קראו: נחשף – התוכן המלא של ההסכם בין משרד הבריאות לחברת פייזר העולמית

משרד הבריאות העלה לפני שעות אחדות את ההסכם המלא בין המשרד לחברת פייזר העולמית לאתר המשרד עם השחרה של מספר קטעים הנוגעים לנושאים מסחריים.

במשרד ציינו כי המסמך פורסם בהסכמת חברת פייזר וכאן בפורטל כיף העתקנו עבורכם בצורה קריאה את תוכן המסמך שהובא באתר משרד הבריאות.

נציין שנמתחה ביקורת רבה על ההסכם בין מדינת ישראל לחברת פייזר, אולם בהעלאת המסמך ניתן להבין שבמשרד הבריאות ובחברת פייזר העולמית מוכנים לשקיפות מול הציבור בנושא שיתוף המידע מישראל עם הנהלת החברה.

הנה לפניכם התוכן המלא של המסמך שנחתם בין מדינת ישראל לחברת פייזר העולמית:

REAL-WORLD EPIDEMIOLOGICAL EVIDENCE
COLLABORATION AGREEMENT
This REAL-WORLD EPIDEMIOLOGICAL EVIDENCE COLLABORATION AGREEMENT

dated as of January 6, 2021 (this “Agreement”) by and between the Israeli Ministry of Health, acting on
its own behalf and on behalf of the State of Israel (the “MoH”), and Pfizer Inc., a Delaware corporation
(together with its Affiliates, “PFIZER”) (each, a “Party” and, collectively, the “Parties”).

WHEREAS, PFIZER and BioNTech SE, a company organized and existing under the laws of
Germany are collaborating to develop a vaccine to address the global COVID-19 pandemic; and
WHEREAS, the Parties had previously entered into the confidential Manufacturing and Supply
Agreement dated (the “Manufacturing and Supply Agreement”), under which MoH

agreed to purchase the Product (as defined below) and PFIZER agreed to manufacture and supply the
Product, all in accordance with the terms of the Manufacturing and Supply Agreement, and subject to
certain conditions precedent, including but not limited to certain regulatory approvals and supply
availability; and

WHEREAS, under Section 2.1(f) of the Manufacturing and Supply agreement, the Parties agreed
to cooperate on a reasonable basis to share information and data regarding the distribution, administration
and use of the Product, including to track its benefits; and

WHEREAS, PFIZER has obtained certain conditional approvals for the Product, including under
Regulation 29(a)(9) of the Israeli Pharmacist Regulations (Medical Preparations), 1986, as amended, and
analogous emergency use authorizations in other jurisdictions; and

WHEREAS, the Parties agree that it would be highly beneficial from a public health perspective to
track pandemic data in accordance with vaccination compliance in a Real-World context to evaluate
whether herd immunity protection is observed during the Product vaccination program rollout.
NOW THEREFORE, for and in consideration of the premises and mutual covenants and

agreements contained herein and for other good and valuable consideration, the receipt and sufficiency of
which are hereby acknowledged, the Parties hereto intending to be legally bound, hereby agree as follows:

1. DEFINITIONS
The following terms shall have the meanings assigned to them for all purposes of the Agreement.
1.1 “Affiliate” means, with respect to each Party or, if applicable, BioNTech, any
corporation, firm, partnership or other entity or person which directly or indirectly controls or is controlled
by or is under common control with the named Party, including but not limited to Pfizer US, or, if
applicable, BioNTech. For purposes of this definition, “control” (including, with correlative meaning, the
terms “controlled by” and “under common control with”) shall be presumed to exist if one of the following
conditions is met: (a) in the case of corporate entities, direct or indirect ownership of at least fifty percent
(50%) of the stock or shares having the right to vote for the election of directors of such corporate entity or
any direct or indirect parent of such corporate entity, and (b) in the case of non-corporate entities, direct or
indirect ownership of at least fifty percent (50%) of the equity interest with the power to direct the
management and policies of such non-corporate entities.

1.2 “Global Trade Control Laws” means the U.S. Export Administration Regulations; the
U.S. International Traffic in Arms Regulations; the U.S. economic sanctions rules and regulations
implemented under statutory authority and/or the President's Executive Orders and administered by the U.S.
Department of the Treasury Office of Foreign Assets Control; European Union (E.U.) Council Regulations
on export controls, including Nos.428/2009, 267/2012; other E.U. Council sanctions regulations, as
implemented in E.U. Member States; United Nations sanctions policies; all relevant regulations and
legislative instruments made under any of the above; other relevant economic sanctions, export and import
control laws, and other laws, regulations, legislation, orders and requirements imposed by a relevant
governmental entity.

