CORPORATE POLICY AND PROCEDURE # 108 Title: U.S. and Puerto Rico Contingent Worker Engagement Policy and Procedure Version: 1.3

Effective Date: 11/03/2007

Last Updated: 06/24/2014

Sponsoring Division: Finance and Business Operations Policy Contact: Tanja Koch, Sean McKenna

Contact Email: [email protected] [email protected] [email protected]

1. PURPOSE AND SCOPE..........................................................................................................................2 2. POLICY....................................................................................................................................................2 3. PROCEDURE ..........................................................................................................................................2 3.1 ENGAGING CONTINGENT WORKERS ........................................................................................2 3.2 ONBOARDING CONTINGENT WORKERS ..................................................................................3 3.3 TREATMENT OF CONTINGENT WORKERS ...............................................................................3 3.4 TRAINING OF CONTINGENT WORKERS ....................................................................................3 3.5 LENGTH OF ENGAGEMENT..........................................................................................................4 3.6 DISCONTINUING SERVICE OF CONTINGENT WORKERS ......................................................4 4. CONSEQUENCES OF NON-COMPLIANCE ........................................................................................4 5. ROLES & RESPONSIBILITIES..............................................................................................................4 6. DEFINITIONS .........................................................................................................................................5 7. REFERENCES .........................................................................................................................................7 ATTACHMENT A – GUIDELINES FOR TREATMENT OF CONTINGENT WORKERS.....................8 ATTACHMENT B – DRUG TESTING & BACKGROUND CHECK.....................................................10

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

1. PURPOSE AND SCOPE

The purpose of this Policy and Procedure is to define the policies, procedures, roles and responsibilities that apply when engaging a U.S. or Puerto Rico-based Contingent Worker (“Contingent Worker”). This Policy and Procedure applies to all aspects of the Contingent Worker engagement lifecycle, which includes sourcing, on-boarding, treatment, training, direction, and off-boarding. Contingent Workers who are not based in the U.S. or Puerto Rico are not in the scope of this Policy and Procedure. For guidance on the engagement of those Contingent Workers, please reach out to local HR, Employment Law or Procurement. 2. POLICY

Pfizer’s Policy is that Contingent Workers may be used only in the following instances: 

to provide services for which Pfizer does not otherwise employ its own resources (e.g., catering, landscaping, maintenance),



when a short-term staff augmentation need exists (i.e. short-term increase in BusinessAs-Usual (BAU) workload) and no internal resources are available, or



when a special skill (e.g., for a special project with specific deliverables and timelines) is required, and the hiring of additional employees is not warranted

Pfizer Colleagues may not directly engage or contract with a Contingent Worker to provide services to Pfizer; a Pfizer Approved Supplier must be used and Global Procurement processes must be followed. 3. PROCEDURE 3.1 ENGAGING CONTINGENT WORKERS

Contingent Workers may be engaged only for appropriate business purposes. Short-term business needs should be filled using internal resources wherever possible. Contingent labor for administrative and clerical support is not permissible to backfill short-term vacancies without the approval of senior management1. Once an appropriate need has been identified, a Pfizer Sponsor must engage a Contingent Worker through a Pfizer Approved Supplier using one of the following Global Procurement programs or processes: (a) Pfizer’s competitively-bid Contingent Labor Master Service Provider (MSP) Program, (b) Pfizer’s Preferred Contingent Worker Payroll Administrator, or (c) valid and current service agreement, e.g., Outsourced Service Agreement, Statement of Work (SOW), or Consulting Agreement 1

For additional details, please review Spend Guidelines issued in April 2012.

2

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

For questions about the best sourcing approach, the Pfizer Sponsor should contact the Global Procurement Category Strategy Manager (CSM), who will provide guidance. Pfizer Sponsors may interview and select (“name”) Contingent Workers who are engaged through the Contingent Labor MSP Program or the Preferred Contingent Worker Payroll Administrator. However, Pfizer Sponsors generally may not select or interview candidates for any service agreement. In most cases, Contingent Workers under service agreements will be “un-named,” meaning the Supplier screens and selects the Contingent Worker(s) for the engagements. However, on occasion and at the discretion of the Pfizer Sponsor, it may be necessary to pre-screen a Contingent Worker for certain critical roles. In all cases, the Supplier should communicate the engagement decision to the prospective Contingent Worker. Pfizer Colleagues may not discuss compensation, pay rate or benefits information with Contingent Workers. All former Pfizer Colleagues (including retirees) returning as Contingent Workers must be cleared through the Office of Contractor Management (OCM) prior to the offer of any engagement. Should a former Pfizer Colleague be bound by the terms of a separation plan or be unable to return for other reasons, it is beyond OCM’s authority to make exceptions. Exception requests will be referred to the Employment Law Administrative Committee, which handles all such requests under the Company’s severance plans, for review. 3.2 ONBOARDING CONTINGENT WORKERS

