Pfizer 2011 Annual Review | Pfizer: the world's largest research-based pharmaceutical company


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Strong standards of ethics and strong ethical performance are at Pfizer's core. We are committed to upholding the highest ethical standards in every aspect of our business.

Our training programs and organizational structures have been developed to go beyond compliance. All colleagues are expected to take ownership of compliance and to perform all tasks with integrity. We continuously scrutinize our internal practices and have put into place procedures for taking immediate action when we identify potential violations. We offer a Compliance Helpline, an Open Door Policy and anti-retaliation protections, and launched in 2011 an Office of the Ombudsman to further encourage all Pfizer colleagues to report potential violations or concerns.


Pfizer's Compliance Program, established under the direction of Pfizer's Board of Directors, is led by our Chief Compliance & Risk Officer (CCRO), who reports to the CEO and is a member of the Executive Leadership Team. The CCRO and staff provide oversight of Pfizer's compliance programs and guidance to help colleagues stay fully compliant with applicable laws, regulations and company policies. In addition, we have a robust internal audit group, with a direct reporting relationship to the Audit Committee of the Board of Directors as well as a reporting relationship to the Chief Financial Officer. Both the CCRO and the head of Corporate Audit have wide authority to investigate any compliance issues in their respective areas. As part of our commitment to continuous improvement, we regularly review our compliance program to make certain that it remains best in class.

Colleagues worldwide are trained every year on Pfizer's Code of Conduct, known as the "Blue Book." Pfizer has made considerable investments to combat bribery and corruption. Our International Anti-Bribery and Anti-Corruption Corporate Procedure, designed to prevent and detect violations of the U.S. Foreign Corrupt Practices Act and its foreign law counterparts, requires the adoption of local procedures and training of appropriate colleagues. We have established reporting mechanisms that include a compliance helpline (available in more than 100 languages) and Web reporting tools, where available, that allow colleagues around the world to raise concerns and seek guidance. Where permitted by law, suspected compliance issues may be reported anonymously. These efforts support our expansion globally and help make certain that our business is conducted in accordance with the highest ethical standards around the world.

In 2011, the Regulatory and Compliance Committee of the Board of Directors was formed.  This Board-level Committee is dedicated to assisting the Board of Directors with overseeing and reviewing the company’s health care related regulatory and compliance issues, including its compliance programs and the status of compliance with related laws, regulations, internal procedures and the company’s Corporate Integrity Agreement. 

Public Policy, Political Contributions and Lobbying

Engaging in public policy is crucial in creating an enabling environment to improve access to quality medicines and health care. As a highly regulated industry, we believe that public policy engagement, including lobbying and political contributions, is an important and appropriate role for companies in open societies, if such engagement is conducted in a legal and transparent manner. We comply with all applicable lobbying registration and disclosure laws, and provide added transparency beyond legal requirements. Pfizer reports quarterly on lobbying expenses. We publicly disclose our Pfizer Political Action Committee and corporate political contributions and grants for health care education on our website. Pfizer has also voluntarily signed onto the European Commission's new register of interest representatives.

2011 Highlight

  • Pfizer ranked among the best of the S&P 100 for disclosing corporate political activity in the first-ever CUNY/Baruch College's Index of Corporate Political Disclosure. Executed by Baruch College's Robert Zicklin Center for Corporate Integrity, and compiled only from the information made public by each company, the Index measures a company's willingness to voluntarily disclose and be transparent about its corporate political activity. Pfizer is the only pharmaceutical company ranked in the Index's top tier.

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.

Disclosing Payments to Health Care Professionals

Transparency in our relationships with health care professionals sets the right tone for our business. We publish on our website Pfizer's payments and the value of noncash items provided to licensed U.S. health care professionals, including 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 health care professionals for prescribing our medicines or as an inducement for promoting our medicines, vaccines or nutritional products.

Pfizer was the first biopharmaceutical company to report payments to investigators conducting Phase I–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 health care professionals to advance patient health.

Direct-to-Consumer Advertising

Responsible consumer advertising has proven value in helping patients engage in more informed conversations with their health care 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 health care professional. And we continue to examine our internal protocols to ensure our DTC standards keep pace with industry standards, guidance, law and regulation.

Human Rights

As a global company, we operate in complex economic, social and political environments. These complexities bring with them an enlarged role for us in ensuring human rights within our operations and in working for human betterment through our increasingly broad global presence.

Thus, we account for and respect human rights in all of our business activities, wherever we operate in the world. We fully support the principles contained in the Universal Declaration on Human Rights and the International Labour Organization Declaration on Fundamental Principles and Rights at Work. Pfizer is a signatory of the United Nations Global Compact and we support its Ten Principles on human rights, labor, environment and the fight against corruption.


Learn more about the policies and practices that govern how we work together.

Learn more about the policy on Interactions with Health Care Professionals.

Learn more about the policy on Payments to Health Care Professionals.