WHEREAS, we believe in full disclosure of Pfizer’s direct and indirect lobbying activities and expenditures to assess whether Pfizer’s lobbying is consistent with its expressed goals and in shareholder interests.

RESOLVED, the shareholders of Pfizer request the preparation of a report, updated annually, disclosing:

1. Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications.

2. Payments by Pfizer used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including the amount of the payment and the recipient.

3. Pfizer’s membership in and payments to any tax-exempt organization that writes and endorses model legislation.

4. Description of management’s and the Board’s decision-making process and oversight for making payments described in sections 2 and 3 above.

For purposes of this proposal, a “grassroots lobbying communication” is a communication directed to the general public that (a) refers to specific legislation or regulation, (b) reflects a view on the legislation or regulation, and (c) encourages the recipient of the communication to take action with respect to the legislation or regulation. “Indirect lobbying” is lobbying engaged in by a trade association or other organization of which Pfizer is a member.

Both “direct and indirect lobbying” and “grassroots lobbying communications” include efforts at the local, state and federal levels.

The report shall be presented to the Governance & Sustainability Committee and posted on Pfizer’s website.

Supporting Statement:
Pfizer remains a top lobbying spender in Washington, in state capitols and internationally. From 1999-2018, Pfizer spent $219 million on federal lobbying—the most of all drug makers.1 This figure does not include state lobbying, where Pfizer lobbies in all 50 states but disclosure is uneven or absent. Pfizer actively lobbies internationally as well, though disclosure remains lacking.

Pfizer sits on the boards of the Chamber of Commerce and the Pharmaceutical Research and Manufacturers of America (PhRMA), which together have spent over $2 billion on lobbying since 1998. Pfizer does not disclose its payments to trade associations and social welfare organizations, or the amounts used for lobbying, including grassroots.

We are concerned that Pfizer’s lack of disclosure presents reputational and regulatory risks when its lobbying contradicts company public positions. These risks are intensified by Pfizer’s prominent role in producing a COVID-19 vaccine, as well as its role lobbying on healthcare during a public health emergency. Pfizer believes patients need access to affordable medicines, yet funds PhRMA’s opposition to lower drug price initiatives.2

We are similarly concerned Pfizer’s direct or indirect payments to third-party groups are potentially being used for undisclosed grassroots lobbying. Pfizer, for example, supports the Alliance for Patient Access and Patients Rising, two organizations characterized as “AstroTurf” groups, which observers claim masquerade as authentic grassroots organizations to undermine lower drug price
initiatives.3

We believe the reputational and regulatory risks stemming from opacity around these misalignments harm long-term value creation by Pfizer. Thus, we urge Pfizer to expand its lobbying disclosure.
 

1 https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2762509
2 https://www.cnn.com/2019/01/23/health/phrma-lobbying-costs-bn/index.html
3 https://www.washingtonpost.com/business/economy/anonymous-ghost-ship-is-among-groups-flooding-drug-pricingdebate/
2019/01/22/3d7356a8-1b3b-11e9-8813-cb9dec761e73_story.html

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