March 2, 2023
Margaret M. Madden
Pfizer Inc.
Re:
Pfizer Inc. (the “Company”)
Incoming letter dated December 16, 2022
Dear Margaret M. Madden:
This letter is in response to your correspondence concerning the shareholder
proposal (the “Proposal”) submitted to the Company by Tara Health Foundation and co-
filer for inclusion in the Company’s proxy materials for its upcoming annual meeting of
security holders.
The Proposal requests that the Company publish an annual report, at reasonable
expense, analyzing the congruency of political, lobbying, and electioneering expenditures
during the preceding year against publicly stated company values and policies, including
the Company’s stated goal to “end discrimination against women, ensure equal
opportunities for leadership and access to reproductive health,” listing and explaining any
instances of incongruent expenditures, and stating whether the identified incongruencies
have led to a change in future expenditures or contributions.
We are unable to concur in your view that the Company may exclude the Proposal
under Rule 14a-8(i)(10). Based on the information you have presented, it appears that the
Company’s public disclosures do not substantially implement the Proposal.
We are unable to concur in your view that the Company may exclude the Proposal
under Rule 14a-8(i)(12)(ii). In our view, the Proposal does not address substantially the
same subject matter as the proposals previously included in the Company’s 2021 and
2022 proxy materials.
Copies of all of the correspondence on which this response is based will be made
available on our website at
https://www.sec.gov/corpfin/2022-2023-shareholder-
proposals-no-action
.
Sincerely,
Rule 14a-8 Review Team
cc:
Sanford Lewis
Margaret M. Madden
Pfizer Inc.
–
Legal Division
Senior Vice President and Corporate Secretary
235 East 42nd Street, New York, NY 10017
Chief Governance Counsel
Tel 212 733 3451 Fax 646 563 9681
margaret.m.madden@pfizer.com
BY EMAIL
(shareholderproposals@sec.gov)
December 16, 2022
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Chief Counsel
100 F Street, N.E.
Washington, D.C. 20549
RE:
Pfizer Inc.
–
2023 Annual Meeting
Omission of Shareholder Proposal of
Tara Health Foundation and Louise Davis
Ladies and Gentlemen:
We are writing pursuant to Rule 14a-8(j) promulgated under the Securities Exchange
Act of 1934, as amended (the
“
Exchange Act
”
), to request that the Staff of the Division of
Corporation Finance (the
“
Staff
”
) of the Securities and Exchange Commission (the
“
Commission
”
) concur with our view that, for the reasons stated below, Pfizer Inc., a
Delaware corporation (
“
Pfizer
”
), may exclude the shareholder proposal and supporting
statement (the
“
Proposal
”
) submitted by Tara Health Foundation (
“
Tara Health
”
) and co-filed
by Nia Impact Capital
(“Nia”)
, on behalf of Louise Davis, from the proxy materials to be
distributed by Pfizer in connection with its 2023 annual meeting of shareholders (the
“
2023
proxy materials
”
). Tara Health and Ms. Davis, together with their respective representatives,
are collectively referred to as the “Proponents.”
In accordance with Section C of Staff Legal Bulletin No. 14D (Nov. 7, 2008)
(
“
SLB 14D
”
), we are emailing this letter and its attachments to the Staff at
shareholderproposals@sec.gov. In accordance with Rule 14a-8(j), we are simultaneously
sending a copy of this letter and its attachments to the Proponents as notice of Pfizer
’
s intent
to omit the Proposal from the 2023 proxy materials.
Rule 14a-8(k) and Section E of SLB 14D provide that shareholder proponents are
required to send companies a copy of any correspondence that the shareholder proponents
elect to submit to the Commission or the Staff. Accordingly, we are taking this opportunity
to remind the Proponents that if the Proponents submit correspondence to the Commission or
the Staff with respect to the Proposal, a copy of that correspondence should concurrently be
furnished to the undersigned.
Pfizer
Breakthroughs that change patients' lives*
pfizer.com
Office of Chief Counsel
December 16, 2022
Page 2
I.
The Proposal
The text of the resolution contained in the Proposal is set forth below:
Resolved: Pfizer publish an annual report, at reasonable expense, analyzing
the congruency of political, lobbying, and electioneering expenditures during
the preceding year against publicly stated company values and policies,
including Pfizer’s stated goal to “end discrimination against women, ensure
equal opportunities for leadership and access to reproductive health.” Such a
report should list and explain any instances of incongruent expenditures, and
state whether the identified incongruencies have led to a change in future
expenditures or contributions.
II.
Bases for Exclusion
We hereby respectfully request that the Staff concur with Pfizer’s view that the
Proposal may be excluded from the 2023 proxy materials pursuant to:
•
Rule 14a-8(i)(10) because Pfizer has substantially implemented the Proposal;
and
•
Rule 14a-8(i)(12)(ii) because the Proposal deals with substantially the same
subject matter as two previously submitted shareholder proposals, and the
most recently submitted of those proposals did not receive the support
necessary for resubmission.
III.
Background
Pfizer received the Proposal via email on November 8, 2022, accompanied by a cover
letter from Tara Health, dated November 8, 2022, and a letter from Merrill Lynch, dated
November 8, 2022, verifying Tara Health’s continuous ownership of at least the requisite
amount of Pfizer common stock for at least the requisite period preceding and including the
date of submission of the Proposal. On November 17, 2022, Pfizer sent a letter to Tara
Health notifying them that Pfizer believed the Proposal exceeded 500 words and requesting
that the Proposal be revised so that it does not exceed 500 words. On November 17, 2022,
Pfizer received the Proposal from Nia, accompanied by a cover letter, dated November 14,
2022, and an authorization letter from Ms. Davis, dated November 11, 2022. On November
21, 2022, Pfizer received a revised version of the Proposal, under 500 words, submitted by
the Proponents via email. Copies of the Proposal, cover letters, authorization letter and
related correspondence are attached hereto as Exhibit A.
Office of Chief Counsel
December 16, 2022
Page 3
IV.
The Proposal May be Excluded Pursuant to Rule 14a-8(i)(10) Because Pfizer
Has Substantially Implemented the Proposal.
Rule 14a-8(i)(10) permits a company to exclude a shareholder proposal if the
company has already substantially implemented the proposal. The Commission adopted the
“substantially implemented” standard in 1983 after determining that the “previous formalistic
applicati
on” of the rule defeated its purpose, which is to “avoid the possibility of
shareholders having to consider matters which already have been favorably acted upon by the
management.”
See
Exchange Act Release No. 34-
20091 (Aug. 16, 1983) (the “1983
Release”)
; Exchange Act Release No. 34-12598 (July 7, 1976). Accordingly, the actions
requested by a proposal need not be “fully effected” provided that they have been
“substantially implemented” by the company.
1
See
1983 Release.
Applying this standard, the Staff has consistently permitted the exclusion of a
proposal when it has determined that the company’s policies, practices and procedures or
public disclosures compare favorably with the guidelines of the proposal.
See, e.g.
,
IDACORP, Inc.
(Apr. 1, 2022);
Edison International
(Feb. 23, 2022);
JPMorgan Chase &
Co.
(Feb. 5, 2020);
The Allstate Corp.
(Mar. 15, 2019);
Johnson & Johnson
(Feb. 6, 2019);
United Cont’l Holdings, Inc.
(Apr. 13, 2018);
eBay Inc.
(Mar. 29, 2018);
Kewaunee Scientific
Corp.
(May 31, 2017);
Wal-Mart Stores, Inc.
(Mar. 16, 2017);
Dominion Resources, Inc.
(Feb. 9, 2016);
Ryder System, Inc.
(Feb. 11, 2015).
In addition, the Staff has permitted exclusion under Rule 14a-8(i)(10) where a
company already addressed the underlying concerns and satisfied the essential objective of
the proposal, even if the proposal had not been implemented exactly as proposed by the
proponent. For example, in
PG&E Corp.
(Mar. 10, 2010), the Staff permitted exclusion
under Rule 14a-8(i)(10) of a proposal requesting that the company provide a report
disclosing, among other things, the company’s standards for choosing the organizations to
which the company makes charitable contributions and specifically asked for disclosure of
the “business rationale and purpose for each of the charitable contributions.”
In arguing that
the proposal had been substantially implemented, the company referred to a website where
the company had described its policies and guidelines for determining the types of grants that
it makes and the types of requests that the company typically does not fund. Although the
proposal appeared to contemplate disclosure of each and every charitable contribution, the
Staff concluded that the company had substantially implemented the proposal.
See also, e.g.
,
The Wendy’s Co.
(Apr. 10, 2019) (permitting exclusion under Rule 14a-8(i)(10) of a proposal
requesting a report assessing human rights risks of the company’s operations, including the
principles and methodology used to make the assessment, the frequency of assessment and
how the company would use the assessment’s results, where the company had a code of
ethics and a code of conduct for suppliers and disclosed on its website the frequency and
1
While there is currently a proposed amendment to Rule 14a-8(i)(10) that would modify this standard, such
proposal has not been adopted. Accordingly, the standard discussed above remains the current
Commission-adopted standard.
Office of Chief Counsel
December 16, 2022
Page 4
methodology of its human rights risk assessments);
MGM Resorts Int’l
(Feb. 28, 2012)
(permitting exclusion under Rule 14a-8(i)(10) of a proposal requesting a report on the
company’s sustainability policies and performance, including multiple objective statistical
indicators, where the company published an annual sustainability report).
In particular, the Staff has permitted exclusion under Rule 14a-8(i)(10) where a
company satisfied the essential objective of a proposal seeking disclosure relating to the
company’s political expenditures even
if the proposal had not been implemented exactly as
proposed by the proponent. For example, in
Exelon Corp.
(Feb. 26, 2010), the Staff
permitted exclusion under Rule 14a-8(i)(10) of a proposal requesting that the company
prepare a report disclosing its policies and procedures for political contributions and its
monetary and non-monetary political contributions. In arguing that the proposal had been
substantially implemented, the company referenced its political contributions guidelines and
report, which
provided information regarding the company’s political contributions policies
and procedures and monetary and nonmonetary political contributions. Although the actions
taken by the company may not have exactly aligned with the requests made by the proponent,
the Staff concluded that the company had substantially implemented the proposal.
In this instance, Pfizer has substantially implemented the Proposal, the essential
objective of which is to obtain a report from Pfizer on how its political expenditures align
with Pfizer’s stated values and policies.
In this respect, the Proposal’s supporting statement
explains that its request for disclosure is based on the view that “Pfizer’s political
expenditures appear to be misaligned with [Pfizer’s]
stated values a
nd interests.”
As
described below, Pfizer already publicly discloses how its political and lobbying
contributions
–
both to trade associations and to candidates and political committees
–
align
with its stated values and policies.
In particular, Pfizer’s website already contains extensive disclosure regarding Pfizer’s
support of trade associations. In addition to disclosing the portion of its membership dues
that are used for federal lobbying activity
, Pfizer publishes on its “Political Partnership”
webpage an Industry Associations
– Report on Incongruencies (the “Congruency Report”)
that describes Pfizer’s positions on important public policy matters and Pfizer’s alignment
with its “most significant trade association memberships” on each position.
2
The
Congruency Report states that Pfizer “believe[s] that public policy engagement is an
important and appropriate role for companies in open societies” and that “there is value in
making sure [Pfizer’s] positions on issues important to Pfizer and [its]
industry are
communicated and understood within those organizations.”
In this respect, the Congruency Report includes the following summaries of Pfizer’s
alignment with its most significant trade association memberships, together with a detailed
analysis
of Pfizer’s alignment with the associations “across six areas of key public policy and
2
See
Pfizer’s
Industry Associations
–
Report on Incongruencies, available at https://www.pfizer.com/
about/programs-policies/political-partnerships and attached hereto as Exhibit B.
Office of Chief Counsel
December 16, 2022
Page 5
ESG significance for Pfizer: Climate Change; Patient Access to Healthcare; Trade; Tax;
Diversity, Equity, and Inclusion; and Civic Integrity”:
•
Biotechnology Innovation Organization.
“The policy goals of Pfizer and the
Biotechnology Innovation Organization (BIO) are generally in alignment across the
key areas reviewed. To the extent differences exist in the company and trade
association’s respective positions, such as on tax, they are largely because either
Pfizer or BIO has taken a position on particular matters on which the other has not.
Indeed, Pfizer has been more vocal than BIO on support of free trade, though both
agree on the importance of intellectual property protections in trade agreements. On
broad policy goals, Pfizer and BIO are well aligned. Pfizer engages with BIO on the
following issues: (a) intellectual property/innovation protection; (b) vaccine policy
and advocacy; (c) patient affordability solutions; and (d) FDA User Fee agreements
(in partnership with PhRMA).”
•
Business Roundtable.
“The policy goals of Pfizer and the Business Roundtable
(BRT) are generally in alignment across the key areas reviewed. To the extent there
are differences in the company and trade association’s respective positions, they are
because Pfizer and BRT are focusing on different specific aspects of the issue.
However, on broad policy goals, Pfizer and BRT are well aligned. Pfizer engages
with the BRT on the following issues: (a) U.S. tax competitiveness; (b) global tax
debate; (c) free trade policies and intellectual property protection; (d) employer health
care and health equity solutions; and (e) enhancing diversity and inclusion in the
workforce.”
•
National Association of Manufacturers.
“The policy goals of Pfizer and the
National Association of Manufacturers (NAM) are generally in alignment across the
key areas reviewed. The alignment is less close in the areas of climate change and
access to healthcare, largely because Pfizer and the NAM are focusing on different
specific aspects of the issue. However, on broad policy goals, Pfizer and BRT are
well aligned. Pfizer engages with NAM on the following issues: (a) high quality
manufacturing; (b) international trade; and (c) to oppose governmental intervention in
health care, including price controls in Medicare.”
•
Pharmaceutical Research and Manufacturers of America.
“Pfizer and
Pharmaceutical Research and Manufacturers of America (PhRMA) are closely
aligned on policy goals and specific positions. The only notable exception is in the
area of climate change, where PhRMA has not taken a public position. Pfizer engages
with PhRMA on the following issues: (a) lead industry efforts to advance pro-patient
policies and defeat negative drug pricing proposals at the federal level; (b) advance
rebate pass-through, copay accumulator bans and out of pocket caps at state level; (c)
protect intellectual property rights globally; and (d) advance FDA User Fee
agreements (in partnership with BIO).”
Office of Chief Counsel
December 16, 2022
Page 6
•
U.S. Chamber of Commerce.
“The policy goals of Pfizer and the U.S. Chamber of
Commerce (Chamber) are generally in alignment across the key areas reviewed. To
the extent there are differences in the company and trade association’s respective
positions, they are generally because Pfizer and Chamber are focusing on different
specific aspects of the issue. However, on broad policy goals, they are well aligned.
Pfizer engages with the Chamber on the following issues: (a) promote and protect
intellectual property/innovation through Global Innovation Policy Center; (b) drive
narrative on counterfeits/product integrity; (c) lead on U.S. tax competitiveness; and
(d) protect employer health care and drive policies to promote competition in health
care.”
In explaining how Pfizer aligns its trade association memberships with Pfizer’s stated
values and policies, the Congruency Report notes that “support of these organizations is
evaluated annually by [Pfizer’s] U.S. Government Relations leaders based on these
organizations’ expertise in healthcare policy and advocacy and support of key issues of
importance to Pfizer.” The Congruency Report also notes that Pfizer “monitor[s] where and
to what extent [Pfizer’s] trade associations are misaligned” with Pfizer on issues important to
Pfizer and “will advocate for the trade association to come into alignment, but if an
organization’s misalignment is egregious, and the membership benefits to Pfizer and its
stakeholders are outweighed by the misalignments, [Pfizer] will reduce or end [its]
involvement with the organization.”
In addition, Pfizer publishes on its website an annual report titled the Pfizer PAC and
Corporate Contributions Report (the “Political Contributions Report”), which lists the
candidates and political committees supported by either Pfizer Inc. or the Pfizer political
action committee (the “Pfizer PAC”) and clearly explains Pfizer’s rationale and motivation
for making such political expenditures.
3
In this regard, the Political Contributions Report
indicates that the driving force behind Pfizer’s political and electioneering expenditures is to
“support candidates of both political parties who support state and federal policies that
impact [Pfizer’s] purpose: Breakthroughs that change patients’ lives.” Pfizer also explains in
the Political Contributions Report how its political and electioneering expenditures align with
Pfizer’s policy priorities, stating that the “decision to contribute to any elected official is
made based on [the candidate’s] voting record on durable policies that support innovation,
patient access to and affordability of their medicines, high quality manufacturing, a secure
supply chain, a competitive tax code and a robust intellectual property system.” The purpose
of such evaluation is “to ensure Pfizer’s values are upheld.” The Political Contributions
Report, therefore, clearly describes the manner in which Pfizer’s political expenditures are
aligned with its stated values and policies.
3
See
Pfizer’s PAC and Corporate Political Contributions Report, available at https://cdn.pfizer.com
/pfizercom/investors/corporate/2021_Pfizer_PAC_and_Corporate_Political_Contributions_Report.pdf and
attached hereto as Exhibit C.
Office of Chief Counsel
December 16, 2022
Page 7
Moreover, the Political Contributions Report acknowledges that politicians will have
a range of views about policy that are both related and unrelated to Pfizer’s business.
While
the Political Contributions Report identifies recipients of contributions who hold a diversity
of political positions, it cl
early states that contributions made to such recipients “[do] not
imply an endorsement of a candidate’s position on any social or religious issue.”
Instead of
focusing on candidates’ political views concerning matters unrelated to Pfizer’s business, the
Political Contributions Report states that Pfizer
’s role is to “activat[e] those [elected officials]
who support Pfizer’s mission and advocat[e] for policymakers who align with
policies that
enable [Pfizer’s] purpose.”
The Political Contributions Report al
so describes Pfizer’s corporate policy requiring
“all PAC and corporate political contributions to be compiled and published annually in a
report that is made available to employees, shareholders, and the public, and posted on
[Pfizer’s] website.”
In addi
tion, the Political Contributions Report describes that Pfizer
requests trade associations receiving $100,000 or more from Pfizer in a given year to report
to Pfizer the portion of Pfizer dues or payments used for certain non-deductible expenditures,
which amounts Pfizer discloses in the Political Contributions Report. Further, the Political
Contributions Report describes the PAC Steering Committee’s process of “evaluat[ing]
candidates on a basis of their views on the issues that impact Pfizer and its coll
eagues.”
In
addition, the Political Contributions Report describes that Pfizer traditionally does not make
contributions to 527 Issue Organizations and that to the extent Pfizer does make those
expenditures, such expenditures “would have to be reviewed an
d approved by the Political
Contributions Policy Committee and subsequently disclosed.”
The Political Contributions
Report also notes that Pfizer “has determined that it will not make any direct independent
expenditures.”
Given the extensive disclosure in the Congruency Report and the annual Political
Contributions Report, Pfizer has already publicly disclosed how its political expenditures
align with its stated values and policies.
Therefore, Pfizer has satisfied the Proposal’s
essential objective
–
obtaining a report from Pfizer on
the congruency between Pfizer’s
political expenditures and
Pfizer’s stated values and policies –
and thus its public disclosures
compare favorably with those requested by the Proposal.
Accordingly, Pfizer believes that the Proposal may be excluded from its 2023 proxy
materials pursuant to Rule 14a-8(i)(10) as substantially implemented.
V.
The Proposal May be Excluded Pursuant to Rule 14a-8(i)(12)(ii) Because It
Deals with Substantially the Same Subject Matter as Two Previously Submitted
Shareholder Proposals, and the Most Recently Submitted of Those Proposals
Did Not Receive the Support Necessary for Resubmission.
Under Rule 14a-8(i)(12)(ii), a shareholder proposal may be excluded from a
company
’
s proxy materials if it deals with
“
substantially the same subject matter as a
proposal, or proposals, previously included in the company
’
s proxy materials within the
preceding five calendar years if the most recent vote occurred within the preceding three
Office of Chief Counsel
December 16, 2022
Page 8
calendar years,
”
and the proposal received
“
[l]ess than 15 percent of the votes cast if
previously voted on twice.
”
A.
Precedent Regarding Exclusion under Rule 14a-8(i)(12).
The Staff has confirmed on numerous occasions that Rule 14a-8(i)(12) does not
require that the proposals, or their subject matters, be identical in order for a company to
exclude the later-submitted proposal. Although the predecessor to Rule 14a-8(i)(12) required
a proposal to be
“
substantially the same proposal
”
as prior proposals, the Commission
amended this rule in 1983 to permit exclusion of a proposal that
“
deals with substantially the
same subject matter.
”
The Commission explained the reason for, and meaning of, this
revision in the 1983 Release:
The Commission believes that this change is necessary to signal a clean break
from the strict interpretive position applied to the existing provision. The
Commission is aware that the interpretation of the new provision will continue
to involve difficult subjective judgements, but anticipates that those judgements
will be based upon a consideration of the
substantive concerns
raised by a
proposal rather than the specific language or actions proposed to deal with those
concerns.
(Emphasis added.)
4
When considering whether proposals deal with substantially the same subject matter,
the Staff has focused on the
“
substantive concerns
”
raised by the proposals. Thus, the Staff
has concurred with the exclusion of proposals under Rule 14a-8(i)(12) when the proposal in
question shares similar underlying issues with a prior proposal, even though the specific
language or scope of the proposals differs or the proposals recommend different actions be
taken by the company.
See, e.g.
,
Pfizer, Inc.
(Jan. 20, 2022) (permitting exclusion under
Rule 14a-8(i)(12) of a proposal requesting that the board take the necessary steps to permit
written consent by shareholders that dealt with substantially the same subject matter as a
prior proposal requesting the same action but that contained different supporting statements);
Exxon Mobil Corp.
(Mar. 15, 2022) (permitting exclusion under Rule 14a-8(i)(12) of a
proposal requesting that the board take the necessary steps to lower the ownership threshold
required to call a special shareholder meeting that dealt with substantially the same subject
matter as a prior proposal requesting the same action but that did not include discussion of
related issues such as
application of the company’s current policy with respect to special
meetings and the use of virtual shareholder meetings);
Alphabet, Inc.
(Apr. 16, 2019)
(permitting exclusion under Rule 14a-8(i)(12) of a proposal requesting a review of the
company
’
s board composition and qualifications that dealt with substantially the same
4
While there is currently a proposed amendment to Rule 14a-8(i)(12) that would modify this standard, such
proposal has not been adopted. Accordingly, the standard discussed above remains the current
Commission-adopted standard.
Office of Chief Counsel
December 16, 2022
Page 9
subject matter as prior proposals containing minor differences in language that also requested
review of the company
’
s board composition and qualifications);
Apple Inc.
(Nov. 20, 2018)
(permitting exclusion under Rule 14a-8(i)(12) of a proposal requesting management review
the company’s policies relating to human rights to assess the need to adopt additional policies
and report on its findings that dealt with substantially the same subject matter as prior
proposals requesting that the company establish a human rights committee of its board);
JPMorgan Chase & Co.
(Jan. 27, 2017) (permitting exclusion under Rule 14a-8(i)(12) of a
proposal requesting a public study regarding whether divestiture of the company
’
s non-core
banking business segments would enhance shareholder value that dealt with substantially the
same subject matter as a prior proposal requesting the board to appoint an independent
committee of the board to address whether divestiture of non-core banking business segments
would enhance shareholder value);
The Coca-Cola Co.
(Jan. 18, 2017) (permitting exclusion
under Rule 14a-8(i)(12) of a proposal requesting that the company prepare a report charting
the number of Arab and non-Arab employees by job category in Israel and Palestine that
dealt with substantially the same subject matter as a prior proposal requesting that the board
make all possible lawful efforts to implement certain equal opportunity employment
principles for corporations in Israel and Palestine);
Pfizer Inc.
(Jan. 9, 2013) (permitting
exclusion under Rule 14(a)(i)(12) of a proposal requesting that the board authorize the
preparation of a report on
the company’s lobbying contributions and expenditures that dealt
with substantially the same subject matter as prior proposals requesting disclosure of both
lobbying contributions and political contributions);
Exxon Mobil Corp.
(Mar. 23, 2012)
(permitting exclusion under Rule 14a-8(i)(12) of a proposal requesting that the board create a
policy articulating the company
’
s commitment to the human right to water that dealt with
substantially the same subject matter as prior proposals, one of which requested that the
board report on how the company ensures that it is accountable for environmental impacts in
communities where it operates).
B.
The Proposal Deals with Substantially the Same Subject Matter as Two
Previously Submitted Proposals.
Pfizer included the following shareholder proposal in its proxy materials for its 2022
annual meeting of shareholders (the
“
2022 Proposal,
”
attached hereto as Exhibit D):
RESOLVED:
Pfizer publish an annual report, at reasonable expense, analyzing
the congruency of political and electioneering expenditures during the
preceding year against the company’s fundamental purpose and publicly stated
company values and policies.
Pfizer also included the following shareholder proposal in its proxy materials for its 2021
annual meeting of shareholders (the
“
2021 Proposal,
”
attached hereto as Exhibit E):
Resolved: Pfizer publish an annual report, at reasonable expense, analyzing the
congruency of political and electioneering expenditures during the preceding year
against publicly stated company values and policies.
Office of Chief Counsel
December 16, 2022
Page 10
As shown above, the resolved clauses of the 2022 Proposal and the 2021 Proposal
(collectively, the “Prior Proposals”)
are virtually identical and overlap significantly with the
current Proposal.
The substantive concern expressed in the Proposal, and in each of the 2022 Proposal
and the 2021 Proposal, is the same
– the congruency of Pfizer’s political expenditures with
Pfizer’s stated values and polic
ies. In this regard, the resolved clause of the Proposal is
essentially the same as the resolved clause of each of the Prior Proposals, as is the action
requested of Pfizer
.
Specifically, the Proposal asks Pfizer to analyze “the congruency of [its]
political, lobbying, and electioneering expenditures during the preceding year against
publicly stated [Pfizer] value and policies.”
Likewise, the 2022 Proposal ask
ed Pfizer to
analyze “the congruency of [its] political and electioneering expenditures during t
he
preceding year against [Pfizer’s] fundamental purpose and publicly stated [Pfizer] values and
policies.”
The 2021 Proposal similarly asked
Pfizer to analyze “the congruency of [its]
political and electioneering expenditures during the preceding year against publicly stated
[Pfizer] values and policies.”
In addition, the supporting statements of the Proposal and the Prior Proposals
demonstra
te each proposal’s shared
concern with
Pfizer’s political expenditures and their
congruency with Pfizer’s stated values and policies.
Each of the Proposal and the Prior
Proposals assert that
“Pfizer’s political expenditures appear to be misaligned” with i
ts
“values and interests,” that “Pfizer should establish policies and reporting systems that
minimize risk to [Pfizer’s] reputation and brand by addressing possible missteps in corporate
electioneering and political spending
”
that contrast with its stated objectives and that Pfizer
analyze “risks to [its] brand, reputation, or shareholder value of expenditures in conflict with
publicly stated [Pfizer] values.”
While the respective supporting statements of the Proposal
and the Prior Proposals contain differences in scope, this does not change the fundamental
concern of each proposal
– the congruency of Pfizer’s political expenditures with Pfizer’s
stated values and policies. In this regard, the Proposal and the 2021 Proposal emphasize
Pfizer’s stated interest in “‘[e]xpanded access to health insurance coverage,’” particularly for
“‘patients with under
-
diagnosed and undertreated conditions.’”
The two proposals also focus
on “women’s access to reproductive health care,” including to Pfizer
-manufactured
“contr
aceptives and a drug commonly prescribed
for [medical abortion].”
The 2022
Proposal, on the other hand, emphasizes Pfizer’s non
-discrimination policy, its stated
opposition to forced labor and its recognition of rights to a healthy environment, life, health,
water and sanitation. However, although the scope of the Proposal and the Prior Proposals
may differ, such distinctions merely stem from the use of different examples of alleged
incongruency to illustrate each
proponent’s underlying concern with
the primary substantive
concern of
consistency between Pfizer’s political expenditures and its stated values.
Similarly, m
inor additions to the Proposal’s resolved clause to include specific
examples of Pfizer’s stated goals (to “end discrimination against wom
en, ensure equal
opportunities for leadership and access to reproductive health”) and
to provide specific
Office of Chief Counsel
December 16, 2022
Page 11
guidelines for the report (to “list and explain any instances of incongruent expenditures, and
state whether the identified incongruencies have led to a change in future expenditures or
contributions”)
do not change the substantive concern of the Proposal.
Moreover, the Staff recently permitted Pfizer to exclude a nearly identical proposal to
the current Proposal as substantially duplicative of the 2022 Proposal. In
Pfizer, Inc.
(February 22, 2022), the Staff determined that a proposal similarly requesting an analysis of
“the congruency of [Pfizer’s] political
, lobbying, and electioneering expenditures during the
preceding year against publicly stated company values and policies” was substantially
duplicative under Rule 14a-8(i)(11) of the 2022 Proposal. Like the Proposal and the 2021
Proposal, the substantially duplicative
proposal’s supporting statement specifically
addressed
expanded access to health insurance coverage for patients with under-diagnosed and
undertreated conditions and
women’s access to rep
roductive health care. Tara Health also
acknowledged that the two proposals at issue were substantially duplicative. Both the
Proponent’s view and the Staff’s decision are
indicative of the substantial similarity between
the Proposal and the 2022 Proposal. Accordingly, each proposal focuses on the same
substantive concern of the congruency between Pfizer’s political expenditures and its stated
values and policies.
C.
The Proposal Included in Pfizer
’
s 2022 Proxy Materials Did Not Receive the
Shareholder Support Necessary to Permit Resubmission.
Rule 14a-8(i)(12)(ii) provides that a company may exclude a proposal that deals with
substantially the same subject matter as previously submitted proposals if the proposal
received
“
[l]ess than 15 percent of the votes cast if previously voted on twice
”
within
“
the
preceding five calendar years.
”
Staff Legal Bulletin No. 14 (July 13, 2001) explains that
only votes for and against a proposal are included in the calculation of the shareholder vote;
abstentions and broker non-votes are not included. As disclosed in Pfizer
’
s Current Report
on Form 8-K, filed with the Commission on May 2, 2022 and attached hereto as Exhibit F,
there were 393,729,907 votes cast in favor of the 2022 Proposal and 3,387,577,521 votes cast
against the 2022 Proposal. This amounts to 10.41% of the votes cast in favor of the 2022
Proposal. Thus, the last time that Pfizer
’
s shareholders considered a proposal substantially
similar to the Proposal, it received less than 15% of the votes cast.
Accordingly, Pfizer believes the Proposal, dealing with substantially the same subject
matter as the 2022 Proposal and the 2021 Proposal, is excludable under Rule 14a-8(i)(12)(ii)
for failing to receive the requisite shareholder support.
VI.
Conclusion
Based upon the foregoing analysis, we respectfully request that the Staff concur that it
will take no action if Pfizer excludes the Proposal from its 2023 proxy materials.
Office of Chief Counsel
December 16, 202
2
Page 12
Should the Staff disagree with the conclusions set forth in this letter, or should any
additional information be desired in support of Pfizer
’
s position, we would appreciate the
opportunity to confer with the Staff concerning these matters prior to the issuance of the
Staff
s response. Please do not hesitate to contact me at (212) 733-3451 or Marc S. Gerber
of Skadden, Arps, Slate, Meagher & Flom LLP at (202) 371-7233.
Very truly yours,
Margaret M. Madden
Enclosures
cc:
Shelly Alpern
Director of Corporate Engagement
Rhia Ventures
Meredith Benton
EXHIBIT A
(see attached)
November 8, 2022
Margaret M. Madden
Senior Vice President, Corporate Secretary & Chief Governance Counsel
Pfizer Inc.
235 East 42
nd
Street
New York, NY 10017
Via email: Margaret.M.Madden@pfizer.com
Re: Shareholder Proposal for 2023 Annual Shareholder Meeting
Dear Ms. Madden,
On behalf of Tara Health Foundation,
I am submitting the attached proposal (the “Proposal”)
pursuant to the Securities and Exchange Commission’s Rule 14a
-8 to be included in the proxy
statement of Pfizer (the “Company”) for its 2023 annual meeting of shareholders. Tara Health
Foundation is the lead filer for the Proposal and may be joined by other shareholders as co-filers.
Tara Health Foundation has continuously beneficially owned, for at least one year as of the date
hereof, at least $25,000
worth of the Company’s common stock. Verificatio
n of this ownership is
attached. Tara Health Foundation intends to continue to hold such shares through the date of the
Company’s 2023 annual meeting of shareholders.
I am available to meet with the Company in person or via teleconference on December 5, 2022
between 9:00 am and 10:00 am ET and December 8, 2022 between 9:00 am and 10:00 am ET.
We expect to be joined by a co-filer, who will be authorizing Tara Health to conduct the initial
engagement meeting but may participate subject to their availability.
Please send future correspondence and communications regarding this proposal to my
representative Shelley Alpern, director of corporate engagement at Rhia Ventures, who can be
contacted at shelley@rhiaventures.org.
Please be advised that we will hereafter be using a representative regarding the management of this
proposal. Please send any correspondence regarding this proposal including deficiency notices, no
action requests or engagement scheduling to Shelley Alpern, director of corporate engagement at
Rhia Ventures, who can be contacted at shelley@rhiaventures.org. I authorize Ms. Alpern to speak
on my behalf, negotiate withdrawal of the proposal and engage with the company and its
representatives.
Sincerely,
Dr. Ruth Shaber
President and Founder
Tara Health Foundation
Enclosures:
Shareholder proposal
Verification of share ownership
cc:
Shelley Alpern, Rhia Ventures
r
Shareholder Proposal for Pfizer 2023 Proxy Ballot re Political Contributions Misalignment
Submitted by Tara Health Foundation
POLITICAL CONTRIBUTIONS MISALIGNMENT
Whereas:
Pfizer
political parties and committees that support public policies important to the industry, such as
aim to end discrimination against women, ensure equal opportunities for leadership and access
How
stated
values and interests.
patients with under-diagnosed and undertreated conditions are able to address them; and that
those who will benefit from Pfizer medicines are better able to have access to them. Yet in
2018, Pfizer was a top contributor to a 527 organization leading efforts to strike down the
Affordable Care Act, which has made prescription drugs more accessible for millions, and
contributes to PhRMA, which donates to numerous organizations opposing congressional efforts
to reform drug pricing.
Pfizer manufactures contraceptives and a drug commonly prescribed for medication abortion.
Yet the proponent estimates that since the beginning of the 2020 election cycle, Pfizer and its
employee PACs have donated at least $5 million to politicians and political organizations
working to weaken
access to reproductive health care. In the South during this period,
to anti-choice state candidates exceeded those to other candidates by a
ratio of 3:1, and its contributions to anti-choice federal candidates exceeded those to other
candidates by a ratio of 2:1. For example, Pfizer contributed to multiple sponsors of bills passed
in 2022 in Tennessee and Louisiana that will restrict access to medication abortion.
This pattern spending has drawn scrutiny from
STAT, Bloomberg News, Huffington Post, The
Minnesota Daily, CQ ESG Briefing, Agenda
(a
Financial Times
publication
)
and
Forbes
.
Proponents believe Pfizer should establish policies and reporting systems that minimize risk to
reputation and brand by addressing possible missteps in corporate electioneering and political
spending that contrast with its stated healthcare objectives.
Resolved:
Resolved: Pfizer publish an annual report, at reasonable expense, analyzing the congruency of
political, lobbying, and electioneering expenditures during the preceding year against publicly
imination against
policy states
that
"political contributions are made
to
support the election
of
candidates,
innovation and
access
to
medicines."
Pfizer listed "Gender Equality"
as
a Sustainable Development Goal in its
ESG
report stating:
"We
to
reproductive health."
ever, Pfizer's political expenditures appear
to
be
misaligned
with
the company's
Pfizer
has
stated
that
"Expanded
access
to
health insurance coverage will help ensure
that
women's
Pfizer's contributions
stated company values and policies, including Pfizer's stated goal
to
"end discr
II
women, ensure equal opportunities
for
leadership and
access
to
reproductive health."
Such
a
Shareholder Proposal for Pfizer 2023 Proxy Ballot re Political Contributions Misalignment
Submitted by Tara Health Foundation
report should list and explain any instances of incongruent expenditures, and state whether the
identified incongruencies have led to a change in future expenditures or contributions.
Supporting Statement:
Proponents recommend that such report contain management's analysis of risks to our
company's brand, reputation, or shareholder value of expenditures in conflict with publicly
stated company values.
ending,
from the corporate treasury and from the PACs, directly or through a third party, at any time
during the year, on printed, internet or broadcast communications, which are reasonably
susceptible to interpretation as in support of or opposition to a specific candidate.
"Expenditures
for
electioneering communications" means
sp
'\:ovember
14.
2022
.\1argaret
M.
Madden
Senior Vice President and Corporate Sccrctarv.
Chief
Governance Counsel
Pfizer
m.
235 East 42nd Street, New York, New York I
001
7.
Attention: Corporate Secretary.
Also via email at:
Re: Shareholder proposal for 2023 Annual Shareholder Meetin
!.!
Dear Corporate Secretary.
Nia Impact Capital
is
co-filing a shareholder proposal on
behalf
of
Louise Davis ("co-filers").
vno are shareholders
of
Pfizer Inc. for action at the next annual meetin~
of
Pfizer Inc. The
co-tilers are submitting the enclosed shareholder proposal for inclusion
in
Pfizer Inc. 's 2023
proxy
statement
for consideration
by
shareholders. in accordance with Rule l 4a-8
of
the
General Rules and Regulations
of
the Securities Exchange Act
of
1934. As lead filer. Tara
Health Foundation
is
designated to conduct the initial engagement conversation with the
company as required
by
amended SEC rules. The lead filer is designated to meet initially with
the Company but the co-filer may join the meeting subject to their availability.
The co-filer has continuously beneficially owned. for at least two years and through today m
least S15.000
of
the Company's common stock. Verification
of
proof
of
ownership will foilO\v.
The co-filer intends to continue to hold such shares through the date
of
the
Company's
2023
annual meeting
of
shareholders.
A letter from the co-filer authorizing Nia Impact Capital to act on their
behalf
is
enclosed. A
representative
of
the lead filer will attend the stockholders' meeting to move the resolution
a~
required.
We
are available
to
discuss this issue and appreciate the opportunity
to
engage and seek
to
resolve the Pro onent's concerns. Please contact Meredith Benton
or
to schedule a meeting and to discuss any
questions. Please address any future correspondence regarding the
pro_oosal
throuQ:h
this
address.
Sincerely.
Kristin Hull. PhD.
Encl: Authorization letters and Proposal
DocuSign Envelope ID: A2A58E13-58CF-4DD6-8O77-71 B94AA907C6
11
/ 11/
2022
Margaret
M.
Madden
Senior Vice President and Corporate Secretary,
Chief
Governance Counsel
Pfizer Inc.
235 East 42nd
Street
New
York_
New
York 10017.
Attention: Corporate Secretary.
Also via email at:
.)ear Ms. Madden_
I hereby authorize Nia Impact Capital to co-file a shareholder resolution on my behalf for the
Pfizer Inc. 2023 annual shareholder meeting. The proposal requests that the company oublish
an
annual report anal
yz
ing the congruency
of
its political, lobbying, and electioneering expendnures
against its stated company rnlues and policies.
I support this proposal and give Nia Impact Capital
full
authority to engage with the company on
my
behalf regarding the proposal and the underlying issues, and to negotiate a withdrawal
of
the
proposal to the extent the representative
Yiews
the company·s actions as responsive. I intend to
hold the requisite number
of
shares required
by
Rule l 4a-8 through the 2023 annual meeting.
I understand that I may be identified on the corporation·s proxy statement as a filer or co-filer
of
the aforementioned resolution.
Sincerely,
CT
DocuS,gnao by:
(pw
St.
V
lW-l
s
F5
DC63
04
0O7
◄4
F
E
Louise Davis
1
From:
Shelley Alpern <
shelley@reprohealthinvestors.org
>
Sent:
Monday, November 21, 2022 1:55 PM
To:
Rolon, Suzanne <
Suzanne.Y.Rolon@Pfizer.com
>
Cc:
Madden, Margaret <
Margaret.M.Madden@Pfizer.com
>
Subject:
[EXTERNAL] Re: Shareholder Proposal Submitted to Pfizer - 2023
Please find attached a revised proposal that is under 500 words.
Best regards,
Shelley Alpern
Rhia Ventures | Director of Corporate Engagement
cell: (617) 970-8944 |
www.rhiaventures.org
To schedule an appointment with me, visit
my Calendly page
.
C18D
Rhia
VENTURES
1
From:
Kelly Hall <
kelly@niaimpactcapital.com
>
Sent:
Monday, November 21, 2022 6:29 PM
To:
Rolon, Suzanne <
Suzanne.Y.Rolon@Pfizer.com
>
Cc:
Meredith Benton <
benton@whistlestop.capital
>; Jaylen Spann <
spann@whistlestop.capital
>; Kristin Hull
<
kristin@niaimpactcapital.com
>; Shelley Alpern <
shelley@reprohealthinvestors.org
>; Madden, Margaret
<
Margaret.M.Madden@Pfizer.com
>
Subject:
[EXTERNAL] Shareholder Proposal Submitted to Pfizer - 2023
Hello Suzanne,
I hope you're doing well!
Please see attached a revised proposal that is under 500 words.
Warm regards,
Kelly
--
Kelly Hall
[She/Her]
Operations & Communications Associate
Nia Impact Capital
www.niaimpactcapital.com
nia
Certified
®
--
·
Co,poration
~
\::::::I
Shareholder Proposal for Pfizer 2023 Proxy Ballot re Political Contributions Misalignment
Submitted by Tara Health Foundation
POLITICAL CONTRIBUTIONS MISALIGNMENT
Whereas:
Pfizer has stated “political contributions are made to support the election of candidates, political
parties and committees that support public policies important to the industry, such as
innovation and access to medicines,” and “[w]e aim to end discrimination against women,
ensure equal opportunities for leadership and access to reproductive health.”
However, Pfizer’s political expenditures appear to be misaligned with the company’s stated
values and interests.
Pfizer has stated that “Expanded access to health insurance coverage will help ensure that
patients with under-diagnosed and undertreated conditions are able to address them; and that
those who will benefit from Pfizer medicines are better able to have access to them.” Yet in
2018, Pfizer was a top contributor to a 527 organization leading efforts to strike down the
Affordable Care Act, which has made prescription drugs more accessible for millions, and
contributes to PhRMA, which donates to numerous organizations opposing congressional efforts
to reform drug pricing.
Pfizer manufactures contraceptives and a drug commonly prescribed for medication abortion.
Yet the proponent estimates that since the beginning of the 2020 election cycle, Pfizer and its
employee PACs have donated at least $5 million to politicians and political organizations
working to weaken women’s access to reproductive health care. In the South during this period,
Pfizer’s contributions to anti-choice state candidates exceeded those to other candidates by a
ratio of 3:1, and its contributions to anti-choice federal candidates exceeded those to other
candidates by a ratio of 2:1. For example, Pfizer contributed to multiple sponsors of bills passed
in 2022 in Tennessee and Louisiana that will restrict access to medication abortion.
This pattern spending has drawn scrutiny from
STAT, Bloomberg News, Huffington Post, The
Minnesota Daily, CQ ESG Briefing, Agenda
(a
Financial Times
publication
)
and
Forbes
.
Proponents believe Pfizer should establish policies and reporting systems that minimize risk to
reputation and brand by addressing possible missteps in corporate electioneering and political
spending that contrast with its stated healthcare objectives.
Resolved:
Resolved: Pfizer publish an annual report, at reasonable expense, analyzing the congruency of
political, lobbying, and electioneering expenditures during the preceding year against publicly
stated company values and policies, including Pfizer’s stated goal to “end discrimination against
women, ensure equal opportunities for leadership and access to reproductive health.” Such a
report should list and explain any instances of incongruent expenditures, and state whether the
identified incongruencies have led to a change in future expenditures or contributions.
Shareholder Proposal for Pfizer 2023 Proxy Ballot re Political Contributions Misalignment
Submitted by Tara Health Foundation
Supporting Statement:
Proponents recommend that such report contain management's analysis of risks to our
company's brand, reputation, or shareholder value of expenditures in conflict with publicly
stated company values. “Electioneering expenditures" means spending, from the corporate
treasury and from the PACs, directly or through a third party, at any time during the year which
are reasonably susceptible to interpretation as in support of or opposition to a specific
candidate.
EXHIBIT B
(see attached)
Industry Associations
–
Report on Incongruencies
Introduction
Pfizer Inc. (Pfizer) actively participates in the public policy arena because
government policies affect our ability to meet patient needs and provide
shareholder value. Barriers to access, counterfeit medicines, illegal importation
and challenges to intellectual property protection challenge essential aspects of
our business.. For this reason, we actively participate in public policy dialogues to
explain our perspectives. We have extensive knowledge about health care and
many ideas about improving its efficiency, as well as a global perspective on public
health, disease prevention and health education. We believe that public policy
engagement is an important and appropriate role for companies in open societies.
In furtherance of these goals, Pfizer is a member of various industry and trade
groups that represent both the pharmaceutical industry and the business
community at large to bring about consensus on broad policy issues that can
impact Pfizer
’
s business objectives and ability to serve patients. Our support of
these organizations is evaluated annually by the company
’
s U.S. Government
Relations leaders based on these organizations
’
expertise in healthcare policy and
advocacy and support of key issues of importance to Pfizer. In addition to their
positions on health care policy issues, we realize these organizations may engage
in a broad range of other issues that extend beyond the scope of what is of
primary importance to Pfizer's business. If concerns arise about a particular issue,
we convey our concerns, as appropriate, through our colleagues who serve on the
boards and committees of these groups. We believe there is value in making sure
our positions on issues important to Pfizer and our industry are communicated
and understood within those organizations. Pfizer
’
s participation as a member of
these various industry and trade groups comes with the understanding that we
may not always agree with each position taken by the larger organization and/or
other members.
Our most significant trade association memberships are with the U.S. Chamber of
Commerce (Chamber), the Business Roundtable (BRT), the National Association of
Manufacturers (NAM), the Biotechnology Industry Association (BIO), and the
Pfizer
2
Pharmaceutical Research and Manufacturers of America (PhRMA). We work
closely and are proud of our collaboration with each of these trade associations on
core issues of great importance to Pfizer
’s business
and our stakeholders. PhRMA
and BIO lead the industry in promoting pro-patient and pro-innovation health care
policies while fighting against harmful government price control policies. The BRT,
Chamber and NAM are leading voices on US tax competitiveness. All of these
trade associations are vocal advocates for robust protections for intellectual
property rights.
Of course, because these trade associations represent so many members with a
diversity of interests, at times their positions and efforts on certain issues are not
perfectly aligned with our own. Some misalignment is an unavoidable
consequence of any collective endeavor. Nevertheless, we monitor where and to
what extent our trade associations are misaligned with the company on such
issues. Where possible, we will advocate for the trade association to come into
alignment, but if an organization
’
s misalignment is egregious, and the
membership benefits to Pfizer and its stakeholders are outweighed by the
misalignments, we will reduce or end our involvement with the organization.
In addition, 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. At least annually, the Committee receives a
report from the company’s U.S. Government Relations leaders regarding our
public policies activities, including an overview of the benefits derived from the
company’s association with certain trade and other organizations.
That said, the following report outlines the public policy positions of Pfizer and the
five trade associations across six areas of key public policy and ESG significance for
Pfizer: Climate Change; Patient Access to Healthcare; Trade; Tax; Diversity, Equity,
and Inclusion; and Civic Integrity. The report also compares Pfizer and the trade
associations’ positions and descri
bes the degree of alignment and areas of
misalignment. Please note that while some of these issues, such as healthcare
access, tax and trade are core to Pfizer's business, the other issues are
nevertheless important to the company although they may not be core to the
company's business
3
4
Biotechnology Innovation Organization
The policy goals of Pfizer and the Biotechnology Innovation Organization (BIO) are
generally in alignment across the key areas reviewed. To the extent differences
exist in the company and trade association
’
s respective positions, such as on tax,
they are largely because either Pfizer or BIO has taken a position on particular
matters on which the other has not. Indeed, Pfizer has been more vocal than BIO
on support of free trade, though both agree on the importance of intellectual
property protections in trade agreements. On broad policy goals, Pfizer and BIO
are well aligned. Pfizer engages with BIO on the following issues: (a) intellectual
property/innovation protection; (b) vaccine policy and advocacy; (c) patient
affordability solutions; and (d) FDA User Fee agreements (in partnership with
PhRMA).
Pfizer
BIO
Gap Analysis
Climate
Change
Pfizer understands and
takes action to reduce the
risks of adverse impacts
from climate threats by
recognizing that climate
change is a defining issue
of the times caused
primarily by human
activities. These values
are illustrated through
demonstrable policies and
goals, supporting
government efforts for
market-based solutions
aimed at achieving
science-based emission
reduction targets, while
also taking steps at the
company level, including
becoming carbon neutral
by 2030. The company
also seeks to engage value
chain partners to help
them achieve target
reductions in emissions.
BIO believes that climate
change is one of the
greatest public policy
challenges facing this
generation and that
biotechnology has the
potential to be a
transformative asset in
this struggle. It supports
efforts to reduce
greenhouse gas
emissions as well as
establishing a national
low carbon fuels
standard. BIO strongly
supports the Growing
Climate Solutions Act,
including the
establishment of a
national carbon market,
the U.S. rejoining the
Paris Climate Accords,
and the development of
Sustainable Aviation
Fuels. Lastly, BIO
opposes the practice of
granting small refinery
Pfizer and BIO are in
close alignment on
climate change, with
both favoring market-
based and scientific-
evidence based
solutions to climate
change.
5
hardship waivers under
the Renewable Fuel
Standard.
Access to
Healthcare
Pfizer seeks to maximize
the use of its medicines
and vaccines for
supporting global public
health efforts. This
includes permitting, as
safely as possible, access
to investigational drugs
still in development in
limited circumstances. As
a global company, Pfizer
attempts to ensure that
underserved patients
around the world have
access to essential
medicines and vaccines.
In addition, Pfizer seeks to
educate underserved
patients on health literacy
to further health equity.
BIO believes that
biotechnology can help
provide healthcare
solutions for a variety of
problems, such as opioid
addiction, vaccine access,
and disease prevention.
BIO member companies
are committed to making
innovative biotechnology
medicines available to
patients who need them
through the efficient
development of
approved, safe and
effective products.
However, BIO opposes
global drug price control
schemes such as those
found in H.R. 3. BIO
favors expanding access
to investigational drugs
as long as proper
safeguards remain in
place. Lastly, BIO and its
members often work
together with patient
advocacy organizations to
better understand the
patients it serves in order
to help raise awareness
and understanding of
disease and to advance
patient-focused public
policies.
Pfizer and BIO are in
close alignment in
expanding access to
healthcare, including
expanded access to
investigational drugs
and COVID vaccines.
Trade
Pfizer balances the
realities of encouraging
trade, commerce, and
patient access while
protecting IP that is at the
heart of the company
’
s
innovation engine. As a
company that engages
BIO supports eliminating
acute and systemic trade
barriers to innovative
biotechnology tools,
particularly in important
export markets, such as
China, the European
Union, and Mexico. It
Pfizer and BIO are in
close alignment on the
importance of
intellectual property
protections in trade
agreements, but Pfizer
has spoken more
favorably of free trade
6
heavily in R&D, it is
imperative to the success
of the company that
products that are the
result of costly research be
given the appropriate
market protections. This
includes advocating for
free trade agreements
that provide legal
certainty. Pfizer also
emphasizes an ethical
supply chain and following
applicable antitrust laws,
both in the U.S. and
abroad.
believes that to fully
leverage the potential of
biotechnology, a level-
playing field at the global
level is essential. BIO also
favors robust intellectual
property protections for
biotechnology
companies. It has
criticized the World Trade
Organization
’
s (WTO)
proposed
“
TRIPS
”
waiver
of intellectual property
rights for technologies
used to prevent, contain,
or treat COVID-19. In
addition, BIO supports
pursuing biotechnology-
specific outcomes in new
trade agreements and
modernizing older trade
agreements to address
biotechnology. It
criticized the United
States-Mexico-Canada
Agreement (USMCA) for
failing to include
enhanced intellectual
property standards for
American
biopharmaceutical
products.
agreements generally
than BIO has.
Tax
Pfizer opposes increasing
the tax burden on U.S.
companies through
changes to the foreign
minimum tax.
BIO supports a number of
state-level tax credits,
deductions, and
exemptions. It supports
seed capital tax credits
and angel investor tax
credits to encourage
early-stage investment,
tax credits to increase the
availability of venture
capital, tax credits for
research and
development, sales tax
exemptions for
Pfizer and BIO have
different focuses in the
area of tax policy. BIO
does not appear to
have taken a position
on the foreign
minimum tax issue of
most interest to Pfizer,
but holds a number of
other positions on tax
policy that Pfizer has
not addressed. Thus,
Pfizer and BIO
’
s
positions are
7
equipment used in
research and
development and
manufacturing, capital
investment tax incentives,
innovation investment tax
incentives, tax credit
transferability, the option
to carry forward net
operating losses (NOL),
and capital gains
deductions. At the
federal level, it supports a
number of biofuel tax
incentives, particularly
the Second Generation
Biofuel Producer Tax
Credit, the Special
Depreciation Allowance
for Second Generation
Biofuel Plant Property,
the Biodiesel and
Renewable Diesel Fuels
Credit, and the
Alternative Fuel Vehicle
Refueling Property Credit.
It also supports reform of
limitations on NOL
carryforwards under
Section 382 of the federal
tax code.
misaligned in this area,
though not in conflict.
Diversity
Equity &
Inclusion
Pfizer has numerous
company policies and
reports that emphasize
the importance of
diversity, equity, and
inclusion to the company
and provide metrics that
reflect the priority that the
company places on such
efforts. This emphasis on
values related to DE&I is
not illustrated only in
policies addressing
company personnel, but
also related to patients, as
BIO supports increasing
diversity, equity and
inclusion (DE&I) in the
biotechnology space. It
has spearheaded several
initiatives dedicated to
improving diversity such
as its BIOEquity Agenda
and the Right Mix Matters
campaign. BIO also
believes that it is
imperative to increase
diversity in clinical trials in
order to best reflect the
population that will
Pfizer and BIO are in
close alignment on
matters of DE&I, in
terms of the corporate
workforce, clinical
trials and access to
healthcare.
8
the company seeks to
overturn longstanding
inequities in healthcare
systems, such as through
inclusive drug trials.
ultimately be using the
tested drugs. Lastly, BIO
has committed to
promoting health equity
by enhancing clinical trial
diversity, promoting
access to vaccines and
therapeutics for
uninsured and
underserved populations
and fostering enhanced
nutritional,
environmental, and
mental wellness
opportunities in
economically
disadvantaged
communities.
Civic Integrity
Pfizer opposed the events
at the Capitol on January 6,
2021 and paused Pfizer
Political Action Committee
(PAC) giving to the 147
Republicans who voted
against certifying the
election for the first half of
2021. Pfizer also supports
ensuring every American
citizen’s right to vote,
which is fundamental to
our democracy.
BIO opposed the events
that took place at the
Capitol on January 6. As a
result, it briefly paused all
political giving in order to
reassess the criteria it
uses to make political
donations.
Pfizer and BIO are in
close alignment on
civic integrity, with
both condemning the
events that took place
at the Capitol on
January 6, 2021.
9
Business Roundtable
The policy goals of Pfizer and the Business Roundtable (BRT) are generally in
alignment across the key areas reviewed. To the extent there are differences in
the company and trade association
’
s respective positions, they are because Pfizer
and BRT are focusing on different specific aspects of the issue. However, on broad
policy goals, Pfizer and BRT are well aligned. Pfizer engages with the BRT on the
following issues: (a) U.S. tax competitiveness; (b) global tax debate; (c) free trade
policies and intellectual property protection; (d) employer health care and health
equity solutions; and (e) enhancing diversity and inclusion in the workforce.
Pfizer
Business Roundtable
Gap Analysis
Climate
Change
Pfizer understands and
takes action to reduce the
risks of adverse impacts
from climate threats by
recognizing that climate
change is a defining issue
of the times caused
primarily by human
activities. These values
are illustrated through
demonstrable policies and
goals, supporting
government efforts for
market-based solutions
aimed at achieving
science-based emission
reduction targets, while
also taking steps at the
company level, including
becoming carbon neutral
by 2030. The company
also seeks to engage value
chain partners to help
them achieve target
reductions in emissions.
The Business Roundtable
believes corporations
should lead by example,
support sound public
policies, and drive
innovation in order to
best address climate
change. However, the
BRT asserts that effective
change will not happen in
a vacuum, and that it is
imperative for the U.S.
government to act in
tandem with
corporations. In
particular, the BRT calls
on the U.S. government
to adopt a more
comprehensive,
coordinated, and market-
based approach to
emissions reduction. This
approach should also
place a premium on
fostering innovation, U.S.
competitiveness, and
compliance flexibility.
The BRT identifies global
cooperation and
diplomacy as the keys to
achieving the collective
Both Pfizer and BRT
favor market-based
and scientific-evidence
based solutions to
climate change. Pfizer
is committed to taking
responsible climate
action and reducing
environmental impact;
BRT also advocates for
corporations to take
such actions. BRT has
been criticized in the
press in recent months
for opposing the Biden
administration
’
s Build
Back Better legislation,
despite its substantial
investment in
combating climate
change. But this
opposition is due to
the onerous tax
provisions included in
the legislation; BRT
has called for separate
legislative action on
climate change.
10
global action that is
necessary to address the
climate change challenge.
However, the BRT has
received criticism in the
press for opposing the
Biden administration
’
s
Build Back Better
legislation, despite its
substantial investment in
combating climate
change.
Access to
Healthcare
Pfizer seeks to maximize
the use of its medicines
and vaccines for
supporting global public
health efforts. This
includes permitting, as
safely as possible, access
to investigational drugs
still in development in
limited circumstances. As
a global company, Pfizer
attempts to ensure that
underserved patients
around the world have
access to essential
medicines and vaccines.
In addition, Pfizer seeks to
educate underserved
patients on health literacy
to further health equity.
The BRT believes that an
affordable, innovative
and efficient healthcare
system is an essential
factor in ensuring a
better quality of life for all
Americans as well as a
more productive and
competitive U.S.
workforce. The BRT has
established its own
Health & Retirement
committee to bring about
its goals. The
committee
’
s purpose is to
support health policy
initiatives and the U.S.
retirement system. The
BRT also supports policies
that will improve the
affordability and quality
of U.S. healthcare and is
particularly interested in
the intersection of racial
equity and health. The
BRT believes that by
focusing on effective and
inclusive healthcare and
retirement policies, the
U.S. will become a more
attractive location for
skilled workers and
businesses. BRT has also
Pfizer and BRT are
both focused on
expanding access to
healthcare. Pfizer
largely focuses on
expanding access to
medicines and
vaccines, including
investigational drugs.
BRT does not appear
to have taken a
position on these
specific initiatives,
except that it has been
promoting access to
COVID vaccines, and is
instead focused on
reducing the cost of,
and expanding access
to, health insurance.
Both Pfizer and BRT
support efforts to
promote equity in
access to healthcare.
11
actively promoted use of
COVID vaccines.
Trade
Pfizer balances the
realities of encouraging
trade, commerce, and
patient access while
protecting IP that is at the
heart of the company
’
s
innovation engine. As a
company that engages
heavily in R&D, it is
imperative to the success
of the company that
products that are the
result of costly research be
given the appropriate
market protections. This
includes advocating for
free trade agreements
that provide legal
certainty. Pfizer also
emphasizes an ethical
supply chain and following
applicable antitrust laws,
both in the U.S. and
abroad.
The BRT believes that
every sector of the U.S.
economy benefits from
free trade, and that
future economic growth
and jobs in the U.S.
depend on expanding
U.S. trade and investment
opportunities around the
world. In this same vein,
the BRT is very supportive
of friendly trade relations
with Canada and Mexico.
However, the BRT takes
issue with China
’
s trade
and investment practices
and supports the
preservation of the Phase
Agreement as well as
working with U.S. allies
and trading partners to
press for further
structural reforms in
China such as stronger
intellectual property
protections. Lastly, the
BRT opposes the Section
232 tariffs on steel and
aluminum imports.
Pfizer and BRT are in
close alignment on
trade policy. Both
favor free trade
agreements and the
protection of
intellectual property
rights through such
agreements.
Tax
Pfizer opposes increasing
the tax burden on U.S.
companies through
changes to the foreign
minimum tax.
The BRT supports tax and
fiscal policies that
promote innovation and
create more opportunity
for America
’
s workers,
communities and job
creators. It strongly
supports the 2017 tax
reform and believe that it
has aligned the U.S.
corporate tax rate with
global competitors
thereby allowing for low
unemployment, better-
Pfizer and BRT are in
close alignment on
opposition to changes
to the foreign
minimum tax that
would increase the tax
burden on U.S.
companies relative to
foreign companies.
BRT has positions on
numerous other tax
issues on which Pfizer
has not taken a public
position.
12
than-expected growth in
GDP, and the fastest two-
year wage growth in 20
years (prior to the
pandemic). Furthermore,
the BRT believes that any
U.S. minimum tax should
be agreed upon at a
global level instead of just
applying to U.S.
companies. Lastly, the
BRT opposes an increase
in corporate taxes being
bundled into an
infrastructure bill.
Diversity
Equity &
Inclusion
Pfizer has numerous
company policies and
reports that emphasize
the importance of
diversity, equity, and
inclusion to the company
and provide metrics that
reflect the priority that the
company places on such
efforts. This emphasis on
values related to DE&I is
not illustrated only in
policies addressing
company personnel, but
also related to patients, as
the company seeks to
overturn longstanding
inequities in healthcare
systems, such as through
inclusive drug trials.
The BRT strongly
supports the DE&I efforts
of its member companies.
It also recommends that
member companies
increase transparency on
corporate diversity by
voluntarily disclosing
their diversity metrics,
including hiring and
leadership. Furthermore,
the BRT has taken a
multi-faceted approach to
DE&I initiatives and has
created substantive
policies that address DE&I
issues in employment,
finance, education,
health, housing, and the
justice system.
Pfizer and BRT are in
close alignment on
matters of DE&I, both
in terms of the
corporate workforce
and access to
healthcare.
Civic Integrity
Pfizer opposed the events
at the Capitol on January 6,
2021and paused Pfizer
Political Action Committee
(PAC) giving to the 147
Republicans who voted
against certifying the
election for the first half of
2021. Pfizer also supports
ensuring every American
The BRT strongly
opposed claims that the
results of the 2020
Presidential election were
the product of fraud
before, during, and after
the events that took place
at the Capitol on January
6, 2021. The BRT also
supports greater access
Pfizer and BRT are in
close alignment on
civic integrity, with
both condemning the
events that took place
at the Capitol on
January 6, 2021, and
supporting access to
voting.
13
citizen’s right to vote,
which is fundamental to
our democracy.
to voting and encourages
broad voter participation.
In the same vein, the BRT
encourages its member
companies to allow their
employees to take the
day off of work in order to
vote.
National Association of Manufacturers
The policy goals of Pfizer and the National Association of Manufacturers (NAM) are
generally in alignment across the key areas reviewed. The alignment is less close
in the areas of climate change and access to healthcare, largely because Pfizer and
the NAM are focusing on different specific aspects of the issue. However, on broad
policy goals, Pfizer and BRT are well aligned. Pfizer engages with NAM on the
following issues: (a) high quality manufacturing; (b) international trade; and (c) to
oppose governmental intervention in health care, including price controls in
Medicare.
Pfizer
NAM
Gap Analysis
Climate
Change
Pfizer understands and
takes action to reduce the
risks of adverse impacts
from climate threats by
recognizing that climate
change is a defining issue
of the times caused
primarily by human
activities. These values
are illustrated through
demonstrable policies and
goals, supporting
government efforts for
market-based solutions
aimed at achieving
science-based emission
reduction targets, while
also taking steps at the
company level, including
becoming carbon neutral
by 2030. The company
The NAM recognizes that
climate change poses a
serious threat to the
planet. It has called for a
clear and unified federal
climate policy that is
based on science-based
metrics and that
preempts conflicting and
duplicative regulations. It
supports increasing
investments in public-
and private-sector energy
and water efficiency,
scaling up the adoption of
energy- and water-
efficient products and
technologies, and
developing pathways for
the deployment of new
technologies like carbon
Both Pfizer and the
NAM favor scientific
evidence based
solutions to climate
change. There is some
misalignment in how
to achieve these
solutions, with Pfizer
focused on market-
based mechanisms
while the NAM
supports greater
regulatory clarity and
consistency that
supports innovation
and a global approach
to climate change.
14
also seeks to engage value
chain partners to help
them achieve target
reductions in emissions.
capture, utilization, and
storage. It believes that
any federal policy must
be part of a broader
global solution and has
encouraged the U.S. to
reengage with the
international community
in order to reduce
greenhouse gas
emissions collectively,
rather than in isolation.
The NAM is opposed to
measures, such as the
Green New Deal, that it
believes would too
quickly transition the U.S.
from fossil fuels and
would put U.S.
manufacturers at a
competitive
disadvantage.
Access to
Healthcare
Pfizer seeks to maximize
the use of its medicines
and vaccines for
supporting global public
health efforts. This
includes permitting, as
safely as possible, access
to investigational drugs
still in development in
limited circumstances. As
a global company, Pfizer
attempts to ensure that
underserved patients
around the world have
access to essential
medicines and vaccines.
In addition, Pfizer seeks to
educate underserved
patients on health literacy
to further health equity.
The NAM supports
market-based solutions
to lower healthcare costs.
In particular, it supports
moving the U.S. from a
fee-for-service or volume-
based healthcare system
to a value-based
healthcare system;
enacting policies that
allow employers to use
innovative approaches to
providing coverage for
their employees, such as
wellness programs,
association health plans,
and direct primary care;
improving health savings
accounts to reduce
patient out-of-pocket
costs; reducing
Affordable Care Act
–
mandated reporting
requirements; and
maintaining the tax-
Pfizer and the NAM are
in broad alignment on
minimizing
government
intervention between
patients and the drugs
and vaccines they
need. Pfizer largely
focuses on expanding
access to medicines
and vaccines, including
investigational drugs.
The NAM does not
appear to have taken a
position on these
specific initiatives,
except that it has been
promoting access to
COVID vaccines, and is
instead focused on
reducing the cost of
healthcare and health
insurance, while
combating
15
exempt status of
employee health benefits
to avoid higher premiums
for workers and families.
The NAM is opposed to
government price
controls, which it argues
will chill innovation and
expose consumers to
unsafe medicines.
government price
controls.
Trade
Pfizer balances the
realities of encouraging
trade, commerce, and
patient access while
protecting IP that is at the
heart of the company
’
s
innovation engine. As a
company that engages
heavily in R&D, it is
imperative to the success
of the company that
products that are the
result of costly research be
given the appropriate
market protections. This
includes advocating for
free trade agreements
that provide legal
certainty. Pfizer also
emphasizes an ethical
supply chain and following
applicable antitrust laws,
both in the U.S. and
abroad.
The NAM supports free
trade agreements to
provide certainty in the
global marketplace, open
markets for U.S.-
manufactured goods, and
eliminate unfair barriers
to trade. It believes that
the U.S. needs to work
with allies to shape the
global rules for trade. It
supports vigorous
protection of intellectual
property rights at home
and abroad and targeted
policies directed at China
to reverse the country
’
s
illegal subsidies,
intellectual property theft,
and discriminatory
industrial policies. It also
supports modernizing
U.S. and foreign customs
operations to cut red tape
and expedite legitimate
trade in the U.S. and
across foreign borders
and implementing U.S.
export control and
investment review
policies that promote the
leadership,
competitiveness, and
strength of the U.S.
manufacturing industry.
The NAM is opposed to
tariffs, which it argues
Pfizer and the NAM are
in close alignment on
trade policy. Both
favor free trade
agreements and the
protection of
intellectual property
rights through such
agreements.
16
undermine economic
growth by restricting
trade.
Tax
Pfizer opposes increasing
the tax burden on U.S.
companies through
changes to the foreign
minimum tax.
The NAM supports a
competitive tax code that
promotes economic
growth and incentivizes
investment in
infrastructure, research
and development, and
human capital. It is
opposed to increasing
taxes, particularly the
corporate tax and foreign
minimum tax, and to
limiting tax deductions,
such as the business
interest expense
deduction.
Pfizer and the NAM are
in close alignment on
opposition to changes
to the foreign
minimum tax that
would increase the tax
burden on U.S.
companies relative to
foreign companies.
The NAM has positions
on numerous other tax
issues on which Pfizer
has not taken a public
position.
Diversity
Equity &
Inclusion
Pfizer has numerous
company policies and
reports that emphasize
the importance of
diversity, equity, and
inclusion to the company
and provide metrics that
reflect the priority that the
company places on such
efforts. This emphasis on
values related to DE&I is
not illustrated only in
policies addressing
company personnel, but
also related to patients, as
the company seeks to
overturn longstanding
inequities in healthcare
systems, such as through
inclusive drug trials.
The NAM supports
diversity, equity, and
inclusion policies. It
encourages
manufacturers to take
proactive measures to
hire more women, people
of color, and members of
the LGBT community and
to make their workplaces
more open and
accepting.
Pfizer and the NAM are
in close alignment on
DE&I, matters in the
corporate workforce,
although the NAM
does not appear to
have focused on
inequities in
healthcare systems
specifically.
Civic Integrity
Pfizer opposed the events
at the Capitol on January 6,
2021 and paused Pfizer
Political Action Committee
(PAC) giving to the 147
The NAM encourages
people to vote and spoke
out against efforts after
the 2020 general election
to undermine the
Pfizer and the NAM are
in close alignment on
civic integrity, with
both condemning the
events that took place
17
Republicans who voted
against certifying the
election for the first half of
2021. Pfizer also supports
ensuring every American
citizen’s right to vote,
which is fundamental to
our democracy.
presidential election
results.
following the 2020
election.
18
Pharmaceutical Research and Manufacturers of America
Pfizer and Pharmaceutical Research and Manufacturers of America (PhRMA) are
closely aligned on policy goals and specific positions. The only notable exception is
in the area of climate change, where PhRMA has not taken a public position. Pfizer
engages with PhRMA on the following issues: (a) lead industry efforts to advance
pro-patient policies and defeat negative drug pricing proposals at the federal level;
(b) advance rebate pass-through, copay accumulator bans and out of pocket caps
at state level; (c) protect intellectual property rights globally; and (d) advance FDA
User Fee agreements (in partnership with BIO).
Pfizer
PhRMA
Gap Analysis
Climate
Change
Pfizer understands and
takes action to reduce the
risks of adverse impacts
from climate threats by
recognizing that climate
change is a defining issue
of the times caused
primarily by human
activities. These values
are illustrated through
demonstrable policies and
goals, supporting
government efforts for
market-based solutions
aimed at achieving
science-based emission
reduction targets, while
also taking steps at the
company level, including
becoming carbon neutral
by 2030. The company
also seeks to engage value
chain partners to help
them achieve target
reductions in emissions.
No public policy or
position identified.
PhRMA does not have
public positions on
climate change, so
there is no material
misalignment between
Pfizer and PhRMA on
this topic.
Access to
Healthcare
Pfizer seeks to maximize
the use of its medicines
and vaccines for
supporting global public
health efforts. This
PhRMA is willing to work
with all stakeholders to
deliver a more resilient,
stronger, affordable and
equitable healthcare
Pfizer and PhRMA are
in close alignment on
expanding access to
healthcare, including
through greater access
19
includes permitting, as
safely as possible, access
to investigational drugs
still in development in
limited circumstances. As
a global company, Pfizer
attempts to ensure that
underserved patients
around the world have
access to essential
medicines and vaccines. In
addition, Pfizer seeks to
educate underserved
patients on health literacy
to further health equity.
system for all. However,
it believes that the
current price setting
proposals in Congress
threaten Americans
’
access to crucial,
breakthrough medicines,
and that there should
instead be a cap on out-
of-pocket costs for
seniors. It also focuses
on lower cost sharing and
making drugs prices
more predictable. PhRMA
wants to ensure that
billions of dollars in
rebates and discounts get
passed on to patients
–
not kept by the insurance
companies, hospitals and
middlemen. PhRMA also
supports expanded
access to investigational
drugs.
to investigational
drugs.
Trade
Pfizer balances the
realities of encouraging
trade, commerce, and
patient access while
protecting IP that is at the
heart of the company
’
s
innovation engine. As a
company that engages
heavily in R&D, it is
imperative to the success
of the company that
products that are the
result of costly research be
given the appropriate
market protections. This
includes advocating for
free trade agreements
that provide legal
certainty. Pfizer also
emphasizes an ethical
supply chain and following
applicable antitrust laws,
PhRMA supports free and
fair trade and believes
that through trade
agreements with other
countries, medicines
developed in the U.S. are
able to reach patients
around the world who
otherwise would not be
able to access the latest
treatments and cures.
However, it argues that
some countries artificially
limit the price of
innovative U.S.
pharmaceuticals, and fail
to adequately protect
intellectual property,
thereby hampering
access to new treatments
in foreign countries and
reducing investment in
Pfizer and PhRMA are
in close alignment on
trade policy, with both
favoring free trade and
strong intellectual
property protections.
20
both in the U.S. and
abroad.
research and
development. PhRMA
argues that this
ultimately harms patients
and health systems.
Therefore, PhRMA
supports strong IP
protection policies.
Tax
Pfizer opposes increasing
the tax burden on U.S.
companies through
changes to the foreign
minimum tax.
PhRMA believes that
increased taxes limit the
ability of pharmaceutical
companies to provide
new treatments abroad
and disincentivizes
research and
development for
lifesaving cures. It
engaged an outside
auditor to estimate the
effects of the Biden
administration
’
s federal
income tax payment plan
on the pharmaceutical
industry. The analysis
showed that the
administration
’
s tax
proposals would increase
tax payments on the
pharmaceutical industry
by more than $95 billion
because of revisions to
the global minimum tax
regime and related
proposals. This coupled,
with the increase in the
corporate income tax rate
to 28%, would raise the
pharmaceutical industry
’
s
taxes by an estimated
$40.7 billion.
Pfizer and PhRMA are
in close alignment on
opposition to changes
to the foreign
minimum tax that
would increase the tax
burden on U.S.
companies relative to
foreign companies.
Diversity
Equity &
Inclusion
Pfizer has numerous
company policies and
reports that emphasize
the importance of
diversity, equity, and
PhRMA is committed to
enhancing diversity,
equity and inclusion in
the pharmaceutical
industry. It published the
Pfizer and PhRMA are
in close alignment on
matters of DE&I, both
in terms of the
corporate workforce,
21
inclusion to the company
and provide metrics that
reflect the priority that the
company places on such
efforts. This emphasis on
values related to DE&I is
not illustrated only in
policies addressing
company personnel, but
also related to patients, as
the company seeks to
overturn longstanding
inequities in healthcare
systems, such as through
inclusive drug trials.
first ever industry-wide
principles on clinical trial
diversity. Further, it has
consistently responded to
government requests for
information on diversity
initiatives. PhRMA has
also created a grant
program that awards
money to community-
based projects to address
inequities in diagnosis,
treatment, and
adherence. Lastly,
PhRMA has published an
open letter on equity,
noting that systemic
racism is as real as any
disease and commits
PhRMA to pursuing
various measures in
order to improve its
diversity, equity and
inclusion efforts.
access to healthcare
and participation in
clinical trials.
Civic Integrity
Pfizer opposed the events
at the Capitol on January 6,
2021 and paused Pfizer
Political Action Committee
(PAC) giving to the 147
Republicans who voted
against certifying the
election for the first half of
2021. Pfizer also supports
ensuring every American
ci
tizen’s right to vote,
which is fundamental to
our democracy.
PhRMA
’
s CEO issued a
strong rebuke of the
events at the Capitol on
January 6. Soon after,
PhRMA paused all
political giving to those
who voted to reject the
outcome of the 2020
presidential election.
Pfizer and PhRMA are
in close alignment on
civic integrity, with
both condemning the
events that took place
at the Capitol on
January 6, 2021.
U.S. Chamber of Commerce
The policy goals of Pfizer and the U.S. Chamber of Commerce (Chamber) are
generally in alignment across the key areas reviewed. To the extent there are
differences in the company and trade association
’
s respective positions, they are
generally because Pfizer and Chamber are focusing on different specific aspects of
the issue. However, on broad policy goals, they are well aligned. Pfizer engages
22
with the Chamber on the following issues: (a) promote and protect intellectual
property/innovation through Global Innovation Policy Center; (b) drive narrative
on counterfeits/product integrity; (c) lead on U.S. tax competitiveness; and (d)
protect employer health care and drive policies to promote competition in health
care.
Pfizer
Chamber
Gap Analysis
Climate
Change
Pfizer understands and
takes action to reduce the
risks of adverse impacts
from climate threats by
recognizing that climate
change is a defining issue
of the times caused
primarily by human
activities. These values
are illustrated through
demonstrable policies and
goals, supporting
government efforts for
market-based solutions
aimed at achieving
science-based emission
reduction targets, while
also taking steps at the
company level, including
becoming carbon neutral
by 2030. The company
also seeks to engage value
chain partners to help
them achieve target
reductions in emissions.
The Chamber
acknowledges the
severity of the climate
threat, that humans are
contributing, and that
steps needs to be taken
to address the crisis. The
organization recognizes
the role that business and
market-driven solutions
can play in slowing the
effects of climate change.
In addition, governments
and technological
solutions should be
leveraged but solutions
must be realistic, durable,
and reinforce U.S.
economic
competitiveness.
On climate change,
both Pfizer and the
Chamber favor
market-based and
technology-based
solutions. Pfizer is
committed to taking
responsible climate
action and reducing
environmental impact;
the Chamber also
advocates for
corporations to take
such actions. The
Chamber has been
criticized for its history
of opposition to
legislation targeting
climate change and
opposing the Biden
administration
’
s Build
Back Better legislation,
which includes climate
provisions. The
Chamber testified
before Congress in
October and noted
that c
ombating climate
change requires
citizens, governments,
and businesses to
work together
–
and
that inaction is not an
option.
.
Access to
Healthcare
Pfizer seeks to maximize
the use of its medicines
and vaccines for
The Chamber believes
private business is a
significant factor in what
Pfizer and the
Chamber are in
alignment on
23
supporting global public
health efforts. This
includes permitting, as
safely as possible, access
to investigational drugs
still in development in
limited circumstances. As
a global company, Pfizer
attempts to ensure that
underserved patients
around the world have
access to essential
medicines and vaccines.
In addition, Pfizer seeks to
educate underserved
patients on health literacy
to further health equity.
makes America the leader
in healthcare in the world.
American innovation
leads to better outcomes
for both domestic and
international patients and
companies must be
provided proper
incentives and protection
to allow research and
development to continue.
These protections should
be balanced to increase
affordability and optimize
access for all patients.
Employer-sponsored
healthcare provides the
best option for many
Americans.
expanding access to
healthcare. Pfizer
largely focuses on
expanding access to
medicines and
vaccines, including
investigational drugs.
The Chamber does not
appear to have taken a
position on these
specific initiatives,
except that it has been
promoting access to
COVID vaccines, and is
instead focused on
reducing the cost of,
and expanding access
to, health insurance.
Trade
Pfizer balances the
realities of encouraging
trade, commerce, and
patient access while
protecting costly IP that is
at the heart of the
company
’
s profitability.
As a company that
engages heavily in R&D, it
is imperative to the
success of the company
that products that are the
result of costly research be
given the appropriate
market protections. This
includes advocating for
free trade agreements
that provide legal
certainty. Pfizer also
emphasizes an ethical
supply chain and following
applicable antitrust laws,
both in the U.S. and
abroad.
The Chamber emphasizes
free trade and opposes
tariffs, providing
American companies the
opportunity to participate
in the global marketplace.
In addition to agreements
that open the
marketplace, it
’
s
important that these
agreements also provide
intellectual property
protections that protect
and encourage
innovation.
Pfizer and the
Chamber are in close
alignment on trade
policy. Both favor free
trade agreements and
the protection of
intellectual property
rights through such
agreements.
Tax
Pfizer opposes increasing
the tax burden on U.S.
The Chamber believes in
tax policies that support
Pfizer and the
Chamber are in close
24
companies through
changes to the foreign
minimum tax.
business and promote
the growth the economy.
This generally means
lower and stable tax rates
for business that spurs
job growth and
investment. In addition,
the Chamber supports
repealing taxes on certain
aspects of healthcare.
Internationally, the
Chamber supports tax
agreements that
establish fair systems by
which American
companies can compete
globally, and opposes an
increase to the global
minimum tax for U.S.
companies.
alignment on
opposition to changes
to the foreign
minimum tax that
would increase the tax
burden on U.S.
companies relative to
foreign companies.
The Chamber has
positions on numerous
other tax issues on
which Pfizer has not
taken a public position.
Diversity
Equity &
Inclusion
Pfizer has numerous
company policies and
reports that emphasize
the importance of
diversity, equity, and
inclusion to the company
and provide metrics that
reflect the priority that the
company places on such
efforts. This emphasis on
values related to DE&I is
not illustrated only in
policies addressing
company personnel, but
also related to patients, as
the company seeks to
overturn longstanding
inequities in healthcare
systems, such as through
inclusive drug trials.
The Chamber supports
and understands the role
that diversity, equity, and
inclusion play in creating
a vibrant and dynamic
economy. This includes
by supporting member
efforts, instituting
programs, and creating
studies that illustrate that
diversity is a strength in
America. The
organization believes that
DE&I efforts will be
central to a growing
economy in the future.
Pfizer and the
Chamber are in close
alignment on matters
of DE&I, with respect
to promoting diversity
in the corporate
workforce.
Civic Integrity
Pfizer opposed the events
at the Capitol on January 6,
2021 and paused Pfizer
Political Action Committee
(PAC) giving to the 147
The Chamber condemned
the attacks against the
Capitol on January 6 and
believes the 2020
presidential electoral
Pfizer and the
Chamber both
condemned the events
of January 6, 2021. The
Chamber has taken a
25
Republicans who voted
against certifying the
election for the first half of
2021. Pfizer also supports
ensuring every American
citizen’s right to vote,
which is fundamental to
our democracy.
college was won by Joe
Biden. After the attacks,
the organization
announced that it would
holistically consider
future contributions to
candidates, including
their positions on issues
related to democracy, but
did not say it would
categorically withhold
funds from those who
voted against certifying
the electoral college. The
Chamber opposes the For
the People Act of 2021,
Democrats
’
signature
voting rights bill this
session, taking the
position that it would
silence voices from the
political process.
position against the
For the People Act of
2021; although Pfizer
has indicated its
support for voting
rights, it has not taken
a public position on
this bill.
26
Methodology
This report surveys the public policy positions of Pfizer and five national trade
associations of which Pfizer is a member: the Biotechnology Innovation
Organization, the Business Roundtable, the National Association of Manufacturers,
the Pharmaceutical Research and Manufacturers of America, and the U.S. Chamber
of Commerce (collectively the
“
Trade Associations
”
). The review included the
notable written policies of Pfizer and the Trade Associations generally addressing
six issues: Climate Change; Patient Access to Healthcare; Trade; Tax; Diversity,
Equity, and Inclusion; and Civic Integrity.
The report draws from the policies maintained on the websites of Pfizer and the
Trade Associations. The policies were identified through a review of the respective
websites and targeted keyword searches of the websites. In addition, we compiled
recent notable criticism of the Trade Associations
’
positions featured in media
outlets through keyword searches of media databases. Please note, this report is
focused on current Pfizer and Trade Association policies as of Fall 2021 and we
omitted policies and criticism that we could determine were written prior to 2019.
27
December 2021
EXHIBIT C
(see attached)
P
$
zer PAC and
Corporate Political
Contributions Report
January 2021 – December 2021
Corporate Affairs
Government Relations
P
$
zer PAC
Leading the Conversation.
2
U.S. Government Rela ons & P zer PAC
A Message from Rady Johnson & Sally Susman, Co-Chairs, P zer PAC
We are pleased to share our 2021 elec on cycle poli cal contribu ons report, which includes a list of candidates and poli cal
commi ees supported either by P zer Inc. or the P zer PAC from January 1, 2021, through December 31, 2021.
It has been an incredible year as our colleagues have once again delivered excellence by developing and advancing our COVID-19
vaccine and an -viral as well as many other breakthrough medicines and vaccines. In 2021, we were able to defend against
challenging policy proposals that would have inhibited pa ents’ access to breakthroughs and support candidates of both poli cal
par es who support state and federal policies that impact our purpose: Breakthroughs that change pa ents’ lives.
In 2021, P zer PAC and P zer Inc. supported 1,285 candidates and mul ple poli cal commi ees at all levels of government. Fi y-
three percent of the P zer PAC disbursements in 2021 went to Republicans and 47% went to Democrats. We con nue to advance
our purpose to discover and deliver breakthrough medicines and vaccines in part thanks to our loyal P zer PAC members and our
P zer U.S. Government Rela ons team who are on the ground educa ng elected o cials about P zer’s purpose, ac va ng those
who support P zer’s mission and advoca ng for policymakers who align with policies that enable our purpose.
As P zer’s Chief Compliance & Corporate A airs O cers, we can tell you unequivocally that our decision to contribute to any
elected o cial is made based on a candidates’ vo ng record on durable policies that support innova on, pa ent access to and
a ordability of their medicines, high quality manufacturing, a secure supply chain, a compe ve tax code and a robust intellectual
property system. Our PAC support does not imply an endorsement of a candidate’s posi on on any social or religious issue, and
we always consider a candidate’s ethical conduct in our evalua on to ensure P zer’s values are upheld. P zer’s ability to innovate
requires a favorable regulatory and legisla ve framework. The P zer PAC helps ensure that framework is strong.
We hope you will take some me to review the report to see which candidates the PAC supported in your state and community.
Our priority in 2022 is to help build a construc ve discourse in the poli cal and regulatory environment while suppor ng policies –
and policymakers – who share these same ideals.
As P zer’s PAC Co-Chairs, and through our interac ons with elected o cials, we see rst-hand how decisions are made that
impact our ability to bring breakthroughs to pa ents and healthcare providers who rely on us every day. When we lead the policy
conversa on, we can ensure our voice is heard and that we can con nue to focus on pu ng pa ents rst in everything we do.
Thank you for your support,
Sally Susman
Execu ve Vice President
Chief Corporate A airs O cer
Co-Chair, P zer PAC
Rady Johnson
Execu ve Vice President
Chief Compliance, Quality & Risk O cer
Co-Chair, P zer PAC
Leading the Conversation
and
Making
an Impact
3
PFIZER PAC
Leading the Conversa on.
What is a PAC?
PAC stands for Poli cal Ac on
Commi ee. A poli cal ac on
commi ee is a government
regulated
organiza on that anyone can form
to raise money for poli cal campaign
dona ons. PACs are formed by
individuals, non-
pro ts, and even
many major corpora ons.
How Does P zer PAC Work?
The P zer poli cal ac on commi ee,
P zer PAC, is a nonpar san
organiza on that provides
opportuni es for employees to
par cipate in the American poli cal
process. The P zer PAC is an
employee
run organiza on with a
Steering Commi ee made up of P zer
employees from di erent divisions
of the company. All corporate PACs
are funded by voluntary employee
contribu ons. P zer PAC is no
di erent; it relies on the par cipa on
of P zer colleagues.
Who Receives P zer
PAC Contribu ons?
P zer PAC is nonpar san. It supports
Democrats and Republicans alike.
From January 2021 through Decmeber
2021, P zer PAC supported 1,285
candidates and commi ees. True to
its nonpar san values, P zer PAC is
commi ed to support candidates
from both poli cal par es who
share P zer’s vision and values for
healthcare. When choosing to make
a contribu on to a candidate, the
P zer PAC considers candidates’ views
on issues that impact P zer and its
employees as well as the presence
of P zer facili es or employees in
the candidate’s district or state. A
complete list of P zer PAC and state
corporate poli cal contribu ons for
January 2021 - December 2021 is
included in this report.
-I
-,
4
PFIZER PAC & POLITICAL CONTRIBUTIONS
GOVERNANCE POLICY
P zer complies fully with all federal, state, and local laws and repor ng requirements governing PAC
and corporate poli cal contribu ons.
P zer has a Corporate Policy Procedure (#802a) that requires all PAC and corporate poli cal
contribu ons to be compiled and published annually in a report that is made available to employees,
shareholders, and the public, and posted on the Company’s website at
www.p zer.com
p
in “Lobbying
and Poli cal Contribu ons” under the “About P zer” tab within the “Corporate Governance” sec on.
At the end of each Federal cycle (every two years), the P zer PAC is audited by Withum, a cer ed
public accoun ng and advisory rm.
P zer also requests that trade associa ons receiving total payments of $100,000 or more from P zer in
a given year report the por on of P zer dues or payments used for expenditures or contribu ons that,
if made directly by P zer, would not be deduc ble under sec on 162(e)(1)(B) of the Internal Revenue
Code. We are disclosing such informa on received from our trade associa ons in this report.
P zer has a PAC Steering Commi ee comprised of seven colleagues who review and approve all
P
AC
and corporate poli cal contribu ons on a monthly basis. Steering Commi ee members represent
di erent divisions across the P zer organiza on. The P
AC Steering Commi ee evaluates candidates
based on issues that impact P zer and its colleagues. It also takes note of whether P zer facili es
or colleagues reside in a candidate’
s district or state. In addi on, all P
AC and corporate contribu on
requests are shared with the P zer Poli cal Contribu ons Policy Commi ee for review
. The Poli cal
Contribu ons Policy Commi ee is responsible for governing the P zer P
AC.
P zer does not tradi onally make contribu ons to 527 Issue Organiza ons. If we were asked to make
such a contribu on, it would have to be reviewed and approved by the Poli cal Contribu ons Policy
Commi ee and subsequently disclosed in our semi-annual report.
Finally, in light of the Supreme Court decision in the Ci zens United case, P zer has determined that
it will not make any direct independent expenditures, a decision which has been discussed at the
executive level as well as with the
Governance & Sustainability Committee
of our Board.
F
F
5
Poli cal Contribu ons Policy Commi ee
P zer PAC Steering Commi ee
CO CHAIR
Sally Susman
Execu ve Vice President
Chief Corporate A airs O cer
CO CHAIR
Rady Johnson
Execu ve Vice President
Chief Compliance, Quality
& Risk O cer
TREASURER
Ma hew Meehan
Director
U.S. Government Rela ons
SECRETARY
Barbara Bon glio
Assistant General Counsel
Corporate Governance
Leslie Black, DBA
Senior Manager
Oncology Training
Jim Cafone
Vice President
P zer Global Supply
Sharon Cas llo
Senior Director
Media Rela ons
David Blackwell
Senior Director
Global General Toxicology
Research & Development
Josh Brown
Vice President
State Government Rela ons
Corporate A airs
Sheryl Colyer
Vice President
People Experience
Navin Katyal
Global Franchise & Business Lead
P zer Vaccines, mRNA
P zer Biopharma Group
John Kelly
Vice President
Quality Opera ons & EHS
P zer Global Supply
Nick Lagunowich
Global President
Internal Medicine
P zer Biopharma Group
Margaret Madden
Senior Vice President
& Corporate Secretary
Chief Governance Counsel
Ed Nowicki
Senior Vice President
Deputy Chief Compliance O cer
Corporate Compliance
Andrew Schmeltz
Global President
P zer Oncology
P zer Biopharma Group
Jennifer Walton
Vice President
U.S. Government Rela ons
Corporate A airs
Sam Gonzalez
Business/Scien c Opera ons Lead
Global Products Development
Mike Ho man
Vice President
GBS Sourcing & Enterprise Services
Andrew Mar n
Vice President
US Marke ng Lead - Xeljanx
P zer Biopharma Group
Dezarie Mayers
Director, Colleague Programs
Corporate A airs
Political Contributions
Recipients
January 2021 – December 2021
P
$
zer PAC
Leading the Conversation.
Corporate Affairs
Government Relations
Pfizer
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
7
ALABAMA
US SENATE
Sen. Thomas H. Tuberville
Up in ‘26
R
$2,500.00
US HOUSE
Rep. Terri Andrea Sewell
D
007
$2,000.00
STATE SENATE
Sen. Gregory J. Reed
R
005
$1,500.00
Sen. Bobby D. Singleton
D
024
$1,000.00
Sen. Larry Stu s
R
006
$1,000.00
Sen. Garlan Gudger, Jr.
