White Guide and Orange Guide Formatting Project - Pfizer

Foreign Corrupt Practices Act
Orange Guide - Chapter 1: Overview and Key Principles
The Foreign Corrupt Practices Act (FCPA) is a federal law that prohibits corrupt or improper payments
to government officials outside the U.S. The FCPA consists of two primary sections: (1) the anti-bribery
provision and (2) the record keeping provision. Violations of the FCPA may subject Pfizer and its
individual employees to criminal and civil penalties. The anti-bribery section of the FCPA prohibits
U.S.-based companies from offering, paying, promising to pay or authorizing payment of anything of
value to a non-U.S. official with the intent of influencing the official or gaining improper advantage.
The statute broadly includes “anything of value,” which consists of cash payments, gifts, meals or any
other item that may have value to the recipient. Further, the definition of “foreign official” includes any
officer or employee of a non-U.S. government (any department, agency or instrumentality) or public
international organization. HCPs at non-U.S. government-owned hospitals, for example, may qualify
as foreign officials under the FCPA. Under the record keeping requirements of the FCPA, Pfizer and its
employees must “keep books, records and accounts, which, in reasonable detail, accurately and fairly
reflect the transactions and dispositions of the assets… and maintain a system of internal accounting
controls…”
Pfizer colleagues that are permitted to engage a non-US HCP as a consultant (or enter into any other
interaction in which a payment or other benefit may be given to the individual), must follow the Pfizer
FCPA procedures applicable to their Division. For more information, see White Guide Chapter 5: HCP
and Government Official Consulting Engagements and Corporate Policy #215 (International Anti-
Bribery and Anti-Corruption Procedure).
Industry Codes, Guidance, Our CIA and State Attorneys General Agreements
PhRMA Code
The Pharmaceutical Research and Manufacturers of America Code on Interactions with Healthcare
Professionals (PhRMA Code) was developed and adopted by many of the country’s leading research-
based pharmaceutical and biotechnology companies. It applies to relationships with physicians and
other HCPs. Pfizer is committed to following its principles.
The PhRMA Code is intended to protect patients from undue influences on healthcare decision-making
and reaffirms that interactions between company representatives and HCPs should be focused on
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