not a legal document and is intended for informational use only.
It does not describe all applicable laws or Company policies or
give full details on any individual law or policy. Pfizer reserves the
right to modify, revise or alter any policy, procedure or condition
related to employment at its sole discretion and at any time
without notice and without revision of the
Blue Book
. The con-
tents of the
Blue Book
do not constitute the terms of a contract
of employment, and nothing contained herein should be con-
strued as a guarantee of continued employment or employment
for any particular period of time—employment at Pfizer is on an
at-will basis (subject to applicable laws). The information herein
can be changed or revoked unilaterally by the Company at any
time and is not all-inclusive. This online version of the
Blue Book
,
accessible through the Compliance website (integrity.pfizer.
com), supersedes all prior versions of the
Blue Book
.
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
SPEAK UP
2020 Blue Book: Pfizer’s Code of Conduct
3
At Pfizer, patients are at the center of everything we do. In fact, they are at the heart of our purpose:
Breakthroughs
that change patients’ lives.
Our ability to deliver breakthroughs depends upon each of us living by our four core values—
Courage, Excellence,
Equity,
and
Joy.
Together these values define our culture and guide our day-to-day interactions with customers,
business partners, and colleagues.
Pfizer’s
Blue Book
—our Code of Conduct—is designed to support these values, particularly Excellence, as
we perform
at our best together,
and Equity, as we always
act with integrity
.
The
Blue Book
describes how we operate and
guides the decisions we make in support of our purpose, including how
we speak up
when we see something that
concerns us—a behavior essential to our value of Courage. Seeking advice, raising concerns, and reporting misconduct
are critical to our ability to serve patients.
Each of us is responsible for understanding the
Blue Book
and adhering to our Code of Conduct every day. In doing so,
we demonstrate our continued commitment to living our values and earning the trust of the patients we serve.
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
SPEAK UP
2020 Blue Book: Pfizer’s Code of Conduct
4
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
ACT WITH
INTEGRITY
We Live Our Values & Are All Responsible
2020 Blue Book: Pfizer’s Code of Conduct
5
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
We Live
Our Values
& Are All
Responsible
At Pfizer, we do the right thing because patients’ lives depend on us. We act with integrity in
everything we do, and our Values guide us in making the right decisions ethically, thoughtfully, and
responsibly so that our business can appropriately meet patient and societal needs. Ethical decisions
promote trust and accountability for doing the right thing, both internally and externally.
To fully realize Pfizer’s purpose—breakthroughs that change patients’ lives—we have established
clear expectations regarding what we need to achieve for patients and how we will achieve those
goals. The “how” is represented by our four powerful Values—Courage, Excellence, Equity, and Joy—
that define our Company and our culture.
Each of us is responsible for living our Code of Conduct and holding each other accountable for
the same. The
Blue Book
applies to everyone, including all colleagues and officers of Pfizer and its
subsidiaries. In certain circumstances, this Code also applies to contingent workers. Managers set
the tone and model ethical behavior, cultivate an inclusive Open Door culture, and communicate the
expectation that each of us must live our Values of Courage, Excellence, Equity, and Joy every day.
Remember, not following our Code may harm our Company, colleagues, patients, customers,
communities, business partners, and investors. Violation of the Code or policies may result in
disciplinary action up to and including termination of employment.
The Code does not answer how to act in every situation, but it does outline the Values and principles
you need to guide you in your daily work. It also provides information on how to seek further
guidance, ask questions, and raise concerns.
Courage.
Breakthroughs start by challenging convention, especially in the face of uncertainty or
adversity. This happens when we think big, speak up, and are decisive.
Excellence.
We can only change patients’ lives when we perform at our best together. This happens
when we focus on what matters, agree who does what, and measure outcomes.
Equity.
We believe that every person deserves to be seen, heard, and cared for. This happens when
we are inclusive, act with integrity, and reduce healthcare disparities.
Joy.
We give ourselves to our work, and it also gives to us. We find Joy when we take pride, recognize
one another, and have fun.
Our Values guide us in our daily work. That is why they are incorporated into every section of this
Blue Book
.
We deliver
breakthroughs
the right way.
2020 Blue Book: Pfizer’s Code of Conduct
6
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
COURAGE
We Speak Up, Keep Open Doors, and Do Not Retaliate
We Raise Concerns
Ways for You to Speak Up
2020 Blue Book: Pfizer’s Code of Conduct
7
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
We Speak Up,
Keep Open
Doors, and Do
Not Retaliate
Speaking up requires Courage. As Pfizer colleagues, we share the privilege and responsibility of
ensuring we honor our Values and follow policies, including by speaking up when we have
questions or concerns. Speaking up helps us learn about issues and manage risks before they
become problems. The environment we need for breakthroughs depends on empowering each
of us to speak our mind.
Speak up if you have an idea. Speak up if you have a question. Speak up if you have a concern.
Our Open Door Policy provides many avenues for you to speak up without fear of retaliation,
harassment, discrimination, or other inappropriate behavior.
We do not tolerate retaliation against those who raise concerns at Pfizer.
