Memorandum by Compass Group PLC (WP 49)
1. INTRODUCTION
1.1 Compass Group PLC is the world's leading
foodservice company, with annual revenues of £12 billion
and over 400,000 employees in 40,000 outlets in more than 90 countries.
In the UK, the Group has revenues of £2.5 billion and employs
more than 90,000 people. The Group's core business is the provision
of food and related services to clients and customers in the workplace,
in schools and colleges, hospitals, on the move and in remote
and sometimes hostile environments.
1.2 As a global foodservice company we know
that we have an enormous influence on what our 20 million customers
a day choose to eat and drink and that the purchasing decisions
we makewe buy over £3.5 billion of food a yearhave
implications in terms of food production and sustainability.
1.3 Unlike other links in the food chain,
the foodservice sector operates on a very decentralised basis
reflecting the different sectors in which we operate and the very
diverse requirements of our clients. The nutritional requirements
of an office worker are different to that of a manual worker,
school child or hospital patient. For example in the education
and healthcare sectors we will be working to nutritional guidelines
laid down by government or other bodies and agreeing in detail
with the client (eg NHS Trust or Local Education Authority) menus
that meet these guidelines as a minimum requirement. Conversely,
in the workplace or travel sectors, whilst operating specifications
may be agreed with the client, menus are designed to appeal to
customers in those locations. In both cases this means much of
the food we serve is freshly prepared on the premises in which
it is served to menus that are developed by chefs locally as opposed
to centrally.
1.4 This is an important distinction to
bear in mind when considering some of the proposals made by the
Government and is reflected in our own approach to wellness and
healthier eating. Compass Group has always been at the forefront
of developing innovative and high quality nutritious offerings
that satisfy our customers' lifestyle choices whilst meeting the
diverse demands of the differing sectors we operate in. Recent
initiatives include:
1.4.1 In the workplace environment,
and in partnership with our clients, we have introduced a menu
planning systemThe Healthy Waywhich is based on
the Food Standard Agency's balance of good health guidelines.
Recognising the growing trend towards grazing or casual dining
we have also introduced a range of "grab and go" products,
"Food Talk", that includes a core range of healthy options.
1.4.2 As the world's largest vending
company we have taken the lead in responding to concerns about
the role of vending machines in schools by re-merchandising machines
to place the emphasis on a more balanced range of products, particularly
waters, juices and healthy snacks, and we have removed machines
branded with a manufacturers logo and replaced them with glass
fronted machines with the emphasis again on healthy products.
1.4.3 As the largest private sector
provider of school meals we have for over a decade run programmes
to help pupils understand the importance of eating a well-balanced
meal based on the key food groups. Since 2002 we have reduced
the salt content in primary school meals by 38% and have removed
all salt from the cooking process in secondary schools resulting
in a reduction of 10,000 kilograms in salt purchases. We also
encourage the baking or grilling of products as opposed to frying.
In secondary schools we offer children a free portion of side
salad or vegetables with every main meal purchased and fruit salad,
mixed salads and low sugar drinks are always available.
1.4.4 We are also working with manufacturers
and processors to re-specify or re-formulate products to meet
our requirements. For example, working with Baxter's soups we
have achieved a 25-50% reduction in the salt content of the standard
range of soups used in our business. We have developed a bespoke
baked bean with a 25% reduction in the salt and sugar content
for use in the education and healthcare sectors.
2. CAN THE
WHITE PAPER
PROPOSALS ENABLE
THE GOVERNMENT
TO ACHIEVE
ITS PUBLIC
HEALTH GOALS?
2.1 The White Paper is an important contribution
to raising awareness of the issues affecting public health and
to stimulating debate on possible actions, though the goals are
challenging, require genuine partnership across the public, voluntary
and private sectors and cannot be achieved in one electoral cycle.
2.2 Of particular concern to Compass Group
are those proposals in relation to tackling obesity and healthy
schools.
2.3 We welcome the emphasis in the White
Paper on developing initiatives to bring healthy eating to the
forefront of the debate on how to tackle rising obesity levels
and the acknowledgement of the economic and social costs of failing
to tackle obesity.
2.4 We are also broadly supportive of the
Government's proposals to work with the food industry to improve
the information available to consumers of the nutritional content
of food whilst recognising that even in the Government's own survey,
Public Attitudes to Health, over 88% of respondents agree that
individuals are responsible for their own health. Proposals in
relation to food labelling need to avoid simplistic schemes that
seek to categorise products into good or bad and which do not
emphasise the role of food in a balanced diet and a healthy lifestyle.
We are also concerned that the Government's timescale for implementing
a workable scheme by mid-2005 is too optimistic given the wide-ranging
nature and importance of the proposals.
