PFIZER CORPORATE COMPLIANCE PROGRAMS

Pfizer's corporate compliance program expects all colleagues to take ownership of our compliance practices and training. We offer a summary of these written guidelines in our Orange (field guide), Blue (Code of conduct) and White (Laws and regulations) guides.

Pfizer's Compliance Program represents a shared undertaking on the part of colleagues ranging from the highest levels of management to the most junior employees. Our training programs and organizational structures have been developed to go beyond compliance. All colleagues are expected to take ownership of compliance and to perform all tasks with integrity. We continuously scrutinize our internal practices and have put into place procedures for taking immediate action when we identify potential violations. We offer a Compliance Helpline, an Open Door Policy, and anti-retaliation protections.

Colleagues at Pfizer have an additional resource for addressing and resolving work-related concerns--Pfizer’s Office of the Ombudsman. Pfizer’s Office of the Ombudsman offers a place where colleagues at any level can get information and guidance to help them address and resolve work-related issues. Pfizer’s Ombudsman is informal, independent and neutral, and is not an advocate for any party, but an advocate for fair process.

Our Compliance Program incorporates the elements of an effective compliance program in accordance with the “Compliance Program Guidance for Pharmaceutical Manufacturers” (“OIG Guidance”), developed by the United States Department of Health and Human Services, Office of Inspector General (“OIG”).

Written Policies and Procedures

Some of the policies that provide our colleagues with guidance around their conduct of day-to-day operations include the following: