Pfizer Anti-Bribery and Anti-Corruption Principles

Pfizer has a longstanding corporate policy that prohibits colleagues or anyone acting on its behalf from providing any payment or benefit to any person or entity in order to improperly influence a government official or to gain an unfair business advantage. Pfizer is committed to performing with integrity and acting ethically and legally in accordance with all applicable laws and regulations, including, but not limited to, anti-bribery and anti-corruption laws. Pfizer expects the same commitment from the consultants, agents, representatives or other companies and individuals acting on its behalf (“Business Associates”), as well as those acting on behalf of Business Associates. 

Bribery of Government Officials 

Most countries have laws that forbid making, offering or promising any payment or anything of value (directly or indirectly) to a government official when the payment is intended to influence an official act or decision to award or retain business. Under Pfizer's policies, "government official" is broadly interpreted and includes: 

(i)  any elected or appointed government official (eg a member of a ministry of health); 

(ii) any employee or person acting for or on behalf of a government official, agency, or enterprise performing a governmental function; 

(iii) any political party, candidate for public office, officer, employee, or person acting for or on behalf of a political party or candidate for public office; or 

(iv) an employee or person acting for or on behalf of a public international organisation (eg the United Nations). 

"Government" is meant to include all levels and divisions of governments (ie local, regional, or national and administrative, legislative, or executive). Because this definition of "government official" is so broad, it is likely that Business Associates will interact with a government official in the ordinary course of their business on behalf of Pfizer. For example, doctors employed by government-owned hospitals would be considered "government officials" under Pfizer policies.  

The U.S. Foreign Corrupt Practices Act of 1977 (the “FCPA”) prohibits making, promising, or authorising the making of a payment or providing anything of value to a non-U.S. government official to improperly or corruptly induce that official to make any governmental act or decision to assist a company in obtaining or retaining business, or to otherwise obtain an improper advantage. The FCPA also prohibits a company or person from using another company or individual to engage in any of the foregoing activities. As a U.S. company, Pfizer must comply with the FCPA and could be held liable as a result of acts committed anywhere in the world by a Business Associate.  As an ex-US affiliate of Pfizer Inc, Pfizer Australia also complies with the tenets of the FCPA. 

Anti-Bribery and Anti-Corruption Principles Governing Interactions with Governments and Government Officials   

Business Associates must communicate and abide by the following principles with regard to their interactions with governments and government officials: 

• Business Associates, and those acting on their behalf in connection with work for Pfizer, may not directly or indirectly make, promise, or authorise the making of a corrupt payment or provide anything of value to any government official to induce that government official to make any governmental act or decision to help Pfizer obtain or retain business.  
• Business Associates, and those acting on their behalf in connection with work for Pfizer, may never make a payment to or offer a government official any item or benefit, regardless of value, as an improper inducement for such government official to approve, reimburse, prescribe, or purchase a Pfizer product, to influence the outcome of a clinical trial, or otherwise improperly to benefit Pfizer's business activities. 
• Business Associates, and those acting on their behalf in connection with work for Pfizer, need to understand whether local laws, regulations, or operating procedures (including requirements imposed by government entities such as government-owned hospitals or research institutions) impose any limits, restrictions, or disclosure requirements on compensation, financial support, donations, or gifts that may be provided to government officials.  
• Business Associates, and those acting on their behalf in connection with work for Pfizer, must take into account and comply with any applicable restrictions in conducting their Pfizer-related activities. If a Business Associate is uncertain as to the meaning or applicability of any identified limits, restrictions, or disclosure requirements with respect to interactions with government officials, that Business Associate should consult with his or her primary Pfizer contact before undertaking their activities. 
• Business Associates, and those acting on their behalf in connection with work for Pfizer, are not permitted to offer facilitation payments. A “facilitation payment” is an unofficial payment of any value, offered to a government official for the purpose of securing or expediting the performance of a routine, non-discretionary governmental action. Examples of facilitation payments include payments to expedite the processing of licenses, permits or visas for which all paperwork is in order. In the event that a Business Associate, or someone acting on their behalf in connection with work for Pfizer, receives or becomes aware of a request or demand for a facilitation payment or bribe in connection with work for Pfizer, the Business Associate shall report such request or demand promptly to his or her primary Pfizer contact before taking any further action. 

Commercial Bribery 

Bribery and corruption can also occur in non-government, business to business relationships. Most countries have laws which prohibit offering, promising, giving, requesting, receiving, accepting, or agreeing to accept money or anything of value in exchange for an improper business advantage. Examples of prohibited conduct could include, but are not limited to, the provision of inappropriate gifts or hospitality, kickbacks, or investment opportunities offered to improperly induce the purchase of goods or services. Pfizer colleagues are not permitted to offer, give, solicit or accept bribes, and we expect our Business Associates, and those acting on their behalf in connection with work for Pfizer, to abide by the same principles. 

Anti-Bribery and Anti-Corruption Principles Governing Interactions with Private Parties and Pfizer Colleagues 

Business Associates must communicate and abide by the following principles with regard to their interactions with private parties and Pfizer colleagues: 

• Business Associates, and those acting on their behalf in connection with work for Pfizer, may not directly or indirectly make, promise, or authorise the making of a corrupt payment or provide anything of value to any person to induce that person to provide an unlawful business advantage for Pfizer. 
• Business Associates, and those acting on their behalf in connection with work for Pfizer, may not directly or indirectly, solicit, agree to accept, or receive a payment or anything of value as an improper inducement in connection with their business activities performed for Pfizer. 
• Pfizer colleagues are not permitted to receive gifts, services, perks, entertainment, or other items of more than token or nominal monetary value from Business Associates, and those acting on their behalf in connection with work for Pfizer.  Moreover, gifts of nominal value are only permitted if they are received on an infrequent basis and only at appropriate occasions. 

Reporting Suspected or Actual Violations 

Business Associates, and those acting on their behalf in connection with work for Pfizer, are expected to raise concerns related to potential violations of these International Anti-Bribery and Anti-Corruption Principles or the law.  Such reports can be made to a Business Associate’s primary point of contact at Pfizer, or if an Associate prefers, to Pfizer’s Compliance Group by  email at  corporate.compliance@pfizer.com or by phone at 1-212-733-3026.