The requirements set forth in Exhibit B, Drug Testing and Background Check Requirements, apply to all Contingent Workers who perform work on a regular or routine basis at a Pfizer manufacturing site or Pfizer office. Suppliers are required to ensure that the Contingent Workers who provide services to Pfizer are and remain drug-free and comply with Pfizer's drug-free workplace standards. All Contingent Workers who require network access or Pfizer site access must be registered in Pfizer’s Global Identity Management system (GIDM) by their Pfizer Sponsor. It is the responsibility of the Sponsor to ensure that local security requirements, such as the Enhanced Security Clearance requirements for Restricted Areas, are followed as part of the onboarding process. 3.3 TREATMENT OF CONTINGENT WORKERS

Contingent Workers are not employees of Pfizer. They are, however, to be treated in accordance with Pfizer values and are expected to comply with all Pfizer policies that apply to Contingent Workers. Pfizer Sponsors must review Attachment A, Guidelines for Treatment of Contingent Workers, prior to the engagement of any Contingent Worker. 3.4 TRAINING OF CONTINGENT WORKERS

Contingent Workers should already possess all the necessary skills and training before they are engaged. However, certain technical, compliance, application and/or safety training may be 3

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

required as part of the on-boarding process for certain Contingent Workers. For questions about mandatory or site-specific training, the Pfizer Sponsor should consult Compliance, Legal, and Environment, Health and Safety. 3.5 LENGTH OF ENGAGEMENT

For those circumstances where the Contingent Worker was selected (“named”) and/or where the deliverable is the responsibility of the Pfizer Sponsor (as supposed to service agreements where the deliverable is the responsibility of the Supplier), the engagement should not extend beyond a 12 month continuous period for a BAU engagement or three years for a Project-based engagement. Project-based engagements require specific deliverables and timelines and are limited to one project for the duration of the engagement. Once the engagement is complete, a previously named Contingent Worker may not return to Pfizer as a named resource on another contracted engagement even if there was a break in between engagements. This requirement does not apply to Students who participate in an HRendorsed Student Worker Program. In those circumstances where the Contingent Worker is selected by the Supplier (“un-named”) and the deliverable is the responsibility of the Supplier, the length of engagement guidelines do not apply as long as there is no involvement by a Pfizer Sponsor in the selection process or the deliverable for the duration of the engagement. Any exceptions to the length of engagement guidelines must be requested from OCM. 3.6 DISCONTINUING SERVICE OF CONTINGENT WORKERS

Pfizer Colleagues may never take direct action terminating a Contingent Worker’s engagement. If a Contingent Worker’s performance or conduct warrants the discontinuance of his or her services or the engagement is ending early, contact the Supplier or OCM. If you have any questions or concerns regarding the discontinuation of a Contingent Worker engagement, contact OCM, your Divisional Human Resources (HR) representative, or Pfizer Global Security. 4. CONSEQUENCES OF NON-COMPLIANCE

Violations of this Policy and Procedure by Pfizer Colleagues may result in disciplinary action up to and including termination. Contingent Workers will be subject to disciplinary action according to the terms and conditions of the agreement with the Supplier. 5. ROLES & RESPONSIBILITIES

Office of Contractor Management (OCM) OCM is part of Global Procurement and manages this Policy and Procedure. OCM is responsible for:  

day-to-day management of the Managed Service Provider (MSP) Program and Preferred Contingent Worker Payroll Administrator; review of exception requests for this Policy and Procedure, administrative and clerical 4

Corporate Policy and Procedure #108 Version # 1.3

   

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

requests, eligibility of former Pfizer Colleagues to return as Contingent Workers; length of engagement and non-compliant off-boarding audits; Contingent Worker data management and reporting; providing information about appropriate sourcing, use and management of Contingent Workers, and co-employment concerns; and partnering with Employment Law, HR, Compliance and Global Security on issues and questions relating to Contingent Workers.