1.3 “Identifiable Health Information” means health information, as such term is defined in
the Israeli Patient’s Rights Law, which contains details that identify an individual without cross referring
to additional information, or health information which does not contain details that identify an individual
but that may result in the identification of an individual by either using reasonable means or other
information which is available to the general public.

1.4 “Intellectual Property” means on a worldwide basis any and all (a) patents, applications
for patents (including, without limitation, divisions, continuations, continuations-in-part and reexamination
applications) and any renewals, extensions or reissues thereof; (b) trademarks, service marks, whether or
not registered, copyrights and registrations or applications for registration of copyrights, rights associated
with works of authorship, including copyrights, moral rights and mask-works; (c) designs, algorithms and
other industrial property rights; (d) computer software, including, without limitation, source code, operating
systems and specifications, documentation and other written materials related thereto; (e) trade secret rights;
(f) data; (g) other ideas, inventions (whether or not patentable), methods, research information and knowhow; (h) reagents, kits, chips, microarrays, instrumentation, devices used for genetic tests, compositions,
methods, markers and method to direct treatment; (i) other intellectual and industrial property rights of
every kind and nature, however designated, whether arising by operation of law, contract, license or
otherwise; and (j) registrations, applications, renewals, extensions, continuations, divisions or reissues
thereof now or hereafter in force (including, without limitation, any rights in any of the foregoing).

1.5 “Pfizer Data” means aggregated information about the Product in other jurisdictions in
the world, which may include scientific, safety and efficacy information collected by PFIZER as may be
useful to serve the Project's objectives which will be provided by PFIZER to the MoH subject to applicable
legal requirements and based on PFIZER’s reasonable determination.

1.6 “Product” means all vaccines manufactured in whole or in part, or supplied, directly or
indirectly, by or on behalf of PFIZER or BioNTech or any of their Affiliates pursuant to the Manufacturing
and Supply Agreement that are intended for the prevention of the human disease COVID-19 or any other
human disease, in each case which is cause by any of the virus SARS-CoV-2 and/or any or all related
strains, mutation, modifications or derivatives of the foregoing.

1.7 “Project” means the COVID-19 Real-World epidemiological data analyses conducted by
the Parties involving data collected during the MoH’s vaccination program using the Product, as described
in Section 2 and Exhibit A of this Agreement, including components thereof and enhancements thereto,
developed and implemented by the Parties under the terms of this Agreement.

1.8 “Project Data” means any de-identified data provided by the MoH to PFIZER in the
framework of the Project.

1.9 “Regulatory Requirements” The requirements of all applicable national, regional, and
local laws and regulations and court rulings and consent decrees and all requirements, guidelines, policies
and orders of all governmental bodies or agencies having jurisdiction over each of the Parties and their
respective employees and agents with respect to activities taken under this Agreement. Regulatory
Requirements include, but are not limited to, the following:
a) the Israeli Patient’s Rights Law, 1996, as amended;

4.2.4 in the event of a catastrophe, such as severe patient safety issue with the Product
resulting in a recall of the Product, requiring early termination of the Project;
4.2.5 in the event of a material breach of this Agreement, the Party alleging such breach
gives written notice thereof to the other Party and such Party fails to cure the breach
within thirty (30) days of such written notice;
4.2.6 either (i) any law, rule or regulation is amended or promulgated, or any new
interpretation is made or given of any law, rule or regulation or (ii) any legal action,
including any investigation, is commenced by a governmental agency against
either of the Parties hereto or their Affiliates which in the case of either (i) or (ii),
(x) can reasonably be expected to have a material adverse effect on such Party’s
ability to fulfill its obligations under this Agreement or (y) renders illegal or
unenforceable material obligations of the other Party under this Agreement;
provided, however, that at least 30 days prior to giving notice of termination, the
terminating Party has notified the other Party of its intention to give such notice of
termination and has made reasonable efforts to work with the other Party to modify
this Agreement so as to preserve its essential purpose while at the same time
making the effect of the event specified in clause (i) or (ii) of this Section 4.2(d)
not materially adverse to the terminating Party or any of its Affiliates;
4.2.7 either Party may terminate this Agreement if the other Party breaches any of the
Representations and Warranties contained in this Agreement.

