Ethics & Compliance

Culture and ethical decision making are foundational to Pfizer’s purpose. We are committed to fostering a culture of integrity throughout the company.

Integrity is built into our Company Values: Courage, Excellence, Equity, and Joy

All colleagues are responsible for acting with integrity in all they do, and our leaders are accountable for proactive risk management and prioritizing a culture of integrity over business results. We incorporate ethics and business integrity into internal performance evaluations, which are designed to enhance colleague accountability, including leadership performance with integrity. We measure our integrity culture and speak-up environment annually through colleague surveys.

Speak Up Culture, Open Door and Whistleblower Protections

Courage is a core value, and we promote a speak up environment. Our whistleblowing policies (e.g., Open Door policy) and strict anti-retaliation policies require reporting misconduct and encourage raising concerns about any issues. Retaliation against anyone who seeks advice, raises a concern, reports misconduct, or provides information in an investigation is prohibited. Pfizer takes all policy concerns seriously and, to the extent violations of policy are identified, takes appropriate disciplinary action and corrective actions, including potential termination. We measure our culture of integrity with surveys, and the results are used to focus leadership communications, training, and other proactive improvement efforts.

We provide multiple channels for asking questions and raising potential compliance concerns, including anonymous reporting options where permitted by law, and keep matters as confidential as possible:

Compliance Direct

Pfizer’s Compliance Division can be contacted directly in any of the following ways:

• Email: [email protected]
• Mail: 66 Hudson Boulevard East, New York, NY 10001-2192
• Phone: 1-212-733-3026
• Secure Fax: 1-917-464-7736

Compliance Helpline (available by phone or online)

Pfizer's publicly available Compliance Helpline allows colleagues, suppliers, customers, and other third parties to report a concern or get information or advice anonymously (where permitted by law). The Helpline is operated by specially trained third-party representatives and can be reached by phone or online, 24 hours a day, every day.

• Compliance Helpline Number∗ (U.S. and Puerto Rico): 1-866-866-PFIZ (7349)
• Compliance Helpline Online: https://pfizer.ethicspoint.com

*The Compliance Helpline numbers for Pfizer locations outside the U.S. and Puerto Rico are available at https://pfizer.ethicspoint.com or can be provided upon request (see contact information above).

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 Compliance Helpline Guidance & Privacy Notice. Furthermore, in certain EU countries, Pfizer also offers local reporting channels. For more information on local reporting, please contact the Compliance Division.

Office of the Ombuds

Our Office of the Ombuds supports all colleagues with information and guidance to help them resolve work-related issues. The Office of the Ombuds is informal, independent, and neutral.

The Ombuds will:

• Provide information on policies or procedures
• Listen and help colleagues articulate their concerns
• Provide coaching and guidance
• Keep information confidential* and protect anonymity
• Remain neutral and objective
• Assist in identifying and evaluating options for a situation
• Identify other Pfizer resources that might be helpful

*Conversations with the Ombuds are confidential except where the Ombuds determines that there appears to be an imminent risk of serious harm.

We maintain a compliance and ethics organization with sufficient independence, experience, and resources, and direct access to leadership and the Board of Directors.

Our quality and compliance governance includes Quality and Risk Committees (QRCs) for our core functions (Commercial, Research & Development / Medical and Global Supply). This innovative QRC framework drives business-led proactive risk management, timely identification, assessment, prioritization, mitigation, and escalation of priority and emerging risks, and informs our company-wide Enterprise Risk Management program.

The QRCs are overseen by and report regularly to both an Executive Compliance Committee chaired by our CEO and a dedicated Regulatory and Compliance Committee of the Board of Directors. These Committees’ oversight of healthcare quality and compliance includes business ethics, responsible product marketing, and compliance with anti-bribery / anti-corruption, transparency, and other applicable laws and regulations, in pursuit of advancing integrity and Pfizer’s purpose. In addition, we conduct internal effectiveness reviews and regularly engage independent third-party experts to evaluate the effectiveness of the Ethics & Compliance Program and quality and compliance governance framework.

Rady Johnson serves as the company's Chief Compliance, Quality, and Risk Officer and is responsible for overseeing Pfizer's global Ethics & Compliance Program. He reports directly to the CEO and makes regular reports to the Audit Committee and the Regulatory and Compliance Committee of the Board of Directors.

Best-in-class policies and procedures underly our Ethics & Compliance Program. We implement written policies and procedures to drive our high standards, provide effective guidance to colleagues, and help prevent non-compliance. Our policies and procedures set the company’s ethical norms and aim to reduce risks identified through our risk assessment process. We strive for clear, principles-based, comprehensive policies, with a focus on accessibility for all colleagues through innovative online resources and search capabilities.

Code of Conduct

Pfizer’s Code of Conduct, the Blue Book, is structured around the values that define our company and our culture—Courage, Excellence, Equity, and Joy. The Blue Book describes how we operate and guides us to make ethical decisions to achieve our purpose – Breakthroughs that change patients’ lives – with integrity. The Code provides an overview of our core compliance policies, including those covering anti-bribery and anti-corruption, personal data, human rights, conflicts of interest, social media, responsible marketing and promotional practices, fair competition, global trade controls, anti-harassment, and whistleblower anti-retaliation. All colleagues and officers of Pfizer and its subsidiaries are responsible for complying with our Code of Conduct and holding each other accountable for acting with integrity, and are encouraged to ask questions, raise concerns, and seek further guidance. The Blue Book is available in over 30 languages.