Pfizer Sponsor The Pfizer Sponsor is responsible for the conduct of the Contingent Worker while on Pfizer’s network and safety while on Pfizer’s premises for the duration of the engagement. The Pfizer Sponsor is also responsible for:   

 

sourcing a Contingent Worker in compliance with Corporate Policy and Procedure 102: Purchasing Policy and Procedure (CP 102); maintaining the Contingent Worker’s identity data as set forth in Corporate Policy 406: Electronic Identity and Information Management; ensuring the Contingent Worker’s correct classification (e.g., BAU, Project-based) at the beginning of the engagement. This only applies to Contingent Workers who are engaged through the Contingent Labor MSP Program or the Preferred Contingent Worker Payrolling Administrator; verifying the length of engagement is compliant with this Policy and Procedure; and terminating the engagement and network access through GIDM within 24 hours once the engagement has ended.

Global Procurement Category Strategy Manager (CSM) The Global Procurement Category Strategy Manager is responsible for  identifying the correct sourcing approach for a Contingent Worker need;  reviewing and approving pre-identified Contingent Worker requests that were initiated by their respective categories/businesses/sites to ensure: o the billing rate is in line with the industry benchmark rate; o the request aligns with the overall category strategy; o there are no conflicts with the terms of any other current agreements Pfizer may have with other Suppliers (e.g., no conflict with any non-compete clauses); and o the request is compliant with CP 102. 6. DEFINITIONS

Administrative Committee: Designated Employment Law appeal committee for all Pfizer and legacy company severance plans, which is tasked with interpreting and implementing all Pfizer and legacy company severance plans, including reviewing and deciding appeals by claimants under those plans and deciding requests for exceptions to the rehire provisions of the plans. Approved Supplier: A Supplier that was selected and approved by Global Procurement 5

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

under CP 102 guidelines. Business-as-Usual (BAU): Defined as general support/staff augmentation with no tangible deliverables. Maximum length of engagement is 12 months. Category Strategy Manager (CSM): A colleague from Global Procurement who manages sourcing for a specific procurement category (e.g., fleet, HR, etc.), business or site. Consulting Agreement: A legal agreement between a consultant and a client, by which the client buys the services of the consultant. Contingent Labor Master Service Provider (MSP): A supplier that takes on primary responsibility for managing an organization’s contingent workforce program. Contingent Worker: A non-employee engaged to provide services to Pfizer in the U.S. or Puerto Rico, including, without limitation: o Agency temporaries – hourly workers engaged through temporary staffing agencies o Professional service consultants – individuals provided through external consulting firms who provide professional expert advice o Outsourced service providers (e.g., catering, building maintenance) o Independent Contractors (IC) o Leased personnel – former Pfizer employees who have been transferred as part of a divestiture and who are helping transition operations to the new organization o Secondees – law firm employees who are on temporary engagement at Pfizer under a short term contract o Certain interns based in student worker programs; consult with your HR representative or OCM for the correct classification. Independent Contractor (IC): A self-employed individual performing services for a company under contract rather than as an employee, either on- or off-site. In the U.S. also referred to as “1099s,” which is the designation of the IRS form that companies use to report the money paid to independent contractors. GIDM: Pfizer’s Global Identify Management system. Office of Contractor Management (OCM): A Global Procurement function that manages the day-to-day operations of the Contingent Labor MSP and Preferred Contingent Worker Payroll Program. Outsource Service Agreement: A form of outsourcing whereby services are provided by an organization that has expertise in operating a specific client function. Pfizer Sponsor: The Pfizer Colleague who secures funding and is the primary contact throughout the Contingent Worker’s engagement lifecycle. 6

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

Preferred Contingent Worker Payroll Administrator: A Preferred Supplier that takes on the responsibility of payrolling pre-identified Contingent Workers. Project: For purposes of this Policy and Procedure, OCM defines a Project as a finite unit of work with a tangible deliverable (as opposed to support, which has no discrete deliverable) and a defined end date, typically three years or less in length. Projects longer than three years are atypical and subject to a greater degree of scrutiny and qualification. Spend Guidelines: Pfizer-issued guidelines concerning the management of spend. Statement of Work (SOW): A document that captures work products and services, including, but not limited to the work activities and deliverables to be supplied under a contract or as part of a project timeline. 7. REFERENCES

    

