DRUG TESTING & BACKGROUND CHECK Pfizer’s …

1 drug TESTING & BACKGROUND CHECK Pfize r s drug Te s ting and B ackground Che ck Re quire me nts for Continge nt Worke rs and Supplie rs , Including Criminal and M VR Re cord Che ck s , FDA De barme nt Databas e and DEA Controlle d Subs tance Re quire me nts (Update d: 10/12/2015) I. Overview drug TESTING , BACKGROUND , criminal and debarment checks are mandatory for all new Contingent Workers who perfor m work at a P fizer location and who are issued a permanent pfizer site badge. Conducting tests and screening is the responsibility of the individua l Supplier and must be performed no earlier than 30 days prior to the start of the engagement. Compliance with this requirement is subject to periodic audit by P fizer.

2 The occurrence of any substance abuse, disqualifying offenses or debarments during a P fizer engagement must also be handled in accordance with these guidelines. These requirements are current as of their date of issuance. P fizer 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. P fizer also reserves the right to require additional security checks, qualifications and BACKGROUND clearances for any individua ls whose duties will require access to any areas deemed by pfizer to be "restricted" or "special access" areas on any pfizer site.

3 drug te s ting s hall be in accordance with the following: Supplier must conduct dr ug tests of all Cont ingent Wor kers to the full extent permitted by federal, state or local law. drug TESTING must be successfully completed pr ior to the Cont ingent Worker s commencement date at pfizer . Tests must be performed no earlier than 30 days prior to the start date. Cont ingent Workers who fail the ir drug screen must not be assigned to a pfizer engageme nt. A Contingent Worker may reapply 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.

4 If any Cont ingent W orker exhibits observable evide nce of substance abuse or impa irment dur ing the course of any engagement, pfizer reserves the right to remove them from the engagement a nd require the Supplier t o conduct an immediate dr ug and alc ohol screen, to t he full extent permitted by federal, state or local law. Results of the screen (an indication of pass or fa il ) must be provided to P fizer. A Cont ingent Wor ker is per mitted to retur n to work f or P f ize r only if the screening was passed. A drug test w ill be cons idered va lid for 1 (one) year or the lengt h of t he Cont ingent W orker s engagement, whiche ver is longer.

5 Any break in engage ment greater than 6 mont hs will necessitate a new drug screen. Employment of the Cont ingent Wor ker by a new Supplier, regardless of the time interval between engagements , w ill ne c e s s ita te a new drug screen by the new Supplier. Corporate Policy and Procedure #108 Title: and Puerto Rico Contingent Worker Policy and Procedure Version # Las t Updat e d: 10/12/2015 B ackground Che cks shall be conducte d in accordance with the following: Supplier must c onduct BACKGROUND checks re lated t o t he employment , educat ion, FDA debarment status and any required licenses or certif icat ions (such as MVR and DEA) of any Cont ingent Worker provided to pfizer to the full extent permitted by federal, state or local law.

6 Detailed requirements for the BACKGROUND CHECK are provided below. BACKGROUND checks must be successfully complete d pr ior t o the Cont ingent W orker s commencement date at pfizer . BACKGROUND checks must be perf ormed no ear lier than 30 days prior to the start date. The cost of the BACKGROUND CHECK is to be absorbed by the Supplier. The BACKGROUND CHECK will be cons idered va lid for 1 (one) year or the length of the Cont ingent Worker s engageme nt, whichever is longer. Any break in engagement greater than 6 mont hs will necessitate a new BACKGROUND CHECK . Emp loy ment of the Cont ingent Wor ker by a new Supplier, regardless of the time interval between engagements, will necessitate a new BACKGROUND CHECK by the new Supplier.

7 Ce rtification of Compliance P rior to a Contingent Worker s commencement of engagement at P fizer, the Supplier is required to obta in a completed dr ug screen and backgr ound CHECK . Cont ingent Workers who f a il the drug screen and BACKGROUND CHECK must not be assigned to a P fizer engagement. P fizer reserves the right to audit results and compliance wit h the above requireme nts annua lly. II. Summary of Scope of B ackground Che ck Pre-Screening for Current Unlawful Substance Abuse Verification of P ersonal Identity, Employment Record and Educational History Criminal Record CHECK (residences, employment locations and names during the past seven years).

8 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 P arties) DEA Checks for Engagements involving Controlled Substances III. Spe cific Are as of Inquiry, Analys is and De cis ion A. SUBSTANCE ABUSE SCREENING P fizer 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 a ll individua ls whom t hey engage t o work on P fizer premises and/or P fizer projects under their control and/or supervision, are and remain drug -free and complia nt with P fizer's drug -free workplace standards.

9 Suppliers will be required t o demonstrate that individua ls , who are designated to w ork on pfizer premises and/or on P fizer projects, have passed drug tests, as follows. 2 Corporate Policy and Procedure #108 Title: and Puerto Rico Contingent Worker Policy and Procedure Version # Las t Updat e d: 10/12/2015 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/M S) or another equa lly sens it ive and reliable methodology.

10 All conf irmat ory tests will be performed by a laboratory certified by the federal Substance Abuse and Mental Health Se r vic e s A dminis tr a tion (SAMHSA) for federal workplace TESTING . pfizer currently requires 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 (P CP ), barbiturates, and benzodiazepines (including Valium and Xanax). B. EMPLOYMENT AND EDUCATIONAL HISTORY VERIFICATION P fizer requires verification of personal identity, employment and educational history for all Contingent Workers.