Practicing Ethical Sales and Marketing

Responsible promotional communication informs health care professionals, payers and patients about the benefits and risks of new treatments for diseases. Research conducted by the Harvard Medical School found that from 1997 to 2002, more than 70 million patients talked with a physician as a result of seeing an advertisement for a prescription medicine. One of four of these patients received a new diagnosis as a result of their conversation; this can lead to early treatment for high-priority conditions and help rein in overall health care costs. Pfizer is committed to evolving our advertising and marketing practices to better meet the needs of patients, doctors and other stakeholders in the health care system.

Global Policy on Interactions with Healthcare Professionals

In an effort to further solidify our commitment to base our interactions with health care 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 in 2005, the Global Policy governs our pharmaceutical operations around the world, including sales, marketing, medical, and research & development operations.

Available in 45 languages, the new Global Policy incorporates common legal and ethical standards from many of Pfizer's major markets, including the U.S. (Pfizer White Guide, PhRMA Code) and international (EFPIA Code on Promotion of Medicines, IFPMA Code of Pharmaceutical Marketing Practices) and applies them to our operations in 180 countries.

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 health care 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 (e.g., 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 health care 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 U.S. laws. In the event of a conflict between our Global Policy and other regulations, the more restrictive provision applies.

DTC Advertising

A year after announcing that we would improve direct-to-consumer advertising of prescription pharmaceuticals, we have delivered on that promise with television and print ads that include better communication about risks and alternative treatment approaches, dedicated advertising for Pfizer Helpful Answers^®, more disease-focused ad campaigns, and product ads that always include the product indication, benefits and risks.

These changes are a natural progression of Pfizer's commitment to make our consumer communications more effective in motivating patients to talk with health care professionals. One of the more visible improvements in print ads has been the addition of "Important Facts" to replace the fine print safety information. It is now even easier to read and understand important information about a medicine's side effects and safety information.

Note: This policy is subject to regular monitoring and evaluation.