Office of Contractor Management Corporate Policy and Procedure 102: Purchasing Policy and Procedure Corporate Policy and Procedure 406: Electronic Identity & Access Management Pfizer Spend Guidelines GIDM

7

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

ATTACHMENT A – GUIDELINES FOR TREATMENT OF CONTINGENT WORKERS

1. Contingent Workers are not eligible for any global or divisional recognition programs, e.g., Achievement Award, Individual or Team Award. Any monetary recognition, if approved, must come directly from the Contingent Worker’s employer, not Pfizer. 2. Contingent Workers are not eligible to participate in any of Pfizer’s employee benefit plans (e.g., Pfizer Savings Plan, Pfizer medical plan) and are not eligible for benefits provided under Pfizer’s policies (e.g., Pfizer vacation, paid time off). Refer the Contingent Worker to his or her employer to address any benefits-related questions. 3. Do not relay any performance-related feedback (e.g., attendance, tardiness, inappropriate behavior) to Contingent Workers. Do not conduct performance evaluations of Contingent Workers or attempt to discuss or resolve performance or employment-related issues directly with Contingent Workers. Do not provide references for Contingent Workers. Communicate any concerns about a Contingent Worker’s provision of services to the agency on-site representative, or in their absence, to the Contingent Worker’s agency or employer. Any Contingent Worker’s inappropriate behavior should be additionally reported to Pfizer HR and OCM. 4. Do not allow a Contingent Worker to use Pfizer titles, to sign documents on behalf of Pfizer, or to obtain or use Pfizer business cards. For Contingent Worker signature suggestions please refer to the OCM site. 5. Contact OCM or HR before responding to any Contingent Workers’ inquiries regarding full-time employment. Do not discuss specific employment opportunities or the possibility of becoming a Pfizer employee with Contingent Workers or on-site agency representatives. Do not direct Contingent Workers to any Pfizer job posting sites to pursue particular vacancies or opportunities. 6. Pfizer Colleagues should avoid direct discussions with Contingent Workers regarding new or additional services outside the scope of the current engagement. The Pfizer Sponsor should engage Global Procurement or OCM for sourcing of additional opportunities. 7. Consult OCM before considering a former Pfizer employee as a possible Contingent Worker. 8. Instruct Contingent Workers to wear a contractor badge at all times and to return the badge after the engagement has ended. 9. Pfizer does not maintain employee records for Contingent Workers. The Contingent Worker’s employer will retain all employment-related records. However, Pfizer may keep training and certification records for Contingent Workers. Contingent Workers’ records should be kept separate from employee records. 8

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

10. If a Contingent Worker raises an issue under Pfizer’s Open Door Policy, contact HR, Global Security or the Employment Law Group immediately, who will notify the agency as appropriate. 11. If a Contingent Worker is injured on the job, follow site-specific protocol for immediate medical attention. Then notify the Environment, Health & Safety department (EHS) immediately. EHS will follow the normal protocol for reporting the injury to the agency. Contingent Workers should be instructed to report any injuries to their employer. 12. Careful consideration should be given to whether Contingent Workers should attend business meetings. Invite Contingent Workers only to meetings that directly pertain to their engagement or the service they provide. Examples could include project update meetings and events. 13. Careful consideration should be given when including Contingent Workers in internal communication, ensuring that the subject matter is appropriate. 14. Careful consideration should be given whether to permit Contingent Workers to attend non-work related functions, play on a company-sponsored sports team, or participate in company-sponsored events that are not open to visitors, guests or the general public. Questions regarding the treatment of Contingent Workers can be directed OCM.

9

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

ATTACHMENT B – DRUG TESTING & BACKGROUND CHECK

Pfizer’s Drug Testing and Background Check Requirements for Contingent Workers and Suppliers, Including Criminal and MVR Record Checks, FDA Debarment Database and DEA Controlled Substance Requirements (Updated 09/2011) I. Overview Pre-engagement drug testing, background, criminal and debarment checks are mandatory for all new Contingent Workers who perform work for Pfizer on a regular or routine basis at a Pfizer site or Pfizer work location, including, but not limited to, periods of time requiring a Pfizer security badge beyond that required for periodic “visitors” (hereinafter referred to as “Contingent Workers.”) Conducting tests and screening is the responsibility of the individual Supplier and is subject to periodic audit by Pfizer. Post-engagement drug testing and background check obligations are also specified herein. The occurrence of any substance abuse, disqualifying offenses or debarments during a Pfizer engagement must also be handled in accordance with these guidelines. These requirements are current as of their date of issuance. Pfizer reserves the right to amend or modify these requirements at any time and will provide ample notice and an opportunity for discussion prior to implementation of any new requirements. Pfizer also reserves the right to require additional security checks, qualifications and background clearances for any individuals whose duties will require access to any areas deemed by Pfizer to be "restricted" or "special access" areas on any Pfizer site. Drug testing shall be in accordance with the following:      

