To develop and apply a theoretical framework to assess the rigour of a district health organisation's response to the commercial determinants of health (CDoH).The multi-method study incorporated literature reviews of CDoH strategies and ways in which organisations can respond; policy document review; and 12 qualitative, semi-structured, key informant interviews.A theoretical framework was developed summarising CDoH and potential responses. The organisation has relevant policies, including those concerning corporate relationships and conflict of interest; however, there are opportunities to strengthen policy content and processes. Key themes were identified based on key informants' perceptions: 1) disconnect between community impacts of harmful commodities and awareness/action on CDoH drivers of these impacts; 2) power imbalance between harmful commodity industries and communities; and 3) need for a robust, values-based, Tiriti-aligned response to CDoH.The health sector has an important role to play in redressing the power imbalance between harmful commodity industries and communities. Responses include: raising awareness about CDoH; strengthening policies related to interactions with corporations, and in particular considering alignment of values; supporting community actions; and advocating for legislative changes which restrict the power of harmful industries and support healthy environments and communities.