Who funds the WHO Foundation? A transparency analysis of donation disclosures over the first 3 years of its operation

Discussion

This is the first analysis of funding disclosures by the WHOF by time period, donor type, amount and programme. It identifies several key findings. First, on transparency, we find a reliance on a few, larger, anonymous donations over time, with named donors increasingly in the minority by value. Nearly 80% of funds donated in January–December 2023 were from anonymous sources and in amounts of over US$100 000. In our analysis applying a modified version of Open Democracy’s ‘Who Funds You’ rubric, results suggest that in 2023, the WHOF’s funding transparency is similar to that of the Institute of Economic Affairs or the Legatum Institute in the UK; organisations characterised as ‘dark money’ think tanks.30 Second, on earmarking, the data indicate increasing earmarked funding going to the running costs of the WHOF, rather than in support of specific WHO programmes, or flexibly funding the WHO itself. Over time, an increasingly substantial proportion of overall funds received has been earmarked as WHOF operational support, rather than flexible funding, or earmarked funding to support specific WHO initiatives. This included single large anonymous donations to WHOF operational support, including an anonymous donation of over US$11 million in 2023. The analysis also identified a shift in the range of programmes funded during the time periods, reflecting a high (in donations and diversity of donor sources) during the pandemic, with the largest programmes being the COVID-19 vaccine-directed Go Give One and the COVID-19 Solidarity Response Fund, the latter having the most diverse funding pool in terms of range of contributors, towards fewer programmes receiving fewer, smaller donations in the latest disclosures. Critically, while transparency in disclosures decreased, and the diversity of programmes funded narrowed, both the overall donation amounts and those designated to supporting specific WHO initiatives were of a very small and decreasing scale, relative to the size of the WHO biennial budget.

This study has several important limitations. First, our findings are dependent on the accuracy of the disclosure files available on the WHOF website. As noted in the relevant documentation, these are not actual financial statements, but rather, voluntarily disclosed information on donations and linked programmes. Moreover, our analysis was limited by the level of detail provided. While the donations were disclosed according to the calendar year in which they were contributed, they do not include specific time frames or dates. It is therefore not possible to make direct comparisons to financial year reporting of overall contributions or of specific programme activities. Due to a lack of available information, we cannot assess the nature of individual partnership agreements, or the extent to which these were led by or initiated as a result of WHOF priorities, individual donor priorities or a combination thereof. However, in a context of very limited information, this study represents a novel addition to the literature regarding the scale and nature of funding disclosures in what remains a new and contested model of WHO-related funding with potentially significant legitimacy implications for the organisation and for global health. These limitations themselves serve to illustrate the challenges in assessing trends, earmarking and implications for accountability when donation disclosures and the processes by which earmarked funds are negotiated are not fully transparent.

While donor earmarking towards specific WHO priorities decreased over time in favour of WHOF operational costs, our analysis of trends in funded programmes identified large inequalities in such earmarking, with donor emphasis on funding of specific initiatives, such as vaccination, or in specific contexts, such as Ukraine (eg, rather than Libya or Sudan). This raises concerns consistent with wider critiques of vertical approaches, donor conditionality and efficiency of allocation and earmarking in the context of global health initiatives. A long-held critique of the rise of multilateral funds and bilaterally arranged health initiatives has been that donor priorities (often for vertical, specific, technology-focused initiatives with measurable outcomes) take precedent over the national plans, priorities and needs of individual countries,32 and emphasise responding reactively to specific high-profile needs over sustained, broad capacity building, a pattern observed most recently in the context of Pandemic Fund deliberations.33

The disclosures that are made do in some cases suggest strategic alignment with donor priorities, particularly as it relates to private companies. For example, Meta was disclosed as funding the WHO department of communications and digital health, both areas in which large social media companies have faced public scrutiny due to their potential role in facilitating misinformation, including health misinformation,34–36 and ongoing debates regarding their role in child and adolescent mental health.37 The relevance of concerns around health misinformation and disinformation may have further increased following the announcement from Meta in early 2025 that it was ceasing the use of independent fact-checking in content moderation.38 The announcement by the new US administration of withdrawal from the WHO also creates a dynamic in which the WHOF is soliciting and receiving funds from companies such as Meta, while said companies also provided political donations to the political leadership which defunded the WHO itself.16

Considering the number and proportion of large anonymous donations, particularly those that go directly to the WHOF, it is difficult to assess the potential for associated conflicts of interest. Such difficulties apply whether in terms of forming longer lasting dynamics of bias or dependence for the WHOF (considering the scale of funding towards WHOF operating costs), or of assessing the potential conflicts of interest from the perspective of donors, particularly considering the broad nature of the programmes of work proposed as future priorities by the WHOF. For example, climate change is among the key priorities announced for WHOF,19 but as fossil fuel companies are not mentioned in the foundation’s gift policy, it is not possible to know whether fossil fuel, energy, petrochemical and related industries are specifically excluded from donating, or are donating currently. The BP Foundation was previously a donor to the COVID Solidarity Fund.2

Such gaps in disclosure occur in a wider context in which the commercial determinants of health are increasingly acknowledged as key drivers of global health inequalities,39 40 not only through the production and sale of harmful products,41 but through corporate political activities13 and the strategic use of corporate social responsibility initiatives and partnerships as a way of preventing future regulation and therefore protecting future growth.42–45 In the context of developing actions to address the commercial determinants, DG Tedros has therefore emphasised the need for health governance to ‘focus on imbalances of power’ and prioritise ‘equity, accountability, and precaution’.46 Such concerns to ensure effective governance in interactions with the private sector seem hard to reconcile with the WHOF promoting ‘unparalleled access to WHO’ to its corporate partners, and with the strikingly limited levels of transparency regarding donors documented above. Particularly in light of recent changes to global health funding and the recent launch of the ‘One Dollar, One World’ Campaign which explicitly seeks small donations as a way of showing solidarity to the WHO in the wake of the USA withdrawing membership,47 there is an urgent need to develop more effective mechanisms for transparency and accountability in such international organisations. The adaptation of existing transparency tools, as in the current study, and their use in grading transparency across greater numbers of such organisations could help identify examples of best practice, as well as areas of greatest concern.

In summary, this analysis of WHOF donor disclosures indicates levels of donor transparency akin to oft-criticised free market think tanks, with attendant risks for both undue influence and/or reputational damage for the WHOF, and by extension the WHO, including in relation to commercial determinants of health. This is particularly the case given the emphasis WHOF places on their close ties with WHO. Such risks appear to have been undertaken for what to date constitute relatively negligible financial benefits to the WHO, much of which follows donor, rather than WHO, priorities.

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