White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
the hosting colleague and with approval the colleague’s manager. In order to qualify as a “widely
attended gathering” under Pfizer guidelines and the rules of the Office of Government Ethics:
Attendance at the speaker program must be open to non-federal employees;
A large number of people must be expected to attend;
Persons with a diversity of views or interests must be expected to attend (e.g., persons from
more than just one practice, specialty area, or government agency); and
The government agency or branch the employee works for must determine that his/her
attendance will further agency programs and operations.
In addition, the meal must be provided in connection with a legitimate educational speaker program
that:
Satisfies Pfizer’s standards for a speaker program as set forth in Orange Guide Chapter 9:
Speaker Programs for HCPs; and
Is not offered on a regular or repeated basis to the HCP.
If you are ever in doubt as to whether an event satisfies the “widely attended gathering” standard,
check with the ethics counselor for the relevant government branch, and/or contact the relevant
Regional Attorney. If an HCP you know to be an employee of the federal government indicates (by
formal RSVP or otherwise) that he or she is coming to a speaker program you are planning, you must
confirm with that HCP that his or her agency or branch has determined that attendance at the program
is in the branch’s interest.
Lunch and Learn
Q. A Sales representative would like to call on an HCP employed by the VA who
has a busy schedule. Because of her crowded schedule, the HCP has offered to
meet with the representative during her lunch hour every other Tuesday. May
the representative have a “lunch and learn” with the HCP on alternating
Tuesdays and bring a modest lunch, such as a sandwich and soda?
A. No. Under the new VA Rules, you are prohibited from providing a meal to VA
employees, even if the office staff gives approval for you to do so.
80
Rev. 09/12
Page 10 of 25