R
004
$500.00
Sen. Clay Sco eld
R
009
$1,000.00
STATE HOUSE
Rep. Laura Hall
D
019
$1,000.00
Rep. Paul W. Lee
R
086
$1,000.00
Rep. Joe Lovvorn
R
079
$500.00
Rep. Nathaniel Ledbe er
R
024
$1,500.00
Rep. Kyle South
R
016
$500.00
Rep. Anthony Daniels
D
053
$500.00
ALASKA
US SENATE
Sen. Lisa Ann Murkowski
R
$2,500.00
ARIZONA
US HOUSE
Rep. Tom O’Halleran
D
002
$3,000.00
ARKANSAS
US SENATE
Sen. Thomas Bryant Co on
Up in ‘26
R
$1,000.00
Sen. John Nichols Boozman
R
$5,000.00
US HOUSE
Rep. Stephen Allen Womack
R
003
$2,500.00
CALIFORNIA
US SENATE
Sen. Alex Padilla
D
$5,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
8
US HOUSE
Rep. Peter Ray Aguilar
D
033
$1,000.00
Rep. Nane e Diaz Barragan
D
044
$2,000.00
Rep. Amerish B. Bera
D
006
$3,000.00
Rep. Kenneth S. Calvert
R
041
$1,000.00
Rep. Tony Cardenas
D
029
$6,000.00
Rep. J. Luis Correa
D
046
$4,500.00
Rep. Anna G. Eshoo
D
016
$2,000.00
Rep. Michael Garcia
R
027
$1,000.00
Rep. Jimmy Gomez
D
034
$7,000.00
Rep. Barbara Jean Lee
D
013
$1,000.00
Devin G. Nunes
R
022
$5,000.00
Rep. James V. Pane a
D
019
$4,000.00
Rep. Nancy Pelosi
D
012
$5,000.00
Rep. Sco H. Peters
D
050
$5,000.00
Rep. Raul Ruiz
D
025
$1,000.00
Rep. Linda T. Sanchez
D
038
$3,000.00
Rep. Michael C. Thompson
D
004
$2,000.00
Rep. Norma Judith Torres
D
035
$1,000.00
Rep. Lucille Roybal-Allard
D
040
$1,000.00
LIEUTENANT GOVERNOR
Sen. Toni G. Atkins
Up in ‘26
D
$2,000.00
Sen. Bill Dodd
Up in ‘26
D
$3,000.00
Sen. Steven M. Glazer
Up in ‘26
D
$1,500.00
STATE ATTORNEY GENERAL
AG Rob Bonta
D
$5,000.00
STATE TREASURER
Hon. Fiona Ma
D
$1,600.00
STATE CONTROLLER
Sen. Bob M. Hertzberg
D
$1,500.00
STATE SENATE
Sen. Josh Becker
Up in ‘24
D
013
$2,000.00
Sen. Melissa Hurtado
D
014
$1,400.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
0
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
9
Sen. Monique Limon
Up in ‘24
D
019
$1,500.00
Sen. Josh Newman
Up in ‘24
D
029
$1,500.00
Sen. Susan Rubio
D
022
$3,000.00
Sen. David K. Min
Up in ‘24
D
037
$1,500.00
Sen. Rosilicie Ochoa Bogh
Up in ‘24
R
023
$1,500.00
STATE HOUSE
Assm. Cecilia M. Aguiar-Curry
D
004
$2,000.00
Assm. Joaquin Arambula
D
031
$2,500.00
Assm. Frank Bigelow
R
005
$1,500.00
Assm. Tasha Boerner Horvath
D
076
$1,500.00
Mia Bonta
D
018
$1,500.00
Autumn R. Burke
D
062
$2,000.00
Assm. Lisa Calderon
D
057
$1,500.00
Assm. Wendy Carrillo
D
051
$2,000.00
Assm. Jim Cooper
D
009
$2,000.00
Assm. Jordan Cunningham
R
035
$1,500.00
Assm. Tom Daly
D
069
$2,000.00
Assm. Heath Flora
R
012
$2,000.00
Assm. Vince Fong
R
034
$2,000.00
Assm. Mike A. Gipson
D
064
$1,500.00
Lorena Gonzalez
D
080
$3,000.00
Assm. Timothy S. Grayson
D
014
$1,500.00
Assm. Jacqui Irwin
D
044
$2,000.00
Assm. Marc Levine
D
010
$1,500.00
Assm. Evan Low
D
028
$2,000.00
Assm. Brian Maienschein
R
077
$1,500.00
Assm. Chad Mayes
I
042
$2,000.00
Assm. Jose Medina
D
061
$1,500.00
Assm. Kevin Mullin
D
022
$1,500.00
Assm. Adrin Nazarian
D
046
$2,000.00
Assm. Patrick O’Donnell
D
070
$1,500.00
Assm. Co e Petrie-Norris
D
074
$2,000.00
Assm. James C. Ramos
D
040
$1,500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
10
Assm. Eloise Gomez Reyes
D
047
$1,500.00
Assm. Robert Rivas
D
030
$1,500.00
Assm. Freddie Rodriguez
D
052
$1,500.00
Assm. Blanca E. Rubio
D
048
$3,000.00
Assm. Rudy Salas
D
032
$2,000.00
Assm. Miguel San ago
D
053
$1,500.00
Assm. Marie Waldron
R
075
$1,500.00
Assm. Christopher M. Ward
D
078
$1,500.00
Assm. Carlos Villapudua
D
013
$1,500.00
Assm. Marc Berman
D
037
$1,500.00
Assm. Suze e Mar nez Valladares
R
038
$1,500.00
W
Assm. Akilah Weber
D
079
$1,500.00
STATE SUPERINTENDENT OF PUBLIC INSTRUCTION
Sen. Anthony J. Portan no
Up in ‘26
D
$2,000.00
COLORADO
US HOUSE
Rep. Kenneth R. Buck
R
004
$2,500.00
STATE SENATE
Sen. Bob Gardner
Up in ‘24
R
012
$200.00
Sen. Chris Hansen
Up in ‘24
D
031
$400.00
Sen. Cleave Simpson, Jr.
Up in ‘24
R
035
$200.00
Sen. Rob Woodward
R
015
$400.00
Sen. Rachel Zenzinger
Up in ‘24
D
019
$200.00
STATE HOUSE
Rep. Mark Baisley
R
039
$200.00
Rep. Colin Larson
R
022
$200.00
Rep. Hugh McKean
R
051
$200.00
Rep. Ma Soper
R
054
$200.00
Rep. Dan Woog
R
063
$200.00
Rep. Tim Geitner
R
019
$200.00
Rep. Tonya Van Beber
R
048
$200.00
CONNECTICUT
US SENATE
Sen. Richard Blumenthal
D
$2,500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
11
US HOUSE
Rep. Joseph D. Courtney
D
002
$1,000.00
Rep. James Andrew Himes
D
004
$1,000.00
Rep. John Barry Larson
D
001
$2,000.00
DELAWARE
US SENATE
Sen. Christopher Andrew Coons
Up in ‘26
D
$5,000.00
US HOUSE
Rep. Lisa Blunt Rochester
D
001
$1,000.00
STATE SENATE
Sen. Nicole Poore
D
012
$300.00
Sen. Bryan Townsend
D
011
$300.00
Sen. David P. Sokola
D
008
$300.00
Sen. Trey Charles Paradee, III
D
017
$300.00
Sen. Gerald W. Hocker
R
020
$250.00
STATE HOUSE
Rep. Andria L. Benne
D
032
$200.00
Rep. Kevin S. Hensley
R
009
$200.00
Rep. Valerie J. Longhurst
D
015
$300.00
Rep. Peter C. Schwartzkopf
D
014
$400.00
Rep. Ruth Briggs King
R
037
$200.00
Rep. Debra J. He ernan
D
006
$250.00
Rep. David S. Bentz
D
018
$300.00
FLORIDA
US SENATE
Sen. Marco Antonio Rubio
R
$1,500.00
US HOUSE
Rep. Gus Michael Bilirakis
R
012
$6,500.00
Rep. Vernon Gale Buchanan
R
016
$10,000.00
Rep. Stephanie N. Murphy
D
007
$4,500.00
Rep. Darren Michael Soto
D
009
$1,000.00
Rep. Greg Steube
R
017
$1,000.00
Rep. Maria E. Salazar
R
027
$2,500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
12
STATE TREASURER
Hon. Jimmy Patronis
R
$1,000.00
STATE SENATE
Rep. Colleen Burton
R
022
$500.00
Sen. Lori Berman
D
031
$500.00
Sen. Ben Albri on
R
026
$500.00
Sen. Manny Diaz, Jr.
R
036
$500.00
STATE HOUSE
Rep. Kamia L. Brown
D
045
$1,000.00
Rep. Charles Wesley Clemons, Sr.
R
021
$500.00
Rep. Lawrence McClure
R
058
$500.00
Rep. William Cloud Robinson, Jr.
R
071
$500.00
Rep. Allison Tant
D
009
$1,000.00
Rep. Lauren Uhlich Melo
R
080
$500.00
Rep. Sam Garrison
R
018
$500.00
Rep. Wyman Duggan
R
015
$500.00
Rep. Daniel Anthony Perez
R
116
$500.00
Rep. Kelly Skidmore
D
091
$500.00
GEORGIA
US HOUSE
Rep. Earl L. B. Carter
R
001
$1,500.00
Rep. A. Drew Ferguson, IV
R
003
$7,500.00
Rep. Henry C. Johnson, Jr.
D
004
$2,000.00
GOVERNOR
Gov. Brian P. Kemp
R
$5,000.00
STATE SENATE
Sen. Ma hew Freeman Brass
R
028
$500.00
Sen. Dean Burke
R
011
$1,000.00
Sen. Gloria Singleton Butler
D
055
$1,000.00
Sen. Gail Davenport
D
044
$1,000.00
Sen. Michael Dugan
R
030
$1,000.00
Sen. Bo Hatche
R
050
$500.00
Sen. Chuck Hufstetler
R
052
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
13
Sen. Burt Jones
R
025
$2,000.00
Sen. John F. Kennedy
R
018
$500.00
Sen. Kay Kirkpatrick
R
032
$500.00
Sen. Nancy Grogan Orrock
D
036
$1,000.00
Sen. Blake Tillery
R
019
$500.00
Sen. Ben L. Watson
R
001
$1,000.00
Sen. Steve Gooch
R
051
$1,000.00
Sen. Jason R. Anavitarte
R
031
$500.00
Sen. Michelle Au
D
048
$500.00
Sen. Clint R. Dixon
R
045
$500.00
STATE HOUSE
Rep. Pa y J. Bentley
D
139
$500.00
Rep. Shaw Blackmon
R
146
$500.00
Rep. Jon G. Burns
R
159
$1,000.00
Rep. Joe Campbell
R
171
$500.00
Rep. Kasey Carpenter
R
004
$500.00
Rep. Sharon M. Cooper
R
043
$1,000.00
Rep. Ka e M. Dempsey
R
013
$500.00
Rep. Chuck Efstra on
R
104
$1,000.00
Rep. Terry England
R
116
$1,000.00
Rep. Barry A. Fleming
R
121
$500.00
Rep. Ma hew Hatche
R
150
$500.00
Rep. Carolyn Hugley
D
136
$500.00
Rep. William W. Mitchell
D
088
$1,000.00
Rep. W. Mark Newton
R
123
$1,000.00
Rep. Larry J. Parrish
R
158
$500.00
Rep. Alan T. Powell
R
032
$500.00
Rep. David Ralston
R
007
$1,000.00
Rep. Richard H. Smith
R
134
$1,000.00
Rep. Tyler Paul Smith
R
018
$500.00
Rep. Calvin Smyre
D
135
$1,000.00
Rep. Al Williams
D
168
$500.00
Rep. Noel Williams
R
148
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
14
Rep. Bruce Williamson
R
115
$500.00
Rep. James Beverly
D
143
$1,000.00
Rep. John L. Corbe
R
174
$500.00
Rep. Ma hew Gambill
R
015
$500.00
Rep. Robert Prui
R
149
$500.00
Rep. Derek J. Mallow
D
163
$500.00
Rep. El-Mahdi Holly
D
111
$500.00
Rep. James D. Burche
R
176
$500.00
Rep. Stan Gunter
R
008
$500.00
Rep. Jodi Lo
R
122
$500.00
Rep. Ma hew S. Dubnik
R
029
$500.00
Rep. Robert F. Levere
R
033
$500.00
HAWAII
US SENATE
Sen. Mazie Keiko Hirono
Up in ‘24
D
$2,500.00
GOVERNOR
Hon. Joshua B. Green
D
$2,000.00
STATE SENATE
Sen. Donovan M. Dela Cruz
D
022
$200.00
Sen. Ronald D. Kouchi
D
008
$500.00
Sen. Dru Mamo Kanuha
D
003
$500.00
Sen. Jarre K. Keohokalole
D
024
$500.00
Sen. Karl Rhoads
D
013
$250.00
STATE HOUSE
Rep. Della Au Bela
D
024
$500.00
Rep. Sylvia J. Luke
D
025
$500.00
Rep. Sco K. Saiki
D
026
$500.00
Rep. Takashi Ohno
D
027
$300.00
Rep. Mark M. Nakashima
D
001
$250.00
Rep. Ryan I. Yamane
D
037
$1,000.00
Rep. Aaron Ling Johanson
D
031
$1,000.00
IDAHO
GOVERNOR
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
15
Gov. Brad Li le
R
$5,000.00
STATE SENATE
Sen. Je C. Agenbroad
R
013
$300.00
Sen. Mark R. Harris
R
032
$400.00
Sen. Abby Lee
R
009
$400.00
Sen. Fred S. Mar n
R
015
$800.00
Sen. Peter J. Riggs
R
003
$300.00
Sen. Janie Ward-Engelking
D
018
$300.00
Sen. Chuck Winder
R
020
$400.00
Ali Rabe
D
017
$300.00
STATE HOUSE
Rep. Sco C. Bedke
R
027
$1,000.00
Rep. Laurie Lickley
R
025
$400.00
Rep. Ilana S. Rubel
D
018
$400.00
ILLINOIS
US SENATE
Sen. L. Tammy Duckworth
D
$5,000.00
US HOUSE
Rep. Sean Casten
D
006
$2,000.00
Rep. Rodney Lee Davis
R
015
$2,500.00
Rep. Robin Lynne Kelly
D
002
$3,000.00
Rep. Darin M. LaHood
R
016
$10,000.00
Rep. Bradley Sco Schneider
D
010
$2,000.00
STATE SENATE
Sen. Omar Aquino
D
002
$500.00
Sen. Melinda Willden Bush
D
031
$250.00
Sen. William Cunningham
D
018
$3,000.00
Sen. Sara Feigenholtz
D
006
$1,000.00
Sen. Laura Fine
D
009
$1,000.00
Sen. Don Harmon
D
039
$2,500.00
Sen. Napoleon B. Harris, III
D
015
$1,000.00
Sen. Michael E. Has ngs
D
019
$500.00
Sen. Linda Holmes
D
042
$250.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
16
Sen. Ma e Hunter
D
003
$1,000.00
Sen. Emil Jones, III
D
014
$250.00
Sen. Steven M. Landek
D
012
$500.00
Sen. Dan McConchie
R
026
$2,500.00
Sen. Julie A. Morrison
D
029
$750.00
Sen. Antonio Munoz
D
001
$500.00
Sen. Chapin Rose
R
051
$250.00
Sen. Dave Syverson
R
035
$500.00
Sen. Celina Villanueva
D
011
$250.00
Sen. John F. Curran
R
041
$250.00
Sen. Win Stoller
R
037
$250.00
Sen. Cris na Castro
D
022
$250.00
Sen. Sue Rezin
R
038
$250.00
STATE HOUSE
Rep. Jaime M. Andrade, Jr.
D
040
$500.00
Rep. Dan E. Brady
R
105
$250.00
Rep. Kambium Buckner
D
026
$250.00
Rep. Kelly M. Burke
D
036
$250.00
Rep. Tim Butler
R
087
$250.00
Rep. Kelly M. Cassidy
D
014
$250.00
Rep. Deborah O’Keefe Conroy
D
046
$250.00
Rep. Fred Crespo
D
044
$250.00
Rep. William Davis
D
030
$250.00
Rep. Anthony DeLuca
D
080
$1,000.00
Rep. Tom Demmer
R
090
$500.00
Rep. Jim Durkin
R
082
$1,000.00
Rep. Marcus C. Evans, Jr.
D
033
$750.00
Rep. Mary E. Flowers
D
031
$1,000.00
Rep. La Shawn K. Ford
D
008
$250.00
Rep. Robyn Gabel
D
018
$1,000.00
Rep. Jehan A. Gordon-Booth
D
092
$2,500.00
Rep. Latoya N. Greenwood
D
114
$500.00
Rep. Gregory Harris
D
013
$1,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
17
Rep. Elizabeth Hernandez
D
024
$2,500.00
Rep. Jay C. Ho man
D
113
$500.00
Rep. Frances Ann Hurley
D
035
$250.00
Rep. Thaddeus M. Jones
D
029
$1,000.00
Rep. Camille Lilly
D
078
$250.00
Rep. Natalie A. Manley
D
098
$250.00
Rep. Rita May eld
D
060
$250.00
Rep. Deanne Marie Mazzochi
R
047
$500.00
Rep. Bob Morgan
D
058
$500.00
Rep. Mar n J. Moylan
D
055
$250.00
Rep. Robert Rita
D
028
$1,000.00
Rep. Lamont J. Robinson, Jr.
D
005
$1,000.00
Rep. Nicholas K. Smith
D
034
$1,000.00
Rep. Ryan Spain
R
073
$250.00
Rep. Lawrence M. Walsh, Jr.
D
086
$1,000.00
Rep. Emanuel Chris Welch
D
007
$4,000.00
Rep. Keith R. Wheeler
R
050
$250.00
Rep. Ann M. Williams
D
011
$250.00
Rep. Kathleen Willis
D
077
$250.00
Rep. Michael J. Zalewski
D
023
$1,250.00
Rep. Sam Yingling
D
062
$250.00
Rep. Tony M. McCombie
R
071
$250.00
Rep. Eva-Dina Delgado
D
003
$250.00
Rep. Aaron M. Or z
D
001
$250.00
CITY COUNCILPERSON
Ald. Howard B. Brookins, Jr.
Up in ‘23
D
$500.00
INDIANA
US HOUSE
Rep. Larry Dean Bucshon
R
008
$8,000.00
Rep. Gregory J. Pence
R
006
$2,500.00
Rep. Jacqueline Walorski
R
002
$1,500.00
Rep. Victoria Spartz
R
005
$1,000.00
Rep. Frank J. Mrvan, Jr.
D
001
$2,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
18
STATE SENATE
Sen. Vaneta G. Becker
Up in ‘24
R
050
$500.00
Sen. Jean D. Breaux
Up in ‘24
D
034
$250.00
Sen. Edward E. Charbonneau
Up in ‘24
R
005
$1,000.00
Sen. Michael R. Crider
Up in ‘24
R
028
$500.00
Ronald T. Grooms
R
046
$500.00
Sen. Kyle Walker
R
031
$500.00
Sen. Mike Bohacek
Up in ‘24
R
008
$500.00
STATE HOUSE
Rep. Bradford J. Barre
R
056
$1,000.00
Rep. Mar n J. Carbaugh
R
081
$1,000.00
Rep. Todd Michael Huston
R
037
$1,000.00
Rep. Donald Joseph Lehe
R
025
$500.00
Rep. Dennis James Zent
R
051
$500.00
Rep. Cindy Meyer Ziemke
R
055
$1,000.00
Rep. Robert Allen Heaton
R
046
$250.00
Rep. Ryan David Ha ield
D
077
$250.00
Rep. Wendy Marie McNamara
R
076
$250.00
Rep. Ma hew Sco Lehman
R
079
$500.00
IOWA
US SENATE
Sen. Charles E. Grassley
R
$3,500.00
GOVERNOR
Gov. Kimberly Reynolds
R
$2,000.00
STATE SENATE
Sen. Tony Bisignano
D
017
$500.00
Sen. Dan Dawson
Up in ‘24
R
008
$200.00
Sen. Pam Jochum
Up in ‘24
D
014
$250.00
Sen. Kevin Kinney
D
039
$250.00
Sen. Liz Mathis
Up in ‘24
D
034
$250.00
Sen. Amanda Ragan
D
027
$250.00
Sen. Amy Sinclair
Up in ‘24
R
014
$500.00
Sen. Anne e Sweeney
R
025
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
19
Sen. Jack Whitver
R
019
$500.00
Sen. Zach Wahls
D
037
$750.00
Sen. Chris Cournoyer
R
049
$250.00
Sen. Nate Boulton
Up in ‘24
D
016
$250.00
Sen. Carrie Koelker
R
029
$250.00
STATE HOUSE
Rep. Brian Best
R
012
$500.00
Rep. Jane E. Bloomingdale
R
051
$500.00
Wesley C. Breckenridge
D
029
$250.00
Rep. Pat Grassley
R
050
$500.00
Rep. Megan Hess Jones
R
002
$500.00
Rep. Kenan Judge
D
044
$250.00
Rep. Brian K. Lohse
R
030
$500.00
Rep. Mary S. Mascher
D
086
$250.00
Rep. Ann Meyer
R
009
$750.00
Rep. Brian Meyer
D
033
$250.00
Rep. Kris n Sunde
D
042
$500.00
Rep. Jon Thorup
R
028
$500.00
Rep. Ma W. Windschitl
R
017
$500.00
Rep. Jacob Bossman
R
006
$200.00
Rep. Lee Hein
R
096
$200.00
Rep. Brent Siegrist
R
016
$200.00
Rep. Dus n D. Hite
R
079
$200.00
Rep. Jennifer Konfrst
D
043
$250.00
Rep. John Forbes
D
040
$500.00
Rep. Gary M. Mohr
R
094
$500.00
KANSAS
US SENATE
Sen. Jerry W. Moran
R
$500.00
US HOUSE
Rep. Ron Estes
R
004
$1,500.00
Rep. Jacob LaTurner
R
002
$1,500.00
Rep. Tracey Robert Mann
R
001
$1,500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
20
GOVERNOR
Gov. Laura Kelly
D
$2,000.00
STATE SENATE
Sen. Beverly Gossage
Up in ‘24
R
009
$500.00
Sen. Kristen O’Shea
Up in ‘24
R
018
$500.00
Sen. Mark Ste en
Up in ‘24
R
034
$500.00
Sen. Mike Thompson
Up in ‘24
R
010
$500.00
Sen. Richard Hilderbrand
Up in ‘24
R
013
$500.00
Sen. Molly Baumgardner
Up in ‘24
R
037
$500.00
KENTUCKY
US SENATE
Sen. Rand Howard Paul
R
$5,000.00
US HOUSE
Rep. Andy H. Barr, IV
R
006
$2,500.00
Rep. S. Bre Guthrie
R
002
$5,000.00
STATE SENATE
Sen. Julie Raque Adams
R
036
$1,000.00
Sen. Ralph A. Alvarado
R
028
$1,000.00
STATE HOUSE
Rep. Kimberly Poore Moser
R
064
$1,000.00
Rep. Bart T. Rowland
R
053
$1,000.00
LOUISIANA
US SENATE
Sen. William Cassidy
Up in ‘26
R
$1,000.00
Sen. John Neely Kennedy
R
$2,500.00
US HOUSE
W
Rep. Troy A. Carter
D
002
$1,000.00
Rep. Stephen Joseph Scalise
R
001
$2,500.00
STATE SENATE
Sen. Regina Ashford Barrow
Up in ‘23
D
015
$1,000.00
Sen. Joseph Bouie, Jr.
Up in ‘23
D
003
$500.00
Sen. Gary M. Carter, Jr.
Up in ‘23
D
007
$1,000.00
Sen. Patrick Page Cortez
Up in ‘23
R
023
$1,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
21
Sen. Jimmy Harris
Up in ‘23
D
004
$1,000.00
Sen. Bob Hensgens
Up in ‘23
R
026
$500.00
Sen. Katrina R. Jackson
Up in ‘23
D
034
$500.00
Sen. Jay Luneau
Up in ‘23
D
029
$500.00
Sen. Fred H. Mills, Jr.
Up in ‘23
R
022
$1,000.00
Sen. Barrow Peacock
Up in ‘23
R
037
$500.00
Sen. Karen Carter Peterson
Up in ‘23
D
005
$500.00
Sen. J. Rogers Pope
Up in ‘23
R
013
$500.00
Sen. Gary L. Smith, Jr.
Up in ‘23
D
019
$500.00
STATE HOUSE
Rep. Lawrence A. Bagley
Up in ‘23
R
007
$500.00
Rep. Raymond J. Crews
Up in ‘23
R
008
$250.00
Rep. Jason Hughes
Up in ‘23
D
100
$250.00
Rep. Mike Huval
Up in ‘23
R
046
$1,000.00
Edward C. James
Up in ‘23
D
101
$500.00
Rep. Edmond Jordan
Up in ‘23
D
029
$500.00
Rep. Dus n Miller
Up in ‘23
D
040
$250.00
Rep. Christopher Turner
Up in ‘23
R
012
$500.00
Rep. Cedric Bradford Glover
Up in ‘23
D
004
$250.00
MAYOR
W
May. LaToya Cantrell
Up in ‘23
D
$5,000.00
CITY COUNCILPERSON
Timolynn Sams
D
$2,500.00
MARYLAND
US SENATE
Sen. Christopher Van Hollen
D
$2,000.00
US HOUSE
Rep. Steny Hamilton Hoyer
D
005
$2,000.00
Rep. Kweisi Mfume
D
007
$1,000.00
STATE SENATE
Sen. Malcolm L. Augus ne
D
047
$250.00
Sen. Pamela G. Beidle
D
032
$250.00
Sen. Joanne Claybon Benson
D
024
$250.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
22
Sen. Mary Beth Carozza
R
038
$250.00
Sen. Arthur Carr Ellis
D
028
$250.00
Sen. Brian Je rey Feldman
D
015
$500.00
Sen. Bill Ferguson
D
046
$1,500.00
Sen. Jason Charles Gallion
R
035
$250.00
Sen. Antonio L. Hayes
D
040
$500.00
Sen. Stephen S. Hershey, Jr.
R
036
$500.00
Sen. Ka e Fry Hester
D
009
$250.00
Sen. J. B. Jennings
R
007
$500.00
Sen. Cheryl Corinne Kagan
D
017
$500.00
Sen. Delores G. Kelley
D
010
$750.00
Sen. Katherine Klausmeier
D
008
$250.00
Sen. Benjamin F. Kramer
D
019
$250.00
Sen. Clarence K. Lam
D
012
$250.00
Sen. Obie Pa erson
D
026
$250.00
Sen. Paul G. Pinsky
D
022
$750.00
Sen. Edward Robert Reilly
R
033
$250.00
Sen. Bryan W. Simonaire
R
031
$250.00
Sen. Mary L. Washington
D
043
$250.00
STATE HOUSE
Del. Lisa Belcastro
D
011
$125.00
Del. Harry Bhandari
D
008
$125.00
Del. Alfred Clinton Carr, Jr
D
018
$125.00
Del. Nick Charles
D
025
$125.00
Del. Brian A. Chisholm
R
31B
$125.00
Del. Bonnie L. Cullison
D
019
$500.00
Del. Terri L. Hill
D
012
$125.00
Del. Steve C. Johnson
D
34A
$125.00
Del. Adrienne A. Jones
D
010
$1,500.00
Del. Ariana Brannigan Kelly
D
016
$250.00
Del. Ken Kerr
D
03B
$125.00
Del. Nicholaus R. Kipke
R
31B
$500.00
Del. Susan W. Krebs
R
09B
$250.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
23
Del. Robbyn Lewis
D
046
$125.00
Del. James Ma hew Morgan
R
29A
$250.00
Del. Joseline A. Pena-Melnyk
D
021
$500.00
Del. Shane E. Pendergrass
D
013
$750.00
Del. Teresa Reilly
R
35B
$125.00
Del. Samuel I. Rosenberg
D
42A
$250.00
Del. Sid Saab
R
033
$250.00
Del. Sheree Sample-Hughes
D
37A
$250.00
Del. Kathryn Y. Szeliga
R
007
$500.00
Del. Karen Lewis Young
D
03A
$250.00
Del. Heather Alice Bagnall
D
033
$125.00
MASSACHUSETTS
US HOUSE
Rep. Katherine M. Clark
D
005
$4,500.00
Rep. Richard Edmund Neal
D
001
$2,500.00
MICHIGAN
US SENATE
Sen. Gary Charles Peters
Up in ‘26
D
$2,500.00
US HOUSE
Rep. Daniel Timothy Kildee
D
008
$3,000.00
Rep. Frederick Stephen Upton
R
006
$5,000.00
Rep. John Moolenaar
R
004
$2,500.00
GOVERNOR
Gov. Gretchen Whitmer
D
$1,000.00
STATE SENATE
Sen. Winnie Brinks
D
029
$500.00
Sen. Rick Outman
R
033
$500.00
STATE HOUSE
Rep. Julie Calley
R
087
$500.00
Rep. Ma hew Hall
R
063
$500.00
Rep. John Robert Roth
R
104
$250.00
Rep. Mike Mueller
R
051
$250.00
Rep. Patrick Outman
R
070
$250.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
24
Rep. Andrew Fink
R
058
$500.00
MINNESOTA
US HOUSE
Rep. Thomas Earl Emmer, Jr.
R
006
$2,500.00
MISSISSIPPI
GOVERNOR
Gov. Tate Reeves
Up in ‘23
R
$1,000.00
LIEUTENANT GOVERNOR
Hon. Delbert Hosemann
Up in ‘23
R
$1,000.00
INSURANCE COMMISSIONER
Hon. Mike Chaney
Up in ‘23
R
$1,000.00
STATE SENATE
Sen. Kevin Blackwell
Up in ‘23
R
019
$500.00
Sen. Nicole Akins Boyd
Up in ‘23
R
009
$250.00
Sen. Hob Bryan
Up in ‘23
D
007
$500.00
Sen. Dennis DeBar, Jr.
Up in ‘23
R
043
$500.00
Sen. Joey Fillingane
Up in ‘23
R
041
$250.00
Sen. Josh Harkins
Up in ‘23
R
020
$500.00
Sen. John A. Horhn
Up in ‘23
D
026
$250.00
Sen. Chris Johnson
Up in ‘23
R
045
$500.00
Sen. M. Dean Kirby
Up in ‘23
R
030
$500.00
Sen. J. Walter Michel
Up in ‘23
R
025
$1,000.00
Sen. Rita Po s Parks
Up in ‘23
R
004
$500.00
Sen. John A. Polk
Up in ‘23
R
044
$500.00
Sen. Brice Wiggins
Up in ‘23
R
052
$250.00
Sen. Angela Turner-Ford
Up in ‘23
D
016
$500.00
STATE HOUSE
Rep. Richard Benne
Up in ‘23
R
120
$500.00
Rep. Philip Gunn
Up in ‘23
R
056
$1,000.00
Rep. Joey Hood
Up in ‘23
R
035
$500.00
Rep. John Thomas Lamar
Up in ‘23
R
008
$500.00
Rep. Sam C. Mims, V
Up in ‘23
R
097
$500.00
Rep. John O. Read
Up in ‘23
R
112
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
25
Rep. Jason M. White
Up in ‘23
R
048
$500.00
Rep. Lee Yancey
Up in ‘23
R
074
$500.00
Rep. Henry B. Zuber, III
Up in ‘23
R
113
$1,000.00
MISSOURI
US HOUSE
Rep. Jason Thomas Smith
R
008
$1,000.00
Rep. Ann Louise Wagner
R
002
$5,000.00
STATE TREASURER
Hon. Sco Fitzpatrick
Up in ‘24
R
$1,000.00
STATE SENATE
Sen. Lincoln Hough
R
020
$900.00
Sen. Holly Rehder
Up in ‘24
R
027
$1,000.00
Sen. Caleb Rowden
Up in ‘24
R
019
$2,400.00
Sen. Brian Williams
D
014
$1,000.00
STATE HOUSE
Rep. Rob Vescovo
R
112
$1,000.00
Rep. Dean Plocher
R
089
$2,000.00
NEBRASKA
US SENATE
Sen. Debra S. Fischer
Up in ‘24
R
$1,000.00
US HOUSE
Rep. Adrian Michael Smith
R
003
$2,500.00
NEVADA
US SENATE
Sen. Catherine Cortez Masto
D
$1,000.00
US HOUSE
Rep. Steven Alexzander Horsford
D
004
$3,000.00
STATE TREASURER
Hon. Zachary Beare Conine
D
$1,500.00
STATE SENATE
Sen. Sco Thomas Hammond
Up in ‘24
R
018
$1,000.00
Sen. Ira D. Hansen
R
014
$1,000.00
Sen. Heidi Seevers Gansert
Up in ‘24
R
015
$2,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
26
Sen. Roberta Ann Lange
Up in ‘24
D
007
$1,000.00
Sen. Keith F. Pickard
R
020
$1,000.00
STATE HOUSE
Assm. Gregory Hafen
R
036
$1,500.00
Assm. Alexis M. Hansen
R
032
$1,500.00
Assm. Melissa Hardy
R
022
$1,500.00
Assm. Glen Kaimi Leavi
R
023
$1,500.00
Assm. Philip O’Neill
R
040
$1,000.00
Assm. Robin L. Titus, M.D.
R
038
$1,500.00
Assm. Heidi Wathne Kasama
R
002
$1,000.00
Assm. Lisa Krasner
R
026
$1,000.00
Assm. Jill Dickman
R
031
$1,000.00
MAYOR
Sen. Patricia Ann Spearman
D
$1,000.00
NEW HAMPSHIRE
US HOUSE
Rep. Ann McLane Kuster
D
002
$3,000.00
STATE SENATE
Sen. Joseph E. Bradley, III
R
003
$1,000.00
Sen. Sharon M. Carson
R
014
$1,000.00
Sen. William M. Gannon
R
023
$1,000.00
Sen. Charles W. Morse
R
022
$1,000.00
Sen. Donna M. Soucy
D
018
$1,000.00
NEW JERSEY
US HOUSE
Rep. Joshua S. Go heimer
D
005
$2,500.00
Rep. Frank Pallone, Jr.
