White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Key Points to Ensure Compliance
Only RC-approved nominally-priced educational materials may be provided to a government
HCP.
Government officials may be given RC-approved educational materials only—gifts of any
value, including meals, are prohibited.
Public employees may be given approved educational materials subject to each institution’s
policies and applicable law.
Every communication with a government official or his or her staff must be coordinated
through the relevant GRD.
Sales Colleagues should spend no more than one hour per week or four hours per month, if at
all, on political activities related to Pfizer business.
Do not suggest, offer or provide campaign contributions in exchange for a promise to perform
any official act.
Pfizer must report certain expenditures made towards lobbying efforts to the federal
government as well as many state governments.
Even if you are not a “lobbyist,” your time spent supporting the lobbying efforts of others
within the Company is reportable under federal law.
Each state’s reporting requirements are different – be sure to check with your Government
Relations Director or team attorney if you are unsure whether you need to register as a
lobbyist and/or which activities must be reported.
For more information on state specific restrictions on interactions with state-employed HCPs,
see the State Laws: HCP and State Employee Restrictions Chapter.
Who Is a “Lobbyist”?
Under the federal law, a “lobbyist” is any individual who is employed by Pfizer and has: (1) made more
than one “lobbying contact” within a three-month period; and (2) spends at least 20% of his or her time
engaged in lobbying for Pfizer in that three-month period.
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