If you seek advice, raise a concern, report misconduct, or provide information in an investigation,
you cannot be retaliated against for having done so. If you believe that you or another colleague
has been retaliated against for any reason, report the conduct using any method described in this
Blue Book
.
Learn More
• Corporate Policy 702 (Open Door Policy)
• Corporate Policy 201 (Integrity, Compliance
Reporting Obligations, No Retaliation Policy)
Our Commitment to
COURAGE
• We encourage reporting by not tolerating
retaliation in any form.
• We report all suspected retaliation.
Retaliation
is adverse action that
can take various forms, including
unfavorable work assignments, unfavorable
performance reviews, threats, harassment,
demotion, suspension, reduced compensation,
denial of benefits, or termination, among others.
We have the
Courage to speak
up if something
doesn’t seem
right.
8
2020 Blue Book: Pfizer’s Code of Conduct
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
If I report a concern to the
Compliance Division, can I expect
a response?
Yes. The Compliance Division’s goal is to respond
promptly to all questions and reported concerns
and take appropriate action to investigate.
Personal Disclosure Requirements
If you have been excluded, debarred,
or suspended, or become otherwise
ineligible to participate in U.S. federal healthcare
or procurement or non-procurement programs,
you must disclose this immediately to the
Compliance Division. You also must disclose if
you are under investigation for certain criminal
offenses and may become excluded, debarred,
or suspended.
We Raise
Concerns
We value, respect, and review all reports. If you suspect potential misconduct, report it. Potential
misconduct includes failing to follow laws, regulations or policies, or failing to live our Values. You
can raise concerns to your manager, another manager, Human Resources, the Legal Division, the
Employee Relations Group, or the Compliance Division. You can also make anonymous reports to
the Compliance Helpline (subject to local restrictions).
Your concerns will be analyzed and addressed by the appropriate Pfizer group according to our
policies and procedures. For example, significant potential, suspected, or actual violations of law
or policy—referable compliance issues (RCIs)—are investigated exclusively by the Compliance
Division.
Learn More
• Corporate Policy 201 (Integrity, Compliance
Reporting Obligations, No Retaliation Policy)
Our Commitment to
COURAGE
• We raise concerns when safety, quality, or
integrity are in question.
• Confidentiality is maintained to the fullest
extent possible.
We live
our Values.
2020 Blue Book: Pfizer’s Code of Conduct
9
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
Department
Contact
Management
Discuss questions, ideas, and concerns without fear of reprisal. Many people are available to help;
consult the person with whom you feel most comfortable.
• Your manager or someone else in your division
• Any other manager
• Company leadership
Human Resources
Contact Human Resources (HR) for any concerns you may have.
• Your local HR representative
• Corporate HR
Employee Relations
Contact Employee Relations directly to ask questions or raise concerns. Employee Relations are
neutral and objective investigators who uphold Company Values and policies in support of the
Open Door Policy.
• Employee Relations (where available)
Compliance Division
Contact the Compliance Division directly to ask questions, present ideas, or raise concerns. The
Compliance Division website includes additional policies, procedures, and resources.
• Your Compliance Division contact
•
corporate.compliance@pfizer.com
• Compliance Division Website:
http://integrity.pfizer.com
• +1-212-733-3026
• +1-917-464-7736 (secure fax)
• 235 East 42nd Street, New York, NY 10017
Helpline
The Compliance Helpline provides a way to report concerns or get advice, 24 hours a day, 7 days a
week, 365 days per year. Anonymous reporting is available in many locations, subject to local laws.
• Visit
pfizer.ethicspoint.com
to make a report
• Visit
helpline.pfizer.com
for local phone numbers
• Visit
raisingcomplianceconcerns.pfizer.com
for information for your location
• In the U.S.: 1-866-866-PFIZ (7349)
Office of the Ombuds
Pfizer’s Office of the Ombuds provides a safe, informal place where colleagues can confidentially
get information and guidance to help address and resolve work-related issues. Conversations with
the Office of the Ombuds are “off-the-record” and not disclosed to anyone unless they involve a
risk of physical harm.
• U.S.: +1-855-PFE-OMBD (1-855-733-6623) or
Ombuds@pfizer.com
• Ex-U.S.:
Ombuds@pfizer.com
• Visit
Ombuds.pfizer.com
for more information and local phone numbers
Ways for You
to Speak Up
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
EXCELLENCE
For Our Patients
With Our Products and Product Development
In How We Conduct Our Business
In Following the Letter and Spirit of Laws
2020 Blue Book: Pfizer’s Code of Conduct
11
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
•
Are you interacting with a
Patient Organization?
Know
who you are engaging with.
•
What is the nature of the interaction?
Think through your decision-making.
•
What is the impact of your interaction?
Think about the impact to yourself, your
colleagues, the Company, and the patient or
Patient Organization.
• Our interactions with Patient Organizations
must be based on mutual respect and
adherence to high ethical standards, and reflect
an understanding that Patient Organizations
are independent entities whose work is guided
by their own interests and mission.