4.3 Effect of Termination.
Except as set forth in the next sentence, termination of this Agreement pursuant to Section 4.2 shall
terminate all obligations and liabilities of the Parties hereunder (or with respect to the individual Project
being terminated, as applicable) except for obligations and liabilities previously accrued. Sections 5, 6, 7,
and 8 shall survive any termination of this Agreement. For the avoidance of doubt, Pfizer is not obligated
to return or destroy Project Data or Results, including after termination of this Agreement.
5. CONFIDENTIALITY
5.1 “Confidential Information” means, other than Exempt Information (defined below), any
and all information, in whatever form or manner presented, and (a) relates to a Party’s business/operations
or plans thereof, technology, research, finances, or any other confidential or proprietary information that
PFIZER or MoH, may disclose through their employees or consultants under this Agreement to the other
Party; (b) is or contains Identifiable Health Information; (c) Pfizer Data; or (d) is Project Data or Results,
unless such Project Data or Results, in the case of Project Data or Results prepared or compiled by MoH,
is considered public health data. “Exempt Information” means information that the receiving Party can
demonstrate (a) was lawfully in its possession prior to the time of disclosure; (b) is or becomes public
knowledge through no fault, omission, or other act of the receiving Party; (c) is obtained from a third Party
lawfully entitled to possession of such information and under no obligation of confidentiality to the
disclosing Party; or (d) was independently collected or developed by or for the receiving Party without
violating the terms of this Agreement. MoH is entitled to publicly disclose this Agreement, subject to
reasonable redaction of any Confidential Information, to be agreed upon by the Parties.

5.2 The Parties, and each of its employees, agents, subcontractors, affiliates and other
representatives (“Representatives”), shall not, either during or after the term of this Agreement disclose any
Confidential Information to any third Party without the approval of the disclosing Party; or (b) use
Confidential Information for its own benefit or advantage, other than in the performance of this Agreement.

7.3 Each Party covenants that all materials, work product and documentation created pursuant
to this Agreement shall not infringe upon any patent, copyright or other intellectual property rights of any
third party.
7.4 Each Party covenants, represents and warrants to the other Party that such Party is not
debarred by any applicable authority, including under subsections 306(a) or (b) of the federal Food, Drug,
and Cosmetic Act, as amended, is not on the U.S. Government Suspension and Debarment List; HHS OIG
Excluded Parties List; or any similar disqualification lists, licensure restrictions, disciplinary sanctions, or
enforcement action against scientists, health care providers, or research professionals under the laws of
Israel, the U.S. or any other jurisdiction and it has not and shall not use in any capacity the services of any
person or entity, including any individuals, agents, employees, subcontractors, customers, healthcare
providers, hospitals, pharmacies, clinics and any other relevant party that is involved, directly or indirectly,
in the activities under this Agreement, that has been debarred by any such applicable authority with respect
to this Agreement. Such Party shall immediately notify the other Parties in the event that it, its
subcontractors or any of its or their employees becomes debarred or excluded during the Term of this
Agreement. Such Party acknowledges that such debarment shall be grounds for termination of this
Agreement by the other Parties for cause.

7.5 Each Party represents and warrants that the services performed under this Agreement do
not and will not involve the counseling or promotion of a business arrangement or other activity that violates
applicable law. Each Party further represents and warrants that it has not and will not in the future directly
or indirectly offer or pay, or authorize the offer or payment, of any money or anything of value in an effort
to influence any government official or any other person in order for Pfizer to improperly obtain or retain
business or to gain an improper business advantage, and, has not accepted, and will not accept in the future,
such a payment. Each party further represents and warrants that MOH has been provided with a copy of
Pfizer’s International Anti-Bribery and Anti-Corruption Principles (attached hereto as Exhibit C) and will
communicate such principles to all persons acting on its behalf in connection with the Project, including
agents or subcontractors. For the avoidance of doubt, nothing in this Agreement shall be construed to (a)
obligate MoH to grant regulatory approval, promote, prescribe, purchase, order or recommend, or arrange
for the promotion, prescription, purchase, order or recommendation of any products manufactured and/or
marketed by PFIZER, or (b) obligate MoH to place any products manufactured and/or marketed by PFIZER
on MoH’s formularies (e.g., formularies MoH operates or maintains on behalf of itself) or third parties
(such as sick funds) formularies.

