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Pfizer's Compliance Program represents a shared undertaking on the part of colleagues, ranging from the highest levels of management to the most junior employees.

It is structured around 8 fundamental elements forming our framework for effective risk management. Our Compliance Program is aligned with the Compliance Program Guidance for Pharmaceutical Manufacturers developed by the United States Department of Health and Human Services, Office of Inspector General.

Best in class policies and procedures underly our compliance and ethics program. 

We offer a summary of our key written guidelines in our Blue Book (Code of Conduct), and Orange (The Field Guide) and White (legal compliance) Guides, and our Global Policy on Interactions with Healthcare Professionals establishes our high standards of integrity in these interactions.

Our international anti-bribery and anti-corruption policies and procedures ensure full compliance with the U.S. Foreign Corrupt Practices Act (FCPA) and applicable international anti-bribery laws

Pfizer prohibits all forms of bribery and corruption, whether by colleagues or our business partners.  Colleagues and business partners must never offer, promise, authorize, or provide a payment or benefit that is intended to improperly influence a government official, healthcare professional, or any other person, including commercial entities and individuals, in exercising their responsibilities. 

These policies and procedures are reinforced through training and communications, and tested through periodic auditing and monitoring.  

Where appropriate, third parties are required to undergo anti-corruption due diligence and auditing, follow Pfizer's internal anti-bribery and anti-corruption policies and procedures, receive anti-corruption training and/or abide by Pfizer's International Anti-Bribery and Anti-Corruption Business Principles (also available in a variety of languages).

  • Rady Johnson serves as the Company's Chief Compliance, Quality, and Risk Officer and is responsible for overseeing Pfizer's global compliance program.    

    In this capacity, Mr. Johnson reports directly to the CEO and makes regular reports to the Audit Committee and the Regulatory and Compliance Committee of the Board of Directors.    

    Mr. Johnson heads the Compliance Division, which is responsible for administering all aspects of the Compliance Program, including training programs and compliance monitoring systems, developing informational colleague resources, and investigating potential violations of law or company policy.   

    The Executive Compliance Committee, which is made up of senior leaders from across the company, provides oversight and support for our efforts to ensure that its business is conducted appropriately around the world. 

  • effective training

    We’re committed to providing effective training to employees, managers, officers, and directors on the Compliance Program.  

    Training resources include online compliance education, as well as online access to policies, including the Blue Book, the Orange Guide, and the White Guide. 

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    We provide multiple channels for asking questions and raising compliance concerns. To facilitate this we have  open door, anti-retaliation, and confidentiality policies to encourage and protect colleagues who raise a valid concern. 

    Open Door Policy

    Pfizer adheres to an Open Door Policy and encourages colleagues to discuss all issues, concerns, problems, and suggestions with their immediate supervisors or other managers without fear of retaliation and with the assurance that the matter will be kept as confidential as possible.  Retaliation is prohibited in all its forms.

    Compliance Direct 

    At Pfizer, colleagues can contact the Compliance Division directly in any of the following ways: 

      

    1. Email: [email protected] 

    1. Mail: 235 East 42nd Street (235/12/1), New York, NY 10017 

    1. Phone: 1-212-733-3026 

    1. Secure Fax: 1-917-464-7736

    Compliance Helpline

    Where available and permitted by law, Pfizer's Compliance Helpline allows colleagues to report a concern or get information or advice anonymously.  
     
    Where available, the Compliance Helpline can be reached by phone or online via the web-reporting tool. This resource is accessible 24 hours a day, 7 days a week, 365 days a year and is offered in multiple languages.  
     
    The Compliance Helpline is operated by specially trained third-party representatives: 
     
    Compliance Helpline Number∗ (U.S. and Puerto Rico): 1-866-866-PFIZ (7349) 
     
    The Compliance Helpline numbers for Pfizer locations outside the U.S. and Puerto Rico can be provided upon request. 
     
