth

Art4:

Expropriatio

n:‘exceptfor

publicpurposes,under

domestic

legalp

rocedure,onanon-discriminatoryba-

sisandagainstcom

pensation’

Trade

&Investment

Fram

ework

Agreement-

South

AfricaandUSA

1999

Art1

The

Partieswill

seek

to:

(1)expand

tradein

goodsandservices

between

them

...(2)take

appropriatemeasuresto

encourageand

facilitatetheexchange

ofgoodsandservices,

andto

secure

favorableconditionsfor

long-term

developm

entand

diversificationof

trade…

(3)encourageprivatesector

investmentbetween

thetwocountries,as

ameans

offurthering

grow

th,job

creatio

n,andeconom

ic

None

Art3

(1)Eith

erPartymay,w

heneveritconsidersit

appropriate,consultthe

civilsociety

inits

country,such

asbusiness,labor,consumer,

environm

entaland

academ

icgroups,on

mattersrelatedto

theworkof

theCouncil.

Eith

erPartymay,w

henitconsidersit

appropriate,presentthe

view

sof

itscivil

societyatmeetings

oftheCouncil.

(2)Fo

rthepurposes

ofprovidingforthefurther

expansionof

bilateraltrade

andinvestment

flow

s,thePartieswill

consider

whether

Art4

(1)ThisAgreementiswith

outp

rejudice

tothe

rightsandobligations

ofeitherPartyunderits

domestic

lawor

underanyotheragreem

ents,

conventio

nsor

otherinstrumentsto

which

either

countryisaparty.

Improving policy coherence for food security and nutrition in South Africa: a qualitative policy analysis 1111

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Tab

le3

(contin

ued)

Policy/Agreement

Date

Nutritio

n-relevant

components

Statedobjectives

ISDS

Incentives

toattractinvestm

entand

trade

Exceptio

ns

developm

ent,and…

prom

otean

open

and

predictableenvironm

entfor

investment…

.furtheragreem

entsrelatin

gto

taxation,

intellectualproperty,andtradeandinvestment

issues

would

bedesirable.

Netherlands

–SA

BIT

(Terminated)

1999

Preamble:

Desiringto

strengthen

thetraditionaltiesof

friendship

betweentheircountries,to

extend

andintensifytheeconom

icrelations

between

them

particularly

with

respecttoinvestments

bytheinvestorsof

oneContractin

gPartyin

theterrito

ryof

theotherContractin

gParty,

Recognising

thatagreem

entu

ponthetreatm

ent

tobe

accorded

tosuch

investmentswill

stim

ulatetheflow

ofcapitaland

technology

andtheeconom

icdevelopm

ento

fthe

ContractingPartiesandthatfairandequitable

treatm

ento

finvestmentisdesirable…

Art9:

*ICSIDor

UNCITRALISDS

mechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art3:

*Broad

fairandequitabletreatm

entp

rovision;

no‘unreasonableor

discriminatorymeasures’

Art4:

*MFN

Art6:

*Broad

expropriationdefinition;bothdirectand

indirectexpropriation

Nonespecificto

publichealth

Art6:

Expropriatio

n:Unlessconditionscompliedwith:‘public

interest’,‘due

processof

law’,‘not

discriminatoryor

contrary

toanyundertaking

which

theContractingParty…

may

have

given’,‘againstjustcom

pensation’

Sweden

–SA

BIT

(In

force)

1999

Preamble:

Desiringto

intensifyeconom

iccooperationto

themutualb

enefitof

both

countriesandto

maintainfairandequitableconditionsfor

investmentsby

investorsof

oneContractin

gParty

intheterrito

ryof

theotherContractin

gParty;

Recognising

thattheprom

otionandreciprocal

protectio

nof

such

investmentsfavour

the

expansionof

theeconom

icrelations

between

thetwoContractin

gPartiesandstim

ulate

investmentinitiativ

es…

Art7:

*ICSIDor

UNCITRALISDS

mechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art3:

*Broad

fairandequitabletreatm

entp

rovision

*MFN

Art4:

*Broad

expropriationdefinition;bothdirectand

indirectexpropriation

Nonespecificto

publichealth

Art4:

Expropriatio

n:Unlessconditionscompliedwith:‘public

interest’,‘due

processof

law’,‘m

easures

distinctandnon-discriminatory’,

‘accom

panied

byprovisions

forpaym

ent

of…

compensation’

Czech

Republic

–SA

BIT

(Inforce)

1999

Preamble:

Desiringtodevelopeconom

iccooperationtothe

mutualb

enefitof

both

States,

Intendingto

createandmaintainfavourable

conditionsforinvestm

entsof

investorsof

one

Statein

theterritory

oftheotherState,and

Conscious

thattheprom

otionandreciprocal

protectio

nof

investments,interm

sof

the

presentA

greement,stim

ulates

business

initiatives

inthisfield…

Art7:

*ICSIDor

UNCITRALISDS

mechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art2:

*Broad

fairandequitabletreatm

entp

rovision

Art3:

*MFN

Art5:

*Broad

expropriationdefinitio

n,butd

oesnot

specifically

noteindirectexpropriation

Nonespecificto

publichealth

Art5:

Expropriatio

n:‘exceptfor

apublicpurposerelatedto

the

internalneedsof

thatPartyon

anon-discriminatorybasisandagainstp

rompt,

adequateandeffectivecompensation’

Finland–SA

BIT

(In

force)

1999

Preamble:

Desiringto

createfavourableconditionsfor

increasedinvestmentb

yinvestorsof

one

ContractingPartyin

theterrito

ryof

theother

ContractingParty,

Recognising

thattheencouragem

entand

reciprocalprotectionof

such

investmentson

thebasisof

anAgreementw

illbe

conducive

Art7:

*ICSIDor

UNCITRALISDS

mechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art2:

*Broad

fairandequitabletreatm

entp

rovision

broad;

‘nounreasonableor

discriminatory

measures’

Art3:

*MFN

Nonespecificto

publichealth

(Art7)

Art5:

Expropriatio

n:‘exceptfor

apublicpurposerelatedto

the

internalneedsof

thatPartyon

anon-discriminatorybasis…

accompanied

byprom

pt,adequateandeffectivecompensa-

tion’

1112 A.M. Thow et al.

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Tab

le3

(contin

ued)

Policy/Agreement

Date

Nutritio

n-relevant

components

Statedobjectives

ISDS

Incentives

toattractinvestm

entand

trade

Exceptio

ns

tothestim

ulationofbusinessinitiativesandto

increasing

theeconom

icprosperity

ofboth

States…

Art5:

*Broad

expropriationdefinitio

n,butd

oesnot

specifically

noteindirectexpropriation

Greece(H

ellenic

Republic)–

SABIT

(Inforce)

2001

Preamble:

Desiringtointensifytheireconom

iccooperation

tothemutualbenefitofContractingPartieson

along

term

basis,

Havingas

theirobjectiveto

createfavourable

conditionsforinvestmentsby

investorsof

eitherContractin

gPartyin

theterrito

ryof

the

otherContractingParty,

Recognising

thattheprom

otionandprotectio

nof

investments,onthebasisof

this

Agreement,will

stim

ulatethe;initiativein

thisfield…

Art9:

*ICSIDor

UNCITRALor

adhoc

ISDSmechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art2:

*Broad

fairandequitabletreatm

entp

rovision;

‘nounreasonableor

discriminatorymeasures’

Art3:

*MFN

Art5:

*Broad

expropriationdefinitio

n,butd

oesnot

specifically

noteindirectexpropriation

Nonespecificto

publichealth

(Art7)

Art5:

Expropriatio

n:‘exceptfor

apublicpurposerelatedto

the

internalneedsof

thatPartyon

anon-discriminatorybasis…

accompanied

byprom

pt,adequateandeffectivecompensa-

tion’

Iran

–SA

BIT

(In

force)

2002

Preamble:

Desiringto

intensifytheeconom

iccooperation

tothemutualb

enefitof

both

States;

Intendingtoutilise

theireconomicresourcesand

potentialfacilitiesin

thearea

ofinvestments

aswellasto

createandmaintainfavorable

conditionsforinvestmentsof

theinvestorsof

theContractin

gPartiesin

each

other’s

territo

ryand;

Recognising

theneed

toprom

oteandprotect

investmentsof

theinvestorsof

the

ContractingPartiesineach

other’sterrito

ry…

Art12:

*ad

hocISDSmechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art2:

*‘fulllegalp

rotectionandfairtreatm

entn

otless

favourablethan

thataccorded

toits

own

investorsor

toinvestorsof

anythirdstatewho

arein

acomparablesituation’

Art5:

*MFN

Art6:

*Broad

expropriationdefinitio

nbutd

oesnot

specifically

noteindirectexpropriation

Nonespecificto

publichealth

Art6:

Expropriatio

n:‘for

publicpurposes,inaccordance

with

due

processof

law,inanon-discriminatoryman-

nerandupon

paym

ento

fprom

pt,effectiv

eandappropriatecompensation’

Trade,D

evelopment

andCooperation

Agreement(TDCA)

(SouthAfrica–EU)

2004

The

objectives

ofthisAgreementare:

(a)to

providean

appropriatefram

eworkfor

dialogue

betweentheparties,prom

otingthe

developm

ento

fcloserelations

inallareas

coveredby

thisAgreement;