2.5 Government's acknowledgement of the
role it plays in promoting healthy eating, particularly through
its procurement policies, is also to be welcomed. We have grave
reservations, though, as to whether the Government's objectives
with regard to local sourcing can be met if local authority procurement
managers continue to interpret "best value" as meaning
lowest price and if local is defined within a very narrow context.
We would prefer to see the emphasis being placed on supporting
the wider British food and farming industry rather than on narrow
regional or local definitions.
2.6 The acknowledgement in the White Paper
of the importance of educating young people in relation to diet,
health and nutrition at an early age is to be welcomed. But we
are concerned that there is no mention of the need for structured
food education within the national curriculumembracing
both theory and practiceand would urge the reintroduction
of compulsory cookery classes for all children up to the age of
11. Whilst the Government proposes the introduction of cooking
clubs there is no mention as to how these are to be established
or of the numerous initiatives already being undertaken to help
children prepare and cook food in a healthy way whilst having
fun at the same time. For example, through our specialist education
subsidiary Scolarest, we already operate a scheme called "On
your marks . . . get set . . . cook!" where two teams race
against the clock to create the best healthy meal from mystery
ingredients, each team consists of two pupils working with one
of our chefs. The meals are then on offer in the school dining
room the next day. The cookery demonstration also features a quiz
for pupils in the audience, with food- and health-related questions.
Many of the answers can be found on Scolarest's healthy eating
and lifestyles leaflet which is given out free and includes information
on the best foods for energy, strong bones and healthy skin and
hair, plus general advice on how to eat a balanced healthy diet
and ideas for staying fit through exercise. We also run a Junior
Chef's Academy for 14-16 year-old school children, this is a 15
week programme that covers all aspects of food preparation and
cooking culminating in a four-course lunch prepared for family
and friends as part of a graduation ceremony hosted by a celebrity
chef.
2.7 The Government's commitment to improve
nutrition in schools over the next three years, in particular
to increase the consumption of fresh fruit and vegetables and
to decrease the consumption of fat, sugar and salt, is very welcome.
We are extremely concerned, however, that there is no accompanying
commitment to increase the average food cost per school meal in
order to meet the Government's stated objectives. Even a modest
increase in food cost per meal would have a disproportionate benefit
in terms of a child's long-term health and well-being. The average
food cost of a school meal in a primary school is just 45p. Whilst
this meets the current nutrition guidelines for a relatively modest
increase to 65p more fresh fruit and vegetables could be used
and an increase to 75p would allow organic and locally sourced
products to be used. Any change to nutrient based guidelines would
require additional funding to levels similar to these. Media coverage,
including recent Evening Standard stories on school meals
in North London, often ignores the problems inherent in providing
nutritious meals on very low budgets, and is largely unconcerned
with the reticence of the majority of local councils to invest
adequately in school meals provision. We believe that targeting
children's diets, through a combination of education and improved
school meals, is crucial to tackling the obesity and health issue
in the long-term and ensuring that a real and effective change
in the country's dietary habits is achieved. Furthermore, there
is a wide body of evidence that links a nutritious diet amongst
school-age children with improved levels of academic attainment.
As such, we believe that government activity, through the Food
and Health Action Plan and other forthcoming initiatives, should
be concentrated on this area.
2.8 We are also concerned that there is
a lack of clarity as to how the Government is going to ensure
consistency of message across its various proposals and how it
is going to evaluate their effectiveness in the short to medium
term. For example, whilst the proposals in relation to improving
the nutritional content of school meals is to be applauded it
should be remembered that less than 50% of children eat school
meals and that children eat less than one fifth of their total
meals in a year at school.
3. ARE THE
PROPOSALS APPROPRIATE,
WILL THEY
BE EFFECTIVE
AND DO
THEY REPRESENT
VALUE FOR
MONEY?
3.1 It is extremely difficult to evaluate
either the effectiveness or value for money of the proposals contained
in the White Paper, as there is little detail on which a judgement
can be based. For example, the White Paper talks in broad terms
in relation to for example obesity of ". . . a new cross-government
campaign to raise awareness of the health risks of obesity";
". . . campaigns will operate at a national and regional
level and use creative social marketing techniques and new technology.
They will promote key messages and local services through a variety
of channels, for example, in schools and workplaces as well as
through health professionals." The White Paper also mentions
campaigns being jointly funded by Government and industry, but
again lacks detailed proposals.
3.2 Labelling
3.2.1 There are specific proposals in relation
to food labelling, namely the introduction by mid-2005 of a system
that could be used as a standard basis for signposting foods and
following FSA consumer research a clear, straightforward coding
system by early 2006.
3.2.2 Compass Group has a number of concerns
in relation to labelling. We have already raised our misgivings
about a system that would simply categorise food as good or bad.
