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To ensure we can continue to deliver on our commitments to the patients, customers and shareholders who rely on us, we are focused on improving the way we do business; on operating with transparency in everything we do; and on listening to the views of all of the people involved in health care decisions. Through working in partnership with everyone from patients to health care providers and managed care organizations to world governments and non-governmental organizations, our goal is to ensure that people everywhere have access to innovative treatments and quality health care.

Policies & Procedures: FCPA and Anti-Corruption

Pfizer has international anti-bribery and anti-corruption policies and procedures that cover, among other things, colleagues’ interactions with government officials and healthcare professionals, as well as parties that provide goods or services to Pfizer. These policies and procedures are reinforced through anti-corruption training and tested through periodic auditing and monitoring. Where appropriate, third parties are required to undergo anti-corruption due dilligence and auditing, following 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.

Pfizer Code of Conduct

Blue Book: Pfizer’s 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 how we make ethical decisions to achieve our purpose - Breakthroughs that change patients’  lives - with integrity. All colleagues and officers of Pfizer and its subsidiaries are resposible for living our Code of Conduct and holding each other accountable for the same, and are encouraged to ask questions, raise concerns, and seek further guidance. The Blue Book is available in over 30 languages.

Sales and Marketing Compliance

Practicing Ethical Sales and Marketing

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.
 

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.
 

We are thus committed to promoting our products responsibly and reporting about our business practices in a fashion that promotes transparency. 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.

Global Policy on Interactions With Healthcare Professionals

In an effort to further solidify our commitment to base our interactions with healthcare professionals on the highest ethical standards, we listened to the concerns of our stakeholders and took action.The result is Pfizer s Global Policy on Interactions With Healthcare Professionals. Adopted originally in 2005 and subsequently updated, the Global Policy 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 major markets.

Ensuring Ethical Business Behavior Worldwide

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 (eg,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.

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