(b)tosupportthe

effortsmadeby

SouthAfricato

consolidatetheeconom

icandsocial

foundatio

nsof

itstransitio

nprocess;

(c)to

prom

oteregionalcooperationand

econom

icintegrationin

thesouthern

African

region

tocontributeto

itsharm

onious

and

sustainableeconom

icandsocial

developm

ent;

(d)to

prom

otetheexpansionandreciprocal

liberalisationof

mutualtrade

ingoods,

services

andcapital;

State-statedisputesettlem

ent

*Art5–12

Establishm

ento

fFree

Trade

Area

andreductions

intariffsandNTBs

*Art13–15Reductio

nsin

agricultu

raltariffs;

Art16

Provisionforagricultu

ralsafeguard

*Art20:‘The

Partiesmay

have

regular

consultatio

nsin

theCooperatio

nCouncilon

thestrategy

andpracticalmodalities

oftheir

respectiv

eagricultu

ralp

olicies.’(i.e.before

implem

entin

gchangestoagricultu

ralpolicies

from

thoseagreed)

*Art30:R

emovalof

barriersanddiscrimination

inservices

trade;positiveservices

list

*Art45:G

overnm

entprocurement‘isgoverned

byasystem

which

isfair,equitableand

transparent’

*Art46:A

pply

Trade-Related

Aspectsof

IntellectualP

ropertyRightsAgreement

(TRIPS)

andInternationalU

nion

forthe

*Nomentio

nof

health

inpreamble

*Art27:E

xceptio

ns‘The

Agreementshallnotp

recludeprohibitions

orrestrictions

onim

ports,exports,goodsin

transito

rtradein

used

goodsjustifiedon

groundsof

publicmorality,public

policyor

publicsecurity;the

protectionof

health

and

lifeof

humans,anim

alsor

plants;the

protectio

nof

natio

naltreasures

possessing

artistic,historicorarchaeologicalvalue;orthe

protectio

nof

intellectual,industrialand

commercialproperty

orrulesrelatin

gto

gold

andsilver.S

uchprohibitionsor

restrictions

shalln

ot,how

ever,constitu

teameans

ofarbitraryor

unjustifiablediscriminationwhere

thesameconditionsprevailo

radisguised

restrictionon

tradebetweentheParties.’

Improving policy coherence for food security and nutrition in South Africa: a qualitative policy analysis 1113

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Tab

le3

(contin

ued)

Policy/Agreement

Date

Nutritio

n-relevant

components

Statedobjectives

ISDS

Incentives

toattractinvestm

entand

trade

Exceptio

ns

(e)to

encouragethesm

ooth

andgradual

integrationof

SouthAfricainto

theworld

econom

y;(f)to

prom

otecooperationbetweenthe

Com

munity

andSo

uthAfricawith

inthe

bounds

oftheirrespectivepowers,in

their

mutualinterest.

Protectio

nof

New

Varietiesof

Plants

(UPOV),etc.

*Art47

cooperationon

standardisation(not

harm

onisation)

*Art61:E

conomiccooperationon

agricultu

re–

supportfor

productionandsupply

chains.

Plan

forAgreemento

nFisheries(A

rt62)

Art92:cooperationto

improvehealth

Nigeria–SA

BIT

(In

force)

2005

Desiringto

createfavourableconditionsfor

greaterinvestm

entbyinvestorsof

eitherParty

intheterrito

ryof

theotherParty;

Recognising

thatthereciprocalprom

otionand

protectio

nofinvestmentswillbe

conduciveto

thestim

ulationof

individualbusiness

initiative,contributeto

developm

entand

increase

theprosperity

ofboth

Parties;

Recognising

therightofthePartiestodefine

the

conditionsunderwhich

foreigninvestment

canbe

received

andtheinvestor’sduty

torespectthe

hostcountry’ssovereigntyand

domestic

law;

Determined

toincrease

favourableconditionsfor

greaterinvestmentb

ynatio

nalsand

companies

ofaPartyin

theterrito

ryof

the

otherParty…

Art8:

*ICSIDor

adhocISDSmechanism

Art1:

*Broad/standarddefinitio

nof

investment

Art4:

*Broad

fairandequitabletreatm

entp

rovision;

‘nounreasonableor

discriminatorymeasures’

Art4:

*MFN

Art6:

*Broad

expropriationdefinitio

n,butd

oesnot

specifically

noteindirectexpropriation

Nonespecificto

publichealth

Art6:

Expropriatio

n:‘exceptforpublicpurposes,underdueprocessof

law,onanon-discriminatorybasisandagainst

paym

ento

fprom

pt,adequateandfaircom-

pensation.’

NationalIndustrial

PolicyFram

ework

(NIPF)

2007

1.1.4…

toprovidestrategicdirectionto

the

econom

ywith

respecttotheissueofindustrial

developm

ent.First,itisaimed

atproviding

greaterclarity

andcertaintyto

theprivate

sector

andsocialpartnerswith

respectto

investmentd

ecisions

leadingup

to2014

and

beyond.S

econd,itisintended

toprovidea

referencepointfor

substantialimprovem

ents

inintra-governmentalcoordinationof

thenu-

merousandcomplex

seto

fpoliciesandpro-

jectsthatwill

form

partof

theNIPF.

1.4.1The

NIPFrecognises

theinherent

intra-governmentalnatureof

industrialpolicy.

Sectio

n2demonstratesthatfour

comple-

mentary

setsof

policiesarenecessaryforthe

successful

implem

entationof

anindustrial

policy:

asupportiv

emacroeconom

icandreg-

ulatoryenvironm

ent;skillsandeducation;

traditionalandmoderninfrastructure;and

supportfor

technologicaleffort.

2.2Astableandsupportiv

emacroeconom

icand

regulatory

environm

ent:Macroeconom

icstabilityiscriticalforindustrialisationinorder

toallowinvestorsto

plan.

2.3Sk

illsandeducationforindustrialisation:

Intheshortterm,thisrequires

muchstronger

alignm

entb

etweenindustrialpoliciesand

skillsinstitu

tions.Inthelonger

term

,it

requires

integrationwith

theeducational

system

,with

aparticular

emphasison

ensuring

larger

numbersof

graduateswith

tertiary

technicalskills.

2.4Traditio

naland

moderninfrastructure:

Sufficient,reliableandcompetitivelypriced

traditionalandmoderninfrastructure

and

logisticssystem

sareessentialfor

amodern

industrialeconom

y.2.5Innovationandtechnology:T

echnology…

canbe

imported

from

abroad;embodied

inthe

form

offoreigndirectinvestment(FDI);

[or]….dom

estic

research

anddevelopm

ent

generatesindigenous

technologies.

1114 A.M. Thow et al.

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Tab

le3

(contin

ued)

Policy/Agreement

Date

Nutritio

n-relevant

components

Statedobjectives

ISDS

Incentives

toattractinvestm

entand

trade

Exceptio

ns

Trade,Investm

entand

Development

Cooperation

Agreement

(TID

CA)-SACU

andUSA

2008

The

Partiesaffirm

theirdesire

toprom

otean

attractiveinvestmentclim

ateandto

expand

anddiversifytradebetweenSA

CUandthe

UnitedStates.

n/a

Art4,Para2.Fo

rthepurposes

ofprovidingfor

thefurtherexpansionof

bilateraltrade

and

investmentflows,thePartieswill

cooperate

onandconsider

whether

furtheragreem

ents

such

asthoseon

sanitary

andphytosanitary

measures(SPS

),standards,technicalb

arriers

totrade(TBT),custom

scooperationandtrade

facilitationwould

bedesirable,as

wellas

cooperatein

undertakingspecifictradeand

investmentp

romotionactiv

ities.

None

Trade

Policyand

Strategy

Fram

ework(TPS

F)

2010

…to

prom

oteandaccelerateeconom

icgrow

thalongapaththatgeneratessustainable,decent

jobs

inorderto

reduce

thepovertyand

extrem

einequalitiesthatcharacterise

South

African

societyandeconom

y.’

*StrategicTariffPo

licy:

‘The

SouthAfrican

Governm

enth

aschosen

agrow

thand

developm

entp

aththatprioritises

industrial

upgradingin

morelabour

intensivesectorsto

generatesustainableanddecentem

ployment’

*Agriculture:‘So

uthAfricahashadanegative

tradebalancein

processedagricultu

raltrade

since2003…

greaterattentionwill

berequired

toprom

otethedevelopm

ento

fthis

sub-sector.’

*Regionalintegratio

napriority

None

Strategicintegration:

‘SouthAfricawillneed

toensurethatits

ongoing

integrationinto

theglobaleconom

yis

pursuedin

amannerthatmoreexplicitly

supportsits

nationald

evelopmental

objectives.[and]…

ensure

thatwepreserve

thepolicyspaceto

pursue

nationalobjectiv

eswhileleveraging

thebenefitsof

more

integrated

regionalandglobalmarkets.’

Protectio

nof

InvestmentA

ct-

Unilateral

2015

Priorto

preamble:

Toprovidefortheprotectionof

investorsand

theirinvestments;toachieveabalanceof

rightsandoblig

ations

thatapplyto

all

investors;andto

provideformatters

connectedtherew

ith.’