All individuals deserve access to
quality healthcare and medicines
prescribed by their physicians. Charitable
contributions to Independent Charity Patient
Assistance Programs (“ICPAPs”) can provide a
means to help patients access their medicines
by providing assistance for co-pay, deductible
and/or premium obligations for prescriptions.
However, any such donations are subject to
strict legal requirements. To ensure compliance
with laws, Pfizer policy places strict limits on
colleagues’ interactions with, donations and
allocations to, and data from or about ICPAPs.
Additionally, Pfizer’s Global Health & Patient
Access group has the sole responsibility for
budgeting and allocating ICPAP donations.
Interactions With Patients and Patient Organizations
Addressing the unique needs and challenges of patients is paramount to what we do, because
patients are at the heart of our purpose: Breakthroughs that change patients’ lives. The ability to
interact with patients and Patient Organizations is a privilege that helps us develop breakthroughs
tailored to patients’ needs and provides us with insights into disease burden. When we interact
with patients and Patient Organizations, we do so respectfully and consistent with applicable
laws, regulations, industry standards and codes, ethical considerations, and our Values.
Given complex and evolving legal, regulatory, and industry requirements on interactions with
patients and Patient Organizations, including interactions relating to certain patient assistance
programs, contact Legal and Compliance within your market for more guidance.
For Our
Patients
Learn More
• Global Guidelines on Interactions with Patients
and Patient Organizations
• Corporate Policy 803 (Contributions to
Independent Charity Patient Assistance Programs)
Patient Organizations
are generally independent
not-for-profit entities that
represent the needs of people living
with medical conditions, their
families, or other caregivers.
2020 Blue Book: Pfizer’s Code of Conduct
12
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
Interactions With Healthcare Professionals and Customers
We interact with healthcare professionals and other customers in many ways, including
through research and development, market access, educational, and promotional activities.
We are committed to the highest standards of excellence and we act with integrity and
transparency in every aspect of our relationships with healthcare professionals.
Our Commitment to
EXCELLENCE
• We consider how our interactions with
customers may appear and do not engage
in illegal or unfair activities, such as false or
misleading advertising, bribery or corruption, or
making unfair comments about competitors’
products.
• We are committed to acting with integrity
in all marketing practices, including labeling,
promotional programs, product samples, and
communications with stakeholders.
• We provide timely and honest product
information to patients, consumers, healthcare
professionals, and regulators worldwide,
providing appropriate uses for our products
and the efficacy and safety data relating to
those uses.
• We recognize our interactions with healthcare
professionals can cause apparent or actual
conflicts of interest; therefore, we support the
disclosure of financial and other interests and
relationships with healthcare professionals in
research, education, or clinical practice.
For Our
Patients
Learn More
• Corporate Policy 201 (Integrity, Compliance
Reporting Obligations, No Retaliation Policy)
• My Anti-Corruption Policies and Procedures
(MAPP)
• Corporate Policy 207 (Global Policy on
Interactions with Healthcare Professionals)
• Global Content Policy – Commercial Standards
for Promotional Materials
• GCO Policy Exchange
The definition of
“healthcare professional”
includes physicians, nurses,
pharmacists, and any others who
administer, prescribe, purchase,
recommend, or are in a position to
influence the use of our products.
13
2020 Blue Book: Pfizer’s Code of Conduct
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
With Our
Products
and Product
Development
Research and Development
Our purpose is to bring innovative therapies to patients that significantly improve their lives. Our
priorities are ensuring the safety and protecting the rights of those who take part in our clinical
trials and upholding the highest ethical, scientific, and medical standards in all our research and
development activities.
We are all responsible for acting in a manner consistent with Pfizer’s high expectations for
excellence and integrity in research and development.
Our Commitment to
EXCELLENCE
• We are committed to conducting our research
and development in compliance with all
applicable laws and regulations and ethical
guidelines related to good laboratory practices
(GLP) and good clinical practices (GCP).
• We are committed to maintaining the
integrity and quality of clinical data from our
sponsored studies to ensure that our regulatory
submissions are founded on data of the highest
quality.
• We are committed to protecting the health,
well-being, and safety of research participants.
• Whenever possible, we seek alternatives to
animal testing and support the development
and adoption of non-animal validated test
methods to assess the safety and efficacy of
potential new products. Where animal testing is
needed, we maintain high standards of animal
care and welfare consistent with or exceeding
those required by law and relevant external
oversight bodies.
We innovate—
courageously
and responsibly.
14
2020 Blue Book: Pfizer’s Code of Conduct
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
Manufacturing and Supply Quality
Our patients rely on Pfizer products to improve health and enhance the quality of their lives.
This can only happen if our products are of high quality, safe, and effective.
We are committed to ensuring that our products are manufactured and supplied to high
standards of quality, safety, and efficacy, assured through deployment of our robust quality
management systems and our focus on the integrity of our data.
Our Commitment to
EXCELLENCE
• We conduct manufacturing operations in
compliance with applicable regulatory
requirements, good manufacturing practices
(GMP), and our internal rigorous quality
standards.
• We require that suppliers and partners operate
in compliance with applicable regulatory
requirements and GMP standards, and we
conduct audits and oversight of our supply
chain to ensure the quality, safety, and efficacy
of our products.
