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White Guide and Orange Guide Formatting Project - Pfizer

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<strong>Orange</strong> <strong>Guide</strong> – Chapter 4: Federal Employee Interactions <strong>and</strong> Lobbying<br />

Before seeking to engage a speaker who works in any capacity for a federal government agency or<br />

institution, Sales Colleagues must first verify that the speaker has received prior approval from their<br />

agency or institution.<br />

Engaging Part-Time Government Employees as Speakers<br />

Q. May I engage an HCP that works part-time at a federal government institution<br />

to be a speaker?<br />

A. Yes, provided the conditions listed above are met. HCPs who work part-time<br />

for a federal government agency are still required to follow the policies of that<br />

agency as if they are full-time employees. Of course, all of <strong>Pfizer</strong> policies<br />

related to engaging HCPs as speakers <strong>and</strong> properly conducting speaker<br />

programs must be followed.<br />

Supporting Independent Medical Education<br />

Federal government agencies <strong>and</strong> institutions often ask <strong>Pfizer</strong> to support their independent medical<br />

education programs. <strong>Pfizer</strong> may be permitted to support these activities through unrestricted<br />

educational grants. Grant requestors must submit all requests for funding through<br />

www.pfizermededgrants.com. Requests will be reviewed according to <strong>Pfizer</strong>’s st<strong>and</strong>ards for supporting<br />

independent medical education. For more information on <strong>Pfizer</strong>’s educational grant process, see the<br />

Support of External Organizations Chapter.<br />

Lobbying<br />

Federal <strong>and</strong> state lobbying laws regulate interactions with government officials <strong>and</strong> public employees<br />

that are intended to influence legislation, regulations or government policies. <strong>Pfizer</strong> is required by<br />

federal law <strong>and</strong> many state laws to publicly disclose its lobbying expenditures on a regular basis.<br />

Federal Lobbying<br />

In 2007, Congress amended the Federal Lobbying Disclosure Act (LDA) in an effort to make lobbying<br />

activity <strong>and</strong> expenditure disclosure more transparent. Although the requirements of what must be<br />

disclosed remain largely the same, the Honest Leadership <strong>and</strong> Open Government Act (HLOGA)<br />

increased the number of times reports must be filed from twice a year to four times a year.<br />

83<br />

Rev. 09/12<br />

Page 13 of 25

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