Wyeth Report on Political Contributions and Policies

As many different laws affect our business, Wyeth has a responsibility to our employees, patients and shareholders to participate in the lawmaking process to provide a necessary perspective on the health care debate in the United States and ensure that our interests are known and addressed. We also support our employees’ involvement in the political process through voluntary contributions to the Company’s political action committee (PAC), grassroots program or direct contributions and volunteering.

The Wyeth Code of Conduct sets forth our policy on political contributions by its employees worldwide.  It states:

“The laws of some countries prohibit corporations making any direct or indirect contributions or expenditures in connection with elections.  In such countries, any employee of the Company may, of course, contribute personally to any political party, candidate or, where permissible, political action committee, but any such contribution must be made on a personal basis, not on behalf of the Company, and reimbursement must not be sought from the Company, directly or indirectly.”

The company is fully committed to complying with campaign finance and lobbying laws, and with any changes that may be enacted in the future, including the laws requiring public disclosure of political contributions and lobbying expenses.

Corporate Political Contributions

Federal law prohibits companies like Wyeth from making corporate contributions to federal candidates. Wyeth has also chosen not to make corporate contributions to support state candidates in those states where such corporate contributions are allowed by law.

Wyeth Good Government Fund

The Wyeth Good Government Fund (GGF), Wyeth’s voluntary political action committee, is a non-partisan PAC that allows Wyeth employees to pool their financial resources to support federal and state candidates who understand and appreciate the value of innovation and its importance to improving health care.

The goal of the GGF is to help elect candidates who, as lawmakers, will best represent the values of Wyeth and the patients we serve. The criteria considered by the GGF in making political contributions are:

• The candidate’s support of positions that encourage pharmaceutical innovation.
• The candidate’s leadership position or membership on key legislative committees.
• The candidate’s potential for leadership.
• The candidate’s financial need and likelihood of being elected.
• The presence of Wyeth employees and facilities in the candidate’s district or state.

GGF contributions are made in accordance with federal and state campaign finance laws and a budget that is determined annually by the Wyeth Good Government Fund Board of Directors. 

As stated in the Wyeth Good Government Fund bylaws, the GGF is authorized to make lawful expenditures to:

1. Candidates for election to public office of the government of the United States of America or of any state, territory, possession, commonwealth, municipality or other political subdivision thereof (including primary, general and special election).
2. One or more political parties or qualified committees established for the purpose of supporting candidates for elective public office.
3. The political action committee of any trade association of which Wyeth or a subsidiary is a member (whether such political action committee makes distributions to candidates, political parties or qualified committees, including primary, general and special elections).

The Wyeth Good Government Fund is designated as a federal PAC and, therefore, is federally regulated.  All contributions are publicly disclosed in reports filed with the Federal Election Commission.  Reports are available at the Federal Election Commission (www.fec.gov). Click here to view Wyeth’s Good Government Fund 2006 Contributions report.