Pfizer Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Pfizer discloses a structured process that links its climate and broader ESG positions to both direct and indirect lobbying activities, indicating strong governance and board-level oversight. The company states that "our engagement activities with policy makers, trade associations, and other organizations are guided by our Climate Change Position Statement," and explains that "our support of trade associations is evaluated annually by the company’s U.S. Government Relations leaders," with concerns escalated by “colleagues who serve on the boards and committees of these groups,” demonstrating an ongoing mechanism to test and correct alignment. For indirect lobbying, Pfizer has already produced an alignment assessment, noting that "Pfizer issued a report outlining the public policy positions of Pfizer and five trade associations… [which] compares Pfizer and the trade associations’ positions and describes the degree of alignment and areas of misalignment," and commits to update this analysis "periodically, as needed," which shows a repeatable review of trade-association positions. Direct lobbying is addressed through “robust internal procedures designed to align these efforts with our public policy priorities,” supported by “an extensive training and reporting program” to ensure compliance and alignment. Oversight is clearly assigned: "the Governance & Sustainability Committee of the Board has oversight of the company’s issues related to public policy, political spending policies and practices, and our lobbying activities," and "at least annually, the Committee receives a report from the company’s U.S. Government Relations leaders." This integration of climate guidance, annual evaluations, a published alignment report, and explicit board committee responsibility indicates strong governance; however, the disclosures stop short of a dedicated climate-specific lobbying audit covering all associations and do not describe any instance of changing or ending memberships, so the transparency around remedial actions could be more detailed. View Sources	B

Overall Assessment

Analysis

Score

Strong

Pfizer discloses a structured process that links its climate and broader ESG positions to both direct and indirect lobbying activities, indicating strong governance and board-level oversight. The company states that "our engagement activities with policy makers, trade associations, and other organizations are guided by our Climate Change Position Statement," and explains that "our support of trade associations is evaluated annually by the company’s U.S. Government Relations leaders," with concerns escalated by “colleagues who serve on the boards and committees of these groups,” demonstrating an ongoing mechanism to test and correct alignment. For indirect lobbying, Pfizer has already produced an alignment assessment, noting that "Pfizer issued a report outlining the public policy positions of Pfizer and five trade associations… [which] compares Pfizer and the trade associations’ positions and describes the degree of alignment and areas of misalignment," and commits to update this analysis "periodically, as needed," which shows a repeatable review of trade-association positions. Direct lobbying is addressed through “robust internal procedures designed to align these efforts with our public policy priorities,” supported by “an extensive training and reporting program” to ensure compliance and alignment. Oversight is clearly assigned: "the Governance & Sustainability Committee of the Board has oversight of the company’s issues related to public policy, political spending policies and practices, and our lobbying activities," and "at least annually, the Committee receives a report from the company’s U.S. Government Relations leaders." This integration of climate guidance, annual evaluations, a published alignment report, and explicit board committee responsibility indicates strong governance; however, the disclosures stop short of a dedicated climate-specific lobbying audit covering all associations and do not describe any instance of changing or ending memberships, so the transparency around remedial actions could be more detailed.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Pfizer provides only limited visibility into its climate-related lobbying. It refers to working “through global trade associations to encourage reduction of GHG emissions voluntarily and, through support of regulations that use market-based approaches,” and says it maintains “ongoing two-way dialogue with policymakers and targeted one-on-one engagement with industry bodies,” indicating that both indirect and direct channels are used, yet it never identifies which government departments, legislators, or regulators are approached, nor does it describe concrete actions such as letters, testimony, or consultation submissions. The company groups climate activity within broad themes such as carbon pricing, alignment with the Paris Agreement, and the HHS Climate Action Pledge, but it does not name any specific bills, regulations, or rulemakings it has tried to influence. Likewise, its stated objectives remain aspirational—supporting “science- and market-based” solutions and achieving Net-Zero by 2040—without clarifying the particular policy changes it advocates or opposes. As a result, while Pfizer acknowledges that it lobbies on climate issues and gives a high-level description of how it engages, it withholds the detailed policy references, targets, and outcomes that would allow stakeholders to understand the scope and substance of its influence efforts.	D