Ethical Sales and Marketing
We are committed to responsibly promoting our products. We believe that it is important to educate patients and providers about health care treatments. Sales and marketing practices provide accurate and balanced information, so that physicians who prescribe our medicines make decisions based upon patient needs and the clinical value to individual patients. We follow an approach to sales and marketing that begins and ends with integrity in our business practices and transparency in our reporting about these practices.
Interactions with Health Care Professionals
Working with health care professionals is essential to delivering the medicines that improve people's health and well-being. The medical community helps us research our medicines and highlight areas of greatest need for innovative treatments. We also retain health care professionals in order to help educate their peers about health conditions and share information about our medicines. We are committed to conducting our work with these health care professionals with the utmost integrity, and we remain vigilant in looking for opportunities to strengthen our practices and procedures. Compliance training in interaction with health care professionals is integral to every colleague's training and is expanded in the case of those who work directly with the medical community.
Disclosing Payments to Health Care Professionals
Transparency in our relationships with health care professionals is of paramount importance to our business. In 2010 we published on our Web site Pfizer's payments and the value of non-cash items provided to licensed U.S. health care professionals, including in connection with speaking engagements and clinical research activities. Our disclosure of research payments further identified major academic institutions involved with clinical trials ongoing as of July 1, 2009, and the principal investigators on clinical trials beginning on or after that date. We are committed to ensuring that these payments and other transfers of value are disclosed in an accurate, clear and consistent manner. We do not pay health care professionals for prescribing our medicines or as an inducement for promoting our medicines, vaccines or nutritional products.
Pfizer is the first biopharmaceutical company to report payments for conducting Phase I–IV clinical trials, in addition to disclosing payments for consulting and speaking. We believe that sharing this information will help the public understand the full breadth of the important collaborative work done by industry, academia and health care professionals to advance health.
We also believe it is appropriate and ethical to fairly compensate health care professionals for the work they do on our behalf. We have robust compliance policies in place to ensure that all payments to health care professionals and research institutions constitute fair market value and are appropriate to the services performed.
Direct-to-Consumer Advertising
Responsible consumer advertising has proven value to help consumers engage in more informed conversations with their health care providers and thereby achieve better health outcomes. In all of our consumer advertising, we adhere to FDA regulations and guidelines. We follow strict internal standards that have been developed to ensure the information we share with consumers is evidence-based, balanced, easy to understand and directs people to engage their health care professional.
Our direct-to-consumer (DTC) practices are carefully designed to bring needed education to patients about prescription medicines, treatments they can only obtain with a prescription from their health care professional. We engage in regular consultation with health care professionals, patients and the groups that represent them to continually evolve and improve our approach to advertising. We strictly adhere to and exceed industry standards as outlined by the PhRMA Guiding Principles on Direct-to-Consumer Advertising About Prescription Medicines. And we continue to examine our internal protocols to ensure our DTC standards keep pace with industry standards, guidance, law and regulation.
Some highlights of our approach include systematic engagement with health care professionals to get their feedback on new campaigns early in our development process. We commit to ensuring clarity and transparency in our advertising which makes use of health care professionals. In addition, our CEO and Chief Compliance Officer sign an annual certification pledge to uphold the PhRMA Principles. We voluntarily submit our new TV advertising to the FDA for review prior to airing and educate physicians about a new product for at least six months after product approval and before introducing branded broadcast and print advertisements, so that physicians are equipped with accurate information to discuss new medicines with patients.
