Ethical Marketing, Sales, and Interactions with Healthcare Professionals

The use of prescription-only medications and vaccines is intermediated by many experts, including doctors, pharmacists, and payers. Patients depend on these intermediaries to make the right choices in medicines and vaccines, with the goal of the best health outcome. It is important that these intermediaries, especially doctors, fully understand both the range of options for treatment or prevention available to them, and 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 healthcare professionals so that physicians who prescribe our medicines and vaccines can make decisions rooted solely in the best interests of their patients. Pfizer adheres to all applicable laws and regulations as well as to industry standards. To help ensure our communication and marketing approaches uphold the highest standards, including prohibitions on off-label marketing, Pfizer has extensive mandatory, company-wide training on our policies, and leaders strongly re-affirm these standards of communication and conduct.

Our policy is based on the principles of maintaining ethics and compassion, building greater transparency, and partnering to facilitate access to healthcare information, medicines, and vaccines. The following are established operating norms worldwide:

• Clinical research sponsored by Pfizer must conform to 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, complete, and unbiased representations of information from scientifically rigorous sources
• Marketing activities with healthcare professionals must convey full and substantiated information about the side effects and the safety profile of medicines and vaccines
• All customer meetings and Pfizer-hosted educational and promotional meetings must focus on education. To that end, such meetings cannot include entertainment (e.g., sporting or leisure events) and must be held in appropriate venues
• Pfizer colleagues are prohibited from promoting off-label use of medicines and vaccines
• Confidential patient data in Pfizer's care must be safeguarded against misuse or inappropriate disclosure
• Pfizer colleagues must ensure that no items of value are offered as an inducement to use, prescribe, purchase, or recommend a product or to influence a clinical trial
• All engagements of healthcare professionals, including for promotional programs, are subject to review and diligence, including an assessment to help ensure that honoraria are fair market value (FMV) using automated calculators that take into consideration qualifications, nature of service, and geography, along with any applicable local limits or regulations
• Gifts to healthcare professionals are prohibited, except certain items of medical utility and promotional aids (pens, notepads) may be given in limited circumstances, consistent with applicable codes

In all cases, Pfizer operations around the world must comply with applicable local and U.S. laws, regulations, and codes. In the event of a conflict between our policies and other regulations, the more restrictive provision applies.

Pfizer's Global Policy on Interactions with Healthcare Professionals governs Pfizer’s interactions with healthcare professionals 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.

Read Our Policy Statement

Responsible consumer advertising in the United States has proven to help patients engage in more informed conversations with their healthcare professionals, leading to better health outcomes. In all our consumer advertising, we adhere to applicable U.S. 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 help ensure our DTC standards keep pace with industry standards, guidance, laws, and regulations.

Transparency in our relationships with healthcare professionals sets the right tone for our business. Our work with healthcare professionals is based in sound science and focused on improving patient health. We are committed to meeting the highest ethical standards in our work with healthcare professionals to help ensure the integrity of these relationships and their value to patients. We prohibit improper payments to healthcare professionals.

Pfizer discloses applicable payments including to healthcare professionals in countries where disclosure is required by regulation or by industry code. Pfizer’s global approach to transparency reporting applies a harmonized set of business standards for consistency and compliance in all countries where we have reporting obligations. We believe that sharing this information helps the public understand the full breadth of the important collaborative work done by industry, academia, and healthcare professionals to advance patient health.

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 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 the Statute, our Compliance & Ethics 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 a year. In setting this limit, we have considered 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 multiple 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. 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.

Gift Restrictions

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 their 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 includes a calculation of educational items that are permissible under the PhRMA Code. Further, Pfizer adheres to the IFPMA Code of Pharmaceutical Marketing Practices, including applicable restrictions on gifts to healthcare professionals, along with adherence to any applicable local industry codes.

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. 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.