Learn More
• Corporate Policy 114 (Corporate Quality
Policy)
With Our
Products
and Product
Development
We keep quality
and integrity
at the heart
of what we do,
always.
Learn More
• Corporate Policy 114 (Corporate Quality Policy)
15
2020 Blue Book: Pfizer’s Code of Conduct
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
Safety Reporting
We are committed to providing products that are safe, effective, and of the highest quality. That
is why we all share responsibility for reporting safety, quality, and performance issues concerning
Pfizer products, no matter how we learned of the issue.
If you become aware of an adverse event or other issue with a Pfizer product, make a product
safety report within 24 hours of receiving the information.
Data Integrity
As a science-based Company, the integrity of our data is of critical importance. Its accuracy,
completeness, and trustworthiness provide assurance to our regulators, patients, and customers
that our products and processes are of the highest quality—safe, effective, and protective of our
patients, employees, and communities.
We maintain the integrity of our data using five key principles: Attributable, Legible,
Contemporaneous, Original, and Accurate (the ALCOA principles).
When our data is recorded
in a manner consistent with ALCOA, it means that who recorded the data is known (attributable);
that it can be reliably read, viewed, or used (legible); that it was recorded at the time of the event
(contemporaneous); that it is the source or authentic record and not an unauthorized copy
(original); and that it is accurate.
With Our
Products
and Product
Development
At a dinner party, a Pfizer
colleague learns that her friend
used a Pfizer product and
experienced a headache. Does she need
to report this?
Yes. Regardless of how she learns of the event, the
severity, or whether she thinks it was a side effect
of the Pfizer product, it is her responsibility to
report it within 24 hours of learning about it.
Learn More
• Corporate Policy 903 (Your Responsibility to
Report Information About the Safety, Quality,
and Performance of Pfizer Products)
• Your Reporting Responsibility (YRR) website
• How to Report
We always do
the right thing—
because
patients’ lives
depend on us.
2020 Blue Book: Pfizer’s Code of Conduct
16
ACT WITH INTEGRITY
SPEAK UP
CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
In How We
Conduct Our
Business
Business Partners and Suppliers
We work with third parties—suppliers, distributors, and other business partners—around the
world to help us achieve our strategic goals. Engaging with third parties, however, can create
compliance, financial, safety, information security, and other risks. These risks may result in
operational disruption, regulatory penalties, or reputational damage. Performing due diligence
and responsible selection and management of our third parties is core to how we do business.
Pfizer holds its business partners to high standards, and they must comply with all laws and
relevant policies and procedures that apply to their work conducted on Pfizer’s behalf.
Learn More
• Corporate Policy 113 (Environmental Health
and Safety Policy)
• Pfizer Supplier Conduct Position Statement
• Pfizer Supplier Conduct Principles
• My Anti-Corruption Policies and Procedures
(MAPP)
• Third Party Risk Management (TPRM)
Resource Center
Our Commitment to
EXCELLENCE
• We carefully manage risks related to engaging
third parties, including through controls, and
policies that help us identify, assess, and
mitigate the risks we may encounter.
• We partner with external suppliers that are
committed to operating in a responsible and
ethical manner, respecting the rights of the
individuals they employ, and helping to protect
the environment.
• We expect our suppliers to operate in a manner
consistent with our Supplier Conduct Principles
and the Pharmaceutical Supply Chain Initiative
(PSCI) Principles for Responsible Supply Chain
Management.
2020 Blue Book: Pfizer’s Code of Conduct
17
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CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
Conflicts of Interest
We are accountable for avoiding situations that present potential or perceived conflicts of interest
between our personal interests and those of Pfizer. A conflict of interest arises when we place our
personal, social, financial, or political interests before the interests of the Company.
Many potential conflicts of interest can be resolved. First, we must disclose any potential conflicts
to our managers. Managers must then determine next steps, including consulting with Legal,
Compliance, and Human Resources when potential conflicts are significant or complex.
Contact your manager or Compliance to disclose the potential conflict. Together you can
determine the best solution.
Learn More
•
Corporate Policy 203 (Conflicts of Interest (COI)
Policy and local and divisional COI policies and
procedures)
• My Anti-Corruption Policy and Procedures
(MAPP)
• Corporate Policy 301 (Travel, Entertainment
and Other Business-Related Expenses)
• Corporate Policy 102 (Purchasing Policy and
Procedure)
In How We
Conduct Our
Business
Our Commitment to
EXCELLENCE
• We do not allow outside businesses or other
interests to affect our objectivity, motivation,
or performance.
Potential conflicts of interest
include:
• Employment with a competitor or potential
Pfizer customer or supplier
• Investing in a Pfizer supplier
• Having a family member that owns a supplier
that Pfizer might use, even if you do not have
decision-making authority
• Receiving a gift from a business associate or
supplier of Pfizer, or someone who is seeking
to work with Pfizer
• Serving on a board of a company, including
a local non-profit in the healthcare industry
• Otherwise taking advantage of Pfizer’s
corporate opportunities for personal gain
We innovate
with a risk
management
mindset.