7.6 Each Party represents and warrants the services and any transfers of value provided by the
respective Party, are in no way based upon the value or volume of purchases or business between the Parties.
7.7 Compliance with Global Trade Controls: The activities covered by this Agreement may
be subject to Global Trade Control Laws. Parties will perform their respective obligations under this
Agreement in full compliance with all applicable Global Trade Control Laws.
7.7.1 Each Party represents and warrants that such party and its respective owners,
directors, and officers are neither a Restricted Party, nor owned or controlled by a
Restricted Party. With respect to the activities performed under this Agreement,
each Party confirms that Affiliates, agents, employees, or subcontractors directly
or indirectly involved in the activities contemplated under this Agreement are not
Restricted Parties and that no such Restricted Parties will be engaged in any
activities contemplated under this Agreement or delegated any activities
contemplated under this Agreement. In the event that any of these representations
change during the Term of this Agreement, the Party connected with such a person
or entity will immediately inform the other Party and suspend all related activities
and payments under this Agreement until the Parties agree to move forward.

specified in Section 2.1, to the public on a regular basis or as required for public
health reasons and according to Israeli laws, or prevent MoH from possessing and
analyzing such data, independent of this agreement and making publications
thereof. Nothing in this Agreement shall prevent PFIZER from making
publications using publicly available data. All publications involving the Project,
will acknowledge the role of MoH and Pfizer in the Project.

Without derogating from the generality of the above, to the extent that PFIZER
and MoH cannot agree on a joint publication within a reasonable time, or to the
extent that PFIZER or the MoH wishes to make further publications of data and
results from this Agreement other than a joint publication, each Party will provide
to the other Party with a copy of the publication days prior to the date
of submission for publication or of public disclosure to review such material.
During its review period, the other Party may provide input, make factual
corrections, and request the deletion of any reference to the other Party’s
Confidential Information from the proposed disclosure or publication. All
disclosures and publications must expressly acknowledge the other Party, unless
such Party objects to such acknowledgment. To the extent the Parties cannot
resolve disputes regarding publications they shall escalate such matters to a good
faith discussion between PFIZER’s and
Sharon Alroy-Preis, MD, MPH, MBA.

9.2 Publicity.
9.2.1 The Parties will issue a press release or public announcement, either joint or
solo (as agreed), about this Agreement, including, information regarding the
Project, it's terms and time after the Effective Date; once content of such an
announcement is mutually agreed upon. All other public announcements (e.g.,
press releases) about this Agreement shall be mutually agreed upon and issued
at a time mutually agreed by the Parties, except to the extent disclosures are
required by law or necessary to respond to requests of state or federal
regulators. Timely written notice shall be provided to the other Party if a Party
is required to make such disclosures. During the course of this Agreement, if
either Party desires to make a public announcement about this Agreement or
the program, such Party shall give reasonable prior advance notice, but in no
event less than days notice, of the proposed text to the other Party
for its prior review and approval.
9.2.2 Except as authorized in this Section, neither Party shall use the corporate or
product name or logo of the other Party in any presentation, including
publications, news releases, promotional materials, advertisement, or other
public announcement, whether written or oral, without the prior written
approval of the other Party.

10. GENERAL
10.1 Relationship of the Parties. PFIZER and MoH acknowledge and agree that nothing herein
contained is intended to constitute them as employer/employee, joint ventures or partners, it being their
intention that each Party shall have an independent relationship with the other Party. PFIZER and MoH
acknowledge and agree that the personnel employed by each Party in connection with any work to be
performed pursuant to this Agreement shall remain at all times employees or hired consultants of such
Party, and such Party shall remain solely liable for all aspects of the employment of such persons including,

[THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK]

Exhibit A
MoH and PFIZER will collaborate on analyses of the data points listed in this Exhibit A. MoH will
provide PFIZER with the data specified in Exhibit B.
Endpoints (beginning and ending dates to be mutually agreed by the Parties)
• Confirmed COVID-19 cases/week
• Confirmed COVID-19 hospitalizations/week
• Confirmed COVID-19 severe/ critical cases /week
• Confirmed COVID-19 ventilator use/week
• Confirmed COVID-19 deaths/week
• Symptomatic cases/week
• Weekly numbers of vaccinees, as total and by age and other demographic subgroups.
• Number of cases per week by age groups, and other demographic factors.
• Additional subgroup analyses and vaccine effectiveness analyses, as agreed by the Parties
Additional potential analyses:
• Direct medical costs averted based on modeled impact of national vaccination program on
outpatient visits, hospitalizations, ICU admissions, etc.
Exhibit B
DATA TRANSFER REQUIREMENTS
MoH will transmit to PFIZER in electronic form aggregate pandemic data as described in this
Exhibit. MoH will use a mutually agreeable electronic transmission method that protects the
security and integrity of the data.