D
006
$2,500.00
Rep. William James Pascrell, Jr.
D
009
$2,000.00
Rep. Mikie Sherrill
D
011
$2,500.00
Rep. Bonnie Watson Coleman
D
012
$1,000.00
STATE SENATE
Dawn Marie Addiego
D
008
$500.00
W
Sen. Jon M. Bramnick
R
021
$1,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
27
W
Sen. Anthony M. Bucco
R
025
$750.00
W
Sen. Richard J. Codey
D
027
$750.00
W
Sen. Kris n M. Corrado
R
040
$500.00
W
Sen. Joseph P. Cryan
D
020
$500.00
W
Sen. Sandra Bolden Cunningham
D
031
$500.00
W
Sen. Vin Gopal
D
011
$1,000.00
W
Sen. Linda R. Greenstein
D
014
$500.00
W
Sen. Gordon M. Johnson
D
037
$500.00
W
Sen. Joseph A. Lagana
D
038
$500.00
W
Sen. Fred H. Madden
D
004
$500.00
W
Sen. Steven V. Oroho
R
024
$500.00
W
Sen. Declan Joseph O’Scanlon, Jr.
R
013
$500.00
W
Sen. Nelida Pou
D
035
$1,000.00
W
Sen. M. Teresa Ruiz
D
029
$500.00
W
Sen. Paul A. Sarlo
D
036
$750.00
W
Sen. Holly T. Schepisi
R
039
$500.00
W
Sen. Robert W. Singer
R
030
$500.00
W
Sen. Troy Singleton
D
007
$500.00
Stephen M. Sweeney
D
003
$2,000.00
W
Sen. Joseph F. Vitale
D
019
$1,000.00
W
Sen. Andrew Zwicker
D
016
$1,000.00
W
Sen. Nicholas P. Scutari
D
022
$1,000.00
W
Sen. Patrick J. Diegnan, Jr.
D
018
$500.00
STATE HOUSE
W
Assm. Daniel R. Benson
D
014
$750.00
John J. Burzichelli
D
003
$500.00
W
Assm. Herbert Conaway
D
007
$1,000.00
W
Assm. Craig J. Coughlin
D
019
$2,000.00
W
Assm. Joseph F. Danielsen
D
017
$500.00
Be yLou DeCroce
R
026
$500.00
W
Assm. Christopher P. DePhillips
R
040
$500.00
W
Assm. John DiMaio
R
023
$500.00
Joann Downey
D
011
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
• • • • • • • • • • • • • • • • • •
• • • •
•
• • •
• •
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
28
W
Assm. Aura Kenny Dunn
R
025
$500.00
W
Assm. Roy Freiman
D
016
$500.00
W
Assm. Louis D. Greenwald
D
006
$1,000.00
W
Assm. Mila M. Jasey
D
027
$500.00
W
Assm. Angelica M. Jimenez
D
032
$500.00
W
Assm. Pamela Rosen Lampi
D
006
$500.00
W
Assm. Yvonne M. Lopez
D
019
$500.00
W
Assm. John Francis McKeon
D
027
$1,000.00
W
Assm. Paul D. Moriarty
D
004
$500.00
W
Assm. Gabriela M. Mosquera
D
004
$500.00
W
Assm. Raj Mukherji
D
033
$500.00
W
Assm. Nancy F. Munoz
R
021
$500.00
W
Assm. Carol A. Murphy
D
007
$500.00
W
Assm. Erik Peterson
R
023
$500.00
W
Assm. Eliana Pintor Marin
D
029
$1,000.00
W
Assm. Anne e Quijano
D
020
$500.00
W
Assm. Kevin J. Rooney
R
040
$500.00
W
Assm. Gary S. Schaer
D
036
$750.00
W
Assm. Sterley S. Stanley
D
018
$400.00
W
Assm. Shavonda E. Sumter
D
035
$500.00
W
Assm. Lisa Swain
D
038
$300.00
Adam J. Taliaferro
D
003
$500.00
W
Assm. P. Christopher Tully
D
038
$300.00
W
Assm. Anthony S. Verrelli
D
015
$500.00
W
Assm. Benjie E. Wimberly
D
035
$500.00
W
Assm. Harold J. Wirths
R
024
$500.00
NEW MEXICO
GOVERNOR
Gov. Michelle Lujan Grisham
D
$5,000.00
LIEUTENANT GOVERNOR
Hon. Howie C. Morales
D
$3,400.00
STATE SENATE
Sen. Gregory A. Baca
Up in ‘24
R
029
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
• • • • • • • • • • • • • • • • • • • • •
• • • •
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
29
Sen. Craig W. Brandt
Up in ‘24
R
040
$1,000.00
Sen. William F. Burt
Up in ‘24
R
033
$250.00
Sen. Joseph Cervantes, Joe
Up in ‘24
D
031
$500.00
Sen. David M. Gallegos
Up in ‘24
R
041
$250.00
Sen. Daniel A. Ivey-Soto
Up in ‘24
D
015
$1,000.00
Sen. Gay G. Kernan
Up in ‘24
R
042
$500.00
Sen. Mark D. Moores
Up in ‘24
R
021
$500.00
Sen. George K. Munoz
Up in ‘24
D
004
$500.00
Sen. Bill B. O’Neill
Up in ‘24
D
013
$500.00
Sen. Michael Padilla
Up in ‘24
D
014
$250.00
Sen. Cli R. Pirtle
Up in ‘24
R
032
$250.00
Sen. Elizabeth Stefanics
Up in ‘24
D
039
$500.00
Sen. Bill G. Tallman
Up in ‘24
D
018
$300.00
Sen. Gerald P. Or z y Pino
Up in ‘24
D
012
$750.00
STATE HOUSE
Rep. Gail Armstrong
R
049
$500.00
Alonzo Baldonado
R
008
$250.00
Rep. Zachary J. Cook
R
056
$500.00
Rep. Rebecca L. Dow
R
038
$500.00
Rep. Brian F. Egolf, Jr.
D
047
$500.00
Rep. Kelly K. Fajardo
R
007
$1,000.00
Rep. Jason Carl Harper
R
057
$400.00
Rep. Patricia A. Lundstrom
D
009
$500.00
Rep. Antonio Maestas
D
016
$250.00
Rep. Javier I. Mar nez
D
011
$250.00
Rep. Rodney D. Montoya
R
001
$250.00
Rep. Roger Evan Montoya
D
040
$500.00
Rep. William R. Rehm
R
031
$250.00
Rep. Elizabeth L. Thomson
D
024
$500.00
Bri ney Aileene Barreras
D
012
$500.00
Rep. Micaela Lara Cadena
D
033
$250.00
Rep. Ambrose M. Castellano
D
070
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
30
NEW YORK
US SENATE
Sen. Charles E. Schumer
D
$5,000.00
US HOUSE
Rep. John Michael Katko
R
024
$2,500.00
Rep. Sean Patrick Maloney
D
018
$2,500.00
Rep. Gregory Weldon Meeks
D
005
$3,500.00
Rep. Joseph D. Morelle
D
025
$1,000.00
Rep. Jerrold Lewis Nadler
D
010
$1,000.00
Rep. Kathleen Maura Rice
D
004
$1,000.00
Rep. Thomas R. Suozzi
D
003
$1,000.00
Rep. Ritchie J. Torres
D
015
$2,000.00
Rep. Nicole Malliotakis
R
011
$1,500.00
Rep. Elise M. Stefanik
R
021
$2,500.00
GOVERNOR
Gov. Kathleen C. Hochul
D
$5,000.00
STATE SENATE
Sen. Jamaal T. Bailey
D
036
$500.00
Sen. Philip M. Boyle
R
004
$500.00
Sen. Neil D. Breslin
D
044
$500.00
Sen. Leroy G. Comrie, Jr.
D
014
$500.00
Sen. Patrick M. Gallivan
R
059
$500.00
Sen. Joseph A. Gri o
R
047
$500.00
Sen. Peter B. Harckham
D
040
$500.00
Sen. Brad M. Hoylman
D
027
$500.00
Sen. Robert Jackson
D
031
$500.00
Sen. Brian P. Kavanagh
D
026
$500.00
Sen. Timothy M. Kennedy
D
063
$500.00
Sen. Andrew J. Lanza
R
024
$500.00
Sen. Shelley B. Mayer
D
037
$500.00
Sen. Robert G. Or
R
062
$500.00
Sen. Kevin S. Parker
D
021
$500.00
Sen. J. Gustavo Rivera
D
033
$1,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
31
Sen. Diane J. Savino
D
023
$500.00
Sen. James G. Skou s
D
039
$500.00
Sen. Toby Ann Stavisky
D
016
$500.00
Sen. Andrea Stewart-Cousins
D
035
$1,000.00
Sen. Kevin M. Thomas
D
006
$500.00
Sen. Elijah Reichlin-Melnick
D
038
$1,500.00
Sen. Anna M. Kaplan
D
007
$500.00
Sen. Michelle Hinchey
D
046
$500.00
Sen. Simcha Felder
D
017
$500.00
Sen. Sean M. Ryan
D
060
$500.00
STATE HOUSE
Assm. Peter J. Abbate, Jr.
D
049
$500.00
Assm. Thomas J. Abinan
D
092
$500.00
Assm. Je rion L. Aubry
D
035
$500.00
Assm. William A. Barclay
R
120
$500.00
Assm. Didi Barre
D
106
$500.00
Assm. Edward C. Braunstein
D
026
$500.00
Assm. Kevin M. Byrne
R
094
$500.00
Assm. Kevin A. Cahill
D
103
$500.00
Assm. Michael J. Cusick
D
063
$500.00
Assm. Steven H. Cymbrowitz
D
045
$500.00
Assm. Maritza Davila
D
053
$500.00
Assm. Erik Mar n Dilan
D
054
$500.00
Assm. Je rey Dinowitz
D
081
$500.00
Assm. Richard N. Go ried
D
075
$1,000.00
Assm. Aileen M. Gunther
D
100
$500.00
Assm. Andrew D. Hevesi
D
028
$500.00
Assm. Alicia L. Hyndman
D
029
$500.00
Assm. Charles D. Lavine
D
013
$500.00
Assm. William B. Magnarelli
D
129
$500.00
Assm. John T. McDonald, III
D
108
$500.00
Assm. Daniel J. O’Donnell
D
069
$500.00
Assm. Amy R. Paulin
D
088
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
32
Assm. Crystal D. Peoples-Stokes
D
141
$500.00
Assm. N. Nick Perry
D
058
$500.00
Assm. Stacey G. Phe er Amato
D
023
$500.00
Victor M. Pichardo
D
086
$500.00
Assm. J. Gary Pretlow
D
089
$500.00
Assm. Dan Quart
D
073
$500.00
Assm. Karines Reyes
D
087
$500.00
Robert J. Rodriguez
D
068
$500.00
Assm. Colin J. Schmi
R
099
$500.00
Assm. Michaelle C. Solages
D
022
$500.00
Assm. Phillip G. Steck
D
110
$500.00
Assm. Helene E. Weinstein
D
041
$500.00
Assm. David I. Weprin
D
024
$500.00
Assm. Kenneth Paul Zebrowski
D
096
$500.00
Assm. Donna A. Lupardo
D
123
$500.00
Assm. Patricia A. Fahy
D
109
$500.00
Assm. Nily D. Rozic
D
025
$500.00
Assm. Angelo L. Santabarbara
D
111
$500.00
Assm. Judy A. Gri n
D
021
$500.00
Assm. Albert A. S rpe, Jr.
D
127
$500.00
Assm. Daniel A. Rosenthal
D
027
$500.00
Assm. Michael V. Lawler
R
097
$500.00
Assm. Carl E. Heas e
D
083
$1,000.00
MAYOR
W
May. Eric L. Adams
D
$1,000.00
NORTH CAROLINA
US HOUSE
Rep. George Kenneth Bu er eld, Jr.
D
001
$4,500.00
Rep. Richard Lane Hudson, Jr.
R
010
$5,000.00
Rep. Patrick Timothy McHenry
R
010
$3,500.00
Rep. Deborah K. Ross
D
005
$2,000.00
NORTH DAKOTA
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
33
US HOUSE
Rep. Kelly M. Armstrong
R
001
$2,500.00
GOVERNOR
Gov. Doug Burgum
Up in ‘24
R
$1,000.00
INSURANCE COMMISSIONER
Hon. Jon Godfread
Up in ‘24
R
$1,000.00
OHIO
US HOUSE
Rep. Joyce Bea y
D
003
$1,000.00
Rep. Bill L. Johnson
R
006
$1,500.00
Rep. David Patrick Joyce
R
014
$1,500.00
Rep. Robert E. La a
R
005
$5,000.00
Steve S vers
R
015
$5,000.00
Rep. Brad R. Wenstrup
R
002
$2,500.00
Rep. Troy Balderson
R
012
$2,500.00
Rep. Timothy John Ryan
D
013
$1,000.00
GOVERNOR
Gov. Mike DeWine
R
$1,000.00
STATE SENATE
Sen. Niraj J. Antani
Up in ‘24
R
006
$350.00
Sen. Nickie J. Antonio
D
023
$350.00
Sen. Hearcel Ford Craig
D
015
$300.00
Sen. Ma hew J. Dolan
Up in ‘24
R
024
$500.00
Sen. Theresa A. Gavarone
Up in ‘24
R
002
$350.00
Sen. Robert D. Hacke
Up in ‘24
R
010
$350.00
Sen. Jay Ho nger
R
031
$500.00
Sen. Ma Hu man
Up in ‘24
R
012
$1,000.00
Sen. Terry A. Johnson
Up in ‘24
R
014
$350.00
Sen. George F. Lang
Up in ‘24
R
004
$350.00
Sen. Mark J. Romanchuk
Up in ‘24
R
022
$350.00
Sen. J. Kirk Schuring
R
029
$350.00
Sen. Cecil Thomas
D
009
$300.00
Sen. Steve Wilson
R
007
$350.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
0
0
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
34
Sen. Kenny Yuko
D
025
$300.00
Sen. Robert McColley
R
001
$350.00
Sen. Timothy O. Scha er
Up in ‘24
R
031
$350.00
Sen. Kris na Daley Roegner
R
027
$350.00
STATE HOUSE
Rep. Cindy Abrams
R
029
$350.00
Rep. Thomas E. Brinkman, Jr.
R
027
$350.00
Rep. Rick Carfagna
R
068
$350.00
Rep. Robert R. Cupp
R
004
$1,000.00
Rep. Alessandro Cutrona
R
059
$350.00
Rep. Mark D. Fraizer
R
071
$350.00
Rep. Timothy Edward Ginter
R
005
$500.00
Rep. Adam Holmes
R
097
$350.00
Rep. Don Jones
R
095
$350.00
Rep. Kris Jordan
R
067
$350.00
Rep. P. Sco Lipps
R
062
$750.00
Rep. Susan Manchester
R
084
$500.00
Rep. Phil Plummer
R
040
$350.00
Rep. Bill Roemer
R
038
$350.00
Rep. Allison Russo
D
024
$300.00
Rep. William F. Seitz
R
030
$350.00
Rep. Jason C. Stephens
R
093
$350.00
Rep. Brian Stewart
R
078
$350.00
Rep. Emilia Strong Sykes
D
034
$300.00
Rep. Terrence Upchurch
D
010
$300.00
Rep. Thomas E. West
D
049
$500.00
Rep. Andrea J. White
R
041
$350.00
Rep. Tom Young
R
042
$350.00
Rep. Shane Wilkin
R
091
$350.00
Rep. Brian Lampton
R
073
$350.00
Rep. Jessica Miranda
D
028
$300.00
Rep. Jon Cross
R
083
$350.00
OKLAHOMA
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
35
US HOUSE
Rep. Thomas Je ery Cole
R
004
$2,500.00
Rep. Markwayne Mullin
R
002
$3,000.00
Rep. Kevin R. Hern
R
001
$2,500.00
STATE SENATE
Sen. Chuck Hall
R
020
$500.00
Sen. Brent Howard
R
038
$500.00
Sen. Paul Rosino
Up in ‘24
R
045
$500.00
Sen. Brenda Stanley
R
042
$500.00
Sen. Zack Taylor
R
028
$500.00
Sen. Darrell Weaver
R
024
$500.00
Sen. John Haste
R
036
$500.00
Sen. Darcy A. Jech
R
026
$500.00
STATE HOUSE
Rep. Mickey Dollens
D
093
$250.00
Rep. Ronny Johns
R
025
$500.00
Rep. Chris Kannady
R
091
$1,000.00
Rep. Cyndi Munson
D
085
$500.00
Rep. Ajay Pi man
D
099
$250.00
Rep. Collin Walke
D
087
$500.00
Rep. Josh West
R
005
$500.00
Rep. Melissa Provenzano
D
079
$250.00
Rep. Trish Ranson
D
034
$250.00
Rep. Kevin W. Wallace
R
032
$1,000.00
Rep. Danny J. Sterling
R
027
$500.00
Rep. Marcus L. McEn re
R
050
$500.00
OREGON
US HOUSE
Rep. Kurt Schrader
D
005
$5,000.00
STATE SENATE
Sen. Lynn P. Findley
Up in ‘24
R
030
$1,000.00
Sen. Fred F. Girod
Up in ‘24
R
009
$1,000.00
Sen. William S. Hansell
Up in ‘24
R
029
$1,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
36
Betsy Johnson
D
016
$1,000.00
Sen. Tim R. Knopp
Up in ‘24
R
027
$1,000.00
Sen. Rob Wagner
D
019
$1,000.00
Sen. Lee Beyer
D
006
$1,000.00
STATE HOUSE
Rep. Daniel G. Bonham
R
059
$1,000.00
Rep. Shelly Boshart Davis
R
015
$1,000.00
Rep. Vikki Breese-Iverson
R
055
$1,000.00
Rep. Janelle S. Bynum
D
051
$1,000.00
Chris ne Drazan
R
039
$1,000.00
Rep. Paul L. Evans
D
020
$1,000.00
Rep. Cedric R. Hayden
R
007
$1,000.00
Tina Kotek
D
044
$1,000.00
Rep. Rick Lewis
R
018
$1,000.00
Rep. Raquel Moore-Green
R
019
$1,000.00
Rep. Nancy L. Nathanson
D
013
$1,000.00
Rep. Ronald H. Noble
R
024
$1,000.00
Rep. Daniel A. Ray eld
D
016
$2,000.00
Rep. E. Werner Reschke
R
056
$1,000.00
Rep. David Brock Smith
R
001
$1,000.00
Rep. Gregory Vincent Smith
R
057
$1,000.00
Rep. Barbara Smith Warner
D
045
$1,000.00
Rep. Marty L. Wilde
D
011
$1,000.00
Rep. Brad K. Wi
D
031
$1,000.00
Rep. Mark W. Meek
D
040
$1,000.00
Rep. Julie Fahey
D
014
$1,000.00
Rep. Jason S. Kropf
D
054
$1,000.00
Rep. David Gomberg
D
010
$1,000.00
Rep. Bobby Levy
R
058
$1,000.00
PENNSYLVANIA
US HOUSE
Rep. Brendan Francis Boyle
D
002
$3,000.00
Rep. Chris na J. Houlahan
D
006
$2,500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
37
Rep. G. Mike J. Kelly
R
016
$2,500.00
Rep. Guy L. Reschenthaler
R
014
$2,500.00
Rep. Ma hew A. Cartwright
D
008
$1,000.00
Rep. Lloyd K. Smucker
R
011
$2,500.00
STATE SENATE
Sen. Lisa Baker
R
020
$500.00
Sen. Michele Brooks
R
050
$500.00
Sen. Patrick M. Browne
R
016
$1,000.00
Sen. Jacob D. Corman, III
R
034
$1,500.00
Sen. Jay Costa, Jr.
Up in ‘24
D
043
$1,000.00
Sen. Vincent J. Hughes
Up in ‘24
D
007
$500.00
Sen. Robert B. Mensch
R
024
$1,000.00
Sen. Ka e J. Muth
D
044
$500.00
Sen. Kris n Lee Phillips-Hill
R
028
$1,000.00
Sen. Judith F. Ward
R
030
$1,000.00
Sen. Kim L. Ward
Up in ‘24
R
039
$1,000.00
Sen. Eugene Yaw
Up in ‘24
R
023
$500.00
Sen. John M. DiSanto
R
015
$500.00
Sen. John R. Gordner
R
027
$500.00
STATE HOUSE
Rep. Kerry A. Benningho
R
171
$1,000.00
Rep. Ma hew D. Bradford
D
070
$500.00
Rep. Tim P. Briggs
D
149
$500.00
Rep. Bryan D. Cutler
R
100
$1,500.00
Rep. Valerie S. Gaydos
R
044
$500.00
Rep. Seth M. Grove
R
196
$500.00
Rep. Jordan A. Harris
D
186
$500.00
Rep. Mark A. Longie
D
007
$500.00
Rep. Joanna E. McClinton
D
191
$1,000.00
Rep. Steven Cur s Mentzer
R
097
$500.00
Rep. Donna R. Oberlander
R
063
$1,000.00
Rep. Tina L. Picke
R
110
$500.00
Rep. Kathy L. Rapp
R
065
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
38
Rep. Stanley E. Saylor
R
094
$1,000.00
Rep. Melissa L. Shusterman
D
157
$500.00
Rep. Mar na A. White
R
170
$500.00
Rep. Barbara J. Gleim
R
199
$500.00
Rep. George S. Dunbar
R
056
$500.00
RHODE ISLAND
US HOUSE
Rep. David Nicola Cicilline
D
001
$5,000.00
SOUTH CAROLINA
US SENATE
Sen. Timothy Eugene Sco
R
$5,500.00
US HOUSE
Rep. James Enos Clyburn
D
006
$5,000.00
Rep. Tom Rice
R
007
$2,500.00
GOVERNOR
Sen. Mia S. McLeod
D
$1,000.00
Gov. Henry Dargan McMaster
R
$3,500.00
STATE HOUSE
Rep. James H. Lucas
R
065
$1,000.00
Rep. J. Todd Rutherford
D
074
$1,000.00
Rep. Russell L. O
D
093
$500.00
SOUTH DAKOTA
STATE SENATE
Sen. R. Blake Curd
R
012
$500.00
Sen. Lee A. Schoenbeck
R
005
$500.00
Sen. Wayne H. Steinhauer
R
009
$500.00
Sen. Erin Tobin
R
021
$500.00
Sen. Troy E. Heinert
D
026
$500.00
STATE HOUSE
Rep. Sydney Davis
R
017
$250.00
Rep. Kent S. Peterson
R
019
$1,000.00
Rep. Jennifer Healy Keintz
D
001
$250.00
Rep. Paul R. Miskimins
R
020
$250.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
39
Rep. Taylor Rae Rehfeldt
R
014
$250.00
Rep. Erin K. Healy
D
014
$500.00
TENNESSEE
US SENATE
Sen. Marsha Wedgeworth
Blackburn
Up in ‘24
R
$1,500.00
Sen. Bill Hagerty
Up in ‘26
R
$2,500.00
GOVERNOR
Gov. Bill Lee
R
$5,000.00
STATE SENATE
Sen. Paul Bailey
R
015
$500.00
Sen. Richard Briggs
R
007
$1,000.00
Sen. Rusty Crowe, II
R
003
$500.00
Sen. Ferrell Haile
Up in ‘24
R
018
$1,000.00
Sen. Joey Hensley
Up in ‘24
R
028
$1,000.00
Sen. Jon C. Lundberg
Up in ‘24
R
004
$1,000.00
Sen. Randy McNally, III
R
005
$1,500.00
Sen. Shane Reeves
Up in ‘24
R
014
$1,500.00
Sen. Art Swann
Up in ‘24
R
002
$1,000.00
Sen. Bo Watson
R
011
$500.00
Sen. Ken Yager
Up in ‘24
R
012
$1,000.00
Sen. Je Yarbro
D
021
$500.00
STATE HOUSE
Rep. Clark Boyd
R
046
$1,000.00
Rep. Michael G. Curcio
R
069
$500.00
Rep. Ron M. Gant
R
094
$500.00
Rep. Mark Hall
R
024
$500.00
Rep. David B. Hawk
R
005
$500.00
Rep. Patsy Hazlewood
R
027
$1,000.00
Rep. Esther Helton
R
030
$500.00
Rep. Gary W. Hicks, Jr.
R
009
$500.00
Rep. Cur s G. Johnson
R
068
$1,000.00
Rep. Kelly T. Keisling
R
038
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
40
Rep. Sabi Kumar
R
066
$500.00
Rep. William G. Lamberth
R
044
$1,000.00
Rep. Pat Marsh
R
062
$1,000.00
Rep. Cameron Sexton
R
025
$1,500.00
Rep. Mike Stewart
D
052
$500.00
Rep. Bryan Terry
R
048
$1,000.00
Rep. Kevin Vaughan
R
095
$1,000.00
Rep. Mark White
R
083
$1,000.00
Rep. Sam Whitson
R
065
$1,000.00
Rep. Iris Rudder
R
039
$1,000.00
Rep. Robert L. Ramsey
R
020
$500.00
Rep. Greg Vital
R
029
$500.00
TEXAS
US HOUSE
Rep. Jodey Cook Arrington
R
019
$1,000.00
Rep. Kevin Patrick Brady
R
008
$5,000.00
Rep. Michael Cli on Burgess
R
026
$2,500.00
Rep. Daniel Crenshaw
R
002
$2,500.00
Rep. Henry Roberto Cuellar
D
028
$1,000.00
Rep. Veronica Escobar
D
016
$1,000.00
Rep. Sylvia R. Garcia
D
029
$1,000.00
Rep. Vicente Gonzalez
D
034
$3,000.00
Rep. Marc A. Veasey
D
033
$1,000.00
STATE TREASURER
Hon. Glenn Hegar
R
$5,000.00
STATE SENATE
Sen. Cesar Blanco
D
029
$1,000.00
Sen. Donna Campbell
R
025
$1,000.00
Sen. C. Brandon Creighton
R
004
$1,000.00
Sen. Joan Hu man
R
017
$1,500.00
Sen. Nathan Johnson
D
016
$1,500.00
Sen. Lois W. Kolkhorst
R
018
$1,500.00
Sen. Jose Menendez
D
026
$1,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
41
Sen. Borris L. Miles
D
013
$1,000.00
Sen. Beverly Powell
D
010
$1,000.00
Sen. Judith Za rini
D
021
$1,000.00
Sen. Carol Alvarado
D
006
$1,000.00
Sen. Charles Schwertner
R
005
$1,000.00
Sen. Juan Hinojosa
D
020
$1,000.00
STATE HOUSE
Rep. Steve Allison
R
121
$1,000.00
Rep. Rafael Anchia
D
103
$500.00
Rep. Trenton E. Ashby
R
057
$1,000.00
Rep. Greg Bonnen
R
024
$1,000.00
Rep. Elizabeth Campos
D
119
$500.00
Rep. Giovanni Capriglione
R
098
$1,000.00
Rep. Mary E. Gonzalez
D
075
$1,000.00
Rep. Jus n Holland
R
033
$500.00
Rep. Donna Howard
D
048
$1,000.00
Rep. Ann Johnson
D
134
$500.00
Rep. Julie Johnson
D
115
$1,000.00
Rep. Tracy O. King
D
080
$500.00
Rep. Stephanie Klick
R
091
$1,000.00
Rep. Je Leach
R
067
$1,000.00
Rep. John Lujan
R
118
$500.00
Rep. Joseph E. Moody
D
078
$500.00
Rep. Tom Oliverson
R
130
$1,000.00
Rep. W. Four Price
R
087
$1,000.00
Rep. Richard Pena Raymond
D
042
$1,000.00
Rep. Toni Rose
D
110
$1,000.00
Rep. Carl O. Sherman, Sr.
D
109
$500.00
Rep. Reggie Smith
R
062
$500.00
Rep. Lynn Stucky
R
064
$500.00
Rep. Senfronia Thompson
D
141
$1,000.00
Rep. Chris Turner
D
101
$1,000.00
Rep. Hubert Vo
D
149
$1,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
42
Rep. Gene Wu
D
137
$500.00
Rep. John H. Bucy, III
D
136
$500.00
Rep. Will Metcalf
R
016
$1,000.00
Rep. Erin Zwiener
D
045
$1,000.00
Rep. John Kuempel
R
044
$500.00
Rep. Brooks Landgraf
R
081
$500.00
Rep. David Spiller
R
068
$500.00
Rep. Nicole Collier
D
095
$1,000.00
Rep. Charlie Geren
R
099
$500.00
Rep. Dade Phelan
R
021
$5,000.00
Rep. Gina Hinojosa
D
049
$1,000.00
Rep. Ernest Bailes
R
018
$500.00
Rep. Kyle J. Kacal
R
012
$500.00
UTAH
US SENATE
Sen. Michael Shumway Lee
R
$4,000.00
US HOUSE
Rep. John R. Cur s
R
003
$8,500.00
STATE SENATE
Sen. J. Stuart Adams
R
022
$750.00
Sen. Cur s S. Bramble
Up in ‘24
R
016
$500.00
Sen. Kirk A. Cullimore, Jr.
R
009
$500.00
Sen. Wayne A. Harper
Up in ‘24
R
006
$500.00
Sen. Michael S. Kennedy
Up in ‘24
R
014
$500.00
Sen. Sco D. Sandall
R
017
$500.00
Sen. Evan J. Vickers
R
028
$750.00
Sen. Chris H. Wilson
Up in ‘24
R
025
$500.00
Sen. Jacob L. Anderegg
Up in ‘24
R
013
$500.00
Sen. Keith Grover
R
015
$500.00
Sen. Daniel McCay
R
011
$500.00
Sen. Todd Weiler
Up in ‘24
R
023
$500.00
Sen. Lincoln Fillmore
Up in ‘24
R
010
$500.00
Sen. Karen Mayne
D
005
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
43
Sen. Luz Escamilla
Up in ‘24
D
001
$500.00
STATE HOUSE
Rep. James A. Dunnigan
R
039
$500.00
Rep. Steven Eliason
R
045
$250.00
Rep. Brian S. King
D
028
$250.00
Rep. Kelly B. Miles
R
011
$500.00
Rep. Calvin R. Musselman
R
009
$250.00
Rep. Mike Schultz
R
012
$500.00
Rep. Robert Spendlove
R
049
$500.00
Rep. Steve Waldrip
R
008
$250.00
Rep. Raymond Ward
R
019
$250.00
Rep. Ryan D. Wilcox
R
007
$250.00
Rep. Brad R. Wilson
R
015
$750.00
Rep. Mike Winder
R
030
$250.00
Rep. Joel Ferry
R
001
$500.00
Rep. Timothy D. Hawkes
R
018
$250.00
Rep. Cheryl K. Acton
R
043
$250.00
Rep. Jen Dailey-Provost
D
024
$250.00
Rep. Stephen G. Handy
R
016
$250.00
Rep. Candice B. Pierucci
R
052
$500.00
Rep. Karianne Lisonbee
R
014
$250.00
Rep. Brady Brammer
R
027
$250.00
Rep. Stewart E. Barlow
R
017
$250.00
Rep. Jordan Teuscher
R
042
$250.00
VIRGIN ISLANDS
US HOUSE
Rep. Stacey Elizabeth Plaske
D
001
$1,000.00
VIRGINIA
US SENATE
Sen. Timothy Michael Kaine
Up in ‘24
D
$500.00
US HOUSE
Rep. H. Morgan Gri th
R
009
$1,000.00
Rep. Benjamin L. Cline
R
006
$500.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
44
GOVERNOR
W
Gov. Glenn Youngkin
R
$25,000.00
STATE SENATE
Sen. George L. Barker
Up in ‘23
D
039
$1,000.00
$1,000.00
Sen. Siobhan S. Dunnavant
Up in ‘23
R
012
$1,000.00
Sen. Janet Denison Howell
Up in ‘23
D
032
$1,000.00
$2,000.00
Sen. Lynwood W. Lewis, Jr.