Supplier must conduct pre-engagement drug tests of all Contingent Workers to the full extent permitted by state or local law. Pre-engagement drug testing must be successfully completed prior to the Contingent Worker’s commencement date at Pfizer. Contingent Workers who fail their drug screen must not be assigned to any Pfizer facility or account and may reapply for an engagement after six months from the date of the failed drug screen. Drug testing is to be conducted by a NIDA Approved laboratory. The cost of the tests will be absorbed by the Supplier. If any Contingent Worker exhibits observable evidence of substance abuse or impairment during the course of any engagement, Pfizer reserves the right to remove them from the workplace and require the Supplier to conduct an immediate drug and alcohol screen, to the full extent permitted by federal, state or local law. Results of the screen (an indication of “pass” or “fail”) must be provided to Pfizer before the Contingent Worker is permitted to return to any Pfizer facility.

10

Corporate Policy and Procedure #108 Version # 1.3

 

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

A drug test will be considered valid for 1 (one) year or the length of the Contingent Worker’s engagement, whichever is longer. Any break in engagement greater than 3 months will necessitate a new drug screen. Employment of the Contingent Worker by a new Supplier, regardless of the time interval between engagements, will necessitate a new drug screen by the new Supplier.

Background Checks shall be conducted in accordance with the following: 

   

Supplier must conduct background checks related to the employment, education, FDA debarment status and any required licenses or certifications (such as MVR and DEA) of any Contingent Worker provided to Pfizer to the full extent permitted by federal, state or local law. Detailed requirements for the background check are provided below. Background checks must be successfully completed prior to the Contingent Worker’s commencement date at Pfizer. The cost of the background check is to be absorbed by the Supplier. The background check will be considered valid for 1 (one) year or the length of the contractor engagement, whichever is longer. However, any break in engagement greater than 3 months will necessitate a new background check. Employment of the Contingent Worker by a new Supplier, regardless of the time interval between engagements, will necessitate a new background check by the new Supplier.

Certification of Compliance  

Prior to a Contingent Worker’s commencement of engagement at Pfizer, the Supplier is required to obtain a completed drug screen and background check and accept or decline a worker for any Pfizer engagement. Pfizer reserves the right to audit results and compliance with the above requirements.

II.   

Summary of Scope of Background Check Pre-Screening for Current Unlawful Substance Abuse Verification of Personal Identity, Employment Record and Educational History Criminal Record Check (residences, employment locations and names during the past seven years). Combination of local, state and county checks.  Motor Vehicle Records (“MVR”) (only for subjects driving company-owned vehicles or driving on company business as a primary component of job)  Debarment (Includes FDA/ORA Debarment, OIG and Excluded Parties)  DEA Checks for Engagements involving Controlled Substances III.Specific Areas of Inquiry, Analysis and Decision A.

SUBSTANCE ABUSE SCREENING Pfizer maintains a substance abuse-free workplace. All Suppliers, especially those whose services are regularly delivered through onsite workers, are required to ensure that their employees, independent contractors and consultants, and all individuals whom they engage to work on Pfizer premises and/or Pfizer projects under their control and/or supervision, are 11

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

and remain drug-free and compliant with Pfizer's drug-free workplace standards. Suppliers will be required to demonstrate that individuals, who are designated to work on Pfizer premises and/or on Pfizer projects, have passed drug tests, as follows. Testing Methods To the full extent permitted by federal, state and/or local law pre-hire drug screening is to be conducted. All urine samples will be screened using an immunoassay technique and all presumptive positive tests will be confirmed using gas chromatography/mass spectrometry (GC/MS) or another equally sensitive and reliable methodology. All confirmatory tests will be performed by a laboratory certified by the federal Substance Abuse and Mental Health Services Administration (SAMHSA) for federal workplace testing. Pfizer currently tests for cannabinoids (marijuana), cocaine metabolites, amphetamines (including methamphetamines and some prescription stimulants), opiates (including codeine, morphine, heroin, methadone, meperidine, hydrocodone, hydromorphone, and oxycodone), phencyclidine (PCP), barbiturates, and benzodiazepines (including Valium and Xanax). B.

