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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Benchmarking Alert: Here is Pfizer’s anti-bribery policy

The New York-headquartered biopharmaceutical giant paid the DOJ and SEC $60 million in 2012 to settle FCPA offenses in Bulgaria, Croatia, China, Czech Republic, Italy, Kazakhstan, Russia, Serbia, Indonesia, Pakistan, and Saudi Arabia. How does Pfizer’s anti-bribery policy compare?

1. Pharma is a high-risk industry for bribes.

As a pharmaceutical company, Pfizer must be particularly sensitive to bribery and corruption issues when government officials are involved because governments are often both the regulators of Pfizer products and major customers.

2. Pay attention to books and records and internal controls.

No false or artificial entries may be made in the books and records for any reason, and all payments and transactions, regardless of value, must be recorded accurately.

3. No facilitating payments.

Under Pfizer policy, a facilitation payment means a nominal, unofficial payment to a Government Official for the purpose of securing or expediting the performance of a routine, non- discretionary governmental action. Such payments are illegal in most countries and Pfizer is committed to eliminating such payments from its business. Pfizer prohibits any Pfizer employee or Business Associate from offering or authorizing the offer of a facilitation payment (directly or indirectly). 

This is similar to Apple, Novartis,  MicrosoftVolkswagenAirbusGM, and 3M which ban all facilitating payments. Coca-Cola and Tesla might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. No commercial bribery.

Under Pfizer’s anti-bribery and anti-corruption policy, Pfizer’s employees and Business Associates must never engage in commercial bribery.

5. The extortion defense. 

Under Pfizer policy, when a payment is extorted by an imminent threat to the health, safety or welfare of a Pfizer employee, the demanded payment may be made. However,once the immediacy of the situation has been resolved, the payment must be reported to a member of Pfizer’s Legal Division, including information on the circumstances and amount of the payment. Any such payment always must be accurately and completely recorded in Pfizer’s books and records.

This is similar to GM and Microsoft, the only two other mentions of extortion we’ve seen.

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View more anti-corruption policy benchmarks here

Click here to view the Pfizer anti-bribery policy

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