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To: Chairperson, Health Professions Council of South Africa (HPCSA)
A Call for the HPCSA to Investigate Potential Conflicts of Interest in the Tobacco Bill Debate
We, the undersigned civil society organisations, health professionals, academics, researchers and concerned members of the public health practitioners, respectfully request that the Health Professions Council of South Africa (HPCSA) consider whether the conduct of a registered medical practitioner participating prominently in parliamentary deliberations on the Tobacco Products and Electronic Delivery Systems Control Bill raises professional and ethical issues warranting investigation under the Health Professions Act, the Ethical Rules and the HPCSA Ethical Guidelines.
This request is made to protect public confidence in the medical profession and the integrity of evidence-informed public health policymaking. It is not intended to interfere with parliamentary processes, restrict legitimate political debate, or prescribe how Members of Parliament should exercise their constitutional responsibilities. Nor does it seek a predetermined finding against any individual practitioner.
Rather, it asks a narrower but fundamentally important question: What ethical responsibilities attach to registered health professionals when they invoke the authority of their professional qualifications while participating in national public health policymaking?
Health professionals increasingly serve in Parliament, provincial legislatures, government departments, statutory councils and other leadership positions. Their participation strengthens public policy and should be encouraged. However, professional registration carries continuing ethical responsibilities that extend beyond clinical practice.
Health professionals increasingly serve in Parliament, provincial legislatures, government departments, statutory councils and other leadership positions. Their participation strengthens public policy and should be encouraged. However, professional registration carries continuing ethical responsibilities that extend beyond clinical practice.
The public accords particular credibility to registered medical practitioners because they are expected to exercise independent professional judgement, communicate scientific evidence honestly and transparently, and remain free from inappropriate commercial influence. When practitioners speak on matters of national health policy while relying on their professional credentials, they do so with an authority derived not only from elected office but also from the trust placed in the medical profession.
The HPCSA itself recognises that the practice of the health professions is "a moral enterprise", requiring lifelong commitment to ethical practice and service to society. Protecting that public trust is one of the Council's most important responsibilities.
Why is this important?
Jurisdiction of the HPCSA
Questions may arise as to whether the HPCSA has jurisdiction where a registered practitioner is simultaneously serving in political office. We respectfully submit that it does.
Questions may arise as to whether the HPCSA has jurisdiction where a registered practitioner is simultaneously serving in political office. We respectfully submit that it does.
Professional registration carries ethical obligations that are not suspended by election or appointment to public office. The Council has previously exercised disciplinary jurisdiction over registered practitioners serving in political office, demonstrating that holding such office does not remove a practitioner from the ethical standards of the profession. While the factual circumstances of that matter differ from those raised here, the underlying principle is clear: political office does not exempt registered practitioners from professional accountability. Accordingly, this request concerns professional conduct, not parliamentary privilege or political opinion.
Why tobacco control requires particular ethical vigilance
This matter warrants particular attention because it concerns tobacco control. Unlike most areas of public policy, tobacco control is governed by the WHO Framework Convention on Tobacco Control (WHO FCTC), an international treaty ratified by South Africa. Article 5.3 requires Parties to protect public health policies from the commercial and other vested interests of the tobacco industry, recognising the industry's long and well-documented history of misleading policymakers, funding favourable research, creating front groups and influencing public discourse.
For this reason, transparency, independence and careful management of actual, potential or perceived conflicts of interest are especially important whenever registered health professionals participate in tobacco-control policymaking.
Why the present circumstances warrant consideration
The present request arises from the public conduct of Dr Kgosi Letlape, a registered medical practitioner, former President of the HPCSA and current Member of Parliament serving on the Portfolio Committee considering the Tobacco Products and Electronic Delivery Systems Control Bill.
The present request arises from the public conduct of Dr Kgosi Letlape, a registered medical practitioner, former President of the HPCSA and current Member of Parliament serving on the Portfolio Committee considering the Tobacco Products and Electronic Delivery Systems Control Bill.