Download the Pfizer Policies on Business Conduct

Note: This policy is subject to regular monitoring and evaluation.

Policies for U.S. Commercial and Corporate Colleagues

Pfizer’s Orange Guide and White Guide provide a comprehensive overview of the laws, regulations, industry codes, and Pfizer policies and guidelines that U.S. field-based commercial personnel (Orange Guide) and U.S. non-field personnel (White Guide) must adhere to as part of our commitment to integrity. These Guides are intended to help U.S. colleagues ensure that they act ethically and continue to build trust in their interactions with patients, healthcare professionals, and other stakeholders.

Global Policy on Interactions with Healthcare Professionals

Our Global Policy on Interactions with Healthcare Professionals, which is applicable in all markets in which we operate, reflects our commitment to operating responsibly, ethically, and with integrity in our business endeavors including marketing, medical, sales, and research and development operations; to focusing on improving patient care and quality of life for consumers in the communities in which we operate; and to ensuring our business activities support the best practice of medicine. The Global Policy incorporates common legal and ethical standards from many of Pfizer's major markets, including the United States (PhRMA Code) and international markets (EFPIA Code on Promotion of Medicines, IFPMA Code of Pharmaceutical Marketing Practices), and applies them to our operations around the world.

Pfizer's Compliance and Ethics training program helps ensure our colleagues, managers, officers, and our board of directors understand and adhere to Pfizer's standards and perform with integrity. Our program includes live, virtual, and online training. It is learner-centric and risk-based and includes role-tailored scenario-based materials to increase relevance, engagement, and retention.

Our online training program uses modern instructional design and technology to accommodate different levels of learner needs and advanced data analytics to measure training effectiveness. Each learning experience explains why the training is important, emphasizes the importance of culture, and reminds the learner that living the company’s values of Courage, Excellence, Equity and Joy is essential to delivering on the company’s purpose – Breakthroughs that change patients’ lives. Leveraging our data analytics, we supplement our training with targeted communications that reinforce key learnings.

Code of Conduct training is assigned to all colleagues worldwide and certain third parties upon hire and regularly thereafter. Our Board of Directors regularly receives this training, as do certain colleagues and others who perform work for the company.

Colleagues and certain third parties also receive training on other key policies and practices upon hire and regularly thereafter, as appropriate, including responsible marketing and advertising, and anti-bribery / anti-corruption training. Compliance and Ethics training at Pfizer is part of a broader enterprise training curriculum that covers additional topics, including privacy, harassment, protecting sensitive information, lobbying, diversity, equity and inclusion, and product quality, safety, and adverse event reporting obligations. Messaging about ethics and integrity, including communications from leadership, ethics and compliance culture campaigns, and creative use of various media, are regularly shared to reinforce ethical behavior and the importance of speaking up with any questions or concerns.

Pfizer has a state-of-the-art live, continuous monitoring system for compliance across all global markets. We have standard operating and quality control procedures across our markets and functions designed to ensure operating effectiveness and compliance. This goes beyond auditing and involves continuous monitoring of activities at all levels of operations, as well as through independent oversight functions. These activities are designed to detect anomalies that could indicate potential non-compliance, for the purpose of early identification of potential issues, root cause analysis, remediation, prevention, and continuous improvement.

Multiple functions across the company coordinate and conduct oversight, monitoring, and auditing that establish Pfizer’s lines of defense. We conduct internal routine monitoring and auditing of all relevant business processes to help detect and prevent emerging risks and potential violations of law or policy.

Pfizer uses different types of risk-based monitoring approaches and employs advanced systems, risk-based algorithms, monitoring tools, resources, and analytics to drive our industry-leading monitoring program. We incorporate advanced corruption and fraud detection techniques and machine learning to identify outliers that might impact enterprise and market risk. We also monitor internal and certain external parties to detect potential non-compliance and opportunities for corrective action or enhancements of the Ethics & Compliance Program.

Our internal audit function has a systematic and regular audit process and is responsible for auditing the company's policies and procedures, including those of the Ethics & Compliance Program. We continue to proactively assess, enhance, and invest in our monitoring functions to bring the most effective, state-of-the-art tools into our arsenal.

We strive to do business with third parties who share our commitment to integrity. Our Third Party Risk Management (TPRM) program is a holistic, risk-based approach to identifying, assessing, and managing risks presented by third parties across our global operations.

Our TPRM program incorporates governance, policy, due diligence, auditing, monitoring, training, and system capabilities supporting management across the full engagement lifecycle. TPRM covers key risks associated with engagement of third parties in the life sciences industry, including: anti-bribery and anti-corruption, pharmacovigilance/safety, promotional practices, cyber/information security, and data privacy risks.

TPRM’s enterprise-wide governance works to reduce risk by improving oversight, identification, and management of third-party risk including due diligence on anti-corruption and anti-bribery to drive business accountability and oversight for risk management. Colleagues and third parties who do not meet our standards for compliance face significant potential consequences, up to and including termination.