Up in ‘23
D
006
$1,500.00
Sen. Mamie E. Locke
Up in ‘23
D
002
$1,500.00
Sen. L. Louise Lucas
Up in ‘23
D
018
$1,000.00
$2,000.00
Sen. Stephen D. Newman
Up in ‘23
R
023
$750.00
Sen. Thomas K. Norment, Jr.
Up in ‘23
R
003
$750.00
Sen. Mark J. Peake
Up in ‘23
R
022
$750.00
Sen. Todd E. Pillion
Up in ‘23
R
040
$750.00
Sen. Richard L. Saslaw
Up in ‘23
D
035
$1,000.00
$1,000.00
Sen. William M. Stanley, Jr.
Up in ‘23
R
020
$750.00
Sen. Sco A. Surovell
Up in ‘23
D
036
$1,000.00
STATE HOUSE
W
Del. Dawn M. Adams
D
068
$1,500.00
Lashrecse D. Aird
D
063
$1,500.00
W
Del. Je M. Bourne
D
071
$1,000.00
W
Del. Kathy J. Byron
R
022
$1,000.00
W
Del. Carrie Emerson Coyner
R
062
$1,000.00
W
Del. Karrie K. Delaney
D
067
$1,000.00
W
Del. Eileen Filler-Corn
D
041
$2,000.00
W
Del. C. Todd Gilbert
R
015
$750.00
W
Del. C.E. Cli Hayes, Jr.
D
077
$1,000.00
W
Del. Christopher T. Head
R
017
$1,000.00
W
Del. Charniele L. Herring
D
046
$1,000.00
W
Del. M. Keith Hodges
R
098
$1,000.00
W
Del. Patrick A. Hope
D
047
$1,000.00
W
Del. Terry G. Kilgore
R
001
$1,000.00
W
Del. Michael P. Mullin
D
093
$750.00
W
Del. Robert D. Orrock, Sr.
R
054
$750.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
•
•
• • • • • • • • • • • • • •
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
•
0
0
0
0
0
0
-.
,.
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
45
W
Del. Margaret Bevans Ransone
R
099
$1,000.00
W
Del. Roxann L. Robinson
R
027
$1,000.00
W
Del. Mark D. Sickles
D
043
$2,000.00
W
Del. Marcus B. Simon
D
053
$1,000.00
W
Del. Richard C. Sullivan, Jr.
D
048
$1,000.00
W
Del. Luke E. Torian
D
052
$1,000.00
W
Del. R. Lee Ware, Jr.
R
065
$1,000.00
W
Del. Rodney T. Wille
D
073
$1,000.00
Anne Ferrell Tata
R
082
$1,000.00
WASHINGTON
US SENATE
Sen. Patricia Lynn Murray
D
$7,500.00
US HOUSE
Rep. Suzan Kay DelBene
D
001
$1,000.00
Rep. Cathy McMorris Rodgers
R
005
$7,500.00
Rep. Marilyn Strickland
D
010
$4,000.00
STATE SENATE
Sen. John E. Braun
Up in ‘24
R
020
$1,000.00
Sen. Kevin Van De Wege
Up in ‘24
D
024
$1,000.00
Sen. Keith L. Wagoner
Up in ‘24
R
039
$1,000.00
Sen. Judith Warnick
R
013
$1,000.00
Sen. Jesse Salomon
D
042
$1,000.00
Sen. Je Holy
R
006
$1,000.00
Sen. Marko Liias
D
021
$1,000.00
Sen. Shelly Short
R
007
$1,000.00
Sen. Pa y Kuderer
D
048
$1,000.00
STATE HOUSE
Rep. Michelle Caldier
R
026
$1,000.00
Rep. Jeremie Dufault
R
015
$1,000.00
Rep. Roger E. Goodman
D
045
$1,000.00
Rep. Paul Harris
R
017
$1,000.00
Rep. Laurie Jinkins
D
027
$1,000.00
Rep. Nicole Macri
D
043
$1,000.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
• • • • • • • •
Pfizer Political Contributions Recipients
January
2021
-
December
2021
,_
-.
,.
0
0
0
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
46
Rep. Jacquelin Maycumber
R
007
$1,000.00
Rep. Joe Schmick
R
009
$1,000.00
Rep. Vandana Sla er
D
048
$1,000.00
Rep. Larry S. Springer
D
045
$1,000.00
Rep. Drew Stokesbary
R
031
$1,000.00
Rep. Monica Jurado Stonier
D
049
$1,000.00
Rep. Pat Sullivan
D
047
$1,000.00
Rep. My-Linh Thai
D
041
$1,000.00
Rep. Amy Walen
D
048
$1,000.00
Rep. J.T. Wilcox
R
002
$1,000.00
Rep. Dan Bronoske
D
028
$1,000.00
Rep. Greg Gilday
R
010
$1,000.00
Rep. Alex Ybarra
R
013
$1,000.00
Rep. Marcus Riccelli
D
003
$1,000.00
WEST VIRGINIA
US SENATE
Sen. Joseph Manchin, III
Up in ‘24
D
$5,000.00
US HOUSE
Rep. Carol Devine Miller
R
003
$1,500.00
STATE SENATE
Sen. David C. Sypolt
R
014
$1,000.00
Sen. Tom Takubo
R
017
$1,000.00
Sen. Eric J. Tarr
R
004
$1,000.00
Sen. Charles S. Trump, IV
R
015
$1,000.00
Sen. Michael Thomas Azinger
R
003
$1,000.00
STATE HOUSE
Del. Vernon Criss
R
010
$1,000.00
Del. Roger Glen Hanshaw
R
033
$1,000.00
Del. Eric Lee Householder
R
064
$1,000.00
Del. Ma hew Alan Rohrbach
R
017
$1,000.00
Je rey Pack
R
028
$1,000.00
WISCONSIN
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
•
0
0
W
Winner
NP
Non-Par san
Debt-Re rement
Facility
47
US HOUSE
Rep. Ronald James Kind
D
003
$2,000.00
GOVERNOR
Gov. Tony S. Evers
D
$1,000.00
STATE SENATE
Sen. Janet Bewley
D
025
$500.00
Sen. John Jagler
R
013
$500.00
Sen. Devin LeMahieu
R
009
$500.00
WYOMING
US HOUSE
Rep. Elizabeth Cheney
R
001
$2,500.00
GOVERNOR
Gov. Mark Gordon
R
$750.00
SECRETARY OF STATE (STATE LEVEL)
Hon. Edward A. Buchanan
R
$300.00
STATE SENATE
Sen. Stephan Pappas
R
007
$200.00
Sen. Bill Landen
R
027
$200.00
Sen. Drew A. Perkins
R
029
$200.00
Sen. Ogden Driskill
R
001
$200.00
STATE HOUSE
Rep. Landon J. Brown
R
009
$200.00
Rep. Shelly Duncan
R
005
$200.00
Rep. John Eklund, Jr.
R
010
$150.00
Rep. Mike Greear
R
027
$200.00
Rep. Bill Henderson
R
041
$200.00
Rep. Lloyd Charles Larsen
R
054
$200.00
Rep. Sandy Newsome
R
024
$200.00
Rep. Jared Olsen
R
011
$200.00
Rep. Tom Walters
R
038
$200.00
Rep. Cyrus Western
R
051
$200.00
Rep. Dan Zwonitzer
R
043
$200.00
TOTAL – CANDIDATE COMMITTEES
$427,900.00
$779,075.00
TOTAL CANDIDATE COMMITTEES – PAC AND CORPORATE COMBINED
$1,206,975.00
State/O ce
Win
Full Name
Facility
Debt
Re rement
Future
Elec on
Party
District
Corp
PAC
•
Pfizer Political Contributions Recipients
January 2021 -
December 2021
,_
-.
,.
0
•
0
0
Leadership PACs,
Trade Associations, and
Party Committees
January 2021 – December 2021
P
$
zer PAC
Leading the Conversation.
Corporate Affairs
Government Relations
Pfizer
49
NP
Non-Par san
CALIFORNIA
BioCom PAC
NP
$4,000.00
California Democra c Party (Non-Federal)
D
$35,000.00
California Life Sciences
NP
$0.00
California Life Sciences Associa on PAC (CLSA PAC)
NP
$6,000.00
Conference of Western A orneys General (CWAG)
NP
$25,000
Democrats Reshaping America (DREAMPAC) (Rep. Linda T.
Sanchez)
D
$4,000.00
Majority Commi ee PAC--Mc PAC (Rep. Kevin Owen
McCarthy)
R
$2,500.00
PAC To the Future (Rep. Nancy Pelosi)
D
$1,000.00
Pharmaceu cal Research & Manufacturers Associa on of
America PAC (PhRMA PAC)
NP
$8,100.00
Suppor ng House Problem Solvers - Shp PAC (Rep. Sco H.
Peters)
D
$5,000.00
Susan Eggman for Senate 2020 O ceholder Account (Sen.
Susan Talamantes Eggman)
D
$2,000.00
Victory By Inves ng Building And Empowering (VIBE) PAC
(Rep. Tony Cardenas)
D
$2,000.00
COLORADO
Coloradans for Western Values Leadership PAC (Sen. Larry
G. Liston)
R
$525.00
Joann Ginal for Colorado Leadership PAC (Sen. Joann Ginal)
D
$200.00
Liberty Leadership PAC (Sen. Dennis Hisey)
R
$400.00
Lundeen Leadership Fund (Sen. Paul Lundeen)
R
$625.00
Majori es Ma er! (Sen. Rob Woodward)
R
$625.00
NOCO Leadership PAC (Rep. Hugh McKean)
R
$625.00
Pu ng Colorado First (Sen. Barbara Kirkmeyer)
R
$200.00
Senate Majority Fund (527)
R
$10,000.00
Values First Colorado
R
$10,000.00
CONNECTICUT
Connec cut Democra c State Central Commi ee
D
$5,000.00
Connec cut Republican Party
R
$5,000.00
Nutmeg PAC (Sen. Richard Blumenthal)
D
$5,000.00
DELAWARE
First State PAC (Sen. Thomas Richard Carper)
D
$5,000.00
DISTRICT OF
COLUMBIA
Across The Aisle PAC
D
$5,000.00
Alliance for Regenera ve Medicine
NP
$0.00
State
Commi ee Name
Party
Corp
PAC
Leadership
PAC's,
Trade
Associations
and Party Committees
January 2021 -
December 2021
,_
•
•
• • •
•
•
-.
,.
50
NP
Non-Par san
Aspire PAC
D
$5,000.00
Biosimilars Forum
NP
$0.00
Biotech Industry Associa on
NP
$0.00
Biotechnology Innova on Organiza on PAC (BIO PAC)
NP
$5,000.00
Business Roundtable
NP
$0.00
Chamber Of Commerce Of The United States Of America PAC
(US CHAMBER PAC)
NP
$5,000.00
CHC BOLD PAC
D
$5,000.00
Congressional Black Caucus PAC
D
$5,000.00
DCCC
D
$15,000.00
Democra c Governors Associa on (DGA)
D
$15,000.00
Democra c Legisla ve Campaign Commi ee (DLCC)
D
$25,000.00
DNC Services Corpora on/Democra c Na onal Commi ee
D
$15,000.00
DSCC
D
$15,000.00
DSCC (Building Fund)
D
$25,000.00
DSCC (Recount and Legal Fund)
D
$5,000.00
Elect Democra c Women
NP
$5,000.00
Equality PAC
NP
$5,000.00
Healthcare Leadership Forum
NP
$0.00
Lgbtq Victory Fund Federal PAC
D
$2,500.00
NAM
NP
$0.00
Na onal Associa on Of Manufacturers PAC (NAM-PAC)
NP
$5,000.00
New Democrat Coali on Ac on Fund
D
$5,000.00
NRCC
R
$15,000.00
NRSC
R
$15,000.00
NRSC (Building Fund)
R
$30,000.00
Pharmaceu cal Research & Manufacturers of America
(PhRMA)
NP
$411,577
Pharmaceu cal Research & Manufacturers Of America Be er
Government Commi ee
NP
$5,000.00
Republican A orneys General Associa on (RAGA)
R
$50,000.00
Republican State Leadership Commi ee (RSLC)
R
$260,000.00
U.S. Chamber
NP
$0.00
State
Commi ee Name
Party
Corp
PAC
Leadership
PAC's,
Trade
Associations
and Party Committees
January 2021 -
December 2021
,_
•
• • • • •
• • •
• •
• •
•
-.
,.
51
NP
Non-Par san
FLORIDA
Building on Your Dreams Poli cal Commi ee (Sen. Jim Boyd)
R
$2,000.00
Building the Bay PC (Sen. Janet R. Cruz)
D
$1,500.00
Ci zens for Solu ons (Sen. Jason T. Brodeur)
R
$500.00
Conserva ves for a Be er Florida (Rep. Daniel Anthony Perez)
R
$5,000.00
Ethics and Honesty in Government (Sen. Ana Maria Rodriguez)
R
$2,000.00
Florida 2020 (Sen. Loranne Ausley)
D
$2,000.00
Florida House Republican Campaign Commi ee
R
$20,000.00
Florida Republican Senatorial Commi ee
R
$10,000.00
Friends of Colleen Burton (Rep. Colleen Burton)
R
$2,000.00
Friends of Ed Hooper (Sen. Ed Hooper)
R
$2,000.00
Friends of Ron DeSan s
R
$5,000.00
Honest Leadership (Rep. Sam Garrison)
R
$2,000.00
Living Life With Purpose (Rep. Thomas J. Leek)
R
$2,000.00
Republican Party of Florida (Non-Federal)
R
$10,000.00
GEORGIA
Building Bridges PAC
R
$5,000.00
Democra c Party of Georgia (Non-Federal)
D
$1,000.00
Georgia Senate Democra c Caucus
D
$2,500.00
HAWAII
Pineapple PAC (Sen. Mazie Keiko Hirono)
D
$5,000.00
IDAHO
Freedom Fund (Sen. Michael Dean Crapo)
R
$5,000.00
PNW PhRMA PAC
NP
$3,000.00
ILLINOIS
Perimeter PAC (Sen. L. Tammy Duckworth)
D
$5,000.00
INDIANA
Oorah! Poli cal Ac on Commi ee (Sen. Todd Christopher
Young)
R
$5,000.00
IOWA
Jobs Opportunity And New Ideas PAC (Sen. Joni Kay Ernst)
R
$3,500.00
KANSAS
Defend Our Conserva ve Senate PAC (DOC’S PAC) (Sen. Roger
W. Marshall)
R
$5,000.00
Free State PAC (Sen. Jerry W. Moran)
R
$2,500.00
Liberty First Project
NP
$2,000.00
Li up Kansas PAC
R
$5,000.00
KENTUCKY
Bluegrass Commi ee (Sen. Mitch McConnell)
R
$5,000.00
House Republican Caucus Campaign Commi ee
R
$5,000.00
Republican Party of Kentucky (Non-Federal)
R
$5,000.00
Senate Republican Caucus Campaign Commi ee
R
$5,000.00
State
Commi ee Name
Party
Corp
PAC
Leadership
PAC's,
Trade
Associations
and Party Committees
January 2021 -
December 2021
,_
-.
,.
•
•
•
52
NP
Non-Par san
LOUISIANA
Con nuing America’s Strength And Security PAC (Sen. William
Cassidy)
R
$3,500.00
Louisiana Republican Legisla ve Delega on Campaign
Commi ee
R
$7,500.00
MAINE
House Republican Majority Fund
R
$3,000.00
Maine Senate Republican Majority
R
$10,000.00
One Maine (Rep. Kathleen Rose J. Dillingham)
R
$1,000.00
S ll Fed Up With Taxes PAC (Sen. Je rey L. Timberlake)
R
$2,000.00
Taking Care of Maine Business PAC
NP
$1,000.00
MARYLAND
AMERIPAC The Fund for a Greater America (Rep. Steny
Hamilton Hoyer)
D
$5,000.00
Blue Dog Poli cal Ac on Commi ee
D
$5,000.00
Future Forum PAC
D
$1,000.00
Maryland Senate Republican Caucus Commi ee
R
$2,000.00
MASSACHUSETTS
Fair Shot PAC (Rep. Katherine M. Clark)
D
$5,000.00
Massachuse s Democra c State Commi ee
D
$5,000.00
The Madison PAC (Rep. Richard Edmund Neal)
D
$5,000.00
MICHIGAN
Bizon Majority Fund (Sen. John Bizon)
R
$500.00
Building Experience Now PAC (Rep. Ben Frederick)
R
$1,000.00
EMBOLDEN PAC (Rep. Kyra Bolden)
D
$500.00
Hauck Majority Fund (Rep. Roger Hauck)
R
$500.00
Joe Tate Leadership PAC (Rep. Joseph Tate)
D
$250.00
Kahle Majority Fund (Rep. Bronna Kahle)
R
$1,000.00
McCann for Michigan (Sen. Sean A. McCann)
D
$500.00
Motor City PAC (Sen. Gary Charles Peters)
D
$5,000.00
Nesbi Majority Fund (Sen. Aric Nesbi )
R
$1,000.00
VanderWall Majority Fund (Sen. Curt VanderWall)
R
$1,000.00
VanWoerkom Solu ons PAC (Rep. Greg VanWoerkom)
R
$500.00
Wentworth Majority Fund (Rep. Jason Wentworth)
R
$1,000.00
Witwer for Michigan (Rep. Angela Witwer)
D
$250.00
MINNESOTA
House Republican Campaign Commi ee
R
$5,000.00
Minnesota D Senate Caucus
D
$2,500.00
Minnesota House D Caucus
D
$2,500.00
State
Commi ee Name
Party
Corp
PAC
Leadership
PAC's,
Trade
Associations
and Party Committees
January 2021 -
December 2021
,_
-.
,.
•
•
53
NP
Non-Par san
Senate Victory PAC
R
$5,000.00
MISSOURI
Missouri United (Rep. Dean Plocher)
R
$2,500.00
Uni ng Missouri PAC
R
$5,000.00
MONTANA
Big Sky Opportunity PAC (Sen. Steve David Daines)
R
$1,500.00
Montana Democra c Legisla ve Campaign Commi ee
(MDLCC)
D
$1,000.00
Montana Democra c Party
D
$1,000.00
Montana Red (Sen. Steve David Daines)
R
$3,000.00
Montana Republican Legisla ve Campaign Commi ee
(MRLCC)
R
$1,500.00
Montana Republican Party
R
$1,500.00
Treasure State PAC (Sen. Jon Tester)
D
$5,000.00
NEBRASKA
Sensible American Solu ons Suppor ng Everyone PAC (Sen.
Benjamin Eric Sasse)
R
$3,500.00
NEVADA
All For Our Country Leadership PAC (Sen. Catherine Cortez
Masto)
D
$5,000.00
Assembly Republican Caucus PAC
R
$2,500.00
Senate Republican Leadership Conference
R
$2,500.00
Smart Solu ons PAC (Sen. Jacky Rosen)
D
$5,000.00
NEW
HAMPSHIRE
Commi ee to Elect House Republicans
R
$2,000.00
Granite Values PAC (Sen. Margaret Wood Hassan)
D
$1,000.00
New Hampshire Senate Democra c Caucus
D
$5,000.00
New Hampshire Senate Republicans Poli cal Ac on
Commi ee
R
$5,000.00
NEW JERSEY
New Jobs
NP
$1,000.00
New Millennium PAC (Sen. Robert Menendez)
D
$5,000.00
Senate Republican Majority
R
$500.00
NEW MEXICO
LOBO PAC (Sen. Mar n Heinrich)
D
$5,000.00
NEW YORK
AVAC
NP
$0.00
Democra c Assembly Campaign Commi ee
D
$2,500.00
$5,000.00
Democra c Assembly Campaign Commi ee Housekeeping
Account
D
$2,000.00
Hudson Valley PAC (Rep. Sean Patrick Maloney)
D
$3,000.00
IMPACT (Sen. Charles E. Schumer)
D
$5,000.00
State
Commi ee Name
Party
Corp
PAC
Leadership
PAC's,
Trade
Associations
and Party Committees
January 2021 -
December 2021
,_
-.
,.
•
•
•
54
NP
Non-Par san
New York State Democra c Commi ee (Non-Federal)
D
$5,000.00
NYS Democra c Senate Campaign Commi ee
D
$2,500.00
$5,000.00
NYS Democra c Senate Campaign Commi ee - Housekeeping
D
$2,000.00
NYS Senate Republican Campaign Commi ee
R
$1,500.00
Republican Assembly Campaign Commi ee
R
$1,500.00
NORTH
CAROLINA
Together Holding Our Majority PAC (Sen. Thomas Roland Tillis)
R
$3,500.00
NORTH DAKOTA
Dakota PAC (Sen. John Henry Hoeven, III )
R
$1,000.00
North Dakota House Republican Leadership Fund
R
$5,000.00
OHIO
Ohio Chamber of Commerce PAC
NP
$5,000.00
Ohio House Democra c Caucus Fund
D
$350.00
Ohio Republican Party (Non-Federal)
R
$1,000.00
Republican Senate Campaign Commi ee
R
$800.00
OKLAHOMA
Leadership And Accountability Are Na onal Keys PAC (Sen.
James Paul Lankford)
R
$4,500.00
OREGON
Three Rivers Poli cal Ac on Commi ee (Rep. Kurt Schrader)
D
$5,000.00
Votevets
D
$5,000.00
PENNSYLVANIA
Campaign for Compassion
D
$500.00
House Democra c Campaign Commi ee (HDCC)
D
$1,000.00
House Republican Campaign Commi ee (HRCC)
R
$1,500.00
Keystone America PAC (Sen. Robert P. Casey, Jr. )
D
$2,500.00
Senate Democra c Campaign Commi ee
D
$1,000.00
Senate Republican Campaign Commi ee (SRCC)
R
$1,500.00
SOUTH
CAROLINA
Building Rela onships In Diverse Geographic Environments
PAC (BRIDGE PAC) (Rep. James Enos Clyburn)
D
$5,000.00
Tomorrow Is Meaningful PAC (Sen. Timothy Eugene Sco )
R
$2,000.00
SOUTH DAKOTA
Heartland Values PAC (Sen. John Randolph Thune)
R
$5,000.00
House GOP PAC
R
$1,000.00
Senate Republican Campaign Commi ee
R
$1,000.00
TENNESSEE
Making A Responsible Stand For Households In America PAC
(Sen. Marsha Wedgeworth Blackburn)
R
$2,500.00
Tennessee Chamber of Commerce and Industry PAC
NP
$1,000.00
TEXAS
Alamo PAC (Sen. John Cornyn, III )
R
$5,000.00
Making America Prosperous PAC (Rep. Kevin Patrick Brady)
R
$2,500.00
State
Commi ee Name
Party
Corp
PAC
Leadership
PAC's,
Trade
Associations
and Party Committees
January 2021 -
December 2021
,_
-.
,.
•
•
•
55
NP
Non-Par san
TOTAL LEADERSHIP PACS, TRADE ASSOCIATIONS, AND PARTY COMMITTEES – PAC AND CORPORATE COMBINED
$1,530,527.00
Manufacturers PAC of Texas
NP
$1,000.00
VERMONT
Green Mountain PAC (Sen. Patrick Joseph Leahy)
D
$5,000.00
The Campaign Research Center
NP
$2,000.00
VIRGINIA
Common Ground PAC (Sen. Timothy Michael Kaine)
D
$5,000.00
Forward Together PAC (Sen. Mark Robert Warner)
D
$5,000.00
WASHINGTON
M-PAC (Sen. Patricia Lynn Murray)
D
$5,000.00
The Jackson Legacy Fund
D
$2,000.00
The Reagan Fund
R
$1,000.00
Washington State Democra c Central Commi ee
D
$5,000.00
WEST VIRGINIA
Wild And Wonderful PAC (Sen. Shelley Moore Capito)
R
$5,000.00
WISCONSIN
Commi ee to Elect a Republican Senate
R
$7,000.00
Republican Assembly Campaign Commi ee (RACC)
R
$7,000.00
WYOMING
Common Values PAC (Sen. John Anthony Barrasso)
R
$5,000.00
Grand Total
$1,465,100.00
$553,850.00
TOTAL – LEADERSHIP PACS, TRADE ASSOCIATIONS, AND PARTY COMMITTEES
$976,677.00
$553,850.00
Total – Candidate Commi ees
$427,900.00
$779,075.00
Total – Leadership PACs, Trade Associa ons and Party Commi ees
$976,677.00
$553,850.00
Total 2021 Poli cal Contribu ons
$1,404,577.00
$1,332,925.00
Summary of 2021 Poli cal Contribu ons
Corp
PAC
TOTAL PAC AND CORPORATE POLITICAL CONTRIBUTIONS IN 2021
$2,737,502.00
State
Commi ee Name
Party
Corp
PAC
Leadership
PAC's,
Trade
Associations
and Party Committees
January 2021 -
December 2021
,_
•
•
•
-.
,.
Financial Statements
January 2021 – December 2021
P
$
zer PAC
Leading the Conversation.
Corporate Affairs
Government Relations
Pfizer
57
P zer Inc. PAC
Combined Statement of Assets and Liabili es
Arising from Cash Transac ons
Assets
2021
Cash
$644,758.83
Net Assets
$644,758.83
See accompanying notes to the combined nancial statements
Revenues: Contribu ons
Payroll Deduc ons
1,167,773.04
Checks
23,020.00
Credit Cards
1,122.00
Refunds from Candidates
6,000.00
Other (Ret Checks Prior Cycle)
14,180.00
Total Revenues
1,212,095.04
Expenditures: Support of Candidates
Federal
431,000.00
State & Local
348,075.00
Poli cal Par es & Other PAC’s
553,850.00
Fundraising Expense
0.00
Interest & Other
100.00
Expenditures
1,333,025.00
Excess of Support over Expenditures
($120,929.96)
Fund Available: Cash Balance
Beginning of Year
$765,688.79
End of Year
$644,758.83
See accompanying notes to the combined nancial statements
Combined Statement of Revenues & Expenditures
Arising from Cash Transac ons
Financial Statements
January 202
1 -
December 2021
-.
,.
58
P zer Inc. PAC
Disbursements
Support of Candidates:
2021
Contribu ons to:
U.S. Senate Candidates
83,000.00
U.S. House Candidates
348,000.00
State & Local Candidates
348,075.00
$779,075.00
Other Expenditures:
Poli cal Par es & Other PAC’s
553,850.00
Fundraising Expense
0.00
Interest & Other
100.00
553,950.00
Total Expenditures
$1,333,025.00
Financial Statements
January 202
1 -
December 2021
-.
,.
P zer Inc. PAC
Notes to the Financial Statements
1. FUND DESCRIPTION
The P zer Inc. PAC (the Fund) was formed by P zer Inc. (the Company) to solicit and receive voluntary
poli cal contribu ons from employees and stockholders of the Company and certain subsidiaries to
assist candidates for elec ve o ce. The Fund was registered with the Federal Elec on Commission in
April 1976.
2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
Basis of Presenta on
The combined nancial statement ac vi es of the Fund include several poli cal ac on commi ees which
were formed to comply with certain state laws. The accounts of the Fund are maintained on a cash basis.
All administra ve costs of the Fund are borne by the Company in accordance with federal law.
Tax Status
The Fund is registered as a poli cal organiza on and, as such, is subject to tax on non-exempt func on
income, which includes interest income, if any.
3. EXTERNAL FINANCING
The Fund may borrow cash, as necessary, to contribute to candidates in an cipa on of employee
contribu ons. The fund did not have any borrowings during the period January 2021 – December 2021.
59
Financial Statements
January 202
1 -
December 2021
-.
,.
www.pfizer.com/about/corporate_governance/political_action_committee_report
235 East 42nd Street,
New York, NY 10017
Corporate Affairs
Government Relations
P
$
zer PAC
Leading the Conversation.
Pfizer
EXHIBIT D
(see attached)
We expect the following proposal (Item 5 on the proxy card) to be presented by shareholders at the Annual Meeting. The company is not
responsible for any inaccuracies this shareholder proposal may contain. As explained below, the Board unanimously recommends that you
vote “AGAINST” this shareholder proposal.
Item 5 – Report on Political Expenditures Congruency
National Center for Public Policy Research, 20 F Street NW Suite 700, Washington DC 20001, which represents that it owns at least
$2,000 worth of Pfizer common stock, has notified Pfizer that it will present the following proposal at the 2022 Annual Meetin
g
:
The Shareholder’s Resolution
RESOLVED:
Pfizer publish an annual report, at reasonable expense, analyzing the congruency of political and electioneering expenditures
during the preceding year against the company's fundamental purpose and publicly stated company values and policies.
SUPPORTING STATEMENT
The Pfizer Inc. Board's Governance and Sustainability Committee is responsible for "maintain[ing] an informed status on the Company's
issues related to public policy, including political spending policies and practices, through ...periodic reports from management; and [for]
monitor[ing] emerging issues potentially affecting the reputation of the pharmaceutical industry and the Company." Company pol
icy
states that "political contributions are made to support the election of candidates, political parties and committees that sup
port public
policies important to the industry, such as innovation and access to medicines."
However, Pfizer's politically focused expenditures appear to be misaligned with the company's purpose, values, and interests.
•
Pfizer's fundamental purpose and legal duty, as a Delaware business corporation, are to maximize long-term shareholder value
by deft development, production, and sale of pharmaceuticals. Yet it has supported many candidates who support government-
run single-payer or universal health-care programs that will stifle innovation and resources that support research and
development, all while increasing taxes exponentially.
1
This will undermine Pfizer's long-term prospects.
•
Pfizer's non-discrimination policy states that "[a]ll workplace decisions are made without regard to personal characteristics
protected under applicable laws and Pfizer policy, including race, age, gender, religion, etc. We do not tolerate discriminat
on,
harassment, or retaliation of any kind."
2
Yet it has supported many candidates and advocacy organizations that support
legislation and regulation that would force Pfizer and other companies into facial discrimination against white and male
employees, while demeaning the talents and responsibility of other employees.
•
Pfizer opposes the "use of all forms of forced, bonded, indentured, or compulsory labor," and recognizes that "the risks of
modern slavery are particularly likely where our business partners rely upon migrant workers," but it supports many candidat
e
s
who have failed to support legislation that would end Uyghur forced labor and who fuel the vulnerable migrant worker problem
here by opposing sensible border security.
3
•
Pfizer recognizes "the rights to a healthy environment,
health, water and sanitation, and standard of living," but it supports
many candidates who oppose even minimal, common-sense pro-life policies to protect society's most vulnerable members.
Proponents believe Pfizer should establish policies and reporting systems that minimize risk to the firm's reputation and br
and by
addressing possible missteps in corporate electioneering and political spending that contrast with its fundamental fiduciary p
urpose and
stated policy objectives.
Proponents recommend that the report also contain management's analysis of risks to our company's brand, reputation, or shareholder
value of expenditures in conflict with publicly stated company values. "Expenditures for electioneering communications" means
spending,
from the corporate treasury and from PACs, directly or through a third party, at any time during the year, which are reasonably
interpretable as in support of or opposition to a specific candidate.
1
https://cdn.pfizer.com/pfizercom/investors/corporate/2019-2020_Pfizer_PAC_and_Corporate_Political_Contributions_Report.pdf; https://www.opensecrets.org/political-action-
committees-pacs/pfizer-inc/C00016683/candidate-recipients/2020; https://www.congress.gov/bill/116th-congress/house-bill/1384/cosponsors; https://www.hhs.gov/sites/default/
files/Reforming-Americas-Healthcare-System-Through-Choice-and-Competition.pdf; https://www.heritage.org/health-care-reform/report/the-real-price-public-health-plan-less-
innovation-and-lower-quality; https://bigthink.com/videos/government-regulation-stifles-innovation; https://americansforprosperity.org/government-option-is-the-wrong-
approach-to-health-care-at-the-wrong-time/; https://www.rand.org/pubs/research_reports/RR2424.html.