The combination of these roles is significant. His medical qualifications and former leadership of the HPCSA inevitably lend additional authority and credibility to his public statements concerning tobacco regulation. That authority carries corresponding ethical responsibilities.
For 10 years, Dr Letlape spoke at the annual tobacco-industry-funded Global Tobacco Nicotine Forum[1]. In 2021, he admitted that he had been consulting with the tobacco industry [2]. That same year he was appointed Commissioner for a commission funded by the Philip Morris-funded Foundation for a Smoke-Free World [3]. Dr Letlape co-founded and currently presides over the African Harm Reduction Alliance, an alliance made possible by Health Diplomates, a consultancy working with British American Tobacco subsidiary Nicoventures. Health Diplomates funded the African Harm Reduction Alliance and manages its website. Just Managing Consulting, a grantee of the Philip Morris-funded Foundation for a Smoke-Free World, produced a report for the African Harm Reduction Alliance [4]. The CEO of the African Harm Reduction Alliance is Delon Human, a South African doctor who has collaborated with British American Tobacco [5]. These publicly documented relationships raise legitimate questions about transparency, professional independence and the management of actual or apparent conflicts of interest that warrant investigation.
For 10 years, Dr Letlape spoke at the annual tobacco-industry-funded Global Tobacco Nicotine Forum[1]. In 2021, he admitted that he had been consulting with the tobacco industry [2]. That same year he was appointed Commissioner for a commission funded by the Philip Morris-funded Foundation for a Smoke-Free World [3]. Dr Letlape co-founded and currently presides over the African Harm Reduction Alliance, an alliance made possible by Health Diplomates, a consultancy working with British American Tobacco subsidiary Nicoventures. Health Diplomates funded the African Harm Reduction Alliance and manages its website. Just Managing Consulting, a grantee of the Philip Morris-funded Foundation for a Smoke-Free World, produced a report for the African Harm Reduction Alliance [4]. The CEO of the African Harm Reduction Alliance is Delon Human, a South African doctor who has collaborated with British American Tobacco [5]. These publicly documented relationships raise legitimate questions about transparency, professional independence and the management of actual or apparent conflicts of interest that warrant investigation.
Publicly available information raises questions regarding:
- the disclosure and management of actual, potential or perceived conflicts of interest arising from reported associations with organisations linked to tobacco-industry funding;
- the timing and adequacy of disclosure of such interests during parliamentary deliberations affecting tobacco industry commercial interests;
- the accuracy and completeness of certain public statements concerning the Tobacco Products and Electronic Delivery Systems Control Bill; and
- whether public advocacy undertaken while invoking professional authority complied with the standards of integrity, scientific accuracy, transparency and independence expected of registered medical practitioners.
These questions are not raised to presume misconduct. Rather, they are presented because they appear sufficiently important to warrant independent consideration by the statutory body entrusted with regulating professional conduct.
Our request
We respectfully request that the HPCSA:
- Undertake a preliminary assessment of the matters outlined in the accompanying evidence memorandum and determine whether a formal professional conduct investigation is warranted.
- Clarify the ethical obligations of registered health professionals who participate in public policymaking while relying upon their professional qualifications and standing.
- Provide guidance on disclosure and management of actual, potential or perceived conflicts of interest involving commercial entities whose products are the subject of public health legislation.
- Reaffirm the profession's commitment to scientific integrity, transparency, professional independence and protection of public trust.
Conclusion
The issue before the Council extends beyond one practitioner or one piece of legislation. It concerns the standards expected whenever registered health professionals participate in shaping public policy. The precedent established in this matter will influence future engagement on tobacco control and many other commercial determinants of health, including alcohol, ultra-processed foods, pharmaceuticals and emerging technologies.
South Africans rightly expect health professionals to place the interests of patients and the public above commercial interests. We respectfully submit that this is an appropriate opportunity for the HPCSA to reaffirm those principles and strengthen public confidence in the medical profession.
Yours faithfully,
National Council Against Smoking (NCAS), South Africa
South African Tobacco-Free Youth Forum
amandla.mobi
National Council Against Smoking (NCAS), South Africa
South African Tobacco-Free Youth Forum
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