White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 19: Sales Activities: Greenstone and Pfizer Injectables
Key Points to Ensure Compliance
Never engage in any actual or perceived quid pro quo. Anything given to or received from a
customer must be considered in light of anti-kickback laws as well as Pfizer’s corporate
policies.
Any payment or gift to customers may implicate pricing and discount considerations.
Any items you provide to customers must be Review Committee-approved and comply with
the policies in this Chapter.
All meals, including meals provided in conjunction with any customer or other meeting, must
adhere to the policies in this Chapter.
The proper process must be followed when purchasing exhibit or display space at a
conference, trade show, or other event in accordance with this Chapter.
Never Engage in Actual or Perceived Quid Pro Quo
Anti-Kickback Laws
Quid pro quo is Latin for “this for that.” This means offering or appearing to offer any remuneration or
item of value in exchange for purchasing, prescribing, dispensing, or formulary acceptance. The
decision of an HCP to prescribe, recommend, or dispense a Pfizer product must be based on the best
interests of the patient and not on any item of value offered to the prescriber.
This principle governs the relationships between Greenstone and Pfizer Injectables and their
customers. Any remuneration from a manufacturer provided to a purchaser that is expressly or
impliedly related to the purchase of a Greenstone or Pfizer Injectables product potentially implicates
the anti-kickback laws. Providing a donation or any funding, including sponsoring any customer event,
also may implicate the anti-kickback laws. This includes charitable contributions if the contribution is
given to a customer or a charity affiliated with a customer as well as donations to patient awareness
programs run by customers.
Please review the Overview and Key Principles Chapter for more information on the anti-kickback laws.
308
Rev. 09/12
Page 3 of 12