Para4.The

purposeof

thisActisto—

(a)protectinvestm

entinaccordance

with

and

subjecttotheConstitu

tion,inamannerw

hich

balances

thepublicinterestandtherightsand

oblig

ations

ofinvestors;

(b)affirm

theRepublic’ssovereignrightto

regulateinvestmentsin

thepublicinterest;

and

(c)confirm

theBill

ofRightsintheConstitu

tion

andthelawsthatapplyto

allinvestorsand

theirinvestmentsin

theRepublic.

Para

13:N

oISDS–reduce

likelihoodof

international

arbitration-allowance

for

state-statedisputesettlem

ent,

where

domestic

remedies

exhausted

Para

6:FE

Tnarrow

lydefined:

‘adm

inistrative,

legislativeandjudicialprocesses’

Para

8:Nationaltreatment

Right

toregulate

Para

12.(1)

‘Notwith

standing

anything

tothe

contrary

inthisAct,the

government…

may,

inaccordance

with

theConstitu

tionandap-

plicablelegislation,take

measures…

’[no

specificmentio

nof

health

inlist]

Improving policy coherence for food security and nutrition in South Africa: a qualitative policy analysis 1115

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Table4

Economicincentives

forinvestors,potentially

relevant

tonutrition

Incentivetitle

Details

Section12ITaxAllo

wance

Incentive(12I

TAI)

The

incentiveisdesigned

tosupportG

reenfieldinvestments(i.e.new

industrialprojectsthatutilise

only

newandunused

manufacturing

assets),as

wellas

Brownfield

investments(i.e.expansionsor

upgrades

ofexistin

gindustrialprojects).The

incentiveofferssupportb

ased

oncapitalinvestm

entand

training.

The

minim

uminvestmentinQualifying

Assetsrequired

isR50

millionforaGreenfieldprojectand

anadditio

nalinvestm

ento

fR30

millionforaBrownfield

project.

Objectiv

es:

The

objectives

oftheincentiveprogrammeareto

support:

•Investmentinman

ufacturing

assets,toim

provetheproductiv

ityof

theSouth

African

manufacturing

sector;and

•Trainingof

personnel;to

improvelabour

productiv

ityandtheskillsprofile

ofthelabour

force.

(ECA)CriticalInfrastructure

Programme(CIP)

Objectiv

e:Su

pportthe

competitivenessof

SouthAfrican

industries

byloweringbusinesscostsandrisksandtoprovidetargeted

financialsupportforp

hysical

infrastructure

thatwill

leverage

strategicinvestmentw

ithapositiv

eim

pacton

theeconom

y.Applicability:

New

orexpandingenterprisesinvestingin

infrastructure

such

asroads,railw

ays,electricity

transm

ission

anddistributio

n,water

pipelin

es,

telecommunicationnetworks,sew

agesystem

setc.Availableto

municipalities,public

sector

enterprisesandprivateenterprises.

Benefit:

Cashgrantincentiv

ethatcoversbetween10

and30%

oftheinfrastructure

developm

entcostslim

itedto

R30

millionperapplication.

(CEI)EnterpriseInvestment

Programme(EIP):Aquaculture

Developmentand

Enhancement

Programme(A

DEP)

Objectiv

e:Investmentintheaq

uaculturesector.

Applicability:

SAentitiesinvolved

infish

hatcheries

andfish

farm

s(primaryaquacultu

re),processing

andpreserving

ofaquacultu

refish

(secondary

aquacultu

re),serviceactiv

ities

tooperatorsof

hatcheries

andfish

farm

s(ancillaryaquacultu

re).

Benefit:

20%

-45%

grantfor

investmentinland,and

build

ings,m

achinery

andequipm

ent,commercialvehicles

andworkboatsandbulk

infrastructure

capped

atR40

millionperapplication.

(CEI)Isivande

Wom

en’sFu

nd(IWF)

Isivande

Wom

en’sFund(IWF)

isan

exclusivewom

en’sfund

establishedby

theDTIGenderandWom

enEmpowermentU

nitinpartnershipwith

Old

Mutual

MasisizaneFu

nd.T

hefund

aimsatacceleratin

gwom

en’seconom

icem

powermentb

yprovidingmoreaffordable,usableandresponsive

financethan

ispresently

thecase.IWFtargetsform

allyregistered,60%

wom

en-ownedand/or

managed

enterprisesthathave

been

existin

gandoperatingfortwoor

moreyears

with

aloan

rangeof

R30

000-R2million.

Objectiv

e:The

fund

improvesandexpandsaccesstofinancetowom

enentrepreneursby

lendingandinvestinginwom

enenterprisesandgeneratin

gincome

thatwill

improvetheirliv

ingstandards.

Applicability:

The

IWFtargetsform

ally

registered,60%

wom

en-ownedand/or

managed

enterprisesthathave

been

inexistenceforatleasttwoyears.Italso

focuseson

professionalwom

enwith

feasiblebusiness

ideas,high

potentialsurvivalists,m

icro-enterprises

andcooperatives

onacase-by-case

basis.The

fund

pursuesdealsinvolvingstart-up

funding,business

expansions,businessrehabilitationandturnaround

franchises

andbridging

finance.

Benefit:

Loanrangefrom

R30

000-R2millionandtheloan

repaym

entp

eriodisamaxim

umof

five

years.

(ECA)The

Cooperativ

eIncentiveScheme(CIS)

Objectiv

e:To

prom

otecooperatives

byim

provingtheviability

andcompetitivenessof

thecooperativeenterprisesby

loweringthecostof

doingbusiness.

Applicability:Any

entityincorporated

andregistered

inSo

uthAfricainterm

softheCooperativ

esAct.Targetiscoop

erativesop

eratingintheem

erging

sector,

andmanufacturing,retailand

services

sector.

Benefits:

Cost-sharinggranto

f100%

paidby

theDTIup

toamaxim

umof

R350000forcostsrelatin

gtobusinessdevelopm

entservices,business

profile

developm

ent,feasibility

studies/marketresearch,start-up

requirem

entsetc.

(ECA)Jobs

Fund

Objectiv

e:To

co-finance

publicandprivatesector

projectsthatwill

significantly

contributeto

jobcreatio

n.Applicability:

The

Fundwill,onacompetitivebasis,consider

co-financing

proposalsfrom

privatesector,non-governm

entalo

rganisations,governm

ent

departmentsandmunicipalities

thatshow

econom

icdevelopm

entp

otentiallinkedto

sustaina

blejobcreation

.Benefit:

Matchinggrantfunding

forthefollo

wingwindows:

•Enterprisedevelopm

entinitiativ

es:Initiativ

esthatreduce

risk,rem

ovebarriersto

marketaccessandbroadensupply

chains;

1116 A.M. Thow et al.

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Tab

le4

(contin

ued)

Incentivetitle

Details

•Infrastructure

initiatives:L

ight

infrastructure

initiatives

necessaryto

unlock

jobcreatio

n;and

•Work-seekersinitiatives:Initiativ

eslin

king

work-seekersto

theform

alem

ploymentsector.

(ECA)SectorSp

ecificAssistance

Schem

e(SSAS)

Objectiv

e:Develop

newexportmarkets,broaden

thespecificindu

stry

expo

rtbase,increaseparticipationof

B-BBEEandSM

MEcompanies

intheexport

process.

Applicability:Approvedexportcouncils,registeredindustry

associations

andjointactions

groups.

Benefit:

Amatchinggranto

f80%

ofthecostto

supportthe

developm

entand

grow

thof

exports.

(ECA)SpecialEconomic

Zones

(SEZs)

Objectiv

e:To

prom

otetargeted

investmenttofacilitateeconom

icgrow

thandjobcreatio

n.Applicability:Q

ualifying

projectslocatedin

SEZs.

Benefit:

•15%

corporatetaxrate.

•Accelerated

write-offof

build

ings

over

a10

year

period.

•Employmenttax

allowance

perjobcreated.

•Customscontrolledarea

forduty-freerebateandVATexem

ptionforim

portinginputsof

exportproducts.

•One-stop-shop

forinvestmentfacilitatio

n.

(ECA)Agro-industries

Objectiv

e:Providesupporttoagro-processingan

daq

uaculturesectors.

Applicability:

Focus

areasare:

•Horticulture

prim

aryagricultu

ralsector

•Fo

odprocessing

sector

•Agro-industrialsector

•Beveragesector

•Fishingandaquacultu

resectors

Minim

umfinancerequirem

ent:Morethan

R1millionin

debt

and/or

morethan

R5millionin

equity.

Benefit:

Com

petitive,risk-related

interestratesarebasedon

theprim

ebank

overdraftrate.

(ECA)Gro-E

Scheme

Objectiv

e:To

prom

otecompetitivenessin

theman

ufacturing

arenaandensure

jobretentionin

thissector.

Applicability:

Financialsupporttostart-up

businesses,including

fundingforbuild

ings,equipmentand

working

capital.

Com

panies

wantin

gto

expand

also

funded.T

heprovisoisthatthey

mustshowan

ability

tocreatejobs.

Africaandtherestof

thecontinent.

Benefit:

Com

petitiverisk-related

interestratesbasedon

theprim

ebank

overdraftrate.

PreferentialC

orporateTaxRate

forSmallB

usiness

Objectiv

e:To

encouragesm

all/m

edium

business

developm

entinSo

uthAfrica.

Applicability:

Qualifying

small/m

edium

businesses

with

aturnoverforthe

yearof

assessmentthatdoesnotexceedR14

millionareeligible(for

yearsof

assessmentcom

mencing

onor

after1April2012).

