Anti-bribery and Anti-corruption

Further to our prohibition on all forms of bribery, we are committed to fostering a culture of ethics and integrity. Pfizer will compete lawfully and ethically in the marketplace and expects every Pfizer Colleague and business partner to conduct all aspects of Pfizer business with integrity. Resources, training, and messaging emphasize the accountability of leaders to own compliance and engage in proactive risk management and ethical decision-making and to make clear that non-compliant conduct is not tolerated. Pfizer also strives to be an ethical leader within our industry by taking leading roles within industry associations and diverse business forums to advance anti-corruption efforts.

A dedicated Anti-Corruption Program Office, composed of attorneys and experts within the Compliance Division, is responsible for establishing our global ABAC policy, its programmatic framework, and procedural controls with implementation oversight to enable risk-based customized solutions and to help ensure compliance with anti-corruption laws and policies across the enterprise. This encompasses ABAC quality oversight and risk management, including identification of anti-corruption risk landscape evolution, emerging risk areas and state of control enhancements. Dedicated operations teams outside of the Compliance Division support transaction execution, including with risked-based due diligence, helping to ensure that transactions and contracts comply with our ABAC policy. Additional support is provided by our various risk management functions.

We regularly execute enterprise and local risk assessments, which cover ABAC, to detect and assess significant risks, allocate resources, and implement appropriate mitigation measures.

Our global ABAC policy prohibits all forms of bribery (whether direct or indirect), corruption, and improper payments, and establishes comprehensive risk-based controls and requirements for certain types of transactions involving healthcare professionals and government officials, as well as other historically higher-risk transactions and engagements. Compliance with our ABAC policy applies to everyone acting on behalf of Pfizer, including colleagues and business partners. Processes with supporting systems and operating models, including transaction centers of excellence, have been implemented globally to enable due diligence, visibility, and execution of controls. Our process requires business rationale evaluations to help ensure appropriate business purpose, fair market value assessments, risk-based diligence, local market regulations check, gatekeeper reviews, and appropriate documentation (e.g., contracts with ABAC terms and conditions). The ABAC policy is periodically reviewed to help ensure continuous focus on evolving ABAC risk landscape and emerging risk areas that require enhancement of related fit-for-purpose controls.

We conduct regular and tailored training for colleagues, contractors, and high-risk third parties on our anti-corruption policies. Our training uses innovative online modules and live formats, including testing methodologies. It is routinely reviewed to incorporate learnings from investigations and monitoring, and we offer local language translation capabilities to best reach target audiences and designed for accessibility and impact. Our communications framework includes an emphasis on fostering a culture of integrity, including annual senior leader certifications that reflect they are working to help ensure effective compliance.

As part of our broader monitoring activities, we monitor internal and higher-risk external parties to detect potential non-compliance with our ABAC policies. Monitoring results are used to help identify potential areas for continuous improvement or enhanced risk mitigation controls.

We respond promptly and consistently to detected offenses and undertake corrective action, including through discipline or other remedial measures. Our global investigations team promptly and thoroughly investigates allegations of potential violations of our ABAC and other policies and procedures and conducts root cause analyses to help understand potential themes, which then drives our proactive risk management.

We maintain risk-based controls, trainings, and processes to identify, evaluate, and mitigate ABAC risk related to our engagements of and interactions with third parties, and we work to help ensure adequate compliance program implementation for companies in which Pfizer obtains a controlling interest. We conduct anti-bribery focused due diligence on third parties, considering factors such as geographic location, service type, and spend. This due diligence process routinely involves consideration of third parties’ internal anti-bribery policies and controls, and, where appropriate, Pfizer provides additional training. Pfizer's International Anti-Bribery and Anti-Corruption Business Principles serves as a guiding document containing the core anti-bribery principles that Pfizer expects higher-risk third parties acting on our behalf to follow and is also available in a variety of languages. ABAC terms, including audit and termination rights, are required in contracts with third parties engaged for certain higher-risk activities. We audit third parties as appropriate, and we also gain visibility into interactions with other higher-risk third parties through auditing Pfizer’s books and records and documentation provided from third parties. For higher-risk third parties, we require training and completion of annual certifications of compliance.