2020 Blue Book: Pfizer’s Code of Conduct
18
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CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
Company Assets, Records, and Information
One way we protect Pfizer, each other, and our patients is by protecting Company assets. These assets include, for example, physical and
intellectual property, equipment, services, records, ideas, and Pfizer sensitive information.
We are accountable for ensuring appropriate use of Pfizer systems and networks to securely create, transfer, or store Pfizer-related business
information. This includes connecting only approved technologies, devices, and applications to the Company network.
Our Commitment to
EXCELLENCE
• We secure all confidential information,
whether spoken or written, when working
remotely or in an open environment, and
dispose of information properly.
• We use only authorized software, devices, and
applications approved by Pfizer.
• We limit our personal use of Pfizer information
systems.
• We comply with Pfizer’s corporate policies
regarding safeguarding sensitive information,
record retention, information incident reporting,
and cybersecurity.
In How We
Conduct Our
Business
Take appropriate precautions to
protect your Pfizer devices and data,
even within Pfizer facilities. If you work in
an open space environment, activate the system
lock when leaving the device. Do not leave your
devices unattended in any location where security
is not reasonably assured. In public settings,
ensure that sensitive information cannot be
viewed or overheard by others.
Learn More
• Corporate Policy 401 (Global Safeguarding
Sensitive Information Policy)
• Corporate Policy 403 (Acceptable Use of
Information Systems)
• Corporate Policy 405 (Records & Information
Management Policy and Procedure)
• Corporate Policy 411 (Information Incident
Response Policy)
• Corporate Policy 412 (Cybersecurity Policy)
• Enterprise Records and Information
Management
• Enterprise Record Retention Schedule
• Protect Pfizer
• Legal Hold Listing
Prohibited activities: You may not
use Pfizer information systems or
devices to:
• Harass, discriminate, or create a hostile
workplace
• View or otherwise post data that is defamatory,
illegal, pornographic, or obscene
• Perform activities that interfere with work or
result in the loss or damage of work or systems
• Solicit colleagues for any unauthorized purpose
• Record communications without authorization
Pfizer must protect our information and
operations from misuse, data breaches,
and other security threats, which can have
serious negative consequences to the Company,
our employees, and our customers. In accordance
with applicable law, Pfizer uses a variety of tools
and processes to monitor and assess the use of
and to help protect Pfizer information systems
and data.
2020 Blue Book: Pfizer’s Code of Conduct
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MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
Learn More
• Copyright Compliance Guidelines
• Intellectual Property Portal
If intellectual property is
protected in one country, is it
protected in other countries?
Not necessarily. For example, patents and
trademarks are territorial rights. The Legal
Division’s Intellectual Property Group tracks the
status of the Company’s assets and can help
you determine whether something has protected
status in a country.
Intellectual Property
Protecting Pfizer’s intellectual property is essential to maintaining our competitive advantage.
We support the establishment, protection, maintenance, and defense of Pfizer’s intellectual
property rights and use those rights in a responsible way. We also respect the intellectual property
of others.
In How We
Conduct Our
Business
Our Commitment to
EXCELLENCE
• We enforce Pfizer’s intellectual property rights
in a responsible way.
Intellectual property
includes
patents, trademarks, trade dress, trade
secrets, and copyrights, as well as scientific
and technical knowledge, know-how, and
experience.
2020 Blue Book: Pfizer’s Code of Conduct
20
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CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
Personal Data
We protect personal data, including that of colleagues, third parties, and customers. In addition
to personal data of our colleagues for employment purposes, Pfizer also is entrusted with personal
data for purposes of conducting research, pharmacovigilance, and other business activities.
We are accountable for protecting personal data and for only using that data in accordance with
Pfizer’s policies and procedures, and applicable laws and regulations.
Learn More
• Corporate Policy 404 (Protecting the Privacy of
Personal Data)
• Corporate Policy 411 (Information Incident
Response Policy)
• Privacy Office: privacy.pfizer.com
• GSOC: datasecurity.pfizer.com
What if I must share personal
data with third parties to meet
business needs?
You must ensure that third parties can protect
personal data and will use it only to provide
services to Pfizer, and that there is an appropriate
contract in place that addresses protection
of personal data. In some jurisdictions, other
requirements may apply. Seek guidance from
Legal before providing any personal data
to third parties.
In How We
Conduct Our
Business
Our Commitment to
EXCELLENCE
• We collect and use the minimum amount of
personal data necessary to achieve our business
purposes and keep it only as long as necessary
to achieve those purposes.
• We share personal data only with individuals
who have a legitimate need for it and will
protect it.
• We report concerns about the inappropriate
disclosure of personal data to our managers
and Pfizer’s Global Security Operations Center
(GSOC).
Personal data
is
information that can
directly or indirectly identify
an individual, such as a name,
contact information, or health-
related and genetic information.