Benefit(taxable

income):

•R0–R70

700=0%

•R70

701-R365000=7%

•>R365001=R20

601+21%

ofam

ount

greaterthan

R350000

•>R550000=R59

451+28%

ofam

ount

greaterthan

R350000

Objectiv

e:To

stim

ulatescientificor

techno

logicalR

&D.

Improving policy coherence for food security and nutrition in South Africa: a qualitative policy analysis 1117

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reflected instances in which nutrition and food securitypolicy objectives were not supported – or were undermined– by food supply policies in the economic sector.

3.1 Review of policy content

We identified 40 policy documents and related govern-ment initiatives relevant to food security and nutrition,including those relevant to the food supply more broadly(Tables 1, 2, 3, and 4). We start here by reviewing nutritionand food security policy priorities relevant to the food supply,and then examine the economic policies that govern the foodsupply.

3.1.1 Nutrition and food security policies

The Government of South Africa has identified specificpolicy objectives to improve nutritional health (Table 1).These include prevention of NCDs and promotion ofhealth and wellness (Strategic Plan for Prevention andControl of NCDs, BNCD Strategic Plan^, 2013–2017),and, in line with the Government’s commitment to theRight to Food, ensuring Bavailability, accessibility andaffordability of safe and nutritious food^ (NationalPolicy on Food and Nutrition Security, 2014). These pol-icies both reflect global recommendations for using foodsupply policy to improve nutrition, with interventionstargeting increased access to affordable healthy food, anexplicit activity. The NCD Strategic Plan mandates en-gagement (by health) with relevant government depart-ments, including agriculture, trade and industry, and trea-sury to achieve this. The National Policy on Food andNutrition Security identifies the need to increase accessto production inputs, leverage government procurement,use market interventions and trade measures for foodsecurity, and address land tenure.

3.1.2 Food security and agricultural policies

Food security has been identified repeatedly as a nationalpriority, including in the National DevelopmentPlan (2012), which mandated the preparation of theDepartment of Agriculture, Fisheries and Forestry’sIntegrated Growth and Development Plan (the nationalagricultural policy). The Government of South Africa’sagricultural policies are the Integrated Growth andDevelopment Plan (2012) issued by the Department ofAgriculture, Fisheries and Forestry and the AgriculturalPolicy Action Plan (2015–2019) (Table 2). National ag-ricultural policies in South Africa include strong supportfor food security, although there is no mention of nutri-tion (Table 2).T

able4

(contin

ued)

Incentivetitle

Details

(CRD)ResearchandDevelopment

(R&D)

Applicability:Expenditureincurred

inthediscoveryof

novel,practicalandnon-obviousinform

ationor

devising,developingor

creatin

ganyinvention,design

orcomputerprogrammeor

anyknow

ledgeessentialtotheuseof

theinvention,design

orcomputerprogramme.

Benefit:

Deductio

nincreasedto

150%

forexpenditu

reincurred

onor

after2Novem

ber2006.A

ccelerated

allowance

onR&Dassets.

(ECA)12iInvestm

entand

Training

Allo

wance

Objectiv

e:To

prom

oteindustrialupgradingandnewinvestmentinlarge-scaleman

ufacturing

.Applicability:Medium

tolargemanufacturerswith

investmentfrom

R30

million.

Benefit:

Trainingallowance:m

ax.R

36000perperson.

Max.55%

ofqualifying

investmentcostsin

machinery

andequipm

ent.

Source:S

outh

Africa:Investorshandbook

2014/2015(Republic

ofSo

uthAfricaDepartm

ento

fTrade

andIndustry

2014)

1118 A.M. Thow et al.

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The objectives that are emphasized in agriculturalpolicies are those relating to economic growth, employ-ment creation and rural development, and the dominantframe through which attainment of food security is ar-ticulated is economic and aggregate production oriented(rather than distribution oriented). In contrast, the textof the Food and Nutrition Security Policy is framed inthe context of the right to food, and access to safe andnutritious food for households (Table 1). However, over-all there is an implicit focus in all the food securityrelated policies on the issue of quantity of food, andlittle consideration of nutritional quality.

3.1.3 Economic policies relevant to the food supply

South Africa’s economic policies that affect the foodsupply have clear objectives: to increase economic pro-ductivity and employment through agriculture, food pro-cessing and food retail. Trade and investment policycommitments include reducing barriers to trade and in-vestment with respect to goods and services (includingfood), and protecting intellectual property rights and in-vestors (including in the food system). As part of this,specific measures to promote agri-food processing arehighlighted as a growth area from an economic perspec-tive (Box 1). Food processing – which is an issue ofconcern from a nutrition and health perspective – is apriority in the National Development Plan and TradePolicy and Strategy Framework, and investment incen-tives are provided in the Industrial Policy (Tables 3 and4).

These economic food supply policy objectives aresupported at a whole-of-government level by theNational Development Plan, which focusses on economicand social development (National Planning Commission2012). Key priorities relevant to the food supply includeincreased employment, poverty reduction and improvedagricultural production – all of which would generallyhave positive spillover impacts for food and nutritionsecurity. However, food supply policy objectivescontained in this broader government policy agenda fo-cus primarily on food as an economic commodity (forexample, as a source of income and employment). TheNational Development Plan does include nutrition as apriority, but only in terms of direct (health sector) inter-ventions for maternal and child undernutrition, with nomention of food supply intervention. (National PlanningCommission 2012) Food security objectives in theNational Development Plan focus on increasing econom-ic access to food and decreasing the cost of food, but noton the nutritional quality of that food. Somewhat contra-dictory definitions of food security appear in theNational Development Plan, which further explain this

lack of focus on the nutritional quality of the food sup-ply. Although the Plan does acknowledge the definitionby the Uni t ed Na t ions Food and Agr i cu l tu r eOrganization, which states that ‘everyone has access tosufficient, nutritious and safe food at all times’ (p.230),the focus overall is on household access dimensions offood security (for example, ‘Household food security isdetermined by the ability to access food rather than itsavailability’, p230). There is no mention of health, nutri-tion or food security in the preamble or objectives oftrade or investment agreements (Box 1, Table 3). Theonly trade agreement with any exceptions for publichealth (implicitly including nutrition) is the Trade,Development and Cooperation Agreement betweenSouth Africa and the European Union. In addition, thereis no mention of nutrition in relation to NCD preventionin Trade, Investment, Industry, or Agricultural policydocuments, or of the food supply policy actions identi-fied in the National Strategic plan for NCDs. There arealso no provisions that explicitly protect food securitywhere economic interests might be in conflict – for ex-ample, to ensure that expanding protection of intellectualproperty rights does not interfere with smallholder accessto seeds.

However, trade policy directions and priorities in SouthAfrica have evolved over the past decade to have more of afocus on equitable development (Box 1). A review of in-vestment policy in South Africa was undertaken between2007 and 2010, in part in response to an international in-vestment dispute regarding the Broad-Based BlackEconomic Empowerment Act in 2007 under the Belgium/Luxembourg - South Africa Bilateral Investment Treaty(Mossallam 2015). This review led to the termination ofseveral ‘first generation’ Bilateral Investment Treaties, andthe new Protection of Investment Act 2015 (Mashigo2014; Adeleke 2015), designed to maintain a level of in-vestor protection while bringing current agreements intoline with the priority given to non-economic (particularlysocial, sustainable development and equality focused) pol-icy objectives (Government of South Africa 2010;Mossallam 2015).

The 2010 Trade Policy and Strategy Framework explicitlyidentifies the need for trade policy commitments to supportbroader national development objectives (Table 3). In addi-tion, the new Promotion of Investment Act 2015 limits thescope for the food industry to contest food security and nutri-tion policy measures that might impact on the value of invest-ments. The termination of existing investment agreementswith very ambiguous definitions of key terms such as Fairand Equitable Treatment, and no broad development objec-tives in their preambles, opens a potential opportunity forpolicy space to protect and promote food security and nutri-tion (Box 1).

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3.1.4 Summary of policy document analysis: pointsof incoherence in food supply policy

Overall, nutrition and food security policy objectives articulatedin health and agriculture policies – particularly those that relateto food supply change that promote availability of affordablenutritious foods – are not explicitly supported by the economicpolicy sectors. Economic policies relating to the food supply donot include explicit consideration of nutrition or food securitypolicy space, but focus on food as an economic commodity.

3.2 Interviews: Actors and coalitions

Analysis of the interview data identified three key coa-litions relating to food and nutrition policy, whichreflected the points of policy incoherence identified inthe policy content analysis. The dominant subsystem wetermed ‘Economic Growth’, due to its framing of the

role of food systems as contributors to economic out-comes and employment. The second was termed, ‘FoodSecurity and Agriculture Production’ ('Food Security'),due to its emphasis on production aspects of food secu-rity. The third we termed the ‘Health’ coalition, due toits emphasis on food as a nutrition and health issue.These coalitions were mutually exclusive, in terms ofthe interviewees who articulated the main tenets of eachcoalition, but there was some overlap observed in be-liefs between the Food Security and Health coalitions,and in some of the framing of food security betweenthe Economic Growth and Food Security coalitions, asindicated below. Most of the actors in each coalitioninteracted formally in various forums and were thuslinked not only in their frames and beliefs but also informal policy processes. However, they did not refer toeach other personally during the interviews, althoughmany referred to colleagues’ institutions as influential.

