Background:
FCTC Article 5.3 requires protection against tobacco industry interference in policy-making. By contrast, manufacturers of alcohol and ultra-processed food and drink products are often identified as potential partners in multi-sectoral health initiatives, including via the Sustainable Development Goals (SDGs). This divergence has been questioned given evidence of strategic similarities across sectors, to which this presentation adds an examination of structural links and their implications for health policy. This focuses on an analysis of 'interlocking directorates', via which directors of one organisation also occupy positions on different boards, widely as the principal indicator of network ties across corporations.

Methods:
Using data from corporate websites, annual reports and business databases, we employ UCINET social network analysis software to examine interlocks in the top six transnational companies of each sector within and across tobacco, alcohol and food companies, with political elites, and with health and development agencies.

Results:
We present findings via (i) profiles of individual tobacco industry directors, highlighting strategically valuable links to other actors; (ii) a quantitative comparison of interlocks across the three sectors, with no direct links between tobacco and food companies but with alcohol companies providing several bridges between them, and with food companies more extensively linked to political elites and health agencies; (iii) a case study of the board of brewing giant SAB Miller at the time of its mega-merger with AB InBev to highlight the significance to tobacco control of wider interactions enabled by interlocks.

Conclusions:
This account of linkages across tobacco, alcohol and ultra-processed food companies calls into question regulatory approaches that treat the tobacco industry as an exceptional case. Neglecting conflicts of interest with other unhealthy commodity producers is potentially damaging to efforts to implement Article 5.3. This highlights important opportunities for efforts to promote policy coherence for NCDs and advancing the SDG agenda.