1. STATUS REPORTS
MoH will provide to PFIZER weekly data transfers that include the following information:
1.1 Epidemiological Data
Each data transfer will include, at a minimum, current counts of the following:
• Confirmed COVID-19 cases/week
• Confirmed COVID-19 hospitalizations/week
• Confirmed COVID-19 severe/ critical cases /week
• Confirmed COVID-19 ventilator use/week
• Confirmed COVID-19 deaths/week
• Symptomatic cases/week
• Weekly numbers of vaccinees, as total and by age and other demographic subgroups.
• Number of cases per week by age groups, and other demographic factors.
2. ANCILLARY DOCUMENTS
Both parties will provide to each other as needed the following Ancillary Documents:
2.1 If relevant an electronic “Data Dictionary” consisting of all data variables used, annotated with
variable names and corresponding datasets;
2.2 documentation of statistical programming algorithms used to create the analysis datasets,
methodologies used to convert source data into output (derived) data; and relevant statistical
analysis assumptions or plans; if needed to understand the datasets (e.g., Statistical Analysis
Plan, List of Tables, programming plan);
2.3 any other documentation as may reasonably be requested by either party and mutually agreed
upon by both parties.
2.4 Transfer Schedule.
MoH will transfer aggregate epidemiological data to PFIZER: (i) weekly; (ii) at the end of 1
year for any residual data both parties mutually agreed upon and other frequency mutually
agreed upon. MoH will work with PFIZER if changes are needed in the data formatting or
transmission process to ensure data quality and usability. Analysis of the data associated with
the vaccination project will be independently or jointly performed by MOH and Pfizer and
shared with the other Party. Any analysis/results Pfizer may perform will be shared with the
MOH to discuss and finalize jointly.
Exhibit C
PFIZER’S INTERNATIONAL ANTI-BRIBERY AND ANTI-CORRUPTION PRINCIPLES
1. Pfizer’s Policy
Pfizer has a long-standing policy forbidding bribery and corruption in the conduct of our business
in the United States or abroad. Pfizer is committed to performing business with integrity, and
acting ethically and legally in accordance with all applicable laws and regulations. Pfizer expects
the same commitment from the collaborators, consultants, agents, representatives or other
companies and individuals acting on Pfizer’s behalf (“Business Associates”), as well as those
acting on behalf of Business Associates (e.g., Subcontractors), in connection with work for Pfizer.

2. Bribery of Government Officials
Most countries have laws that forbid making, offering or promising any payment or anything of
value (directly or indirectly) to a Government Official when the payment is intended to influence
an official act or decision to award or retain business. “Government Official” will be interpreted
broadly and means: (a) any elected or appointed Government official (e.g., a legislator or a member
of a Government ministry); (b) any employee or individual acting for or on behalf of a Government
Official, agency or enterprise performing a governmental function, or owned or controlled by, a
Government (e.g., a health care professional employed by a Government hospital or researcher
employed by a Government university); (c) any political party officer, candidate for public office,
officer, or employee or individual acting for or on behalf of a political party or candidate for public
office; (d) any employee or individual acting for or on behalf of a public international organization;
(e) any member of a royal family or member of the military; and (f) any individual otherwise
categorized as a Government Official under law. “Government” means all levels and subdivisions
of Governments (i.e., local, regional or national and administrative, legislative or executive).
Because the definition of Government Official is so broad, it is likely that Business Associates will
interact with a Government Official in the ordinary course of their business on behalf of Pfizer.
For example, doctors employed by Government-owned hospitals are considered Government
Officials.
3. The FCPA
The U.S. Foreign Corrupt Practices Act (the “FCPA”) prohibits making, promising or authorizing
a payment or providing anything of value to a non-U.S. Government Official to improperly or
corruptly influence that official to perform any governmental act or make a decision to assist a
company in obtaining or retaining business, or to otherwise gain an improper advantage. The FCPA
also prohibits a company or person from using another company or individual to engage in any
such activities. As a U.S. company, Pfizer must comply with the FCPA and could be held liable
as a result of acts committed anywhere in the world by a Business Associate.
4. Anti-Bribery and Anti-Corruption Principles Governing Interactions with Governments and
Government Officials
Business Associates must communicate and abide by the following principles with regard to their
interactions with Governments and Government Officials:

4.1 Business Associates, and those acting on their behalf in connection with work for Pfizer, may not
directly or indirectly make, promise or authorize the making of a corrupt payment or provide
anything of value to any Government Official to induce that Government Official to perform any
governmental act or make a decision to help Pfizer obtain or retain business. Business Associates,
and those acting on their behalf in connection with work for Pfizer, may never make a payment or
offer any item or benefit to a Government Official, regardless of value, as an improper incentive
for such Government Official to approve, reimburse, prescribe, or purchase a Pfizer product, to
influence the outcome of a clinical trial, or to otherwise benefit Pfizer’s business activities
improperly.

4.2 In conducting their Pfizer-related activities, Business Associates, and those acting on their behalf
in connection with work for Pfizer, must understand and comply with any local laws, regulations
or operating procedures (including requirements of Government entities, such as Governmentowned hospitals or research institutions) that impose limits, restrictions or disclosure obligations
on compensation, financial support, donations or gifts that may be provided to Government
Officials. If a Business Associate is uncertain as to the meaning or applicability of any identified
limits, restrictions or disclosure requirements with respect to interactions with Government
Officials, that Business Associate should consult with his or her primary Pfizer contact before
engaging in such interactions.
4.3 Business Associates, and those acting on their behalf in connection with work for Pfizer, are not
permitted to offer facilitation payments. A “facilitation payment” is a nominal payment to a
Government Official for the purpose of securing or expediting the performance of a routine, nondiscretionary governmental action. Examples of facilitation payments include payments to
expedite the processing of licenses, permits or visas for which all paperwork is in order. In the
event that a Business Associate, or someone acting on their behalf in connection with work for
Pfizer, receives or becomes aware of a request or demand for a facilitation payment or bribe in
connection with work for Pfizer, the Business Associate will report such request or demand
promptly to his or her primary Pfizer contact before taking any further action.
5. Commercial Bribery
Bribery and corruption also can occur in non-Government, business to business relationships. Most
countries have laws that prohibit offering, promising, giving, requesting, receiving, accepting or
agreeing to accept money or anything of value in exchange for an improper business advantage.
Examples of prohibited conduct include, but are not limited to, providing expensive gifts, lavish
hospitality, kickbacks or investment opportunities to induce improperly the purchase of goods or
services. Pfizer colleagues are not permitted to offer, give, solicit or accept bribes, and we expect
our Business Associates, and those acting on their behalf in connection with work for Pfizer, to
abide by the same principles.

6. Anti-Bribery and Anti-Corruption Principles Governing Interactions with Private Parties
and Pfizer Colleagues
Business Associates must communicate and abide by the following principles with regard to their
interactions with private parties and Pfizer colleagues:

6.1 Business Associates, and those acting on their behalf in connection with work for Pfizer, may not
directly or indirectly make, promise or authorize a corrupt payment or provide anything of value to
any person to influence that person to provide an unlawful business advantage for Pfizer.

6.2 Business Associates, and those acting on their behalf in connection with work for Pfizer, may not
directly or indirectly, solicit, agree to accept or receive a payment or anything of value as an
improper incentive in connection with their business activities performed for Pfizer.

6.3 Pfizer colleagues are not permitted to receive gifts, services, perks, entertainment or other items of
more than token or nominal monetary value from Business Associates, and those acting on their
behalf in connection with work for Pfizer. Moreover, gifts of nominal value are permitted only if
they are received on an infrequent basis and only at appropriate gift-giving occasions.

7. Reporting Suspected or Actual Violations
7.1 Business Associates, and those acting on their behalf in connection with work for Pfizer, are
expected to raise concerns related to potential violations of these International Anti-Bribery and
Anti-Corruption Business Principles or the law. Such reports can be made to a Business
Associate’s primary point of contact at Pfizer or, if a Business Associate prefers, to Pfizer’s
Compliance Group by e-mail at corporate.compliance@pfizer.com or by phone at 1-212-733-3026.