2020 Blue Book: Pfizer’s Code of Conduct
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CONTENTS
MESSAGE FROM OUR CEO
COURAGE
EXCELLENCE
EQUITY & JOY
Social Media
One of the most powerful tools we have to communicate Pfizer’s stories of innovation, patient
centricity, and colleague commitment is social media. We are all accountable for using social media
responsibly, whether creating or using social media in our personal lives or on behalf of Pfizer.
Financial Integrity
Accurate business records are essential to our business operations and safeguarding investor
confidence, and we maintain strong internal controls to ensure the accuracy, completeness, and
reliability of Company accounting records and publicly filed financial statements.
We each must ensure our business records are correct and accurately reflect our work—from time
sheets and invoices, to expense reports and benefits records. We all must watch for suspicious or
inaccurate transactions, invoices, or payments made to or on behalf of Pfizer. This helps Pfizer
provide full, accurate, and timely financial and other disclosures to the public and governments
around the world.
In How We
Conduct Our
Business
Learn More
• Corporate Policy 511 (Integrity of Pfizer’s Books
and Records)
• Corporate Policy 407 (Social Media Policy)
Our Commitment to
EXCELLENCE
• We do not disclose material non-public
information or other confidential, proprietary,
or personal information on social media.
• We do not reference Pfizer products or content
related to specific pipeline or in-line products on
social media unless our use and reference has
been approved by Legal.
We achieve
Excellence
when we are
accountable for
our actions.
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External Inquiries
Government
We fully cooperate with government authorities in connection with proper requests for information.
Non-routine government requests may expose Pfizer or colleagues to civil or criminal liability, so
we immediately notify a member of the Legal Division, Government Litigation Group (within the
Legal Division), and the Compliance Division if we are contacted by any government authority for
such information at a Pfizer facility, at our homes, or otherwise.
Media, Analyst, Investor, and Public
We are committed to delivering accurate and reliable information to the media, financial analysts,
investors, and other members of the public. Therefore, only Global Media Relations is authorized
to answer questions from the media, and only Investor Relations is authorized to answer
questions from financial analysts and investors.
Learn More
• Corporate Policy 602 (Requests for Information
or Facility Visits)
• Corporate Policy 604 (Treatment of Material
Non-Public Information)
• Media inquiries: Global Media Relations Press
Office at +1-212-733-1226
• Analyst and investor inquiries, including those
related to Corporate Governance: Investor
Relations at +1-212-733-2668
In How We
Conduct Our
Business
We achieve
Excellence
when we know
our standards
and live by them.
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Our industry is subject to many rules and regulations designed to protect patients and consumers, improve the quality of medicines and
healthcare services, and help eliminate fraud and improper influence on medical judgment. We demonstrate our commitment to Excellence by
following all laws and regulatory requirements governing our activities, including in the development, manufacturing, distribution, marketing,
government contracting, sale, and promotion of our products.
Anti-Corruption, Anti-Bribery, and Anti-Kickback Laws
We conduct our business in a transparent and ethical manner. Pfizer prohibits all forms of bribery and corruption, whether by colleagues or our
business partners.
Colleagues and business partners must never offer, promise, authorize, or provide a payment or benefit that is intended to improperly influence a
government official, healthcare professional, or any other person, including commercial entities and individuals, in exercising their responsibilities.
In our dealings with healthcare professionals employed by or affiliated with government or regulatory authorities, care is taken to ensure that
such dealings comply with all applicable laws, regulations, professional requirements or industry codes of conduct or practice, including local
transparency and anti-kickback regulations.
In Following
the Letter and
Spirit of Laws
Why do I need to be well informed
about my business partner?
Knowing our partners includes
understanding healthcare professional and
government official status and may also
include understanding professional qualifications,
employment position, and the ability to influence
government decisions that could benefit Pfizer’s
business. We must ensure that our business
partners meet Pfizer’s high standards for
expertise and integrity. We also must identify
any real or perceived risks associated with our
business partners. Collecting this information
enables us to assess the appropriateness of our
interactions, and identify and manage any risks.
Our Commitment to
EXCELLENCE
• We ask ourselves whether there is a legitimate
purpose for entering into a transaction.
• We ensure that every transaction is of
appropriate value and that every interaction
is permitted under local rules.
• We exercise great care when engaging with
government employees or private individuals
who have real or perceived ability to affect
decisions that impact Pfizer’s business.
• We take ownership and responsibility in Pfizer’s
Antitrust and competition laws protect free enterprise and prohibit interactions between Pfizer and our competitors that affect prices, terms or
conditions of sale, or fair competition. We ensure fair competition in all our business dealings, including, among other things, distribution agree-
ments, rebates and discounts to customers, patent, copyright, and trademark licenses, territorial restrictions on resellers, and pricing policy generally.
We are committed to competing fairly and following the antitrust and competition laws of all countries in which we operate. Laws vary and are
sometimes complex, so we consult with the Legal Division before interacting with competitors or engaging in business dealings which could unfairly
restrict trade.
We also only collect and use business information about other companies in a manner that is ethical, lawful, and meets confidentiality obligations.
In Following
the Letter and
Spirit of Laws
Our Commitment to
EXCELLENCE
• We do not permit direct or indirect discussions
or contact with competitors about pricing,
costs, terms or conditions of sale, or other
competitively sensitive information.
