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Global Forum on Food Security and Nutrition • FSN Forum

Re: Invitation to an open discussion on the ICN2 Framework for Action zero draft to implement the Rome Declaration on Nutrition

Malyn Ando
Malyn AndoARROWMalaysia

Inputs for the open discussion on the ICN2 Framework for Action zero draft to implement the Rome Declaration on Nutrition

by the Asian-Pacific Resource and Research Centre for Women (ARROW)

ARROW, a global South NGO based in the Asia-Pacific,* appreciates the opportunity to comment on the Framework for Action. We hope that our input can be included in the subsequent drafts. We would like to contribute the following input, which is also attached.

1. General Comments

We welcome the development of the Framework for Action (FFA), and see this as a critical opportunity for coherence of global agendas, policy frameworks and global mechanisms, in the midst of ongoing global discussions on the post-2015 development agenda.

We support that the FFA recognizes that the nature and underlying causes of malnutrition are complex and multidimensional, and that it draws especial attention to women and children. We also welcome that health and education, are recognized amongst others, as key sectors. We would recommend that additionally, the FFA should adequately recognize various structural issues, including poverty and gender discrimination, as causal and exacerbating factors to malnutrition, hunger, food insecurity, ill health and lack of wellbeing. Women and girls comprise an estimated 60% of the undernourished[1], and various socio-economic, cultural and political factors combine to make certain groups of women even more vulnerable to hunger and malnutrition, including widows, women with disabilities, women from lower castes, adolescent women and women living with HIV and AIDS.

The FFA needs to specifically recognize the rights to food and nutrition and mention ways to promote, protect and respect these.

The FFA mentions that it will be implemented together with the Decade of Action on Nutrition in the preamble; however, this is not consistently seen in the document. Priority actions must be reframed to be measurable and time-bound where possible. While we acknowledge that resources, needs and problems vary among and within countries and regions, countries should set goals that are sufficiently ambitious to inspire action and show their commitment to solving problems related to hunger, and achieving nutrition, health and food security.

Comments on Chapter 1

Aside from specific nutrition goals, to ensure that it really looks at the interrelatedness with other sectors, the FFA should include specific goals related to access to land, credit, technology, markets, water, and other productive resources and commons. Across the globe, laws and customary practice have restive consequences for women’s access to these, and yet securing these resources enhance women’s rights, and support their nutrition, health and wellbeing, as well as that of their families and communities.                          

While it is good that the FFA recognizes CSOs and social movements as partners in implementing the Rome Declaration on Nutrition, it should enable and guarantee full and meaningful participation of CSOs and social movements, especially women’s rights groups, and particularly from the Global South, at the national, regional and global levels. This includes provision of funding support and giving adequate time so they could meaningfully participate in global discussions.

2. Comments on Chapter 2

2.1 Enabling environments: Aside from those mentioned, to create an enabling environment respect for human rights, including the right to food and nutrition, must be the underlying basis. Additionally, political will and commitment must explicitly be backed by funding.

2.2 Better governance for nutrition: Add women’s groups among the list of groups to be consulted.

2.3 Financing for improved nutrition outcomes: We appreciate the power of economic arguments in convincing governments and donors to address hunger and malnutrition issues, and as such the document should emphasise on the high costs of inaction. This should also be balanced by rights-based framework, which is not sufficiently emphasized in the document. Stakeholders representing those most directly affected by nutrition programmes and policies, including community organisations and women’s rights groups, need to be part of decisionmaking regarding investments and funding.

Comments on Chapter 3

3.1 Food systems: We appreciate that the discussion noted how gender-sensitive interventions can improve nutritional outcomes, and that women’s critical roles in the food system has been specifically mentioned. However, the priority actions must reflect this.

3.3.1 Delivery of effective nutrition interventions: This section should acknowledge more the unacceptable rates of maternal mortality and morbidity, and have stronger priority actions beyond addressing anemia.

3.3.2 Delivery of health interventions with an impact on nutrition:

-          On the section prevention and treatment of infectious diseases, HIV and AIDS is mentioned as one of the infectious diseases contributing to anemia. We would recommend adding an action dealing with the special nutritional needs of women living with HIV and AIDS. Good nutrition is important for those living with HIV as they have compromised immune systems.

-          We welcome the section on Reproductive Health and Family Planning. We strongly support the priority action, “Ensure access to sexual and reproductive health services for all women” and would caution against the removal of any element. We would also want to highlight the importance of the respect, protection and promotion of sexual and rights of women (not just reproductive rights). Sexuality is in integral aspect of being human, and as such, sexual rights are fundamental human rights; we would like to call for the promotion of an enabling environment wherein everyone may enjoy sexual rights as part of development. We would like consistent use of sexual and reproductive health, as well as sexual and reproductive rights across the document.

