White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide - Chapter 18: Meals, Educational Items, and HCP Payment Disclosure
provide modest food or beverages to HCPs in restaurants or other appropriate venues (such as Pfizer’s
offices) as long as there is a “legitimate business reason” for hosting the meal. (While Sales
representatives and their immediate managers may attend meals hosted by such colleagues, they
should not use them as a means to conduct activities or events that they cannot host on their own.
Further, for all Sales Colleagues, it is presumed that discussions regarding unapproved indications for
Pfizer products, or disease state or treatment areas for which Pfizer has no product, are impermissible
and thus cannot constitute a “legitimate business reason” for an HCP meal interaction. Sales
Colleagues should consult with their Regional Attorney with any questions regarding whether the
topic(s) to be discussed at proposed HCP meal are appropriate.)
In order to determine whether the “legitimate business reason” requirement is satisfied, these
colleagues should determine whether the proposed interaction and meal is consistent with their role
and responsibilities and whether the interaction helps them satisfy (in a legitimate way) their goals and
objectives. The central focus must be the business interaction, with the meal being incidental to that
primary purpose. At all times, colleagues must exercise sound judgment and discretion when providing
meals in conjunction with a business interaction. Any questions about whether a meal can be provided
to an HCP should be directed to the relevant team attorney.
Legitimate Business Reason
Educational Items to HCPs
Q. Pfizer is hosting a promotional booth staffed by Marketing Colleagues at a
medical conference. Can a Marketing Colleague take a group of physicians out
to a restaurant meal to discuss new Pfizer RC-approved data on a Pfizer
product?
A. Yes. This would be considered a “legitimate business purpose” since it is
certainly permissible for Marketing Colleagues to discuss RC-approved content
with HCPs so long as they adhere to the Four Core Compliance Principles.
Marketing colleagues may continue to provide a modest meal incidental to the
discussion (unless restricted by state law). For more information, see the
Chapter on State Laws: HCP and State Employee Restrictions.
In accordance with the PhRMA Code and Pfizer policy, RC-approved educational items valued at $100
or less may be provided on occasion to HCPs or members of their staff. Non-educational items are
prohibited from being offered, even if the items are practice-related and of minimal value (such as
294
Rev. 09/12
Page 10 of 21