• We do not permit direct or indirect discussions
or contact with suppliers and customers that
unfairly restrict trade or exclude competitors
from the marketplace
• We do not allocate markets or customers with
competitors.
• We do not engage in the boycott of customers
or suppliers.
• We never use, or ask any third party to
use, unlawful or unethical means, such as
misrepresentation, deception, theft, spying
or bribery to gather information about our
competitors.
I want to know what patient
recruitment exclusion criteria a
competitor is using in a clinical
trial. That information is not public. Can I
pose as a potential patient recruit, call the
research site, and ask questions?
No. Misrepresentation—not disclosing that you
are a Pfizer colleague or posing as someone you
are not—is an unethical way to gain access to a
competitor’s confidential information. Before you
engage in any competitive intelligence primary
field research, consult with the Legal Division or
Competitive Intelligence to confirm that your
strategy is legal and ethical.
A friend and former Pfizer
colleague now works for a Pfizer
competitor. Is it okay to discuss
how her company deals with managed care
companies?
No. Competitively sensitive information may not
be discussed with friends or former colleagues
employed by competitor companies, whether in
a business or a social setting.
Learn More
•
Corporate Policy 603 (Compliance with
Antitrust Laws)
• Corporate Policy 121 (Competitive Intelligence
Policy and Procedure)
Trade association
meetings
and
other
industry gatherings
can pose
certain risks, as they bring together
competitors who might discuss matters of mutual
concern. Even joking about inappropriate topics—
such as marketing or pricing strategies—could
be misinterpreted. If any kind of anti-competitive
discussion arises, you should refuse to discuss the
matter, leave the conversation immediately, and
report the incident.
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Insider Trading Laws
Securities laws and Pfizer policy prohibit us from disclosing or using any material non-public or “inside” information that we acquire during our
employment at Pfizer.
We do not use material, non-public information to buy or sell the securities of Pfizer or any other company with which Pfizer has or may be
considering a relationship (such as a customer, supplier, research partner or potential acquisition or collaboration candidate), before this
information is known publicly. We also do not give inside information to anyone else so that they can do so.
Learn More
• Corporate Policy 604 (Treatment of Material
Non-Public Information)
• Corporate Policy 401 (Safeguarding Corporate
Proprietary/Confidential Information)
• Corporate Policy 605 (Trading in Pfizer Stock
Derivatives)
• Corporate Policy 206 (Compliance with Global
Trade Control Laws)
• Global Trade Controls Center of Excellence
I am working with a co-promote
partner, and I’ve become aware
that our partner is on the verge
of a major scientific breakthrough. Can I
purchase some stock in our partner?
No. Neither you nor anyone who lives in your
household or is financially dependent on you
can purchase this stock until the first business
day after the information you have is known to
the public. You also cannot give this information
to anyone else so that they can trade on that
information.
In Following
the Letter and
Spirit of Laws
Material information is any
information that a reasonable
investor would consider important in
deciding whether to buy, sell, or hold securities.
Information is considered non-public until it
has been adequately disseminated to the public
and the public has had time to absorb the
information.
Global Trade Control Laws
We are all responsible for complying with import, export control, and economic sanctions laws that govern the transfer of certain products, items,
software, and technology, as well as the performance of some services and interactions with third parties. Global trade control laws may restrict
Pfizer’s sales, investments, transactions, research, charitable contributions, and business activities with certain markets, entities, or individuals.
We direct all questions or concerns about global trade control laws to Pfizer’s Global Trade Control Center of Excellence.
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EQUITY &
JOY
We Respect Human Rights
We Prioritize Health and Safety, and Protect the Environment
We Support the Communities in Which We Work
We Embrace Diversity, Equity & Inclusion
We Do Not Tolerate Discrimination, Harassment, or Retaliation
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We Respect
Human
Rights
Pfizer is committed to conducting business in an ethical and responsible manner, which includes
respecting internationally recognized human rights. In honoring our commitment, we seek to
prevent and mitigate adverse human rights impacts in our global operations, and remediate any
adverse human rights impacts we may inadvertently cause or perpetuate. Wherever we can,
we also seek to advance human rights. Our approach to human rights risks is informed by
international standards, industry best practice, and expert assessments.
Learn More
• Human Rights Policy Statement
• Human Rights FAQ
Our Commitment to
EQUITY
• Our responsibility to respect human rights
extends throughout our operations, from lab
to patient, including our diverse global supply
chain of numerous local suppliers.
• In line with the UN Guiding Principles on
Business and Human Rights, Pfizer’s human
rights policy statement focuses on addressing
risks that could have the most severe impact on
people: our patients, our colleagues, the workers
of our business partners, and the communities
in which we operate.
Human rights
are fundamental rights
and freedoms that all people are entitled
to, regardless of race, sex, nationality,
ethnicity, language, religion, or any other status.
These rights are enshrined in the International Bill
of Human Rights and other international treaties
and instruments.