-          We would like to reiterate the Civil Society Declaration read endorsed by CSOs and read at the Informal Consultation with Non-State Actors for ICN2 in Rome, Italy on 20 June 2014, which stated, “Actions to end hunger and malnutrition in all forms must work to transform societal norms that result in violations of sexual and reproductive rights.” We would like to ask the consistent use of Sexual Health, and the addition of sexual rights.

-          We strongly support the inclusion of adolescent pregnancy as an issue. As priority action, measures to prevent adolescent pregnancy should include comprehensive sexuality education and changing of norms, values and policies to eliminate child, early and forced marriage.

-          Gap: The intersections of nutrition and sexual health and sexuality is not mentioned in the document. While sexuality, including sexual health, are integral parts of human beings, they receive little attention. Studies have shown that poor nutrition and malnutrition affect sexual health through adverse effects like sexual dysfunctions, in both men and women, including tiredness, lack of desire and painful intercourse among others. There is also plenty of evidence and literature on impact of diabetes, which is linked with obesity, on the sexual health of women and men.[2] It should also be mentioned that undernutrition or obesity can also have other impact on reproductive health, such as lead to subfertility or infertility.

3.3.3 Breastfeeding: Priority actions should include regulations for maternal and paternal leaves.

3.4 International trade and investment: We support that trade and investments policies be coherent with and not undermine nutrition strategies and policies, and that innovations in nutrition are included in the public health exception to intellectual property rights. Food sovereignty should be included as the main principle. There should be accompanying priority actions for this section as currently this is the only section not to contain any.

Comments on Chapter 4: Accountability

We support the establishment of an accountability mechanism, which should be based on human rights and should be gender-responsive. We appreciate that the process is going to be inclusive, where we assume that CSOs and social movements being given opportunity to input into the development of this monitoring and accountability framework. However, sufficient time should be provided to give input – something that current ICN2 processes do not give. This allows those from the global South, and those who also need time to consult among its constituencies, to be able to give feedback.

CSOs and social movements also need to be included in the list with responsibility for action. Monitoring to ensure that governments and international partners are implementing commitments is a key role.

Comments on Chapter 5

There needs to be global policy coherence; it needs to make clear how the Rome Declaration and the Framework for Action will be linked with the post-2015 development agenda, including Sustainable Development Goals, as well as the Committee on Food Security and Human Rights Council.

2. Does the Framework for Action adequately reflect the commitments of the Rome Declaration on Nutrition, and how could this be improved?

We would like to see the latest version of the Rome Declaration to respond to this, and also to be given further opportunity to give input.

3. Does the Framework for Action provide sufficient guidance to realize the commitments made?

As mentioned above, priority actions must be reframed to be measurable and time-bound where possible.

4. Are there any issues which are missing in the draft Framework for Action to ensure the effective implementation of the commitments and action to achieve the objectives of the ICN2 and its Declaration?

This is already addressed in the above questions.


ARROW is a regional, non-profit, women’s NGO based in Kuala Lumpur, Malaysia, and has consultative status with the Economic and Social Council of the United Nations. Since it was established in 1993, it has been working to promote and defend women’s rights and needs, particularly in the areas of health and sexuality, and to reaffirm their agency to claim these rights. ARROW’s current work spans information and communications, knowledge exchange and transfer, evidence generation for advocacy, consistent monitoring of progress towards relevant international commitments made vis-a-vis women’s health, capacity building, partnership building for advocacy, engagement at international and regional forums, and enhancing the organisational strength of both ARROW and her partners. ARROW works with national partners in 17 countries across Asia and the Pacific, as well as with other allies from the global South in Africa, Pacific, Eastern Europe, Latin America and the Caribbean, and the Middle East and North Africa, and with allies from the global North.

[1] Sources: UN Economic and Social Council (ECOSOC). 2007. Strengthening Efforts to Eradicate Poverty and Hunger, Including through the Global Partnership for Development. Report of the Secretary-General. UN doc. E/2007/71. New York: ECOSOC. And World Food Programme (WFP). 2009. WFP Gender Policy and Strategy: Promoting Gender Equality and the Empowerment of Women in Addressing Food and Nutrition Challenges. Rome: WFP, p.6

[2] See ARROW & the World Diabetes Foundation (2012). Diabetes: A missing link to achieving sexual and reproductive health in the Asia-Pacific Region. Kuala Lumpur.