108 Contingent Worker Engagement - Pfizer

1 CORPORATE POLICY AND PROCEDURE # 108 Title: and puerto rico Contingent Worker Engagement Policy and Procedure Version: Date: 11/03/2007 Last Updated: 06/24/2014 Sponsoring Division: Finance and Business OperationsPolicy Contact: Tanja Koch, Sean McKennaContact Email: 1. PURPOSE AND ENGAGING Contingent ONBOARDING Contingent TREATMENT OF Contingent TRAINING OF Contingent LENGTH OF DISCONTINUING SERVICE OF Contingent CONSEQUENCES OF ROLES & A GUIDELINES FOR TREATMENT OF Contingent B DRUG TESTING & BACKGROUND Policy and Procedure #108 Title: and puerto rico Contingent Worker Policy and ProcedureVersion # Updated: 06/24/201421. PURPOSE AND SCOPE The purpose of this Policy and Procedure is to define the policies, procedures, roles and responsibilities that apply when engaging a 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.

2 Contingent Workers who are not based in the 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 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 ( , catering, landscaping, maintenance), when a short-term staff augmentation need exists ( short-term increase in Business-As-Usual (BAU) workload) and no internal resources are available, or when a special skill ( , for a special project with specific deliverables and timelines) is required, and the hiring of additional employees is not warrantedPfizer 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 3. 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, , Outsourced Service Agreement, Statement of Work (SOW), or Consulting Agreement1 For additional details, please review Spend Guidelines issued in April Policy and Procedure #108 Title: and puerto rico Contingent Worker Policy and ProcedureVersion # Updated: 06/24/20143 For questions about the best sourcing approach, the Pfizer Sponsor should contact the Global Procurement Category Strategy Manager (CSM), who will provide guidance.

4 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 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 .

5 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. 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 Contingent Workers who require network access or Pfizer site access must be registered in Pfizer s Global Identity Management system (GIDM) by their Pfizer 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.

6 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 . 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 Corporate Policy and Procedure #108 Title: and puerto rico Contingent Worker Policy and ProcedureVersion # Updated: 06/24/20144required 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 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 .

7 Project-based engagements require specific deliverables and timelines and are limited to one project for the duration of the Engagement . Once the Engagement i s 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 HR-endorsed Student Worker 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. DISCONTINUING SERVICE OF Contingent WORKERS Pfizer Colleagues may never take direct action terminating a Contingent Worker s Engagement .

8 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 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 & RESPONSIBILITIESO ffice 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 Corporate Policy and Procedure #108 Title: and puerto rico Contingent Worker Policy and ProcedureVersion # Updated: 06/24/20145requests, 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.

9 And partnering with Employment Law, HR, Compliance and Global Security on issues and questions relating to Contingent SponsorThe 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 ( , 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 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:othe billing rate is in line with the industry benchmark rate;othe request aligns with the overall category strategy.

10 Othere are no conflicts with the terms of any other current agreements Pfizer may have with other Suppliers ( , no conflict with any non-compete clauses); andothe request is compliant with CP 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 Corporate Policy and Procedure #108 Title: and puerto rico Contingent Worker Policy and ProcedureVersion # Updated: 06/24/20146under CP 102 (BAU): Defined as general support/staff augmentation with no tangible deliverables. Maximum length of Engagement is 12 months.