White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 3: Support of External Organizations
Key Points to Ensure Compliance
Colleagues in the U.S. Biopharmaceutical Business (including Sales), Pfizer Medical (formerly
called the CMO division) and PEAC groups may fund sponsorships that provide an appropriate
“tangible benefit” (as defined later in this Chapter) to Pfizer.
Any funding request that does not include a “tangible benefit” will not be treated as a
sponsorship but rather as a charitable contribution. Charitable contributions are not eligible
for funding by Sales Colleagues. Select non-Sales Colleagues are permitted to make certain
narrowly defined charitable contributions in accordance with the policies outlined in this
Chapter.
External organizations will often submit funding requests using key terms (e.g., “charitable
contribution”, “grant” and “sponsorship”) interchangeably and inconsistently. Pfizer
colleagues must identify the substantive nature of each request based on Pfizer definitions to
ensure that it is a type of request they are permitted to fund.
Only provide funding based on the merits of the request and never: (i) as a “quid pro quo” to
inappropriately influence the formulary positioning, recommendation or increased
prescribing of a Pfizer product; or (ii) to gain improper favor with a healthcare professional,
government official or any other individual or organization.
Never provide individual HCPs or group practices with non-research grant funding or
donations unless approved in advance by the relevant Chief Counsel or Compliance Counsel.
Never link charitable funding to a commercial transaction or interaction.
Never provide funding to an organization in a manner that undermines the organization’s
independence or mission, or for capital support or “start up” costs.
Never provide funding for any activity that may result in off-label promotion of Pfizer
products or where there is a likelihood that treatment options will not be presented in a fair
and balanced manner.
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