    Compliance Helpline Web-Reporting Tool
     
    EU Note: For more details on what information Pfizer collects and how it uses the information in the context of the Helpline, as well as for more information about your rights, please see the EU Online Notice
     
    Office of the Ombuds: 
     
    Colleagues at Pfizer have an additional resource for addressing and resolving work-related concerns: Pfizer’s Office of the Ombuds. Pfizer’s Office of the Ombuds offers a place where colleagues at any level can get information and guidance to help them address and resolve work-related issues. Pfizer’s Ombuds is informal, independent, and neutral, and is not an advocate for any party, but an advocate for fair process. 

    Communication With Management About Compliance Issues 

    The Compliance Division regularly communicates with senior management about compliance matters. The development and implementation of compliance and ethics policy benefit from input and support from company management.

    Communication With the Audit Committee

    Communication with the Audit Committee of the Board of Directors, the Regulatory and Compliance Committee of the Board of Directors, and the full Board is part of an effective compliance program.  
      
    Members of the Board and its audit.regulatory,compliance committees are readily accessible to senior management, including the Chief Compliance, Quality and Risk Officer. 

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    Internal monitoring and auditing of business processes are important parts of an effective Compliance Program to help detect and prevent emerging risks and potential violations of law or policy.  

    Corporate Audit is responsible for auditing the company's policies and procedures, including those of the Compliance Program.

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    Our core compliance guidance documents (Blue Book, Orange Guide, and White Guide) educate colleagues about our company's commitment to compliance. Failure to adhere to our compliance standards may have disciplinary consequences, up to and including termination of employment.  

    If an investigation suggests that discipline may be warranted, appropriate action is taken.

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    Our Compliance Program supports prompt response and corrective action for significant, potential, suspected or actual violations of law or policy.  

    It is expected that compliance concerns referred through any of the many communication channels available (personal contact, email, Compliance Helpline, etc.) will be carefully reviewed, thoroughly and thoughtfully investigated in a timely manner, and appropriately resolved.

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    Pfizer declares, based on its good faith understanding of the California Health and Safety Codes §§ 119400-119402, that as of July 1, 2022, it is in substantial compliance with its Comprehensive Compliance Program and the requirements of California Health and Safety Codes §§ 119400-119402.   

    This declaration is based on Pfizer’s most recent evaluation, which includes consideration of the annual aggregate limit noted on covered promotional expenditures, and this declaration will be updated on an annual basis. 

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    We have embedded in the structure of our Corporate Compliance Program, and established in our guidelines for interactions with healthcare professionals, the principles articulated in the OIG Guidance and PhRMA Code.   

    As appropriate, and consistent with the law, we will amend and update our policies and this statement to ensure compliance with the law.  

    A description of Pfizer's Corporate Compliance Program, including the company's written declaration and certification of compliance with California SB 1765, can be requested by calling the Compliance Division directly via telephone at (212) 733-3026, via Pfizer's Compliance Helpline number at (866) 866-7349 FREE (PFIZ), or by emailing us at [email protected]

Pfizer Global Policy adheres to all applicable laws and regulations and industry standards, while maintaining the highest ethical standards of reporting on our marketing, sales and research and development operations.

Pfizer Marketing and sales ethics

  • 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 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. 

  • Pfizer Policies on Interactions with Healthcare Professionals in California

    Policies that regulate our colleagues' interactions with healthcare professionals in the United States reflect our commitment to compliance with applicable federal and state laws and regulations. We review and revise our policies as we deem appropriate to meet the requirements of a highly regulated and complex healthcare environment. 

    California SB 1765 (California Health and Safety Code Sections 119400, 119402 or "Statute"), requires pharmaceutical companies to set a specific annual dollar limit on gifts, promotional materials, and items or activities that pharmaceutical companies may give or otherwise provide to an individual medical or healthcare professional as defined under the Statute. Accordingly, Pfizer has modified certain policies and procedures that regulate interactions with covered medical and healthcare professionals in the State of California. 