2
https://cdn.pfizer.com/pfizercom/about/Human-Rights-Policy-Aug-2020.pdf.
3
https://www.rubio.senate.gov/public/index.cfm/2021/1/rubio-merkley-colleagues-re-introduce-uyghur-forced-labor-prevention-act; https://www.washingtonexaminer.com/
opinion/the-new-guard-of-the-democratic-party-absolutely-supports-open-borders; https://www.huffpost.com/entry/decriminalizing-border-crossing-
democrats-2020_n_5d15884ee4b03d6116392906.
Pfizer
2022 PROXY STATEMENT
Shareholder
Proposals
Item
5
-
Report
on
Political
Expenditures
Congruency
E
c
i<
life,
■
EXHIBIT E
(see attached)
Shareholder
Proposals
Item
5
-
Shareholder
Proposal
Regarding
Political
Spending
Report
Item
5 -
Shareholder Proposal Regarding Political Spending
Report
Tara
Health Foundation, 47 Kearny Street,
San
Francisco, CA 94108, which represents that it owns no
less
than 1,840
shares
of
Pfizer
common stock,
has
notified Pfizer that it will present the following proposal at the 2021 Annual Meeting:
The Shareholder's Resolution
Whereas:
The
Pfizer
Inc.
Board's Governance and Sustainability Committee
is
responsible
for
"maintain[ing]
an
informed status on the Company's
issues
related to public policy, including political spending policies and practices, through .
..
periodic reports from management; and [for)
monitor[ing] emerging
issues
potentially affecting the reputation
of
the pharmaceutical industry and the Company." Company policy
states that "political contributions are made
to
support the election
of
candidates, political parties and committees that support public
policies important to the industry,
such
as
innovation and
access
to medicines. "
However, Pfizer's politically focused expenditures appear
to
be
misaligned with the company's values and interests.
•
Pfizer
has
stated that "Expanded
access
to
health insurance coverage will help ensure that patients
with
under-diagnosed and
undertreated conditions are able to address them; and that those
who
will benefit from Pfizer medicines are better able to have
access
to
them." Yet the report Conflicted Consequences revealed that
in
2018, Pfizer was a
top
contributor
to
a 527 organization
that
has
been leading efforts to strike down the Affordable Care Act, which
has
made prescription drugs more accessible for millions
of
Americans.
•
Pfizer manufactures contraceptives and a drug commonly prescribed
for
use
as
an
abortifacient. Yet the above-cited report notes that
Pfizer was a
top
contributor
to
a 527 organization that funds state legislators' efforts
to
implement extreme anti-abortion measures.
The
2019 report Funding the
Bans
estimated
that
Pfizer donated more than $50,000
to
politicians
in
six
states responsible
for
that
year's wave
of
abortion bans.
The
proponent estimates that
in
the last three election
cycles,
Pfizer and its employee
PACs
have made
political donations totaling at least $8.4 million
to
politicians and political organizations working
to
weaken women's
access
to
reproductive health care.
•
Pfizer
has
committed to achieving science-based greenhouse
gas
reduction targets, yet
is
a member
of
the
U.S.
Chamber
of
Commerce, which
has
consistently lobbied to roll back specific
US
climate regulations and promote regulatory frameworks that would
slow the transition towards a
low
GHG
emissions energy mix.
This
raises
questions about whether Pfizer
is
also supporting
electioneering efforts that conflict with its environmental commitments.
Proponents believe
that
Pfizer should establish policies and reporting systems that minimize
risk
to
the firm's reputation and brand
by
addressing possible missteps
in
corporate electioneering and political spending
that
are
in
contrast
to
its stated healthcare and
environmental objectives.
Resolved
:
Pfizer publish
an
annual report, at reasonable expense, analyzing the congruency
of
political and electioneering expenditures during the
preceding year against publicly stated company values and policies.
SUPPORTING
STATEMENT
Proponents recommend that
such
report
also
contain management's analysis
of
risks
to
our company's brand, reputation, or shareholder
value
of
expenditures
in
conflict
with
publicly stated company values. "Expenditures
for
electioneering communications" means spending,
from the corporate treasury and from the
PACs,
directly or through a third party, at any time during the year, on printed, internet
or
broadcast communications, which are reasonably susceptible to interpretation
as
in
support
of
or opposition to a specific candidate.
■
pfizer
2021
PROXY
STATEMENT
EXHIBIT F
(see attached)
Delaware
(State
or
other
jurisdiction
of
incorporation)
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORMS-K
CURRENT REPORT
PURSUANT TO SECTION
13
OR
15(d) OF THE
SECURITIES EXCHANGE ACT OF 1934
Date
of
report (Date
of
earliest event reported): April 28, 2022
PFIZER INC.
(Exact name
of
registrant as specified in its charter)
1-3619
(Commission File
Number)
235 East 42nd Street 10017
New
York,
New
York (Zip Code)
(Address
of
principal executive offices)
Registrant's telephone number, including area code:
(212) 733-2323
Not
Applicable
(Former name
or
former address,
if
changed since last report)
13-5315170
(I.RS
. Employer
Identification
No
.)
Check the appropriate box below
if
the Form 8-K filing is intended to simultaneously satisfy the obligation
of
the registrant under any
of
the following
provisions (see General Instruction A.2. below):
□
Written communication pursuant to Rule 425 under the Securities Act (17
CFR
230.425)
□
Soliciting material pursuant to Rule 14a-12 under the Exchange Act (17
CFR
240.14a-12)
□
Pre-commencement communications pursuant to Rule 14d-2(b) under the Exchange Act (17
CFR
240.14d-2 (b))
□
Pre-commencement communications pursuant to Rule l 3e-4( c) under the Exchange Act ( 17
CFR
240. l 3e-4( c))
Securities registered P.Ursuant to Section 120!).
of
the Act:
Title
of
each class
Common Stock, $.05
par
value
1.000% Notes due 2027
TradingJ?Y.mbolW.
PFE
Name
of
each exchange on which registered
New
York Stock Exchange
PFE27
New
York Stock Exchange
Indicate by check mark whether the registrant is an emerging growth company as defined in Rule 405
of
the Securities Act
of
1933 (§230.405
of
this
chapter) or Rule 12b-2
of
the Securities Exchange Act
of
1934 (§240.12b-2
of
this chapter).
Emerging growth company
□
If
an emerging growth company, indicate
by
check mark
if
the registrant has elected not to use the extended transition period for complying with any new
or revised financial accounting standards provided pursuant to Section 13(a)
of
the Exchange Act.
□
Item 5.07 Submission
of
Matters to a Vote
of
Security Holders
(a) The Pfizer Inc. (the "Company") Annual Meeting of Shareholders was held on April 28, 2022.
(b)
Shareholders voted on the matters set forth below.
1.
The nominees for election to the Company's Board
of
Directors set forth in Item 1 to the Company's Proxy Statement filed with the U.S.
Securities and Exchange Commission on March 17, 2022 were elected to hold office until the Company's next Annual Meeting
of
Shareholders,
based upon the following votes:
Nominee
Votes For
Votes Against
Abstentions
Broker non-vote
Ronald
E.
Blaylock
3,701,357,646
97,026,302
10,925,480
Albert Bourla
3,577,655,169
204,869,446
26,783,357
Susan Desmond-Hellmann
3,744,546,772
54,872,805
9,887,325
Joseph
J.
Echevarria
3,315,350,
611
483,108,900
10,848,394
Scott Gottlieb
3,775,202,986
23,651 ,
661
10,414,283
Helen
H.
Hobbs
3,704,020,993
95,742,430
9,505,507
Susan Hockfield
3,773,537,829
25,701,939
10,029,162
Dan R. Littman
3,741,506,546
57,146,873
10,615,511
Shantanu Narayen
3,766,994,058
31,021,763
11
,292,326
Suzanne Nora Johnson
3,605,854,757
193,599,113
9,854,277
James Quincey
3,729,849,039
68,041,486
11
,406,359
James C. Smith
3,694,497,573
103,133,820
11
,676,754
2. The proposal to ratify the selection
of
KPMG LLP as the Company's independent registered public accounting firm for the 2022
fiscal year was approved based upon the following votes:
Votes for approval
Votes against
Abstentions
Broker non-votes
4,440,636,499
204,291,133
14,009,991
n/a
849,628,501
849,628,501
849,628,501
849,628,501
849,628,
501
849,628,
501
849,628,
501
849,628,501
849,628,501
849,628,501
849,628,501
849,628,501
3. The proposal to approve, on
an
advisory basis, the compensation
of
the Company's Named Executive Officers was approved based
upon the following votes:
Votes for approval
Votes against
Abstentions
Broker non-votes
3,509,
011
,827
275,230,428
25,057,788
849,628,501
4. The shareholder proposal regarding amending proxy access was not approved based upon the following votes:
Votes for approval
Votes against
Abstentions
Broker non-votes
1,096,172,490
2,686,465,588
26,655,147
849,628,501
5. The shareholder proposal regarding report on political expenditures congruency was not approved based upon the following votes:
Votes for approval
393,729,907
Votes against
3,387,577,521
Abstentions
27,996,591
Broker non-votes
849,628,501
6. The shareholder proposal regarding report on transfer
of
intellectual property to potential COVID-19 manufacturers was not
approved based upon the following votes:
Votes for approval
Votes against
Abstentions
Broker non-votes
1,023,141,083
2,714,524,824
71,640,637
849,628,501
7.
The shareholder proposal regarding report on board oversight
of
risks related to anticompetitive practices was not approved based
upon the following votes:
Votes for approval
Votes against
Abstentions
Broker non-votes
1,138,551,810
2,600,688,619
70,069,294
849,628,501
8. The shareholder proposal regarding report on public health costs
of
protecting vaccine technology was not approved based upon the
following votes:
Votes for approval
Votes against
Abstentions
Broker non-votes
325,762,383
3,415,442,745
68,096,240
849,628,501
SIGNATURE
Pursuant to the requirements
of
the Securities Exchange Act
of
1934, the registrant has duly caused this report to be signed on its behalf by the undersigned
hereunto duly authorized.
Dated: May 2, 2022
PFIZER INC.
By:
Isl
Margaret M. Madden
Margaret M. Madden
Senior Vice President and Corporate Secretary
Chief Governance Counsel
Sanford Lewis & Associates
PO Box 231
Amherst, MA 01004-0231
413 549-7333
sanfordlewis@strategiccounsel.net
January 17, 2023
Via electronic mail
Office of Chief Counsel
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Shareholder Proposal to Pfizer Inc. Regarding Political Contributions Congruency by
Tara Health Foundation
Ladies and Gentlemen:
Tara Health Foundation has submitted a shareholder proposal (the “Proposal”) to Pfizer Inc.
(the “Company”). We have been asked by the Proponent to respond to the letter dated December
16, 2022 ("Company Letter") sent to the Securities and Exchange Commission by Margaret M.
Madden, Senior Vice President and Corporate Secretary. In that letter, the Company contends
that the Proposal may be excluded from the Company’s 2023 proxy statement.
We have redacted personal information consistent with the Staff's guidance. A copy of this
letter is being emailed concurrently to Margaret M. Madden at margaret.m.madden@pfizer.com.
SUMMARY
The Proposal requests that the Company issue a report analyzing the congruency of its
political expenditures against its own publicly stated company values, including its stated goal to
“end discrimination against women, ensure equal opportunities for leadership and access to
reproductive health.” The Supporting Statement further recommends that the report contain an
analysis of the risk posed to the Company brand, reputation, or shareholder value in making
political expenditures that conflict with the Company’s publicly stated goals and values. The full
proposal is appended.
Following the
Dobbs v. Jackson Women's Health Organization
decision and the enablement
of state laws prohibiting access to abortion, the proposal notes that it appears that Pfizer’s
political contributions are in stark conflict with its stated goal to “ensure… access to
reproductive health.” This should be of concern to the Company’s investors as Pfizer is donating
to extremist politicians and committees undertaking policy initiatives in conflict with the
Company’s publicly stated values, product offerings, and reputation. The “instruments of
shareholder democracy,” here, seeking disclosure of how the board is navigating these
Office of Chief Counsel
January 17, 2023
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incongruities, are the critical tool reserved for protection of shareholder risk management and
free speech interests.
The Company Letter asserts that the Proposal has been substantially implemented under
Rule 14a-8(i)(10) and constitutes an excludable resubmission of previous proposals under Rule
14a-8(i)(12).
However, the Proposal has not been substantially implemented. The Company’s existing
actions have met neither the guidelines nor the essential purpose of the Proposal. Although the
Company does some reporting on its analysis of congruency of contributions to trade
associations, that analysis does not focus on the focal issue of the Proposal and further there is no
analysis of the congruency of Pfizer’s political donations. Year after year, Pfizer has apparently
donated to candidates that conflict with the Company’s interests, particularly candidates who
have actively worked to eliminate women’s rights to reproductive healthcare. Yet, there is no
analysis provided regarding the congruency of supporting these political candidates, several of
whom have led the fight to constrain reproductive rights in their states.
Further, the Proposal does not constitute resubmission under Rule 14a-8(i)(12) because it
focuses on a materially different subject matter than previous shareholder proposals voted upon
at the Company. The prior proposals were not focused principally on congruency of political
contributions with the Company’s stake in the issue of reproductive rights. The distinguishing
importance of the focal issue of this contributions congruency proposal is evidenced by the
dramatically different votes on prior proposals due to the dramatically different focal issues in
the background statements, with the 2021 proposal receiving 47% support and the 2022 proposal
receiving only 10% support. It is evident that investors recognize the difference between the
prior proposals and that it is entirely appropriate to allow them the opportunity to vote on the
subject matter of the current Proposal.
ANALYSIS
In the 2010 Citizens United ruling, the Supreme Court declined to support a ban on
electioneering spending by corporations and trade associations despite the “[g]overnment's asserted
interest in protecting shareholders from being compelled to fund corporate speech.” The ruling suggested
that that disclosure and shareholder democracy are sufficient to defend the risk management and free-
speech rights of shareholders. Disclosure of political spending, Justice Kennedy wrote, “can
provide shareholders…with the information needed to hold corporations…accountable,” and “to
react to the speech of corporate entities in a proper way.”
Thus, corporate support of politicians through PACs, and via dark money organizations
enabled by the Citizens United decision, has elevated the importance of shareholder oversight of
corporate political spending. The courts have recognized the interest of investors in using the
instruments of shareholder democracy, including transparency and voting on proposals like the
present one, to ensure accountability on corporate political spending. Of particular concern is the
Office of Chief Counsel
January 17, 2023
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prospect that a corporate board or management might use the corporate treasury or PAC to
support personal favorite politicians or organizations that support extremist positions out of line
with the company’s interests and professed values, and also out of line with the company’s own
consumer’s perspectives.
In June of 2022, the Supreme Court overturned longstanding precedent in
Roe v. Wade
and
the subsequent patchwork of state laws has shifted the legal landscape for reproductive health.
Pfizer has a proactive commitment to women’s rights and health, and produces products that
are used in medication abortions, yet it has apparently supported numerous politicians that are
leading or supporting legislative efforts to restrict reproductive rights.
The Proposal focuses on this issue. As noted in the background section of the Proposal,
Pfizer’s political donations appear to contradict its stated goal to “ensure… access to
reproductive health.” The Proposal notes that Pfizer’s political donations also appear to
contradict its own interests. Pfizer manufactures contraceptives and a medication commonly
prescribed for medication abortion. However, since the start of the 2020 election cycle, the
Proponent estimates that Pfizer and its employee PACs have donated at least $5 million to
politicians and organizations that are actively working to weaken access to reproductive health.
In the South, Pfizer donated to anti-choice state candidates at a ratio of 3:1 to its donations to
other candidates and to anti-choice federal candidates at a ratio of 2:1. The Company continues
to donate to politicians who are working to make access to Pfizer’s product more difficult or
even illegal. For example, Pfizer contributed to multiple sponsors of 2022 bills in Tennessee and
Louisiana which restrict access to medication abortion.
1
This apparent incongruence has been scrutinized by publications such as STAT, Bloomberg
News, Huffington Post, The Minnesota Daily, CQ ESG Briefing, Agenda (a Financial Times
publication) and Forbes.
Accountability is necessary where the board and management appear to be supporting
politicians who are advancing major policy initiatives that are contrary to the Company’s
interested and articulated values. The failure of the board or management to explain why these
incongruities are acceptable to the Company is a strong impetus for investors to support the
current Proposal and to clarify whether and why the board and management may believe that
maintaining support for such political leaders is consistent with investor interests.
I.
The Proposal has not been substantially implemented.
In order for the Company to meet its burden of proving substantial implementation pursuant
to Rule 14a-8(i)(10), it must show that its activities meet the guidelines and essential purpose of
the Proposal. The Staff has noted that a determination that a company has substantially
1
In addition, Pfizer was a top contributor to a 527 organization that lead the effort to strike down the
Affordable Care Act, which has made prescription drugs, such as the ones manufactured by Pfizer, more accessible
for millions of people. Pfizer also contributes to PhRMA, which donates to numerous organizations which oppose
the congressional efforts to reform drug pricing.
Office of Chief Counsel
January 17, 2023
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implemented a proposal depends upon whether a company’s particular policies, practices, and
procedures compare favorably with the guidelines of the proposal.
Texaco, Inc.
(Mar. 28, 1991).
Substantial implementation under Rule 14a-8(i)(10) requires a company’s actions to have
satisfactorily addressed both the proposal’s guidelines and its essential objective. See, e.g.,
Exelon Corp.
(Feb. 26, 2010).
Thus, when a company can demonstrate that it has already taken actions that meet most of
the guidelines of a proposal and meet the proposal’s essential purpose, the Staff has concurred
that the proposal has been “substantially implemented.” In the current instance, the Company has
substantially fulfilled
neither
the guidelines nor the essential purpose of the Proposal.
A.
The essential objective of the proposal, Pfizer’s political contribution congruency
related to its own stated goals, especially regarding reproductive rights, has not been
addressed by the Company.
The Company argues that it has substantially implemented the Proposal and it describes the
Proposal’s “essential objective” as being “to obtain a report from Pfizer on how its political
expenditures align with Pfizer’s stated values and policies.” This distorts the Proposal’s essential
objective. The Resolved Clause itself requests a report on congruency of political expenditures
specifically against Pfizer’s stated goal to “end discrimination against women, ensure equal
opportunities for leadership and access for reproductive health.
”
The background section of the Proposal also speaks to the primacy of reproductive rights as
an essential focus of the Proposal. All of the background information provided focuses on
women’s rights and reproductive healthcare. It appears from available information that Pfizer’s
political donations are not congruent with its stated goal to “end discrimination against women,
ensure equal opportunities for leadership and access for reproductive health.” Existing
disclosures referenced by the Company do not appear to provide an assessment of the
congruency of its political contributions in support of politicians that are leading the effort to
restrict reproductive rights.
As explained in the Proposal, Pfizer has donated to an organization which led efforts to
strike down the Affordable Care Act, to politicians and organizations who worked to limit
women’s access to reproductive healthcare, and even disproportionately donated to anti-choice
candidates in the South.
Pfizer manufactures contraceptives and a drug commonly prescribed for use as an
abortifacient. The contradictory and potentially self-defeating impact of Pfizer’s support for anti-
choice politicians has been noted in media coverage.
2
The Sustainable Investments Institute (“SI2”) found that Pfizer was a top funder of anti-
abortion candidates in states banning abortion with $357,699 in donations in the last two election
2
https://www.businessinsider.com/healthcare-corporations-and-pharma-give-big-to-anti-abortion-movement-
2022-5
Office of Chief Counsel
January 17, 2023
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cycles. SI2 also found that Pfizer was a top contributor to five attorneys general who played key
roles in the effort to ban abortion.
3
In the last two election cycles, Pfizer’s expenditures in the South and Midwest have been
largely in favor of anti-choice candidates. 74% of Pfizer’s political donations in the South and
66% of its donations in the Midwest went to anti-choice politicians.
4
The above review of numerous unexplained political contributions which are in direct
contrast to company policies and values demonstrates the need for investors to demand
accounting from the board on its apparent failure to evaluate and manage significant
incongruencies in political contributions.
B.
The Company’s current disclosures are insufficient to satisfy the request of the
Proposal.
While the Company argues substantial implementation, it admits throughout the no-action
letter that its Congruency Report addresses only trade associations. Pfizer implemented this
Congruency Report after a previous shareholder proposal received significant support from
shareholders. However, this report does not satisfy the request of the Proposal because there is
no discussion of the congruency of the $1,333,025 Pfizer donated to candidates and political
committees.
5
Instead, for donations to candidates and political committees, the Company publishes only
the Pfizer PAC and Corporate Contributions Report (the “Political Contributions Report”). This
is distinct from the Congruency Report because it focuses on the amounts given to individual
candidates, but it does not address the incongruence of donations. The Company argues that this
report explains Pfizer’s rationale and motivation for making such political expenditures.
First, the report does not actually provide the rationale and motivation for any particular
candidate and instead gives broad rationale such as “candidates of both political parties who
support state and federal policies that impact [Pfizer’s] purpose: Breakthroughs that change
patients’ lives.” This statement of the company’s internal policy for deciding how to direct
political contributions is not equivalent to a statement by management explaining glaring
incongruities in donations, some of which might threaten to overwhelm the benefits to the
company associated with company donations.
As important as the decision to donate money to a candidate is, the discernment involved in
recognizing the congruency and in deciding to halt donations to candidates because their actions
do not align with the Company’s stated goals and policies is equally important. While the
Company may support politicians who advance company-supportive policies on some matters, if
those same politicians are well known as leaders of policy initiatives that directly undercut
3
Divided States of America - Heavily Tilted Company Support for State Abortion Ban Politicians (October 17,
2022) Heidi Welsh,
https://siinstitute.org/reports.html
4
Id.
5
Pfizer’s PAC and Corporate Political Contributions Report, available at https://cdn.pfizer.com
/pfizercom/investors/corporate/2021_Pfizer_PAC_and_Corporate_Political_Contributions_Report.pdf at Page 58.
Office of Chief Counsel
January 17, 2023
Page 6 of 12
company interests or values, investors may appropriately ask for an explanation of whether
support for those individuals is appropriate and congruent and can reasonably, through this
Proposal, seek explanation from management.
Investors have a right to transparency when Pfizer chooses to donate money to a candidate or
committee which makes decisions that harm Pfizer’s publicly stated goal and its own product
offerings.
The existing reports from the Company do not analyze the incongruence of the donations to
politicians. Proponents believe that Pfizer should establish policies and reporting systems that
minimize risk to the firm's reputation and brand by providing an accounting of any possible
missteps in corporate electioneering and political spending in the prior year that are in contrast to
its stated healthcare and environmental objectives, and ensuring midcourse corrections when
needed.
Under the framework of the Proposal, it does not rest with the Proponent to determine which
donations were incongruent; rather it rests with the company to explain the incongruence of
specific donations, and what overriding considerations cause it to provide donations despite
incongruent voting records of some donation recipients.
The Proponent believes that these examples illustrate that while the Company may have put
in place evaluation procedures in advance of making political contributions, the Company has
not published an analysis explaining its assessments of congruency and whether and where it is
making exceptions in contributions between its stated values priorities and the contributions to
political candidates and campaigns.
Review of Staff precedents confirms that failure to publish a core analysis requested
by a Proposal, especially on political contributions, precludes substantial implementation.
The Staff has confirmed repeatedly that proposals will not be excluded despite a claim
of substantial implementation if a core analysis requested by the proposal has not been
performed and published.
The courts have long acknowledged the challenges posed by the corporate form that board
and management might use the corporate treasury to advance their own political predilections,
and therefore the right of shareholders to weigh in and demand transparency. For instance,
in
Medical Committee for Human Rights v. SEC,
432 F.2d 659 (D.C. Cir. 1985) in which the
D.C. Circuit Court found that shareholder proposals are proper (not ordinary business) when they
raise issues of corporate social responsibility or question the unaccountable exercise of
“political and moral predilections” of board or management in the management of the company.
In more recent years, this responsibility and right of shareholders was amplified and echoed
by Justice Anthony Kennedy in
Citizens United
, who described the need and potential for
shareholders to hold their companies accountable for misdirected corporate political spending.
The
Citizens United
majority wrote that the rights of shareholders dissenting
Office of Chief Counsel
January 17, 2023
Page 7 of 12
to political spending by board and management would be protected “through the procedures of
corporate democracy.”
Citizens United
, 558 U.S. 310 (2010).
Since
Citizens United,
institutional and individual investors and coalitions have recognized
their responsibility to monitor political spending transparency and to demand disclosure across
all publicly traded companies. A rulemaking petition to the SEC for standardized mandatory
disclosure of corporate political spending, including disclosure of trade association funding and
other lobbying initiatives, received a record level of support: more than 1.2 million comment
letters have been submitted on the petition, the vast majority in support of the proposed rule.
9
A key staff precedent is
CVS Health Corporation
(February 9, 2015, recon denied, March 23,
2015) where the company made similar assertions on a very similar proposal requesting a report
on congruency between the corporate values and electioneering contributions. CVS had asserted
that the Company's existing disclosures of amounts contributed to candidates would allow
shareholders to assess for themselves the issues of congruency should they choose
to.
Proponents successfully argued that since the essential purpose of the Proposal is for the
management to publish its own analysis of the congruency of its donations and to explain the
exceptions made, the Company's actions fail to constitute substantial implementation for
purposes of Rule 14a-8(i)(10).
The same is true in the present instance.
Strict scrutiny of substantial implementation in proposals on political contributions
The Staff has utilized rigorous standards in assessing substantial implementation on
proposals relating to political contributions and lobbying, because these are issues that are of
major concern to many investors, and implicated by
Citizens United
as issues meriting
engagement through the “instruments of shareholder democracy.”
Investors have frequently asserted in recent years that in light of the Supreme Court ruling
of
Citizens United
and ongoing public backlash against corporate political spending, disclosure
of how companies are managing these issues and risks of merits rigorous and comparable
disclosure for shareholders to assess potential exposure to risks caused by our future
electioneering contributions.
Numerous efforts by companies to claim substantial implementation of political spending
disclosure proposals when the companies had only done disclosure that partially fulfilled the
request have been rejected by the Staff. For example, see
NextEra Energy, Inc.
(February 24,
2020);
Exxon Mobil Corp.
(April 2, 2019);
Goldman Sachs Group, Inc.
(March 14, 2013
); EQT
Corp.
(January 23, 2013);
Nike, Inc.
(July 5, 2012);
Southwestern Energy Co.
(March 15,
2011);
The Boeing Co.
(February 14, 2011);
Citigroup Inc.
(March 9, 2007);
Bristol-Myers
Squibb Co.
(February 18, 2005);
Exxon Mobil Corp.
(March 5, 2004);
Wells Fargo
Co.
(February 11, 2004). For instance, in
Nike, Inc.
(July 5, 2012) the company’s failure to
provide a breakdown of itemized political contributions, as was requested in that proposal, led
the SEC Staff to find that the company had not substantially implemented the proposal.
In addition, numerous other company attempts to exclude proposals under Rule 14a-8(i)(10)
have failed where the company has provided public disclosure of some, but not all, of the
Office of Chief Counsel
January 17, 2023
Page 8 of 12
elements of reporting requested. See for instance
Marathon Oil Corporation
(January 22,
2013);
Dominion Resources, Inc.
(February 28, 2014),
Nike, Inc.
(July 5, 2012) (requesting
reports on lobbying or political contributions and expenditures).
Internal assessment without disclosure of core requested elements does not constitute
substantial implementation
A request for publication of an assessment, even if the assessment may have been conducted
internally but not published, does not yield substantial implementation on a proposal seeking
reporting. For instance, in
McDonalds Corp.
(March 14, 2012) the proposal requested the board
issue a report assessing the company's policy responses to growing evidence of linkages between
fast food and childhood obesity, diet related diseases and other impacts on children's health. The
proposal also specified that the report should include an assessment of the potential impacts of
public concerns and evolving public policy on the company's finances and operations. The
company's substantial implementation argument was rejected, even though the company may
have internally or implicitly conducted some of the assessments requested by the Proposal. Its
reporting to shareholders did not fulfill the guidelines of the Proposal in disclosure of an
assessment.
II.
The Proposal is not an excludable resubmission because it does not deal with the same
subject matter as previous shareholder proposals at the Company.
Rule 14a-8(i)(12), the resubmission exclusion, provides that a shareholder proposal may be
excluded from a company’s proxy materials if it “addresses substantially the same subject matter
as a proposal, or proposals, previously included in the company’s proxy materials within the
preceding five calendar years if the most recent vote occurred within the preceding three years,”
and the proposal received “[l]ess than 15 percent of the votes cast if previously voted on twice.”
The Company argues that current Proposal addresses substantially the same subject matter as
the 2021 Proposal, also filed by Tara Health, and the 2022 Proposal, filed by the National Center
for Public Policy Research.
In 2022, the proposal submitted by the National Center for Public Policy Research received
10.41% of the vote, a stark contrast to the 47.2% vote of the 2021 Tara Health (current
proponent) proposal that Pfizer argues addresses substantially the same subject matter.
Each of the three Proposals are distinct. The 2021 Proposal requested a congruency report on
Pfizer’s political contributions due to the Company’s apparent misalignment in contributions and
its publicly stated values and interests including the Affordable Care Act, Pfizer’s contraceptive
and abortifacient medications, and its commitment to greenhouse gas reduction targets.
In contrast, the 2022 Proposal requested a congruency report based on that proponent’s
argument that Pfizer’s contributions were misaligned because of allegations that supporting
universal health-care programs would stifle innovation and resources; that Pfizer’s
nondiscrimination policy would force the company to discriminate against white and male
Office of Chief Counsel
January 17, 2023
Page 9 of 12
employees; that Pfizer’s contributions went to candidates who did not support legislation to end
Uyghur forced labor or “sensible border security”; and finally, that Pfizer supports candidates
“who oppose even minimal, common-sense pro-life policies to protect society’s most vulnerable
members.” For most of these issues, the 2021 and 2022 Proposals take completely opposing
stances on major topics - which is the best available explanation for the dramatic shift in voting
support among shareholders.
While the 2021 and 2022 Proposals share the same resolved clause, the 2023 Proposal has a
distinct resolved clause to reflect the core focus of the Proposal. Looking at the background
section of the three proposals shows even more contrast, with the 2023 Proposal focusing
entirely on reproductive health. In response to the significant
Dobbs v. Jackson Women's Health
Organization
decision, the Proponent in the 2023 Proposal is requesting that Pfizer provide
transparency to its shareholders on how it is ensuring that its political contributions align with its
publicly stated goal to “ensure . . . access to reproductive health.” This subject matter is distinct
from the previous proposals.
Unlike the current Proposal, in the precedents cited by the Company, the resubmitted
proposals focused on the same substantive core concerns. For example, in
Exxon Mobil
Corporation
(March 15, 2022), the proposals at issue were so similar that the Company was able
to create a chart showing that the only edits to the proposals were minor additions or deletions
and the four proposals all had identical resolved clauses. Similarly, in
Alphabet Inc.
(April 16,
2019), the proposals at issue were virtually identical, with only minor additions or edits, in both
the resolved clause and supporting statements. In
JPMorgan Chase & Co.
(January 27, 2017),
the proposals at issue were so similar that the proponent even stated in this proposal, “this
resolution drew scant support last year.” It is clear that these proposals had the same substantive
concerns because the proposals shared nearly identical language. That is not the case here
because the proposals have different resolved clauses and the background sections of the current
Proposal raises a unique subject matter concern.
In another precedent cited by the Company,
Apple Inc.
(November 20, 2018), the proposals
addressed the same policy concern regarding human rights implications of the Company’s
operations in China. In contrast, the current Proposal addresses a different policy concern than
the previously submitted proposals.
