White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
later than one week after the close of the reporting period, or by April 7th, July 7th, October 7th,
and January 7th.
Determining Time Engaged in Lobbying Activities
Q. When I fill out Pfizer’s lobbying form, I have to include the issue that pertained
to the lobbying efforts I supported. If the work I did was about a particular
Senate bill, can I just write the bill number?
A. No, while the bill number must be reported under the law, the number alone is
not a sufficient description of the issue for purposes of disclosing Pfizer’s
lobbying contacts and filing the Federal report. You should try and be as
specific as possible, and include, in addition to the bill number, the bill’s name,
the bill title and/or section heading if one exists, and the specific provisions that
were the subject of your work.
If ever in doubt, consult with a GRD or your team attorney to verify whether your activities subject
you to registration or reporting requirements.
Gifts to Government Officials
Like the PhRMA Code’s guidelines on gifts to HCPs, almost all states and the federal government
prohibit or restrict officials and their staff from accepting gifts from outside sources.
Pfizer colleagues are prohibited from giving any gift to a government official, no matter how
inexpensive. Prohibited gifts include meals (food and beverage), travel, lodging, and entertainment.
The only items that may be provided to government officials are RC-approved educational materials of
nominal value.
Gifts to Public Employees
HCPs in government institutions, such as VA hospitals or federal or state prisons, are considered to be
public employees. Unless otherwise restricted by state law or a particular institution’s policies (such as
with the VA), Pfizer policy permits Sales Colleagues to provide public employees with RC-approved and
nominally priced PhRMA Code compliant educational items. For more information on state specific
laws, see the State Laws: HCP and State Employee Restrictions Chapter. If you have any questions
about whether an item can be left with a public employee, consult with a GRD or your team attorney.
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