EMPLOYMENT AND EDUCATIONAL HISTORY VERIFICATION Pfizer requires verification of personal identity, employment and educational history for all Contingent Workers. Prior to assigning any individual to a Pfizer site placement or project Suppliers are required to verify that the employment and educational histories of Contingent Workers are accurate and acceptable. Inaccurate information and/or unexplained gaps must be reviewed by the Supplier. Contingent Workers who fail to fully and accurately disclose information shall be disqualified from any Pfizer engagement. Employment history and reasons for leaving (including, but not limited to Pfizer engagements) must be verified and reviewed for the greater of either the last 7 years or the last 3 positions held. Contingent Workers terminated from prior employment for misconduct, violations of Policy or law, behavioral issues or other unacceptable reasons shall be disqualified from any Pfizer engagement. Verification of educational history should include ALL qualifications, regardless of date undertaken or job relevance.

C.

CRIMINAL and MOTOR VEHICLE REQUIREMENTS Pfizer strives to maintain safe and secure working environments for all Colleagues, customers, business partners, visitors and guests. All Suppliers are required to verify criminal and MVR records to ensure that Contingent Workers do not pose a safety or security risk to Pfizer sites, property or personnel. Prior to assigning any individual to a Pfizer placement or project the Supplier shall inquire as to whether the individual had been convicted of any criminal offense or offenses. The inquiry shall be followed by a detailed criminal records check. The failure to fully disclose any conviction prior to the criminal records check shall disqualify the individual from any Pfizer engagement. If during the course of an engagement a disqualifying offense is committed by a Contingent Worker, the Supplier must take the actions specified in this Policy. 12

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

Disqualifying Offenses Certain criminal offenses that substantially relate to all anticipated Pfizer-related project duties pose risks to Pfizer’s efforts to maintain safe and secure workplaces and business operations. These offenses are identified below as disqualifying offenses. The other listed offenses require further review by the supplier to determine based on the relevant facts and applicable laws whether to assign the individual to a Pfizer project or placement. When conducting all such reviews, the supplier is required to apply substantial deference to Pfizer’s interests in maintaining a safe, violence-free and substance abuse-free working environment. All unresolved determination or questionable circumstances are to be considered disqualifying offenses. Felonies Except as restricted by applicable federal, state and local laws, all felony convictions, arrests (where prosecution is pending) and deferred adjudication, within the last seven (7) years shall be disqualifying offenses. Misdemeanors/Violations/Other Offenses Except as restricted by applicable federal, state and local laws, all convictions for misdemeanors, Violations and Other Offenses within a period of five (5) years shall be reviewed to determine the underlying facts, followed by further supplier review to determine whether a Pfizer placement would be appropriate. Factors include whether the offense substantially relates to the anticipated Pfizer-related project duties and/or poses risks to Pfizer’s efforts to maintain safe and secure workplaces and business operations. Pending Charges Except as restricted by applicable federal, state and local laws, an individual charged with a offense (Felony and/or Misdemeanor) should be interviewed to determine the underlying facts, followed by further supplier review to determine whether a Pfizer placement would be appropriate during pendency of the charge[s]. Decisions should be based on underlying facts obtained from the candidate and other available sources, and not the mere pendency of a criminal charge. Factors include whether the offense substantially relates to the anticipated Pfizer-related project duties and/or poses risks to Pfizer’s efforts to maintain safe and secure workplaces and business operations. An individual exonerated of the charge[s] may be considered for placement. Outstanding Warrants An individual with an outstanding arrest warrant may not be placed with Pfizer until the warrant has been dismissed or adjudicated.

13

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

Motor Vehicle Record (MVR) MVR check is required prior to the placement of any individual in a position, the principal duties of which require the operation of a motor vehicle. When multiple licenses are involved, all of the applicant’s licenses will be evaluated together in order to reach final hiring decision. Violations not listed below shall be reviewed to determine the underlying facts, followed by further supplier review to determine whether a Pfizer placement would be appropriate. Disqualifying MVR Criteria:  Current suspended, cancelled, expired, revoked license, no license, permit only, and ID card only  Single DWI/DUI within the past year, 2 or more DWI/DUI no time limit  3 or more moving violations (do not count accidents) within the past 3 years. Careless and Reckless Driving will be considered moving violations  Accumulation of suspensions over 1 year in length within the last 3 years  More than 2 accidents with indication of fault within last 3 years  More than 3 accidents, no time limit D.