Whilst we assume that the thrust of the Government's proposals
relate to packaged foods, research undertaken by the FSA in relation
to signposting and nutrition profiling acknowledges the need to
conduct further research into the application of such a scheme
to the catering and restaurant sectors.
3.2.3 We are extremely concerned that the
thrust of the Government's proposals takes no account of the practicality
or cost of mandating such a scheme to hundreds of thousands of
catering and restaurant establishments of different types, nor
how such a scheme would be administered. Whilst we are broadly
supportive of the objective of improving the nutritional information
available to consumers we believe the Government has failed to
take sufficient cognisance of the effectiveness of initiatives
already being taken across the food chain to help consumers make
more informed choices.
3.2.4 We are also concerned as to how any
signposting or labelling would operate in environments such as
schools in a meaningful and practical way or how schools with
delegated budgets would be able to undertake the analysis required
if they were self- operating their school meals service.
3.2.5 We are sceptical as to whether any
scheme, whether applied to packaged foods or the catering and
restaurants sector, will have any impact if it is not within the
context of a more general campaign to raise public awareness of
the importance of eating a balanced diet, calorific intake, exercise
and guideline daily amounts in relation to fat, sugar and salt.
Consequently Compass believes that the burden of compliance may
fall disproportionately on SMEs and sole traders. In view of this
Compass suggests the Government undertake a Regulatory Impact
Assessment to ascertain the impact of its labelling proposals
before proceeding with them. Compass is also concerned about compliance
verification of the proposal and would like to see more details
of how the Government proposes to achieve this.
3.2.6 The White Paper also fails to acknowledge
that labelling is an EU competency.
3.3 Food and Health Action Plan
3.3.1 Compass Group welcomes the proposal
for a Food and Health Action Plan to co-ordinate and take forward
actions contained in the White Paper, but we are sceptical as
to whether the Government will meet its target of producing the
plan early in 2005. It is unclear in the White Paper the process
that will lead to the production of the report and at the time
of writing there is no indication that consultation with the necessary
stakeholders has commenced. Unless the plan enjoys the support
of all stakeholders, particularly the farming and food industries,
then it will almost certainly fail to meet its objectives.
3.4 Healthy Schools
3.4.1 Compass Group welcomes the link the
White Paper makes between health and education and the commitment
to adopt a whole school approach embracing consistent messages
in relation to nutrition and healthy eating and the provision
of opportunities to learn about all aspects of food. Though we
are disappointed that there is no commitment to make practical
cookery compulsory, as learning how to prepare and cook food is
a key life skill for future generations.
3.4.2 The commitment to invest over the
next three years to improve nutrition in school meals and to revise
school meals standards is particularly welcome, though it is disappointing
that there is no indication of the sum set aside for such investment.
We would welcome clarification from government as to the projected
levels of investment and the form such investment will take. We
are also disappointed that there is not a firm commitment under
these proposals to increase the average food cost per meal or
to invest in the establishment of breakfast clubs, particularly
in disadvantaged areas. Nor is there any acknowledgement of the
need to invest in upgrading school kitchens and equipment to meet
any new requirements. Over the last two decades there has been
chronic under-funding in school kitchens with the consequence
that many are simply not fit for purpose and will not be able
to cope with any step change in requirements eg more food prepared
on site. Furthermore the White Paper appears to take no account
of the additional labour that would be required to prepare meals
if there is to be a greater emphasis on fresh and locally sourced
ingredients. Schools with small pupil rolls in particular are
unlikely to be able to afford additional food costs let alone
increased labour costs.
3.4.3 In secondary schools we are concerned
that no mention is made of the need to ensure that sufficient
time is allocated to lunch so that pupils can enjoy a nutritious
whole meal. In many secondary schools pupils have less than 30
minutes to get from the classroom to the dining hall and back
to class again. Also in many schools there is not sufficient space
or tables and chairs allocated to dining and this discourages
pupils from taking a school meal and almost encourages them to
go outside the school gate at lunchtime.
3.4.4 It is also disappointing that the
introduction of nutrient-based standards for school meals is not
a firm commitment and that the role of Ofsted inspectors in looking
at healthy eating is so poorly defined. As one of the leading
private sector providers of school meals, through our subsidiary
Scolarest, we joined with the Soil Association and Local Authority
Caterers Association (LACA) in September 2004 to press DfES to
adopt such an approach. We believe that nutrient-based standards
are the only way to improve the quality of school meals and drive
up participation levels. Unless school meals are appetising, nutritious
and represent value for money the numbers participating will not
increase. Increased participation, thus reducing the number of
children who bring packed lunches or go off-site, is key to meeting
the Government's objectives. Increased participation also leads
to a direct economic benefit as the relative costs of administration
and preparation are minimised and in time, if participation levels
are sustained, the increase in food cost should become self-funding.