The shareholders in the cited precedent had multiple years to vote on the nearly identical
proposals and they made their lack of interest in the proposals obvious. In contrast, this Proposal
provides an opportunity for investor support on the hot button issue of the Company’s
incongruent political expenditures that undermines reproductive rights.
The Proponent further notes the twisted effect that would result from the Company’s
argument – a proponent could effectively stifle the voice of a future proponent with a different
perspective by filing a shareholder proposal on an issue that is peppered with arguments that are
counter to prevalent perspectives of investors and therefore fails miserably. The point of the
resubmission rule is to maintain efficiency by preventing yearly resubmissions of a proposal that
clearly does not evoke shareholder interest. It would be counterproductive to prevent submission
of a new proposal which contains an entirely different subject matter and perspective.
Office of Chief Counsel
January 17, 2023
Page 10 of 12
The purpose of the resubmission rule as articulated by the Staff is to relieve the management
of the necessity of including proposals which have been previously submitted to security holders
without evoking any substantial security holder interest therein. This purpose is not served by
excluding the 2023 proposal. Based on the drastic contrast in shareholder support, it is evident
that shareholders recognize the difference between the two previous proposals, and that
regardless, the current proposal with its focus on congruency of company contributions affecting
reproductive rights is a substantially different core focus from both of the prior proposals
submitted at the Company in the past five years and therefore it is not eligible for exclusion.
CONCLUSION
The Company has not met its burden that the Proposal is excludable under Rule 14a-8(i)(10)
or Rule 14a-8(i)(12). Therefore, we request that the Staff inform the Company that the SEC
proxy rules require denial of the Company’s no-action request. Please call me at (413) 549-7333
with respect to any questions in connection with this matter, or if the Staff wishes any further
information.
Sincerely,
Sanford Lewis
Brittany Blanchard Goad
cc: Margaret M. Madden
Office of Chief Counsel
January 17, 2023
Page 11 of 12
POLITICAL CONTRIBUTIONS MISALIGNMENT
Whereas:
Pfizer has stated “political contributions are made to support the election of
candidates, political parties and committees that support public policies important to the
industry, such as innovation and access to medicines,” and “[w]e aim to end
discrimination against women, ensure equal opportunities for leadership and access to
reproductive health.”
However, Pfizer’s political expenditures appear to be misaligned with the company’s stated
values and interests.
Pfizer has stated that “Expanded access to health insurance coverage will help ensure
that patients with under-diagnosed and undertreated conditions are able to address them;
and that those who will benefit from Pfizer medicines are better able to have access to
them.” Yet in 2018, Pfizer was a top contributor to a 527 organization leading efforts to
strike down the Affordable Care Act, which has made prescription drugs more accessible
for millions, and contributes to PhRMA, which donates to numerous organizations
opposing congressional efforts to reform drug pricing.
Pfizer manufactures contraceptives and a drug commonly prescribed for medication
abortion. Yet the proponent estimates that since the beginning of the 2020 election cycle,
Pfizer and its employee PACs have donated at least $5 million to politicians and political
organizations working to weaken women’s access to reproductive health care. In the South
during this period, Pfizer’s contributions to anti-choice state candidates exceeded those to
other candidates by a ratio of 3:1, and its contributions to anti-choice federal candidates
exceeded those to other candidates by a ratio of 2:1. For example, Pfizer contributed to
multiple sponsors of bills passed in 2022 in Tennessee and Louisiana that will restrict access
to medication abortion.
This pattern spending has drawn scrutiny from STAT, Bloomberg News, Huffington Post, The
Minnesota Daily, CQ ESG Briefing, Agenda (a Financial Times publication) and Forbes.
Proponents believe Pfizer should establish policies and reporting systems that minimize risk
to reputation and brand by addressing possible missteps in corporate electioneering and political
spending that contrast with its stated healthcare objectives.
Resolved: Pfizer publish an annual report, at reasonable expense, analyzing the congruency
of political, lobbying, and electioneering expenditures during the preceding year against publicly
stated company values and policies, including Pfizer’s stated goal to “end discrimination against
women, ensure equal opportunities for leadership and access to reproductive health.” Such a
Office of Chief Counsel
January 17, 2023
Page 12 of 12
report should list and explain any instances of incongruent expenditures, and state whether the
identified incongruencies have led to a change in future expenditures or contributions.
Supporting Statement:
Proponents recommend that such report contain management's analysis of risks to our
company's brand, reputation, or shareholder value of expenditures in conflict with publicly
stated company values. “Electioneering expenditures" means spending, from the corporate
treasury and from the PACs, directly or through a third party, at any time during the year
which are reasonably susceptible to interpretation as in support of or opposition to a
specific candidate.
Margaret M. Madden
Pfizer Inc. – Legal Division
Senior Vice President and Corporate Secretary
235 East 42nd Street, New York, NY 10017
Chief Governance Counsel
Tel 212 733 3451 Fax 646 563 9681
margaret.m.madden@pfizer.com
BY EMAIL
(shareholderproposals@sec.gov)
January 24, 2023
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Chief Counsel
100 F Street, N.E.
Washington, D.C. 20549
RE:
Pfizer Inc. – 2023 Annual Meeting
Supplement to Letter dated December 16, 2022
Relating to Shareholder Proposal of
Tara Health Foundation and Louise Davis
Ladies and Gentlemen:
We refer to our letter dated December 16, 2022 (the “No-Action Request”), pursuant
to which we requested that the Staff of the Division of Corporation Finance (the “Staff”) of
the Securities and Exchange Commission (the “Commission”) concur with our view that the
shareholder proposal and supporting statement (the “Proposal”) submitted by Tara Health
Foundation (“Tara Health”) and co-filed by Nia Impact Capital, on behalf of Louise Davis,
may be excluded from the proxy materials to be distributed by Pfizer Inc., a Delaware
corporation (“Pfizer”), in connection with its 2023 annual meeting of shareholders (the “2023
proxy materials”). Tara Health and Ms. Davis are collectively referred to as the
“Proponents.”
This letter is in response to the letter to the Staff, dated January 17, 2023, submitted
on behalf of Tara Health (the “Proponents’ Letter”), and supplements the No-Action Request.
In accordance with Rule 14a-8(j), a copy of this letter also is being sent to the Proponents.
The Proponents’ Letter argues that the Proposal is not an excludable resubmission
under Rule 14a-8(i)(12) because it does not deal with the same subject matter as the 2022 and
2021 proposals voted on by Pfizer’s shareholders (together, the “Prior Proposals”). The
Proponents’ Letter also claims that the Proposal has not been substantially implemented by
Pfizer and thus may not be excluded under Rule 14a-8(i)(10). Neither argument is
persuasive.
Office of Chief Counsel
January 24, 2023
Page 2
I.
The Proposal Deals with Substantially the Same Subject Matter as the Prior
Proposals.
In arguing that the Proposal does not address substantially the same subject matter as
the Prior Proposals, the Proponents’ Letter mischaracterizes the Proposal as “focus[ed]
entirely on reproductive health.” This characterization requires ignoring the plain text of the
Proposal.
The Proposal, seeking a report on the congruency of Pfizer’s political expenditures
with Pfizer’s stated values and policies, references at least six different “stated values and
policies” of Pfizer. Alongside the discussion of (1) reproductive health, the Proposal
references Pfizer stated values such as (2) “innovation,” (3) “access to medicines,” (4)
“end[ing]discrimination against women,” (5) “ensur[ing] equal opportunities for leadership”
and (6) “[e]xpand[ing] access to health insurance coverage.” The Proposal text clearly
conveys that Pfizer has a number of publicly stated values and policies and provides no basis
to conclude that the Proposal focuses on a single publicly stated value or policy to the
exclusion of other publicly stated values and policies.
The variety of publicly stated values and policies referenced in the Proposal is
entirely consistent with the Proposal’s resolved clause, which not only does not contain any
limitation on the analysis to a single publicly stated value or policy but sets forth as examples
three different publicly stated values and policies to be included in any analysis – “publicly
stated company values and policies, including Pfizer’s stated goal to ‘end discrimination
against women, ensure equal opportunities for leadership and access to reproductive health.’”
Moreover, this resolved clause remains substantively unchanged from the Prior Proposals,
simply adding an “including” clause to provide examples of publicly stated values and
policies (three examples, to be precise). Like the Prior Proposals, the Proposal is not focused
on a single policy issue and the decision to append an “including” clause does nothing to
limit the substantive concern of the Proposal to the congruency of Pfizer’s political
expenditures exclusively with one of the three examples set forth in the “including” clause.
As described in the No-Action Request, where proposals address the same substantive
concern, the Staff has concluded that the proposals cover substantially the same subject
matter. Here, all three proposals express the same substantive concern, namely “the
congruency of [Pfizer’s] political . . . expenditures” with “publicly stated company values
and policies.” The fact that the Staff determined, and Tara Health acknowledged, less than a
year ago that a proposal nearly identical to the current Proposal was substantially duplicative
of the 2022 proposal under Rule 14a-8(i)(11) is further indication of the substantial similarity
between the Proposal and the 2022 proposal. To accept the Proponents’ argument that the
Proposal is unique and only about reproductive health would require the Staff to ignore the
actual text of the Proposal and its own prior determination regarding the substantial overlap
between two of the proposals under consideration.
The Proponents’ Letter also attempts to draw a conclusion regarding the “drastic
contrast in shareholder support” received by the Prior Proposals as definitive evidence that
Office of Chief Counsel
January 24, 2023
Page 3
the two Prior Proposals are substantially different. This conclusion is not only baseless, but
it ignores the most logical explanation – shareholders became less concerned about this topic
following Pfizer’s responsive actions to the vote on the 2021 proposal. Regardless of
investors’ motives for voting differently in 2022, shifting levels of shareholder support does
not alter the language of the proposals, each of which expresses the same concern with
consistency between Pfizer’s political expenditures and its stated values and policies.
Because the Proposal and the Prior Proposals address substantially the same subject matter,
and the shareholder vote on the 2022 proposal was less than 15% of the votes cast, the
Proposal is excludable under Rule 14a-8(i)(12)(ii) for failing to receive the requisite
shareholder support.
II.
Pfizer Has Substantially Implemented the Proposal.
The Proponents’ Letter also misinterprets the Staff’s view on the substantial
implementation basis for exclusion. The Proponents’ Letter details the perceived
shortcomings of Pfizer’s extensive disclosures regarding the alignment of its political
expenditures with its stated values and policies, claiming that “strict scrutiny of substantial
implementation” is warranted where proposals relate to political contributions and lobbying.
This view has no basis in either law or Staff no-action decisions. The substantial
implementation test under Rule 14a-8(i)(10) does not require differing levels of scrutiny
depending on subject matter. As noted in the No-Action Request, a company may exclude a
proposal pursuant to Rule 14a-8(i)(10) if the company has already substantially implemented
the proposal. Applying this standard, the Staff consistently has permitted the exclusion of a
proposal when it has determined that the company’s policies, practices and procedures or
public disclosures compare favorably with the guidelines of the proposal. Moreover, as
demonstrated in countless no-action determinations, the Staff also has permitted exclusion
under Rule 14a-8(i)(10) where a company already addressed the underlying concerns and
satisfied the essential objectives of the proposal, even if the proposal had not been
implemented exactly as proposed by the proponent. As elaborated above, the substantive
concern of the Proposal is disclosure about political expenditure congruency generally, and
not with respect to any one particular value or policy issue.
1
Accordingly, the appropriate
inquiry is whether Pfizer’s political expenditure congruency disclosures as a whole—not
solely those disclosures with respect to reproductive rights—compare favorably with the
disclosures requested in the Proposal. As described in the No-Action Request, Pfizer has
satisfied the Proposal’s essential objective of providing disclosure regarding political
expenditure congruency, and given the nature and extent of Pfizer’s reporting, such
1
We note the Proponents’ Letter discussion of the Supreme Court’s decision in
Citizens United
. To the
extent that the Proponents are concerned with Pfizer’s contributions to 527 Issue Organizations, as stated in
the No-Action Request, Pfizer discloses in its Political Contributions Report that (i) it traditionally does not
make contributions to 527 Issue Organizations, and if such a contribution is requested, such expenditures
must be reviewed and approved by the Political Contributions Policy Committee and subsequently
disclosed and (ii) it has determined that it will not make any direct independent expenditures. The Political
Contributions Report also notes that the decision to refrain from making direct independent expenditures
has been discussed at the executive level as well as with the Governance & Sustainability Committee of
Pfizer’s Board.
Office of Chief Counsel
January 24, 2023
Page 4
disclosures compare favorably with those requested by the Proposal. Accordingly, the
Proposal is excludable under Rule 14a-8(i)(10).
For the reasons stated above and in the No-Action Request, we respectfully request
that the Staff concur that it will take no action if Pfizer excludes the Proposal from its 2023
proxy materials.
Should the Staff disagree with the conclusions set forth in this letter, or should any
additional information be desired in support of Pfizer’s position, we would appreciate the
opportunity to confer with the Staff concerning these matters prior to the issuance of the
Staff’s response. Please do not hesitate to contact me at (212) 733-3451 or Marc S. Gerber
of Skadden Arps, Slate, Meagher & Flom LLP at (202) 371-7233.
Very truly yours,
Margaret M. Madden
Enclosures
cc:
Shelly Alpern
Director of Corporate Engagement
Meredith Benton
Sanford Lewis & Associates
PO Box 231
Amherst, MA 01004-0231
413 549-7333
sanfordlewis@strategiccounsel.net
February 6, 2023
Via electronic mail
Office of Chief Counsel
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Supplemental Response Regarding Shareholder Proposal to Pfizer Inc.
Regarding Political Contributions Congruency by Tara Health Foundation
Ladies and Gentlemen:
Tara Health Foundation has submitted a shareholder proposal (the “Proposal”) to
Pfizer Inc. (the “Company”). We previously responded to the Company’s No-Action
Request of December 16, 2022 on January 17, 2023.
We have been asked by the Proponent to respond to the letter dated January 24, 2023
("Company Supplemental Letter") sent to the Securities and Exchange Commission by
Margaret M. Madden, Senior Vice President and Corporate Secretary. In that letter, the
Company supplements its No-Action Request provided on December 16, 2022 (the “No-
Action Request”). A copy of this letter is being emailed concurrently to Margaret M.
Madden at margaret.m.madden@pfizer.com.
We are grateful for the opening provided by the Supplemental Letter to add
additional information to the decision-making record on this No-Action Request.
Prompted by the Supplemental Letter, we re-examined the record of the company’s
actions and the requests of the proposal. We stand by our original arguments, and
appreciate the opportunity to provide additional analysis for the Staff’s consideration.
The Company’s original letter and supplement assert that its existing actions
implement the Proposal. But further examination of the Company’s actions demonstrates
Office of Chief Counsel
February 6, 2023
Page 2 of 9
that there is no support for the idea that the current proposal is substantially implemented
- the Company has not conducted the actions requested by the guidelines of the proposal.
The clear and compelling evidence for lack of substantial implementation also
demonstrates clearly that the
subject matter of the proposal
is not the same as prior
submitted proposals on which the company bases its resubmission argument.
In this instance,
the Proposal’s clear focus on the element of women’s
reproductive and economic rights
resoundingly rebukes both the substantial
implementation and resubmission arguments. There is no evidence provided by the
Company that it implemented the focal question raised by the proposal in assessing
congruency of either trade association or political contributions on the issue of
reproductive rights, and as we will show further below, there is ample evidence of the
need for such an assessment.
Substantial Implementation
The Proposal requests that the Company publish an annual report, at reasonable
expense, analyzing the congruency of political, lobbying, and electioneering expenditures
during the preceding year against publicly stated company values and policies, including
Pfizer’s stated goal to “end discrimination against women, ensure equal opportunities for
leadership and access to reproductive health.” Such a report should list and explain any
instances of incongruent expenditures, and state whether the identified incongruencies
have led to a change in future expenditures or contributions.
Congruency with rights to contraception and reproductive health not evaluated in
existing reporting
The Supplemental Letter from the Company which alleged that shareholder
support previously declined for the 2022 congruency proposal due to the Company’s
“responsive actions.” Further evaluation demonstrates that it certainly does not
implement the current Proposal, because it was not prepared with an eye toward the
current proposal’s focal issue which includes reproductive rights. We can find no
evidence whatsoever of any action by the company that would appear to evaluate the
congruence of contributions against the request of the proposal to assess against Pfizer’s
stated goal to “ensure … access to reproductive health.”
Office of Chief Counsel
February 6, 2023
Page 3 of 9
Pfizer produces and sells one of the leading birth control products, the injectable
product, Depo-Provera. The apparent incongruence in its support for politicians that have
opposed contraception rights makes the Proposal’s request for ongoing reporting on this
issue a necessity.
In its 2021 ESG report, the Company touts its role as is a producer of contraceptive
products, including Sayana® Press, Pfizer’s long-acting, injectable and reversible
contraceptive. As the Company notes in the report, page 21:
The all-in-one prefilled, single-use, auto-disable system eliminates the need to
prepare a needle and syringe. It also allows the contraceptive to be administered
by a health worker outside of a clinical setting, or it can be self-injected if
approved locally and after health care worker instruction.
Notably, the Company website highlights the manner in which this product improves
contraceptive access, particularly for low income women:
Because of its unique contraceptive delivery technology – enabling the product to
be compact, discreet, and easily transportable – Sayana® Press can be provided in
low- resource, non-clinic settings, potentially transforming the way in which
women can access and receive their preferred method of contraception.
1
Despite these important products, the Company’s existing disclosures did not entail
any congruency analysis regarding the fact that Pfizer's PAC donated to numerous
politicians
2
who opposed and blocked the federal Right to Contraception Act, which
1
Also, this is a substantial and touted initiative of the company on contraception:
Pfizer completed its investment in 2021 to establish a new automated filling line for the UnijectTM
injection system, which delivers the contraceptive. In total, Pfizer allocated $39 million from the bond
proceeds to fund the capital expense. Once operational, this new filling line will allow for capacity to scale
from 23 million units per year to up to 30 million units per year. The new automated filling line will undergo
process validation and EU regulatory review in 2022, and is expected to enter into commercial production in
2023.
2
Pfizer’s PAC and Corporate Political Contributions Report lists that the PAC donated $3,500 to "Jobs
Opportunity And New Ideas PAC (Sen. Joni Kay Ernst)." Senator Ernst blocked efforts to pass the Right to
Contraception Act in the Senate. https://iowacapitaldispatch.com/2022/07/27/ernst-blocks-bill-guaranteeing-right-to-
birth-control/
The Report also lists PAC donations to the following Congress members who voted against the Act in the
House: $2,500 to Rep. Kelly Armstrong; $1,000 to Rep. Jodey Cook Arrington; $2,500 to Rep. Troy Balderson;
$2,500 to Rep. Andy Barr; $6,500 to Rep. Gus Michael Bilirakis; $5,000 to Rep. Kevin Patrick Brady; $10,000 to
Rep. Vernon Gale Buchanan; $2,500 to Rep. Kenneth Buck; $8,000 to Rep. Larry Dean Bucshon; $2,500 to Rep.
Michael Clifton Burgess; $1,000 to Kenneth Calvert; $1,500 to Rep. Earl L. B. Carter; $500 to Rep. Benjamin L.
Cline; $2,500 to Rep. Thomas Jeffrey Cole; $2,500 to Rep. Daniel Crenshaw; $8,500 to Rep. John R. Curtis; $2,500
to Rep. Thomas Earl Emmer, Jr.; $1,500 to Rep. Ron Estes; $7,500 to Rep. A. Drew Ferguson; $1,000 to Rep.
Office of Chief Counsel
February 6, 2023
Page 4 of 9
would have established a federal right to contraception, from passing in Congress last
year.
3
This Act was particularly important compared to other bills about contraception
because it would protect the right to access and use contraception even if the Supreme
Court overturns the constitutional right to contraception and state laws are enacted to
restrict or ban birth control.
Such concern regarding the right to all forms of birth control have been placed at risk
by the recent Supreme Court decision in Dobbs. As one expert noted in a recent article:
“Over the years, some abortion opponents have put forth a narrative about
contraceptives that is not consistent with medical and scientific consensus,” she told
us. “So the question is who gets to decide if a particular product induces abortion? We
see language in this decision about letting the states decide. Can a state label
something as an abortifacient even if the science said it is not? This decision has
opened up uncertainty and could well mean that companies have shot themselves in
the foot.”
4
The crux of the lack of substantial implementation is that there is no evidence that the
Company has performed and published an analysis of incongruency on this issue of
support for contraception and other reproductive rights. The potential threat directly to
the company’s own contraception products is an issue which is expected to deepen in
coming years and creates a compelling argument for the current proposal. For Pfizer this
is recognized by media as a major point of controversy and congruency with the
company’s business needs, as demonstrated by the STAT coverage headlined:
‘A slippery
slope’: Pfizer sells a contraceptive and donated to political groups that could come after the
company.
Generally speaking, a company would not want to contribute to a politician whose
actions could hurt its sales. But one of the biggest drugmakers may have set itself up for
Michael Garcia; $1,000 to Rep. H. Morgan Griffith; $5,000 to Rep. S. Brett Guthrie; $2,500 to Rep. Kevin R. Hern;
$5,000 to Rep. Richard Lane Hudson; $1,500 to Rep. Bill Johnson; $1,500 to Rep. David Patrick Joyce; $10,000 to
Rep. Darin LaHood; $5,000 to Rep. Robert E. Latta; $1,500 to Rep. Jacob LaTurner; $1,500 to Rep. Nicole
Malliotakis; $1,500 to Rep. Tracey Robert Mann; $3,500 to Rep. Patrick Timothy McHenry; $2,500 to Rep. John
Moolenaar; $3,000 to Rep. Markwayne Mullin; $2,500 to Rep. Gregory J. Pence; $2,500 to Rep. Guy L.
Reschenthaler; $2,500 to Rep. Tom Rice; $7,500 to Rep. Cathy McMorris Rodgers; $2,500 to Rep. Stephen Joseph
Scalise; $1,000 to Rep. Jason Thomas Smith; $2,500 to Rep. Adrian Michael Smith; $2,500 to Rep. Lloyd Smucker;
$1,000 to Rep. Victoria Spartz; $2,500 to Rep. Elise Stefanik; $5,000 to Rep. Ann Louise Wagner; $1,500 to Rep.
Jacqueline Walorski; $2,500 to Rep. Brad Wenstrup; $2,500 to Rep. Stephen Allen Womack.
https://clerk.house.gov/Votes/2022385
3
https://www.help.senate.gov/chair/newsroom/press/republican-senator-blocks-bill-to-codify-americans-
right-to-contraception-
4
https://www.politicalaccountability.net/wp-content/uploads/2022/07/STAT-Contraceptive-makers-
donated-to-political-groups-that-could-target-them-7.1.22.pdf
Office of Chief Counsel
February 6, 2023
Page 5 of 9
that kind of dichotomy. Since 2018, Pfizer contributed to three groups that, in turn,
played a notable role in overturning Roe v. Wade through their support of elected
officials. And a future item on the politically conservative agenda may be contraceptives
sold by the company, a scenario that could suggest they acted against its own financial
interest.
5
In addition, although we have not conducted a comprehensive review of trade
association positions related to reproductive rights we note that a proposed national
comprehensive data privacy bill quite relevant to current reproductive rights
controversies was opposed by the US Chamber of Commerce and is not described in the
Company’s congruency report on trade associations. The bill would have helped to
ameliorate the threat to reproductive healthcare posed by sensitive individual consumer
data. Under the legislation, consumer consent would be required prior to data being
shared with data brokers and, potentially, with law enforcement. Companies would not be
able to provide law enforcement with certain sensitive data as they would be prohibited
from retaining it in the first place. Finally, individuals would be entitled to request to
delete data that may implicate them in abortion-related prosecutions, as for instance,
information about abortion medication that was legally obtained in a jurisdiction that
does not criminalize the procedure. In opposing this legislation, the Chamber undercut
the implementation of additional protections that would have strengthened the privacy of
persons seeking abortions, including through the use of Pfizer’s own products.
The specificity of the current proposal on the controversial topic of reproductive
health -
as it affects the company’s own customers
, in particular, is neglected by the
company’s purported congruency analysis. The Chamber publicly opposed the bipartisan
American Data Privacy and Protection Act (“ADPPA”).
6
The ADPPA would support
reproductive rights by providing a nationwide comprehensive consumer privacy
framework that would protect personal data such as reproductive and sexual health
information.
7
Information protected under the Act includes: (1) any information that
describes or reveals the past, present, or future physical health, mental health, disability,
diagnosis, or healthcare condition or treatment of an individual; (2) biometric
5
https://www.statnews.com/pharmalot/2022/07/01/abortion-contraception-pfizer-political-donations
6
See
https://www.cnbc.com/2022/06/09/bipartisan-privacy-proposal-is-unworkable-chamber-of-
commerce-says.html
;
see also
https://www.uschamber.com/technology/data-privacy/u-s-chamber-letter-on-national-
privacy-legislation
7
See
https://www.brookings.edu/blog/techtank/2022/07/07/how-comprehensive-privacy-legislation-can-
guard-reproductive-privacy/
Office of Chief Counsel
February 6, 2023
Page 6 of 9
information; (3) genetic information; and, (4) precise geolocation information.
8
The
ADPPA would also require covered entities to obtain consumer consent before
transferring “sensitive covered data” -- like the above mentioned categories of
information – to a third party. In addition, the Act would provide consumers with myriad
controls over data that is held by covered companies, such as a right to access, correct
and delete their data.
This policy opposed by the Chamber is hindering safe access to reproductive
health care that is dependent on digital privacy. Following the revocation of federal
constitutional rights in June 2022, various states have criminalized or severely restricted
abortion access. To enforce such criminal abortion laws, it is pivotal that states are
relying on personal digital data. For instance, law enforcement is seeking to access data
about all individuals who were near an abortion clinic in order to identify people who
may have aided or received an abortion.
9
Strict Scrutiny of Substantial Implementation
The Company further argues that there is “no basis in either law or Staff no-action
decisions” for the Proponent to assert that strict scrutiny of substantial implementation is
warranted where proposals related to political contributions and lobbying.
The Proponent rests on its previous arguments in its response to the Company’s no
action request to show that, in fact, there is significant precedent at the SEC to support
the Proponent’s assertion that the Staff has utilized rigorous standards in assessing
substantial implementation on proposals relating to political contributions and lobbying,
because these are issues that are of major concern to many investors. The influential
Citizens United
case decided by the United States Supreme Court similarly supports the
Proponent’s assertion that shareholders have a right and responsibility to hold companies
responsible for misdirected corporate political spending “through the procedures of
8
https://www.congress.gov/bill/117th-congress/house-bill/8152/text#toc-
H13C0EF0ECD5A46F8A9BCC8714B8A2FC9
9
Law enforcement typically obtain such personal digital data by submitting informal information requests
to companies, since companies can voluntarily share the data without running afoul of Fourth Amendment search
warrant requirements. Law enforcement may also obtain these data indirectly from data brokers, as was the case
with Fog Data Science – a company that the Federal Trade Commission accused of selling raw geolocation
information, including individual presence at a reproductive health clinic, to law enforcement agencies.
Office of Chief Counsel
February 6, 2023
Page 7 of 9
corporate democracy”
10
which includes shareholder proposals such as this one. As we
demonstrated in the prior citations, failure to rigorously meet each of the guidelines in a
political contributions disclosure proposal has often been sufficient to deny the claim of
substantial implementation.
Resubmission
The Company also reiterates its arguments that the proposal deals with
substantially the same subject matter as the prior proposals.
Last year’s proposal was not a resubmission of the proposal submitted in the prior
year because, regardless of the similarities of the resolved clauses, shareholders would
have understood the proposals quite differently. The conflicting background statements
of the 2021 and 2022 proposals told a different story for voting shareholders regarding
the thrust four implementation of a congruency analysis, leaning into issues like racial
diversity and reproductive rights in the analysis contemplated by the 2021 proposal, and
into concerns about discrimination against white men and ensuring a “pro-life”
orientation based on the background statement of the 2022 proposal. Shareholders would
have understood that they were engaging in very different signaling to the board and
management in their support of the different proposals, and one would anticipate
significantly different implementation based on the emphasis of the background
statements. As such, the proposals were in effect addressing different subject matters.
Moving beyond the proposal of last year, this year’s Proposal clearly did not
address the same subject matter as last year’s given the important focus on reproductive
rights – a challenging issue for the company especially given its contributions records. As
demonstrated in our discussion of substantial implementation above, the current proposal
cannot be seen as substantially implemented in part because the Company’s existing
actions did not address the new focal element of the proposal. Contrary to the current
Proposal, the 2022 NCPPR proposal did not center or even address the issue of
reproductive rights and instead was explicitly anti-choice. This 2023 Proposal, and the
measures that would implement it with the distinct in its focus on reproductive rights thus
cannot be seen as a resubmission of NCPPR’s proposal.
10
Citizens United, 558 U.S. 310 (2010).
Office of Chief Counsel
February 6, 2023
Page 8 of 9
The Company further claims that the “most logical explanation” to explain the
difference in shareholder support between Tara Health’s 2021 Proposal and NCPPR’s
2022 Proposal is that “shareholders became less concerned about this topic following
Pfizer’s responsive actions to the vote on the 2021 proposal.” We are skeptical that the
“responsive actions” referenced by the Company were the basis for the low vote in 2022.
The congruency analysis of trade associations activities provided little evidence that the
board found any incongruities with trade Association activities, instead it seemed at best
an effort to rationalize different positions by referencing the idea that the trade
associations in some instances had policies on issues on which the company had given
little focus.
While we cannot be certain as to why there was a decline in shareholder support, it is
at least equally likely that the decline was due to the emphasis of the 2022 proposal’s
background statement on discrimination against white men and promotion of an
antiabortion agenda. Unlike the current Proposal, NCPPR’s 2022 proposal noted that
Pfizer “supports many candidates who oppose even minimal,
common-sense pro-life
policies
to protect society’s most vulnerable members.” (Emphasis added).
The Company’s shareholders were prudent enough to grasp this material difference in
the focus of the proposals and the votes reflect that. To reiterate, Tara Health’s 2021
proposal received 47.2% of the vote, while NCPPR’s 2022 proposal received only
10.41%.
In 2022 NCPPR used nearly an identical resolved clause as Tara Health had applied
the year before, but with opposing objectives, and a resultant low vote. It is as if NCPPR
were gaming the system – filing a proposal that may have indeed had the intent of
repelling votes and blocking a resubmission. In recognition of the outcome of the tactic
used by NCPPR, Tara Health withdrew its 2022 proposal and amended it for presentation
in 2023 with a resolved clause intended to refocus on issues neglected in the 2022
proposal: Pfizer’s political contribution incongruence with its own stated goal to “end
discrimination against women, ensure equal opportunities for leadership and access to
reproductive health.” This goal is not referenced in the previous proposals.
Allowing exclusion of this Proposal as a result of NCPPR’s unpopular tactic last year
to use Tara Health’s successful resolved clause, with a materially different focus, would
not serve the purpose of the resubmission rule of preventing shareholders from voting on
an issue that has already been effectively deliberated upon by the shareholders. The
Office of Chief Counsel
February 6, 2023
Page 9 of 9
current proposal with its focus on women’s economic and reproductive right was not
voted upon in 2022 and it is appropriate for shareholders to consider the proposal in
2023.
CONCLUSION
Because the Company has not met its burden in the No-Action Request nor the
Supplemental Letter to prove that the Proposal is excludable under Rule 14a-8(i)(10) or
Rule 14a-8(i)(12), we request that the Staff inform the Company that the SEC proxy rules
require denial of the Company’s no-action request. Please call me at (413) 549-7333 with
respect to any questions in connection with this matter, or if the Staff wishes any further
information.
Sincerely,
Sanford Lewis
Brittany Blanchard Goad
cc: Margaret M. Madden