White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure
Colleagues Permitted to Host Non-Speaker Program Restaurant Meals
Q. The PhRMA Code states that meals (except for speaker programs) offered in
connection with presentations by Sales representatives and their immediate
managers should be limited to in-office or in-hospital settings. Does that mean
that all colleagues who meet with customers are prohibited from providing
these types of presentations in restaurants?
A. No. The following senior Sales Colleagues may host modest restaurant meals
with HCPs at appropriate venues if there is a “legitimate business reason” to do
so: Regional Managers, Regional Directors, and Regional Presidents. Non-
Sales colleagues, such as Marketing, are likewise permitted to provide
restaurant meals subject to the same standard. Meanwhile, the following
colleagues may host restaurant business meals for non-HCPs and HCP
customers who do not treat patients: Account Managers, Directors, Employers,
Key Account Managers (formerly Customer Alliance Directors), and Alliance
Development Managers. Finally, the following colleagues are prohibited from
providing restaurant meals to HCPs outside of speaker programs: Healthcare
Representatives, Therapeutic Specialty Representatives, District Managers,
Clinical Specialists, and all other Sales Colleagues who either call on HCPs or
who supervise colleagues who call on HCPs.
Sales Representatives Attending Non-Speaker Program Restaurant Meals
Q. May a Sales representative or District Manager attend a restaurant meal with a
customer that is hosted by an appropriate colleague?
A. Yes. Representatives and DMs may attend meals that are hosted by an
appropriate colleague (e.g., restaurant meals hosted by RMs and RDs at
conventions or congresses), as long as they do not use the meal as an
opportunity to conduct activities or events that they cannot host on their own.
Q. May a Sales representative or District Manager attend a restaurant meal with
an HCP if the parties each agree to pay their own way?
A. No. The spirit of the PhRMA Code is to help address perceived and real
conflicts of interest. Continuing to provide information in restaurants, even if
we are not paying the bill, does not help to address these perceptions.
Meals Provided by Senior Sales Colleagues and Headquarters Colleagues
While all colleagues are subject to the general rules and restrictions set forth at the beginning of this
section, the PhRMA Code restriction on restaurant meals is not applicable to senior Sales Colleagues
above District Manager level or non-Sales colleagues. These colleagues, including Marketing, may
293
Rev. 09/12
Page 9 of 21