Box 1 Summary of provisions in trade and investment agreements and related economic policies with implications for food security and nutrition

Provisions in economic agreements with implications for food security andnutrition raised in literature

Relevant content of concern in the South African economic policylandscape (Detail in Tables 1, 2, 3, and 4)

Use of preamble and/or objectives to define scope and policy priorities insuch a way that encompasses health (or social development) as policypriority for government more broadly.

• No mention of health or nutrition in objectives of agreements.• Acknowledgement of broader development objectives in trade and

investment policy reviews.

Reductions in barriers to trade in goods and services, leading to increasedavailability of foods and food services.

• Trade agreements reduce barriers to trade in goods and services.

Incentives to promote investment, with implications for food industryinvestment. These may generate tensions regarding concerns aboutprocessed food affordability and availability (see also Annexures:Table 4).

• Investment incentives for food processing may be contrary to health.• Trade Policy and Strategy Framework promotes agri-food processing

(growth area from economic perspective).• Investment incentives for aquaculture and infrastructure may support

access to fish and primary produce.

Protection of intellectual property rights, with implications for biodiversityand food security.

• Concerns over smallholder access to seeds.

Provisions for harmonisation and regulatory coherence (included inTechnical Barriers to Trade provisions and more generally) – canconstrain policy space and innovation in nutrition action

• Harmonisation – not in SA agreements to date, but included within broadscope of Trade, Investment and Development Cooperation Agreement(TIDCA) between SACU and USA

• Macro-economic stability priority (NIPF) may imply a reduced opportu-nity for innovation in using economic policy tools to improve foodsupply for health.

Fair and Equitable Treatment (FET) provisions underpinning investorprotection, with implications for scope for industry to contest govern-ment (public health) measures, because it sets expectations for investors.

•Broad FET definition apparent in many active BITs (e.g. lack of clarity onwhat constitutes an ‘unreasonable’ measure).

• 2015 Investor Protection Act contains very specific and narrow FETprovisions.

Investor-State Dispute Settlement Mechanisms (ISDS), with implicationsfor foreign investors’ opportunities to seek compensation regardingimpact of measures on industry (constrain innovation).

• ISDS still in some active BITs but new Investor Protection Act movesaway from this to state-state dispute settlement.

Exceptions to protect public health measures; also related is explicit prioritygiven to nutrition.

• Few specific exceptions for public health (including nutrition) – only oneis in TDCA between SA and EU.

• No mention of nutrition in relation to NCD prevention in trade,investment, industry, or agricultural policy documents, or of the foodsupply priorities identified in the NCD Strategic Plan.

Source: (Schram et al. 2013; Baker et al. 2014; Thow and McGrady 2014; Hawkes 2015; Schram et al. 2015; Thow et al. 2015a; Thow et al. 2015b;Baker et al. 2016; Friel et al. 2016; Labonté et al. 2016; Ruckert et al. 2016)

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3.2.1 Economic growth coalition

The Economic Growth coalition focused on the role ofeconomic growth and employment in delivering im-proved food security and nutrition outcomes. Key actorswere the Department of Trade and Industry and othereconomic policy departments, Agricultural trade withinthe Department of Agriculture, Fisheries and Forestry,the food industry, and agricultural producers/traders.

The Economic Growth coalition appeared to be a dominantcoalition, as it had the most resonance with the priorities andframes of overarching government policy objectives: in par-ticular, the resonance between the beliefs of this coalition,regarding food as primarily an economic commodity, andthe primacy of economic growth (employment, balance oftrade and other indicators) within the priorities of theNational Development Plan. The framing and beliefs of thiscoalition were evident in the focus on economic growth andemployment that permeated policy documents relating to thefood supply, described above. In line with this policy contentfocus on economic growth, the interviews identified a strongbias towards economic interests (both government and privatesector) in the formal government forums convened to informpolicy making. Indeed, the dominance of this coalition wasfurther indicated through the direct access that the food indus-try has to government, formalized through their participationin a range of forums, including the National AgroprocessingForum, the Agricultural Trade Forum and Value ChainRoundtables on key commodities.

[We] have walked a long journey building relationshipswith government, so we can engage robustly [Interview4, Food Industry]

Within government, cross-sectoral Clusters are convenedat a high level (DG/Ministerial) to deal with policy co-ordination and cross cutting issues in government. Theseinclude Economic, Social, Trade and Foreign PolicyClusters. It was notable that interviewees did not iden-tify an obvious place of responsibility in either theroundtables or these cross-cutting forums for food secu-rity and nutrition to be discussed.

Framing of food security and nutrition The Economic Growthcoalition framed hunger and undernutrition as the priority is-sue to be addressed by food security and nutrition policy.Nutrition in the context of NCD prevention was perceived assomething that would resolve itself with economic growth(i.e. consumers becoming wealthier), and trade in particularwas seen as critical for ensuring food security. The Economicgrowth coalition framed the causes of nutrition and food

security problems as a lack of access to (healthy) food – relat-ed to income – among vulnerable sectors of the population.This was closely linked to employment opportunities.

40% unemployment is at the bottom of the issue… SouthAfrica can’t have food security when people don’t haveincomes … [Interview 6, Academic, Food Science]

In the Economic Growth coalition there was acknowledge-ment of dietary change and a shift towards processed foods,with negative implications for nutrition. However, thesetrends were framed as the result of individual preferences forfat, salt and sugar, related to taste and palatability. Consumerdecisions not to purchase healthy foods were also framed aspersonal decisions based on preference and consumer desiresfor ‘status’ foods. In line with this, solutions for NCDs wereframed as addressing personal factors through improving ed-ucation. This was seen as an avenue to improve consumptiondecisions and also as a mechanism to improve the food supply,since industry was seen as responding to consumer demands.

However, there was also some acknowledgement of thecurrent food and nutrition problems as the result of systemicissues. One actor in the Economic Growth coalition identifiedthe need for policy entrepreneurs and advocates as ‘vision-aries’. Such actors could use systems-thinking approaches toidentify and articulate long-term economic consequences (in-cluding with respect to health) of policy making.

There may be unintended consequences [of liberalizingtrade] for diets… South Africa has potential to pick thisup earlier than the wealthy countries… We needed vi-sionaries in negotiations back then… Thinking in sys-tems would change policy making. [Interview 7,Agricultural trade].

Beliefs: economic solutions to achieve nutrition and food se-curity Actors aligned with the Economic Growth coalitionheld an evident belief that food security and nutrition werepositive by-products of economic growth. In contrast tothe Health coalition (described below), there was littleperceived tension between the goals of economic policyand nutrition/food security policy. Integration into globalvalue chains was seen as the main opportunity for agricul-tural industries, which was a key point of difference withthe Food Security coalition (described below). Thisreflected the priority given to employment and perceivedindicators of economic development, such as maintaininga positive balance of payments.

In this coalition, there was an evident belief that industrywas a (if not the) key stakeholder in achieving food policy

Improving policy coherence for food security and nutrition in South Africa: a qualitative policy analysis 1121

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goals. Food industry actors were portrayed as highly knowl-edgeable stakeholders, and the avenue through which policyobjectives would be achieved. A strong, formalized, compet-itive local industry was seen as critical to achieving develop-ment goals. The food industry supported this view, and artic-ulated a belief that they were key to achieving food securityand nutrition policy goals. As part of this, there was a beliefthat Government and Industry could bemutually supportive inachieving food security and nutrition goals.

It was evident within this coalition that there was littleperceived tension between achieving goals of economicgrowth and food security/nutrition. There was a belief thatthe market would resolve any perceived tension:

If industry doesn’t have a healthy market then they arenot going to be economically viable, so they have vestedinterest in maintaining a healthy market… It is possibleto reconcile health/nutrition and profit motives… at theend of the day, the food supply is mostly consumer driv-en and a high level of competition means it is too risky tobe unethical in marketing… [Interview 2, FoodIndustry].

Resources: high level political will and industry supportAlignment with the core objectives of the NationalDevelopment Plan and priority government economic goalsgave the Economic Growth coalition a high level of politicalsupport. For example, agriculture and the food industry wereidentified as a means to achieve the government’s stated goalof creating 11 million jobs by 2030.

Industry and industry associations positioned themselves askey resources to achieve not only these economic objectivesbut also food security and nutrition policy goals. In particular,as the main holder of technical expertise, as evidenced by theirassistance to government in setting food standards; as a sourceof innovation in food and nutrition; and as experts in logistics,essential for meeting food needs (e.g. fish, staples). Industryactors portrayed themselves as direct contributors to food secu-rity and nutrition, through general food production and theirCorporate Social Responsibility activities. For example:

[Regulators] grossly underestimate [our] contributionto food security. [Interview 1, Food Industry]

3.2.2 Food security and agricultural production coalition

The Food and Nutrition Security Policy was the product ofwhat we termed the (minority) ‘Food Security andAgricultural Production’ coalition (hereafter, the FoodSecurity coalition). It was developed by the Food SecurityDivision of the Department of Agriculture, Fisheries and

Forestry in consultation with (primarily) Education, Healthand Social Development.

