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Sales and Marketing Compliance
Practicing Ethical Sales and Marketing
The use of prescription-only medications and vaccines is intermediated by a number of experts, including doctors, pharmacists, and payers. Patients depend on these intermediaries to make the right choices in medicines, with the goal of the best health outcome. It is important that these intermediaries, doctors in particular, fully understand the range of options for treatment available to them and also fully understand the risks and benefits of each treatment. Patients should similarly be informed about treatment choices so they are better equipped to engage in discussions with their doctors and know how to use products safely and effectively.
We are thus committed to promoting our products responsibly and reporting about our business practices in a fashion that promotes transparency. We believe that it is important to educate patients and providers about health care treatments, so that physicians who prescribe our medicines can make decisions rooted solely in the best interests of the patient. Pfizer adheres to all applicable laws and regulations as well as to industry standards. To ensure our communication and marketing approaches uphold the highest standards, Pfizer has extensive mandatory, company-wide training on these standards of communication and conduct.
Global Policy on Interactions With Healthcare Professionals
In an effort to further solidify our commitment to base our interactions with healthcare professionals on the highest ethical standards, we listened to the concerns of our stakeholders and took action. The result is Pfizer's Global Policy on Interactions With Healthcare Professionals. Adopted originally in 2005 and subsequently updated, the Global Policy governs interactions with healthcare professionals by Pfizer around the world, including marketing, medical, sales, and research and development operations, with the limited exception of certain business-to-business interactions, which are defined by and must comply with other applicable Pfizer policies and guidelines.
The Global Policy incorporates common legal and ethical standards from many of Pfizer's major markets, including the US (Pfizer White Guide, PhRMA Code) and international (EFPIA Code on Promotion of Medicines, IFPMA Code of Pharmaceutical Marketing Practices) and applies them to our operations around the world.
Ensuring Ethical Business Behavior Worldwide
Our policy is based on the principles of maintaining ethics and compassion, building greater transparency, and partnering to facilitate access to healthcare information and medicines. The following are established operating norms worldwide:
- All customer meetings and Pfizer-hosted educational and promotional meetings must focus on education and avoid the appearance of being anything other than educational in purpose. To that end, such meetings cannot include Pfizer-sponsored entertainment (eg, sporting or leisure events) and must be held in appropriate venues
- Clinical research sponsored by Pfizer must conform to well-accepted international standards, including Good Clinical Practice (GCP) guidelines of the International Conference of Harmonization, the Nuremberg Code, the Belmont Report, and relevant national and local standards
- Medical communications must be accurate and scientifically rigorous; Pfizer colleagues are prohibited from promoting off-label use of medicines
- Marketing activities with healthcare professionals must convey full and substantiated information about the side effects and the safety profile of medicines
- Confidential patient data in Pfizer's care must be safeguarded against misuse or inappropriate disclosure
- Sales representatives must ensure that no items of significant value are offered as an inducement to use, prescribe, purchase, or recommend a product or to influence a clinical trial
In all cases, Pfizer operations around the world must comply with local laws and all applicable US laws. In the event of a conflict between our Global Policy and other regulations, the more restrictive provision applies.
Responsible consumer advertising has proven value in helping patients engage in more informed conversations with their healthcare providers, leading to better health outcomes. In all of our consumer advertising, we adhere to applicable FDA regulations and guidance. We also abide by the PhRMA Guiding Principles on Direct-to-Consumer (DTC) Advertising About Prescription Medicines. We follow strict internal standards that have been developed to ensure the information we share with consumers is: (1) scientifically sound; (2) balanced; (3) easy to understand; and (4) helpful in encouraging people to consult with a healthcare professional. We also continue to examine our internal protocols to ensure our DTC standards keep pace with industry standards, guidance, law, and regulation.
Disclosing Payments to Healthcare Professionals
Transparency in our relationships with healthcare professionals sets the right tone for our business. On our website, we publish Pfizer's payments and the value of non-cash items provided to licensed US healthcare professionals, including those in connection with speaking engagements and clinical research activities. Our disclosure of research payments further identifies major academic institutions involved with clinical trials and the principal investigators on clinical trials. We do not pay healthcare professionals for prescribing our medicines or as an incentive for promoting our medicines, vaccines, or nutritional products.
Pfizer was the first biopharmaceutical company to report payments to investigators conducting Phase IV clinical trials, in addition to disclosing payments for consulting and speaking. We believe that sharing this information will help the public understand the full breadth of the important collaborative work done by industry, academia, and healthcare professionals to advance patient health.
Note: This policy is subject to regular monitoring and evaluation.