A target for increasing the number of pupils taking a school meal
should have been included in the proposals. The White Paper also
provided an opportunity for the Government to commit to establishing
the link between nutrition, attainment and behaviour. Anecdotal
evidence suggests that there is a clear link and DfES should be
urged to set up a research project to investigate this further.
3.4.5 We also wonder whether the Government
should not have considered the benefits of making meals free for
all primary school children.
3.5 Delegated Budgets
3.5.1 We are concerned that whilst the commitment
to support schools to provide the best meal service possible is
well-intentioned there has been little consideration given to
the possible implications of delegating school meal budgets to
the local level, particularly in the primary sector. There are
a number of concerns here.
3.5.2 First, there is a marked trend amongst
Local Education Authorities to move away from multi-site contracts
for meals to schools managing their own arrangements and budgets.
We are concerned that if no new money is found primary schools
with small pupil rolls will no longer benefit from the "cross-subsidy"
they received from larger schools when LEAs negotiated group contracts
and as a consequence will not be able to provide a school meal
that meets the new guidelines. Loss of such a "subsidy"
may lead to cold sandwich lunches in place of hot meals. For some
children in deprived areas this could remove the one hot meal
they eat regularly every day. A balance needs to be struck between
the benefits of devolving the provision of school meals to the
local level and the disproportionate burden it could impose on
small or remote schools.
3.5.3 Secondly, when companies such as Compass
contract with LEAs, some LEAs impose an administration charge
of as much as 15p per meal on the price paid by parents. This
further reduces the funding left to be spent on meals as the revenue
raised from the administration charge is rarely reinvested in
the school meals service.
3.5.4 Thirdly, head teachers and school
governors need more than just advice on food procurement. They
also need guidance on drawing up tender specifications for a school
meal service, selecting a provider and managing the service. We
would suggest that DfES should work with LACA to produce such
guidance.
3.5.5 Fourth, where LEAs are still managing
school meals contracts there is clear evidence that best value
is still being interpreted as lowest price. This is either a consequence
of a squeeze on school meal budgets or local authority procurement
managers being unable to define what "best value" means
when procuring a service or because there is no requirement to
take into account the long term implications of the decision they
make. For example, a contract in Wokingham was awarded recently
solely on the basis of price with no other factors being taken
into consideration eg nutrient content, local sourcing etc.
3.5.6 Finally, we support improved training
and support for catering staff. Scolarest, our specialist education
subsidiary, has pioneered a unique distance learning healthy eating
qualification for school cooks. Our school chefs and catering
assistants in 1,700 state schools have been enrolled for a new
NCFE Intermediate Certificate in Nutrition and Health which could
be made available to any LEA who wanted to provide such an opportunity
for their staff.
4. DOES THE
NECESSARY PUBLIC
HEALTH INFRASTRUCTURE
AND MECHANISMS
TO ENSURE
IMPLEMENTATION EXIST?
4.1 The White Paper is ambitious, many issues
are addressed and the actions proposed require partnership across
the public, voluntary and private sectors. The key to success
will be ensuring that those actions that are taken forward are
given the time and resources to yield results and are not subject
to political whim.
4.2 In relation to the fight against obesity
Compass Group believe that there are no magic bullets that will
provide a whole population solution. Raising awareness of the
risks associated with obesity is one thing but changing peoples
eating habits is going to take time. We would suggest that particular
focus be given to actions relating to the health and wellbeing
of young people, particularly school children.
5. COMPASS' KEY
RECOMMENDATIONS
5.1 The Government needs to increase the
average food cost per school meal in order to meet its stated
objectives. Currently Compass receives an average of 45p to provide
each primary school meal, imagine trying to buy a nutritious lunch
for 45p from the local supermarket. For only 65p per meal Compass
could provide an extremely healthy nutritious meal with more fresh
ingredients and cooked on site. Compass believes that such a modest
increase in food cost per meal would have a disproportionate benefit
in terms of a child's long-term health and wellbeing. Considering
the public health benefit over a whole life costing this could
amount to a considerable economic benefit for a small investment.
5.2 The Government should undertake a Regulatory
Impact Assessment to ascertain the impact of its labelling proposals
before proceeding with them.
5.3 The Government should reintroduce compulsory
cooking classes.
5.4 Any changes to food labelling and nutritional
information should seek to avoid basic schemes that classify products
as either good or bad and do not emphasise the role of the food
in a balanced diet and a healthy lifestyle.
5.5 The Government should set a target for
increasing the number of pupils taking a hot school meal.
January 2005
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