Framing of food security and nutrition In the Food Securitycoalition, food insecurity (i.e. lack of sufficient food) wasframed as a major problem requiring a policy response, andthere was little consideration of other issues of nutrition, suchas NCD prevention and micronutrient deficiencies. In contrastto the Economic Growth coalition, the cause of the problemwas framed primarily as one of increasing food prices andinsufficient production, in a context of poverty, rather than alack of access to income/employment. Although these are twosides of the same issue (food affordability), the difference inemphasis (production rather than employment) influenced per-ceptions of appropriate policy solutions.

Drought is a big problem … Not enough food [was]produced so prices went up… the whole food basket[is] affected [Interview 13, Agriculture]

Framing of food supply problems tended to focus on the lackof support for local production of diverse food crops. Thepolicy agenda of the Food Security coalition was perceivedby other actors as being almost too focused on primary pro-duction [Interview 7, Agricultural trade]. Similarly, while pub-lic procurement was identified as a strategy to increase avail-ability of fresh healthy food, provide stable income for localfarmers, and support rural development, this was embracedmore cautiously on the side of the Economic Growth coali-tion. Public procurement is a key issue in trade agreements,which tend to minimize the potential for preferential localpublic procurement.

However, there was some overlap between the FoodSecurity and Economic Growth coalitions. For example, therewere a few crops mentioned across coalitions as high econom-ic value, and feasible for smaller scale production, such asberries [Interview 5 & 7, Agriculture]. Related to this areopportunities to improve demand for fresh produce throughsupporting local markets that link farmers more directly withconsumers. This would increase accessibility of healthy foodfor consumers, support local farmers in a way that was inclu-sive of smallholder farmers, and support economic growth inrural areas (an economic policy priority) – and potentiallyreduce costs incurred by long supply chains. This strategywas also seen as feasible from the economic growth coalitionbecause creating local markets and encouraging diversifica-tion would benefit small scale farmers economically.

Beliefs: food is a local, social good, and not an economicpolicy issue The Food Security coalition held an evident beliefthat food security was a social rather than economic issue.Actors highlighted the policy tension between food as an eco-nomic commodity, and as a social good.

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Food security is a social issue… [it] will always be atopposite end to economics… The Government is tryingto bring these together but it is not possible….Economists will tell you that economic growth bringsspin offs, but social issues are marginalized [Interview13, Agriculture].

In line with this, the Food and Nutrition Security Policy wasdeveloped with limited input from the economic sector, de-spite the economic sector (Trade, Investment, Commerce etc)having a significant policy influence on the food supply. Thekey actors involved in the development of the policy were theDepartment of Education – seen as particularly relevant withgrowing interest in school feeding (Bnutrition is a side issuefor them but they are interested because of what children eat^[Interview 13, Agriculture]) – the Department of Health, be-cause of their expertise in nutrition, and the Department ofSocial Development, which has early childhood developmentcentres and provides social grants.

The Food Security coalition was also characterized by abelief that local markets (production and consumption) wouldstrengthen food security, through a focus on providing accessto consumers and also supporting poor farmers. Social grantswere seen as helpful contributions at the household level, butthe primary need was framed as affordable, accessible food.

The local food processing industry also positioned itself ascontributing to the policy objectives of this coalition, particu-larly processing companies. They framed their supply chainexpertise and preference for local primary produce asexpanding production capacities and increasing localproduction:

[We are] supporting local farmers, and try to sourcelocally… we prefer not to import due to cost…and pur-chase 2 million tonnes of agricultural commodities peryear, of which 2/3 is local [Interview 4, Food Industry].

Resources: high level political will but limited Civil Societyengagement The Government of South Africa has prioritisedfood security as part of national and international commit-ments, including the Constitution and the SustainableDevelopment Goals (Table 4).

However, although this political commitment exists, theuse of the term ‘food security’ in the National DevelopmentPlan appears to align more with the Economic Growth coali-tion’s frame than the Food Security frame, with more of afocus on increasing household employment and national mea-sures of food security. In addition, while the Food andNutrition Security Policy was developed by the Ministry ofAgriculture, the locus of implementation of the Food Securityand Nutrition Policy is with the National Government in theplanning department. This may indicate future challenges in

maintaining the conceptualization of food security used by theFood Security Coalition.

Actors in this coalition reported interest from Civil SocietyOrganizations (CSOs) in contributing to food security policy,but CSOs had limited involvement in policy making – andnotably, no formal avenues for input. In particular, they weren’tincluded in the development of the Food Security and Nutritionpolicy. In the next policy stage (implementation) CSOs will beincluded in the high-level council on Food Security. However,an actor from Government expressed caution about engage-ment with CSOs, voicing a perception that small informal pro-ducers have limited representation.

Civil Society Organizations wanted to be consulted onpolicy … But it is not clear who they represent. It isunlikely to be the rural poor… [and] farmer associa-tions don’t have local roots. CSOs are not organized…[they] need to be properly represented and organized[Interview 13, Agriculture].

3.2.3 Health coalition

The actors in what we termed the Health coalition evidencedbeliefs regarding the importance of food supply policy in cre-ating healthy food environments for good nutrition for health(including aspects of food security, but more health focused).For example:

[Health and nutrition is] not just about education, be-cause nutritious food/healthy convenience food is notaffordable, even when you are not poor [Interview 11,Public Health]

The main actor was perceived as the Department of Health, asthe focal ministry for nutrition related policy, and also CSOs.However, there was also recognition that achieving nutritionpolicy goals would require action in economic sectors.

The Food Legislation Advisory Group is the multi-stakeholder forum related to food and health, which sits withthe Department of Health, and acts as a platform forGovernment to engage with industry associations, academics,and other government departments on food regulation.Although interviewees from a range of coalitions identifiedthis as the key multisectoral forum relevant to food securityand nutrition, it is not constituted to address either of theseissues, and its main focus is on food safety.

Framing of food security and nutrition The Health coalitionframed the main nutritional problem as the coexistence ofmultiple forms of malnutrition (undernutrition, micronutrientdeficiencies and diet-related NCDs/obesity). In particular,they emphasized that these different forms of malnutrition

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are affecting common (not different) populations, and thusneeded to be addressed in a coordinated manner.

In the Health coalition the problem of poor diets wasframed as a response to food environments, rather thanan issue of personal choice, in contrast to the EconomicGrowth coalition – although there was recognition thatlimited household finances also played a role inskewing consumption to cheap, unhealthy foods. Theyidentified the relative inexpensiveness of unhealthyfoods, as well as industry efforts in the marketing andadvertising of such foods as key factors driving dietarychange.

Energy dense, low nutrient foods are what is commonlyconsumed… This is very cheap and tastes nice – e.g.chips [Interview 11, Public health]

In line with this, the solution was framed as a need for sys-temic change – to increase access to healthy affordable foods,such as fruit and vegetables. However, the food system wasseen as very difficult to change in terms of reorienting tohealthy food production.

Beliefs: solutions require food policy change, without indus-try influence Actors in the Health coalition articulated a beliefthat considerations of health and nutrition were marginalizedin food supply policy. This was perceived as being due to theprevailing focus on Bbringing investment, not on the impact ofinvestment^ [Interview 14, Public Health]. The Department ofHealth also had limited participation in decision-making re-garding economic policy relating to the food supply.

Nutrition is not really considered [in the InterministerialCommittee on Investment]… it is the domain of theDepartment of Health [Interview 8, Economic policy].

There were overlaps in beliefs about food security and nutri-tion policy between the Food Security and Health coalition,and also some evidence of collaboration between theMinistries of Health and Agriculture, for example on the de-velopment of orange-fleshed sweet potato. This was also sup-ported by the consideration of micronutrient content of cropsin the national agricultural policy (Table 2). However, a keydifference appeared to be the focus of the Health coalition onthe outcomes of agricultural production for the health of con-sumers, which was not perceived as a core issue for consider-ation by agricultural policy makers, who were seen by thehealth sector as more concerned with ensuring the welfare offarmers. This was seen as limiting the scope for more signif-icant collaboration on nutrition.

In contrast to the Economic growth coalition, the Healthcoalition held a strong belief regarding the need to limit

industry involvement in food security and nutrition policymaking due to conflicts of interest:

Policy space [for nutrition and food security] needs tobe protected – industry should not be involved in thepolicy space … Health must engage with industry butneeds to have very clear rules of engagement and guide-lines [Interview 10, Public Health].

Resources: limited influence and capacity for enforcementPart of the marginalization of health was perceived as due tothe lack of Civil Society activity in the nutrition policy space,which is needed to help raise concerns to the attention ofpolicy makers. However, there appeared to be no formalmechanism for their engagement (in contrast to industry actorsin the economic policy space. The advantage to the healthsector of having Civil Society actors calling for strong foodsecurity and nutrition policy, was that it would circumvent theneed for the health sector to directly lobby against governmentpolicies that they perceived as favouring industry over health.It would also give access to broader expertise than containedwithin the government.

Health actors need to consider how to strengthen CivilSociety, in terms of capacity and education, and to cre-ate organized lobbying. Improving food security andnutrition needs multidisciplinary expertise…[Interview 10, Public Health]

The Health coalition also faced a significant challenge in theform of lack of resources. This meant that policies weren’timplemented. Two areas of resource imbalance werehighlighted in the interviews, which made it difficult for theHealth coalition to successfully shape policy agendas. Onewas the lack of resources for government nutrition promotion,compared to the advertising budgets of industry, resulting inpoor quality health promotion interventions.