    Additionally, in accordance with California Health and Safety Code Sections 119400, 119402 ("Statute"), our Compliance Program includes policies for compliance with the Pharmaceutical Research and Manufacturers of America (PhRMA) "Code on Interactions with Health Care Professionals."  

     

    Annual Aggregate Limit 

    Subject to this law, Pfizer has determined that the annual aggregate limit on covered promotional expenditures is set at $3,500 per California licensed prescriber or other covered medical or health professional as defined by the Statute for annual periods commencing on May 1, 2008. This limit may be revised by Pfizer from time to time. The foregoing limit does not represent a usual, customary, average, or typical amount for medical or healthcare professionals.

    The Statute excludes from promotional expenditures such items as drug samples given to medical or healthcare professionals intended for free distribution to patients, financial support for continuing medical education forums, financial support for health educational scholarships, and payments made at fair market value for legitimate professional services provided by healthcare professionals.   

    Pfizer's annual aggregate limit is based on an estimate of the maximum value of gifts, promotional materials, and other items or activities as defined herein that a medical or healthcare professional may receive in 1 year.   

    In setting this limit, we have taken into account the size of the company and the size of its product portfolio in the United States. Pfizer is one of the largest pharmaceutical companies in the United States with one of the largest field forces.   

    The company markets more than 20 products, many of which are prescribed by the same base of primary care physicians. This often requires multiple interactions with the same physician to provide appropriate information about our products.  

    Our sales force has been advised and will be reminded that this limit applies to California licensed prescribers and other covered medical or healthcare professionals in California. We do not believe it applies to medical or healthcare professionals practicing in other states and who are not licensed in California.  

    Each category of items or activities that are included in the annual aggregate limit—gifts, promotional materials, and other items or activities—is discussed separately below. 

      

    Gifts 

    The Pharmaceutical Research and Manufacturers of America (PhRMA) Code allows pharmaceutical companies to provide "items designed primarily for the education of patients or healthcare professionals if the items are not of substantial value ($100 or less) and do not have value to healthcare professionals outside of his or her professional responsibilities," as long as they are not provided "in exchange for prescribing products or for a commitment to continue prescribing products" or "in a manner or on conditions that would interfere with the independence of a healthcare professional's prescribing practices."  

    Our annual aggregate limit on certain promotion-related expenditures for purposes of California law excludes from calculation educational items that are permissible under the PhRMA Code. 

       

    Promotional Materials 

    Neither California Business & Professions Code §§ 119400-119402, nor the PhRMA Code, nor the Office of Inspector General (OIG) Guidance defines "promotional materials." For purposes of this statute, Pfizer does not include in its definition of "promotional materials," documents and information that inform medical or healthcare professionals about Pfizer products, provide scientific and educational data, or support medical research and education. 

     

    Other Items or Activities 

    The statute also subjects to the per-medical or healthcare professional annual aggregate limit all other "items or activities that the pharmaceutical company may give or otherwise provide to an individual medical or healthcare professional in accordance with the OIG Guidance and with the PhRMA Code."  

    We include, among other items in this category, the retail cost of meals provided to covered medical or healthcare professionals in connection with educational presentations. Historically, Pfizer has not limited attendance at these educational events.    

    The per-medical or healthcare professional annual aggregate limit on certain promotional expenditures reflects Pfizer's commitment to responsible education and reasonable facilitation of attendance at educational programs in California.    

    To comply with the statute, Pfizer will monitor and limit, if necessary, the number of educational presentations that covered medical or healthcare professionals may attend during the reporting period for compliance with the annual aggregate limit.

  • Pfizer's Global Policy on Interactions with Healthcare Professionals. 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. 

    Pfizer's Global Policies on Interactions with Healthcare Professionals

    Read Our Policy Statement

  • 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 (e.g., 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. 

  • 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.

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