White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
This only pertains to Pfizer colleagues, and not independent contractors retained by Pfizer. A “lobbying
contact” is any oral or written communication, including e-mail, with certain executive and legislative
branch employees made with regard to federal legislation, a rule, regulation, or any other program,
policy or position of the United States Government. Affected executive and legislative branch
employees include Members of Congress and their staff, the White House, Secretary and Deputy
Secretary positions within the federal agencies, and some members of the military.
Most Pfizer colleagues do not qualify to be registered as lobbyists because they do not spend 20% of
their time “lobbying” during the reporting period (three-month intervals); however, it is important to
remember that even if you are not a “lobbyist,” your time spent supporting the lobbying efforts of
others within the Company is still reportable under federal law.
Calculating Lobbying Contacts
Q. I am a Public Affairs Colleague. I called Congressman A’s office and spoke with
a member of his staff to request the congressman call me back. Two days later,
the congressman returned my call, and I explained I was calling about access to
medication for the elderly, and we set up a time to meet. Does this count as
two “lobbying contacts” for purposes of determining whether I am a lobbyist
under federal law? I thought requesting meetings did not count as lobbying?
A. This would likely count as one lobbying contact. The purpose of your first call
was to contact the congressman, which you were unable to do. On the second
call, however, you did speak with the congressman, and you explained the
purpose of your call, which was to discuss some aspect of federal law or policy.
While you did call to set up a face-to-face meeting, you also discussed policy
issues during the telephone call. The two telephone calls would be considered
one lobbying contact and the in-person meeting would count as a second
lobbying contact.
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