DEBARMENT LISTS Pfizer will not provide access to our facilities for any individual listed on certain debarment lists maintained by various government agencies. As a result, all contracting agencies are required to ensure that their employees, independent contractors, and consultants, and all individuals who work on Pfizer premises and/or Pfizer projects under their control and/or supervision, are checked against the following debarment/exclusion lists and any whose name appears must be disqualified from any Pfizer engagement. (The exclusion lists are available on the official government websites maintained by each supplier.) In the event that an existing Contingent Worker is added to a debarment list during an engagement, the contract agency must remove the worker from all Pfizer engagements, whether conducted at a Pfizer site or elsewhere. 1. Federal Department of Health and Human Services List of Excluded Individuals/Entities 2. General Services Administration Excluded Parties List System (EPLS) 3. Federal Drug Administration Debarment List

E.

DEA CONTROLLED SUBSTANCES CHECKS Under CFR 1301.90 Pfizer is required to obtain additional information on all individuals who will have access to controlled substances, as defined by the Drug Enforcement Administration. Contracting agencies must therefore ask the following questions of any individual considered for engagement to a Pfizer facility where they will be in contact with controlled substances. As set forth in Section III C above, an affirmative response to question 14

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

1 will preclude a candidate from assuming any engagement at Pfizer. An affirmative response to questions 2-5 will not necessarily preclude a candidate from working in a noncontrolled substances area, but that information should be used by the Supplier as part of the overall evaluation of the individual’s qualifications for a Pfizer engagement. 1. Within the past five years, have you been convicted of a felony, or within the past two years, of any misdemeanor or are you presently formally charged with committing a criminal offense? (Do not include any traffic violations, juvenile offenses or military convictions, except by general court martial.) If yes, furnish details of convictions, offense, location, date and sentence. 2. In the past three years, have you ever knowingly used any narcotics, amphetamines or barbiturates, other than those prescribed to you by a physician? If yes, furnish details. 3. Have you at any time had an application for registration with the DEA denied for cause? If so, please describe the application and date of such denial. 4. Have you at any time had an application for registration with the DEA revoked for cause? If so, please describe the application and date of revocation. 5. Have you at any time surrendered a DEA registration for cause? If so, please describe the registration and the date of such surrendering. In conducting this DEA controlled substances check, Suppliers should comply with the following guidelines: a. Obtain an authorization, in writing, that allows inquiries to be made of courts and law enforcement agencies for possible pending charges or convictions. The authorization must be executed by any contingent worker who is seeking to work in an area where access to controlled substances clearly exists. b. The person must be advised that any false information or omission of information will jeopardize his or her position with respect to the engagement. c. The application for employment should inform the person that information furnished or recovered as a result of any inquiry will not necessarily preclude engagement, but will be considered as part of an overall evaluation of the person's qualifications. d. The Supplier must commit to maintain fair employment practices, the protection of the person's right of privacy, and the assurance that the results of such inquiries will be treated by the Supplier in confidence and will be explained to the Contingent Worker. IV. Retention of Records and Audit The supplier must maintain records demonstrating its compliance with these background check requirements for each individual placed with Pfizer. Pfizer reserves the right to audit the supplier’s compliance and the contracting agency will provide these records to Pfizer upon request. In the event Pfizer becomes aware that the supplier failed to abide by the terms set forth herein, Pfizer reserves the right to remove and deny access to any individual who has not been screened as outlined above. 15

Corporate Policy and Procedure #108 Version # 1.3

Title: U.S. and Puerto Rico Contingent Worker Policy and Procedure Last Updated: 06/24/2014

V. Compliance with Applicable Laws and Indemnification The supplier will implement these background check requirements in a manner that complies with all relevant federal, state and local laws. The supplier agrees to indemnify and hold Pfizer harmless for all claims, damages, losses and liabilities (including claims or demands made by its employees, agents, consultants, independent contractors, and applicants) as a result of the supplier’s compliance or noncompliance with the foregoing requirements. VI. Falsification or Omission The falsification or omission of any information provided by an employee, independent contractor, or consultant shall preclude the supplier from placing the individual on any Pfizer engagement.

16