White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Fees paid to outside consultants for analyses, studies or reports, if they are used for
lobbying;
Communicating with government officials as part of Pfizer’s grassroots lobbying programs;
Negotiating contracts with government agencies;
Providing educational information or materials to influence government formulary
decisions; and
Promotional interactions with certain state hospital administrators or HCPs.
The federal definition of lobbying does not include:
Drafting and developing comments to proposed regulations in a formal agency rulemaking
proceeding;
Representing Pfizer in an agency adjudicatory matter or criminal proceeding;
Drafting legislation, regulations or legal analyses (applicable to attorney work-product only);
Preparing for and providing “on the record” testimony in a congressional or agency hearing;
Requesting a meeting with a congressional or agency official or his or her staff, if the request
does not include an attempt to influence the official; and
Responding to a request by an official for reports, information, statistics, subpoenas or
similar documents.
Pfizer’s grassroots lobbying programs include Pfizer in Action, Congressional District Captains, and
certain other programs aimed at influencing the environment. There may be other activities developed
by a State Action Team (formerly called the State Resource Team) or the Regional Council that involve
interaction with government officials or public employees and would be subject to the Pfizer policies in
this Chapter.
To help ensure that Pfizer complies with all registration and reporting requirements, all of your
interactions with government officials must be coordinated through a GRD. If calling on HCPs who
work for a state or federal facility or institution, check with your team attorney to find out whether your
promotional activities are considered “lobbying” in your state.
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