White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Chapter 4: FEDERAL EMPLOYEE INTERACTIONS
AND LOBBYING
Introduction
This Chapter focuses on: (a) the important rules you must understand and follow when engaging in
promotional and non-promotional activities with the Department of Veterans Affairs (VA), Department
of Defense (DoD) and other federal employees; and (b) summarizes certain key Pfizer policies regarding
lobbying registration and disclosure. This Chapter is relevant to any colleague who interacts with
healthcare professionals (HCP) employed by the federal government (including interactions with any
HCP employed by the VA or DoD) or engages in lobbying activities with any elected or appointed state
or federal government official or public employee (including state Medicaid agency employees and
public hospital and government HCPs).
Each Colleague is responsible for adhering to Pfizer's policies regarding interactions with federal
employees and lobbying activities involving federal or state government officials and public
employees. Non-compliance with these policies puts the Company at risk and can subject
Colleagues to disciplinary action up to and including termination.
Federal Employee Interactions
As Pfizer’s sales to the federal government continue to increase, interactions with government officials
(e.g., Director of Medicaid) and government employees (e.g., a physician at a federal institution or at a
federal prison) are becoming common. Pfizer’s customers include federal government agencies and
institutions, including the VA and its hospitals, and the DoD and its medical facilities. Pfizer colleagues
may interact with HCPs who work for these government agencies and institutions and who are
employees of the federal government.
Interactions with federal employees are governed by the Standards of Ethical Conduct established by
the Office of Government Ethics (“Standards of Ethical Conduct”) as well as the local site policies of
each institution. In the case of VA employees, your activities are even further restricted by the more
specific rules contained in Veterans Health Administration Handbook 1004.07 (“Financial Relationships
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