[There are] huge disparities in resources – theDepartment of Health doesn’t even have 100 millionrand/year for prevention… but industry spends 100 mil-lion rand on just one ad. [Interview 14, Public Health].

The marginalization of nutrition interests was compounded byan imbalance in resources and influence for lobbying. Theresources available to industry to fight policy (for example,in relation to the proposed [at the time] soft drink tax) weremuch more significant than that available to the HealthCoalition actors – primarily government and civil society.The direct access that industry had to economic forums wasalso seen as giving them a preferential position in food supplypolicy making.

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4 Discussion

4.1 Current policy agendas

Food security and nutrition policy is a political and contestedpolicy space. This study identified three different policy coa-litions contributing to policy incoherence regarding food sup-ply and food security and nutrition in South Africa. Drawingon Sabatier’s conceptualization of coalitions of actors as in-fluential in shaping policy outcomes in a given policy subsys-tem, we analysed the framing of food security and nutrition bydifferent actors, the resonance of these frames with policycontent, and the evident beliefs and resources that character-ized each coalition. Overall, we found recognition across allthe coalitions that the government is trying to balance com-peting agendas in the food security and nutrition policy space.One of the key challenges to policy coherence identified wasthe very different framing of food and nutrition between theFood Security and Health coalitions, with the problem nar-rowly (coalition-based) defined as: hunger and economic ac-cess to calories; or rising consumption of unhealthy foods; orlack of diversity in diets based on staple foods. There is animplicit incoherence between economic/agricultural policyemphasis on value-adding, which is primarily an avenue forjob creation, and health policy emphasis on fresh, unprocessed(healthier) foods.

The dominant policy coalition, whose beliefs we see mostclearly reflected in policy documents governing the food supply,we termed the Economic Growth coalition. Actors in this coa-lition frame food insecurity and malnutrition as primarily theresult of a lack of income and a lack of knowledge about healthyeating. This understanding of the problem as primarily derivingfrom individual level factors, such as being poor (i.e. lack ofeconomic access to food) or personal preference (e.g. for foodshigh in fat, salt and sugar), is reflected in the focus on personaleducation and economic growth (to provide employment andincome) as core components of the solution. The core beliefs ofthis coalition are that employment and economic growth, withina neoliberal economic dispensation, are the primary mechanismto improve nutrition and food security, and that industry is there-fore key to achieving food security and nutrition in the longterm. This coalition is supported by high level political will –these beliefs are reflected in the National Development Plan andother core food supply policy documents. They are also heavilysupported by the food industry, which is represented as a re-source to achieve food security and nutrition policy goals.Industry has several formal mechanisms to input into policymaking; their role is framed as both technical experts in foodsystems, and their significant contribution to economic growth.

Support for economic growth within a neoliberal, unregu-lated framework have been documented elsewhere as domi-nant in food policy making (Pinstrup-Andersen 2013). Thefood industry has been heavily engaged with developing

policy solutions that focus on individual responsibility andportray the food industry as a key part of the solution(Jenkin et al. 2011; Scott et al. 2017), and in framing food asprimarily an economic good and the food industry as a signif-icant contributor to GDP (Friel et al. 2016). The heavy in-volvement of industry in policy forums in South Africa raisesconcerns about conflicts of interest in nutrition policy making.The World Health Organization has unequivocally recom-mended that nutrition policy processes be protected from theinfluence of vested interests (WHO 2013). However, it is un-clear how this can be operationalized when policies shapingthe food supply are both nutrition and economic policies.

The second policy coalition is focused on food security,with frames and beliefs resonant with the National Food andNutrition Security Policy. Actors in this coalition frame foodinsecurity as primarily a problem of production and accessi-bility of food. This framing regarding production is reflectedin solutions focused on increasing production for local popu-lations, such as through increased investment in local markets.Food security is a political priority, and the Right to Food isenshrined in South African legislation; the planned NationalFood and Nutrition Security council will be situated under thePresident’s Office. However, there is ambiguity in the use ofthe term food security in high level policy documents – forexample, the National Development Plan and national agri-cultural policy reflect much more of the framing of theEconomic Growth coalition, in contrast to the national foodand nutrition security policy, which is much more in line withthe framing and beliefs of the Food Security coalition. A keyopportunity to increase the resources available to this coalitionis the civil society interest in this framing of food security.However, they have had limited participation in policy devel-opment to date.

The concept of food as a social good is embedded in asocial perspective on food security (Riches 2016), and reflectsaspects of the food sovereignty discourse in its focus on small-holder production and the right to food (Jarosz 2014).However, in this context this seems to be core to the margin-alization of the Food Security coalition. Food trade andindustry-led growth is a tenet of the dominant framing of foodsecurity by the Economic Growth coalition, and a focus onsmallholder farmers and local markets is marginalized by theprivileging of large-scale production and seen as unable tomeet overarching policy objectives for economic develop-ment. This tension is reflected in recent calls to ‘revision’ ofagricultural and food systems with respect to nutrition, whichhighlight the need to identify opportunities to achieve botheconomic and nutritional policy goals through agriculturalproduction and distribution (Jones and Ejeta 2015;McDermott et al. 2015; Pingali 2015). As in this study, rec-ommendations include strengthening incentives for diversifi-cation to nutrient-rich crops and strengthening markets.However, the potential of promoting small scale agricultural

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production of vegetables, fruit and small livestock to bothsupply more accessible nutritious food and create livelihoodsremains marginalised in policy discourse in South Africa.

The third coalition identified we termed the Health coali-tion, which frames food security and nutrition from the per-spective of malnutrition as a health outcome. Actors in theHealth coalition frame malnutrition (undernutrition, micronu-trient deficiency and diet-related non-communicable diseases)as primarily the result of an unhealthy food environment, inwhich unhealthy foods are among the most affordable andheavily marketed. In contrast to the Economic Growth coali-tion, the solution is thus framed as primarily the responsibilityof the food system to deliver healthy affordable foods. A corebelief of the Health coalition is the need for food supply policyto support nutrition objectives. Another key belief – particu-larly in relation to NCD prevention – is that the influence ofthe food industry on food-related (nutrition related) policymaking should be circumscribed. However, the influence ofthis coalition does not appear to extend far beyond healthpolicy documents and it is characterized by limited resources:in particular, limited engagement by civil society organiza-tions, a low capacity for enforcement, and limited financialresources for raising awareness and exerting influence on pol-icy (particularly in contrast to industry).

The challenges faced by the health coalition in translatingtheir core beliefs into policy action have been observed else-where (Roberto et al. 2015). For example, a marked differencein the beliefs and frames between actors in public health andtrade/agriculture has also been observed in the EU (Walls et al.2016). This has often been attributed to resource constraints,including lack of political will and human and organizationalcapacities, which have resulted in limited policy action onmalnutrition in other low and middle income countries(Pelletier et al. 2012). The lack of civil society engagementobserved here has also been identified as a barrier to policyaction for nutrition globally (Timotijevic et al. 2010; Huang etal. 2016). Recent research has identified strategies to buildpublic support for nutrition policy action such as: improvingpublic information; population-specific framing; strengthen-ing media advocacy; and cultivation of change agents withingovernment (Huang et al. 2016). One argument that has beenadopted globally by nutrition policy advocates, but had littlepresence in the data we collected, was on the economic cost ofpoor nutrition and NCDs (Batura et al. 2015; Shekar et al.2016).

4.2 Improving policy coherence

Evident in the understanding of the problem of food insecurityand malnutrition and the solutions identified by these policycoalitions is a tension between overarching policy objectives,as the Government of South Africa seeks to reconcile priori-ties of economic growth and productivity with health, social

transformation, and the right to food. The renegotiation ofinvestment agreements by the Government of South Africa,and the explicit policy priority for achieving social and devel-opment goals in the context of trade agreements indicates thatthe economic policy paradigmmay be changing. This presentsa potential policy window for inclusion of public health / nu-trition considerations into trade and investment policy, suchthat policy space for current and future nutrition policy inter-ventions is protected. This changing investment policy spacein South Africa and the Southern African DevelopmentCommunity (SADC) reflects wider concerns regarding thepotential for investment agreements, including BilateralInvestment Treaties, to constrain national policy space forachieving social, health and other objectives. The UnitedNations Conference on Trade and Development has recentlyconcluded that BToday, the question is not whether or not toreform [International Investment Agreements], but about thewhat, how and the extent of such reform^ (UNCTAD 2016).

Policy coherence in this context would mean that foodsecurity and nutrition policy objectives are not undermined –and ideally are supported – by economic policy that relates tothe food supply. Change in the economic paradigm that hasresulted from the social policy subsystem disruption (whichled to the significant changes in investment policy describedin Findings) might create scope for more positive economicpolicy in the food system. Leveraging this opportunity to im-prove food security and nutrition will require acknowledge-ment of broader development, food security, nutrition andhealth objectives in economic policy objectives (includingeconomic development, trade, investment, industrial and ag-ricultural policies). It will also require food security and nutri-tion to be perceived as a domestic policy priority, to be pur-sued in the protected policy space. With the current domi-nance of the Economic Growth coalition in framing the issues,it is not clear whether nutrition and food security would beprioritized, even with increased policy space to do so.Previous research in South Africa has documented the tenden-cy for relatively minor policy change with respect to the foodsupply. Even in response to the significant food security andnutrition crisis engendered by the global food price increasesof 2007–09, South African food policy focused on householdfood access rather than changes to the food supply (Kirsten2012; Watson 2017). This likely reflects the political expedi-ency of maintaining the status quo, as well as the power offood system actors that benefit from the current policy struc-ture. For example, the strong influence of business interests onSouth African policy priorities that has been documented else-where (Kirsten 2012).