Pfizer is committed to fairness, cooperation, teamwork, and trust. We do not tolerate hostility, harassment, or retaliation. Our global policies prohibiting all forms of inappropriate
behavior are intended to create a workplace that promotes a positive and productive environment that is Equitable and Joyful for all.
This commitment to promoting Equity and Joy extends beyond our workplace to the communities in which we operate and the patients we serve. Pfizer is committed to
sustainable and ethical business operations. We recognize the importance of Environmental, Social and Governance (ESG) issues as part of our overall business strategy and work
to integrate ESG perspectives into our decision-making and governance processes. We are committed to respecting human rights, taking responsible climate action, reducing our
environmental impact, lessening healthcare disparities, and ensuring health, safety, diversity, inclusion, fairness, cooperation, and trust across our operations and supply chain.
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We Prioritize
Health and
Safety, and
Protect the
Environment
Protecting the environment, and the health and safety of our colleagues, contingent workers,
visitors and the communities in which we operate is a business priority and is core to Pfizer’s
Values of Excellence and Equity. We are committed to integrating climate action and
sustainability into the lifecycle of our medicines to address global health challenges and
preserve resources for future generations.
Learn More
• Corporate Policy 113 (Environment, Health, and
Safety Policy)
• Global Environment, Health & Safety Standards
Our Commitment to
EXCELLENCE & EQUITY
• We are committed to running safe, compliant,
and sustainable operations that comply with
Environmental, Health and Safety (EHS) laws
and internal standards.
• We actively seek and act upon meaningful
opportunities to reduce risk and improve our
EHS performance.
• We are committed to selecting business
partners with consideration of their ability
to run safe and environmentally responsible
operations.
• We are committed to educating, training,
and motivating colleagues to work in a safe,
compliant, and environmentally responsible
manner.
We take pride
and feel Joy in
our reputation
for integrity.
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We
Support the
Communities
in Which
We Work
We are committed to actively participating in and improving the communities in which we do
business. We believe better health is possible for everyone, everywhere. We seek to improve the
well-being of people through responsible business actions and through sustainable social
investments designed to improve access to medicines, vaccines, and quality health services and
to reduce healthcare disparities.
Learn More
• Corporate Policy 801 (Global Charitable
Contributions Policy)
• Commitment to Global Health
• Global Health Fellows
Our Commitment to
EQUITY & JOY
• We believe that people are the heart of Pfizer,
and for our colleagues, contributing does not
begin and end in the workplace.
• We apply our research, medicines, vaccines,
funds, and the expertise of our people to make
a meaningful difference in people’s lives.
• Through partnerships with organizations,
governments, and foundations, we work to
address health disparities, create bridges
and connections, and break down barriers to
improve access to quality healthcare in our
communities at home and abroad.
• We place colleagues in short-term fellowships
with international organizations to bring about
meaningful and systematic improvements in
healthcare.
• We find power and strength in community
by coming together in the places we live and
work to contribute financial support, time, and
expertise.
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We Embrace
Diversity,
Equity
& Inclusion
At Pfizer, Equity means that every person deserves to be seen, heard, and cared for. This happens when we are inclusive, act with integrity, and
reduce healthcare disparities.
We celebrate our differences with Joy and take action to advance diversity across our workforce and our business. We also are committed to
ensuring that our workforce and business model reflect the diversity of the patients we serve, by employing a diverse array of colleagues, engaging
diverse suppliers, and including diverse individuals in our research and clinical studies.
We are committed to providing equal employment opportunities to all of our job applicants and colleagues, and we treat them without regard to
personal characteristics such as race, color, ethnicity, creed, ancestry, religion, sex, sexual orientation, age, gender identity or gender expression,
national origin, marital status, pregnancy, childbirth or related medical condition, genetic information, military service or veteran status, medical
condition (as defined by applicable law), presence of a mental or physical disability, or other characteristics protected by applicable laws.
Learn More
• Corporate Policy 703 (Equal Opportunity Policy)
• Corporate Policy 103 (Pfizer Supplier Diversity
Initiative)
Our Commitment to
EQUITY & JOY
• We expect our managers to promote
standards of equitable employment and to
report any potential violations of Pfizer’s
Equal Opportunity Policy.
• We seek out and hire diverse talent by
partnering with external organizations that
provide rich engagement opportunities with
people of varying backgrounds, ethnicities,
and other unique traits.
• We celebrate the unique qualities, perspectives,
and life experiences that define us as
individuals, and maintain a robust Supplier
Diversity Program so that underrepresented
or disadvantaged businesses have an equal
opportunity to compete for our business.
• We include individuals of varied races,
ethnicities, ages, and genders in clinical trials
to help improve the completeness and quality
of demographic subgroup data reporting and
analysis.
We advance
Equity when we
seek diverse
perspectives.
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We Do
Not Tolerate
Discrimination,
Harassment,
or Retaliation
We promote and value a work environment free of discrimination, harassment, and retaliation,
including bullying and mobbing as defined by applicable laws. All workplace decisions are made
without regard to personal characteristics protected by applicable laws.
Our managers must maintain a work environment that is free of harassment, discrimination,
retaliation, and bullying, and must report any such conduct of which they become aware.
