In this paper the author implies that there is no hard evidence demonstrating consistent violations of the International Code by the baby food industry, despite the regular monitoring reports published by the International Code Documentation Centre (ICDC) (http://ibfan.org/ icdc/). And it must be pointed out that there is more than ‘an assumption’ that the baby food industry plays a part in decreasing breastfeeding rates. Studies have found that when frequency of adverts for artificial feeding increased, percentage change in breastfeeding rates decreased, while a 2006 review by the US Congressional Accountability Office found a majority of studies that examine giving free formula samples to mothers at hospital discharge found lower breastfeeding rates among mothers receiving samples. No one denies that the Code includes recommendations for stakeholders other than the baby food industry. There is also no argument that some of these stakeholders have failed as duty bearers to protect the best interest of the child. But when it comes to unethical marketing and the ensuing harm to infant and young child health, the fault must lie solely with industry. What the author describes as a ‘systematic deficiency’ in a ‘multi-stakeholder’, ‘multi-layered process’ is no excuse for the baby food industry to not comply with the minimum standard set by the International Code. Forward looking companies recognise that compliance is the price of doing business and are developing governance, risks and compliance initiatives to ensure greater corporate accountability. The baby food industry should not be looking for excuses or soft alternatives where Code commitments are concerned. FTSE4Good is one glaring example of a soft alternative. While the author points to it as an interesting initiative addressing governance of infant formula manufacturers through its breastmilk substitute criteria, many critics point out that the FTSE4Good criteria were actually weakened to allow a well-known Code violating company like Nestle to gain access to this ethical investment index, while still engaging in marketing practices prohibited by the Code. Just like Nestle (and lately Danone), the FTSE criteria now introduce a false distinction between high-risk countries (those with at least 10 per 1000 under five mortality rate) where they require an ‘acknowledgement that the adoption and adherence to the Code is a minimum requirement’ and the rest of the world where they don’t. The author endorses the Nestle/Danone /FTSE approach on the assumption that global infant feeding policy is oriented towards the poorest of nations and finds it illogical that all nations should commit to the same recommendations. This is contrary to the World Health Assembly’s position that the International Code is global and applies in all countries, since parents and infants in industrialised countries deserve the same level of protection from inappropriate and unethical marketing as those in developing nations. Interestingly, the author ignores the 2012 UNICEF-commissioned report from his own country which shows that low breastfeeding rates in the UK lead to an increased incidence of illness with significant cost to the health service. Even a moderate increase in breastfeeding rates could save £40 million in the UK health budget. If that is not considered significant for a policy review on Code implementation, one can only speculate as to what interests are at play. See also Pediatircs which reported that if 90% of US families comply with recommendations to breastfeed exclusively for 6 months, the US would save $13 billion and prevent more than 911 deaths per year.