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Corporate Compliance

Pfizer Compliance

Pfizer's Compliance Program represents a shared undertaking on the part of colleagues ranging from the highest levels of management to the most junior employees. 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.

Colleagues at Pfizer have an additional resource for addressing and resolving work-related concerns--Pfizer’s Office of the Ombudsman. Pfizer’s Office of the Ombudsman offers a place where colleagues at any level can get information and guidance to help them address and resolve work-related issues. Pfizer’s Ombudsman is informal, independent and neutral, and is not an advocate for any party, but an advocate for fair process.

Our Compliance Program incorporates the elements of an effective compliance program in accordance with the “Compliance Program Guidance for Pharmaceutical Manufacturers” (“OIG Guidance”), developed by the United States Department of Health and Human Services, Office of Inspector General (“OIG”).

Written Policies and Procedures

Some of the policies that provide our colleagues with guidance around their conduct of day-to-day operations include the following:

Policies & Procedures: FCPA and Anti-Corruption

Pfizer has international anti-bribery and anti-corruption policies and procedures4 that cover, among other things, colleagues' interactions with government officials and non-U.S. healthcare professionals, as well as third 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 diligence and auditing, follow 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.5

Chief Compliance and Risk Officer and Compliance Committees

Rady Johnson serves as the Company's Chief Compliance and Risk Officer and is responsible for overseeing Pfizer's global compliance program. In this capacity, Mr. Johnson reports directly to the CEO and makes regular reports to the Audit Committee and the Regulatory and Compliance Committee of the Board of Directors. Mr. Johnson heads the Compliance Division, which is responsible for administering all aspects of the Compliance Program, including training programs and compliance monitoring systems, developing informational colleague resources, and investigating potential violations of law or Company policy. The Executive Compliance Committee, which is made up of senior leaders from across the Company, provides oversight and support for Pfizer's efforts to ensure that its business is conducted appropriately around the world.

Effective Training and Education

Pfizer is committed to providing effective training to employees, managers, officers, and directors on the Compliance Program. Training resources include online compliance education, as well as online access to policies, including the Blue Book,6 the Orange Guide,7 and the White Guide.8

Effective Lines of Communication

Pfizer provides multiple channels for asking questions and raising compliance concerns. The Company has open door, anti-retaliation, and confidentiality policies to encourage and protect colleagues who raise a valid concern.

Open Door Policy

Pfizer adheres to an "Open Door Policy" and encourages colleagues to discuss all issues, concerns, problems, and suggestions with their immediate supervisors or other managers without fear of retaliation and with the assurance that the matter will be kept as confidential as possible.

Compliance Direct

At Pfizer, colleagues can contact the Compliance Division directly in any of the following ways:

Compliance Helpline

Where available and permitted by law, Pfizer's Compliance Helpline allows colleagues to report a concern or get information or advice anonymously. Where available, the Compliance Helpline can be reached by phone or online via the web-reporting tool. This resource is accessible 24 hours a day, 7 days a week, 365 days a year and is offered in multiple languages. The Compliance Helpline is operated by specially trained third-party representatives:

  • Compliance Helpline Number∗ (US and Puerto Rico): 1.866.866.PFIZ (7349)
    • ∗ The Compliance Helpline numbers for Pfizer locations outside the US and Puerto Rico can be provided upon request.
  • Compliance Helpline Web-Reporting Tool

Communication With Management About Compliance Issues

The Compliance Division communicates with senior management about compliance matters. The development and implementation of compliance policy benefit from input from company management.

Communication With the Audit Committee of the Board of Directors, the Regulatory and Compliance Committee of the Board of Directors, and the Full Board of Directors

Communication with the Audit Committee of the Board of Directors, the Regulatory and Compliance Committee of the Board of Directors, and the full Board is part of an effective compliance program. Members of the Board and its Audit and Regulatory and Compliance Committees are readily accessible to senior management, including the Chief Compliance and Risk Officer.

Internal Monitoring and Auditing

Internal monitoring and auditing of business processes are important parts of an effective Compliance Program to help detect and prevent potential violations of law or policy. The Corporate Internal Audit team maintains responsibility for auditing the company's policies and procedures, including those of the Compliance Program.

Enforcement Through Discipline Pursuant to Published Guidelines

Our Compliance Guidance documents (eg, Blue Book, Orange Guide, and White Guide) educate colleagues about our company's commitment to compliance. The Guidance documents put all colleagues, including management, on notice that failure to adhere to our compliance standards may have disciplinary consequences, up to and including termination of employment. If an investigation suggests that discipline may be warranted, appropriate action is taken.

Prompt Response and Corrective Action for Detected Problems

Our Compliance Program supports prompt response and corrective action for significant, potential, suspected or actual violations of law or policy. It is expected that compliance concerns referred through any of the many communication channels available (personal contact, email, Compliance Helpline, etc.) will be carefully reviewed, thoroughly and thoughtfully investigated in a timely manner, and appropriately resolved.

Pfizer Policies on Interactions With Health Care Professionals in California

Policies that regulate Pfizer colleagues' interactions with health care 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 we deem appropriate to meet the requirements of a highly regulated and complex health care 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 health care professional as defined under the Statute. Accordingly, Pfizer has modified certain policies and procedures that regulate interactions with covered medical and health care professionals in the State of California.

Additionally, in accordance with California Health and Safety Code Sections 119400, 119402 ("Statute"), our Compliance 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 health care professionals.

The Statute excludes from promotional expenditures, such items as drug samples given to medical or health care 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 health care 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 health care professional may receive in 1 year. In setting this limit, we have taken into account 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 more than 20 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 on 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 health care professionals in California. We do not believe it applies to medical or health care professionals practicing in other states and who are not licensed 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.


The PhRMA Code allows pharmaceutical companies to provide "items designed primarily for the education of patients or health care professionals if the items are not of substantial value ($100 or less) and do not have value to health care professionals outside of his or her 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 health care professional's prescribing practices." Our annual aggregate limit on certain promotion-related expenditures for purposes of California law excludes from calculation educational items that are permissible under the PhRMA Code.

Promotional Materials

Neither California Business & Professions Code §§ 119400-119402, nor the PhRMA Code, nor the OIG Guidance defines "promotional materials." For purposes of this Statute, Pfizer does not include in its definition of "promotional materials," documents and information that inform medical or health care professionals about Pfizer products, provide scientific and educational data, or support medical research and education.

Other Items or Activities

The Statute also subjects to the per-medical or health care professional annual aggregate limit all other "items or activities that the pharmaceutical company may give or otherwise provide to an individual medical or health care 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 health care professionals in connection with educational presentations. Historically, Pfizer has not limited attendance at these educational events. The per-medical or health care 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 health care professionals may attend during the reporting period for compliance with the annual aggregate limit.

Request a Copy

We have embedded in the structure of our Corporate Compliance Program, and established in our guidelines for interactions with health care professionals, the principles articulated in the OIG Guidance and PhRMA Code. As appropriate, and consistent with the law, we will amend and update our policies and this statement to ensure compliance with the law.

A description of Pfizer's Corporate Compliance Program, including the Company's written declaration and certification of compliance with California SB 1765, can be requested by calling the Compliance Division directly via telephone at (212) 733-3026, via Pfizer's Compliance Helpline number at (866) 866-7349 FREE (PFIZ), or by emailing us at