White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 4: Federal Employee Interactions and Lobbying
Board of Ethics and file semi-annual reports detailing expenditures as they relate to marketing activities
directed towards members of the Medicaid Pharmaceutical and Therapeutics Committee.
In Colorado, an amendment to the Colorado Constitution prohibits individuals considered lobbyists
from giving anything of value, including gifts and meals, to government employees. Various other
states, and even counties, also have lobbying registration and disclosure requirements (e.g., New York
and Miami-Dade County, Florida). To ensure that expenses and interactions are properly tracked,
please consult with the relevant Regional Attorney before engaging in any marketing interactions with
state or local government employees.
State Formularies
Attempts to influence state formulary decisions is currently considered lobbying in many states. As a
result, registration and/or reporting may be required. If you are interacting with members of a state
committee or agency that make decisions with respect to their state’s formulary you should check with
the GRD with responsibility for that state prior to those interactions to determine whether any of your
activity could be considered lobbying.
Each Pfizer colleague is responsible for adhering to Pfizer’s policies regarding lobbying registration
and disclosure. Non-compliance with these policies puts the Company at risk and can subject
Pfizer colleagues to disciplinary action up to and including termination.
Campaign Contributions
It is important to understand the difference between lobbying and grassroots efforts and campaign
contributions. Lobbying and grassroots efforts are intended to influence government policy.
Campaign contributions are intended to influence campaigns and elections.
While corporations like Pfizer are permitted to lobby government officials, federal and various state
laws prohibit corporations from making financial contributions to support a candidate’s election. This
prohibition applies to both monetary and “in kind” donations, such as employee time and the use of
corporate resources on behalf of a campaign committee.
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Rev. 09/12
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