This raises the question of what might incentivize increasedpolicy priority for food security and nutrition with respect tothe food supply. The research presented here clearly indicatedthe influence of whole-of-government policy objectives onpolicies across sectors, and particularly the dominance lent

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to the economic growth coalition by its clear alignment to theoverarching government priorities for employment and eco-nomic growth. It is possible that agencies with a whole-of-government mandate, such as the Department of Monitoring,Planning and Evaluation, or the 5-yearly African NationalConference, which shapes the programme of work for gov-ernment (Kirsten 2012), may have an increasing interest inimproving policy coherence for food security and nutritionwith respect to the food supply. In particular, due to the highsocial costs of food insecurity and malnutrition and the inef-fectiveness of current approaches to address these (evidencedby high rates of food insecurity, undernutrition and NCDs), aswell as growing global consensus that food supply-orientedpolicy is part of an effective response. The recent adoption bythe Government of South Africa of a soft drink tax, in the faceof strong industry opposition, indicates growing recognitionof the importance of – and willingness to take policy action for– a food supply that supports good nutrition.

This analysis indicates that the forums for stakeholder en-gagement in the food policy subsystem heavily favour indus-try, suggesting that formal mechanisms for capacitating civilsociety and promoting its engagement might help to improvepolicy coherence. Interviewees from the Food Security andHealth coalitions identified the need for CSOs to engage inmore strategic advocacy for consideration of social, environ-mental and health issues in food security and nutrition policymaking. Improving outcomes for food security and nutritionthrough increased civil society engagement will require in-creased capacity for CSO lobbying and communication inthe food security and nutrition policy space. The capacity ofcivil society to support public interest, engage with policyissues, and bring key issues to the attention of policy makershas been identified as a significant facilitator of nutrition pol-icy action globally (Roberto et al. 2015; Huang et al. 2016;Ruckert et al. 2016). Further research is needed to investigatethe opportunities and challenges to increasing capacity of civilsociety actors to support more coherent food security andnutrition policy in South Africa.

Addressing the double burden of malnutrition will require apolicy focus on rendering foods of high nutritional qualityaccessible geographically and financially to consumers acrossthe income spectrum, to complement the current focus onpoverty reduction. The dominant framing and beliefs in theEconomic Growth and Food Security policy coalitions focuson production of (and access to) sufficient food, but not onnutritional quality. This is a global challenge; there have beenrepeated calls for food systems that deliver nutritional qualityand not simply calories, such that they would achieve foodsecurity and nutritional objectives while not discounting other(economically oriented) food supply policy priorities(McDermott et al. 2015). Taking a nutritional quality and foodsecurity lens to the existing policy priorities, content and in-terests regarding the food supply in South Africa in this study

identified four specific opportunities to strengthen policy forfood security and nutrition. First, the opportunity for specificchanges to economic policy relating to the food supply thatachieve both food security/nutrition and economic objectives,such as incentivizing small scale producers to produce foodsof high nutritional value, that also create employment throughtheir high economic value (such as fruit and vegetables).Second, creating links between producers and consumers,through markets and fiscal incentives, that make healthy andfresh foods more accessible and affordable. Third, increasingformal avenues for engagement by Civil Society in nutritionand food security policy making, as well as avenues for foodsecurity and nutrition policy makers to engage in economicpolicy forums that affect the food supply. Fourth, to includeconsideration of the nutritional quality of the food supply inpolicy objectives across sectors, to create a framework forpolicy coherence across sectors relating to the food supply.

South Africa is a co-chair of the global Sustainable FoodSystems Programme, which does not currently address nutri-tion, but this might afford an opportunity to open a broaderdialogue about relevant and appropriate policy objectives toaddress the pervasive nutrition challenges that South Africafaces. Another opportunity may be strategic use of publicprocurement. In Brazil, local public procurement for schoolshas played an important role in promoting food security aswell as rural development, including through reduction ofthe costs associated with long supply chains with multipleactors (Sidaner et al. 2013).

4.3 Limitations of the study

The main limitation of this study is the limited number ofinterviews conducted. The selection of stakeholders is likelyto have shaped the coalitions identified. However,complementing interviews with a systematic review of policycontent is likely to have balanced out this risk. Further re-search in this space would be strengthened by including inter-views with cross-cutting agencies such as the Department ofMonitoring, Planning and Evaluation and the CompetitionCommission, with retailers, and with civil society actors.Another limitation is our focus only on national level policy.It is also likely that these kinds of policy incoherence alsomanifest at the provincial and local level.

Acknowledgements The authors gratefully acknowledge the generosityof the interviewees who contributed their time to this study. An earlierversion of this analysis was also published as a Working Paper by theUniversity of the Western Cape in 2017.

Compliance with ethical standards

Conflict of Interest statement The authors declared that they have noconflict of interest.

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Open Access This article is distributed under the terms of the CreativeCommons At t r ibut ion 4 .0 In te rna t ional License (h t tp : / /creativecommons.org/licenses/by/4.0/), which permits unrestricted use,distribution, and reproduction in any medium, provided you give appro-priate credit to the original author(s) and the source, provide a link to theCreative Commons license, and indicate if changes were made.

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Dr Anne Marie Thow is SeniorLecturer in Health Policy at theUniversity of Sydney. Her re-search uses theories of public pol-icy to explore facilitators and bar-riers to best practice public healthnutrition policy, with a particularfocus on the interface betweeneconomic policy and nutrition.Anne Marie currently collabo-rates on research in Asia, Africaand the Pacific, designed tostrengthen nutrition policy mak-ing, and regularly consults withinternational agencies regarding

nutrition policy, including the World Health Organization, Food andAgriculture Organization and International Food Policy ResearchInstitute. Prior to her PhD, Anne Marie worked for the Governments ofAustralia and Fiji on nutrition policy issues. She trained in nutrition andhas a Masters in Public Policy and Economics.

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Stephen Greenberg , at the timeof writing, was a researcher withthe Institute for Poverty, Land andAgrarian Studies (PLAAS) andCentre of Excellence in FoodSecu r i t y (CoE-FS) a t t heUniversity of the Western Cape.Current work is on corporatepower in the South African agro-food system and links to nutrition,as well as other work on small-scale agriculture and agro-ecology in Africa. Stephen wasawarded a DPhil f rom theInstitute of Development Studies

(IDS) at Sussex University in 2011 on land reform, space and power inLimpopo, South Africa.

Associate Professor MafanisoHara , is a social scientist withover thirty years experience in in-ter-disciplinary research and de-velopment work focusing on ruralcommunities in Southern Africa,inparticular fisheries (both fresh-water and marine). He obtainedhis PhD from UWC in 2001. Hiscurrent research is on inter-rela-tionships between food security,poverty and resourcemanagement.His passion is how integrated natu-ral resource governance and foodvaluechains should led to sustain-

able livelihoods for communities. He represents Africa and the Middle Easton the Executive Committee of the International Institute forFisheriesEconomics and Trade (IIFET). He has over seventy publications,more than half of whichare peer reviewed journal articles and books chapters.

Sharon Friel is Professor ofHealth Equity and Director of theSchool of Regulation and GlobalGovernance (RegNet), AustralianNational University. She is aFellow of the Academy of SocialSciences Australia. Sharon is Co-Director of the NHMRC Centrefor Research Excellence in theSocial Determinants of HealthEquity. She held an ARC FutureFellowship to investigate the inter-face between health equity, foodsystems and climate change.Between 2005 and 2008 she head-

ed the Scientific Secretariat (University College London) of the WHO

Commission on Social Determinants of Health. Her current interests arein the political economy of health; policy, governance and regulation inrelation to the social determinants of health inequities, including trade andinvestment, food systems, and climate change.

Andries du Toit has a PhD inComparative Studies from theUniversity of Essex. His trainingis in political theory and in quali-tative and anthropological ap-proaches to social science re-search. He has done extensive re-search on the political economy ofstructural poverty and racialisedinequality in a range of contextsin South Africa: his publicationsinclude work on the social rela-tions of labour on commercialfruit and wine farms in theWestern Cape, on chronic and

structural poverty in the rural and urban Western Cape and in theEastern Cape, and on the dynamics of marginalised livelihoods and in-formal social protection in the migrant networks of the Eastern andWestern Cape.

David Sanders , EmeritusProfessor and founding Directorof the School of Public Health atthe University of the WesternCape (UWC), South Africa, is apaediatrician qualified in PublicHealth. He has over 35 years’ ex-perience of health policy and pro-gramme development, researchand teaching in Zimbabwe andSouth Africa, having advisedgovernments and UN agenciesand published extensively on pri-mary health care, child health andnutrition, including four books on

global health and PHC. He serves on the International Malnutrition TaskForce and was on the UN Standing Committee on Nutrition and theKnowledge Network on Globalisation of the WHO Commission onSocial Determinants of Health. He received the Nutrition Society ofSouth Africa Award in 2002 and an Honorary Doctorate from UCT in2012. He serves on the Management Committee of South Africa’s Centreof Excellence on Food Security and on the Global Steering Council ofPeoples Health Movement.

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