White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Determining Time Engaged in Lobbying Activities
What Is Lobbying?
Q. I am a Public Affairs Colleague. From time to time, I call congressional staff
members and ask a series of prepared questions to gauge perceptions of
healthcare issues or policy perspectives. Does the amount of time I spend on
those calls factor into the 20% threshold for registering as a lobbyist?
A. It depends. If the questions pertain to the status of legislation affecting Pfizer’s
interests, the calls may have been made in an effort to influence the
congressional members for whom the staff members work, and the calls
therefore would be considered lobbying contacts. If the questions constitute
routine information-gathering and there is not an attempt to influence a
covered official, then the communications will not amount to lobbying
contacts. If you are unsure if your call would count towards the 20% threshold,
please consult your GRD or team attorney. Remember, even if you do not
qualify as a “lobbyist,” you still may need to keep track of your time spent on
some of these types of activities for the Company’s federal lobbying disclosure
report.
The LDA defines “lobbying activities” as lobbying contacts, as defined above, and any efforts in support
of these contacts, including preparation and planning activities, research, and other background work
intended for use in lobbying contacts. Reportable expenses include time spent by Pfizer colleagues in
meetings with federal officials for the purpose of influencing federal laws, regulations or policies, and
expenses incurred in connection with lobbying, such as expenses for travel, lodging or food. The LDA
(as amended by HLOGA) requires Pfizer to file quarterly reports. The reports must provide a list of the
specific issues that were addressed by “lobbying activities” and an estimate of the total expenses
incurred in connection with the lobbying activities.
Although most Pfizer colleagues do not qualify as “lobbyists,” the time Pfizer colleagues spend in
supporting the lobbying efforts of others within the Company is reportable, including:
Developing “talking points” or “white papers” if they are used for lobbying purposes;
Attending internal meetings or discussions regarding lobbying strategy (e.g., identifying
federal officials who should be targeted or developing and testing messages);
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