Pfizer Ltd. — Regulatory Filings 2020

May 27, 2020

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Limited

The Capital, 1802 / 1901, Plot No. C - 70, G Block, Bandra Kurla Complex, Bandra (East), Mumbai 400 051. Tel : +91 22 6693 2000 Fax : +91 22 2654 0274

May 27, 2020

The Corporate Relationship Dept. The Manager, Listing Dept. BSE Limited The National Stock Exchange of India Ltd. 1[st] Floor, P.J.Towers Exchange Plaza, 5[th] Floor, Dalal Street, Fort Plot No. C/1, G Block Mumbai – 400 001 Bandra-Kurla Complex, Bandra (E) Scrip Code: 500680 Mumbai – 400 051 Scrip Symbol: PFIZER

Dear Sirs,

Sub: Compliance under Regulation 24(A) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015

(Listing Obligations and Disclosure Requirements) Regulations, 2015, please find enclosed, Secretarial Compliance Report for the year ended March 31, 2020, issued by Mr. K. G. Saraf, Practicing Company Secretary.

We request you to kindly take the above on record.

Thanking you,

Yours truly,

For Pfizer Limited

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Prajeet Nair Company Secretary

CIN: L24231MH1950PLC008311 contactus.india@pfizer.com

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Secretarial Compliance Report of Pfizer Limited For the Financial Year Ended 31[st] March 2020 (Pursuant to SEBI- CIR/CFD/CMD/1/27/2019 Dated February 8, 2019)

I Mr. K.G. Saraf, Practicing Company Secretary (FCS No. 1596, Certificate of Practice No. 642) have examined:

• (a) all the documents and records made available to us and explanation provided by Pfizer Limited ("the listed entity"),

• (b) the filings/ submissions made by the listed entity to the stock exchanges,

• (c) website of the listed entity, (d) any other document/ filing, as may be relevant, which has been relied upon to make this certification,

for the year ended 31[st] March 2020 ("Review Period") in respect of compliance with the provisions

of:

• (a) the Securities and Exchange Board of India Act, 1992 ("SEBI Act") and the Regulations, circulars, guidelines issued thereunder; and

• (b) the Securities Contracts (Regulation) Act, 1956 ("SCRA"), rules made thereunder and the Regulations, circulars, guidelines issued thereunder by the Securities and Exchange Board of India ("SEBI");

The specific Regulations, whose provisions and the circulars/ guidelines issued thereunder, have been examined, include:-

• (a) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015;

• (b) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018; (Not applicable for the period under review )

• (c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;

• (d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; (Not applicable for the period under review )

• (e) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014; (Not applicable for the period under review )

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� Saraf and Associates (Company Secretaries)

Secretarial Compliance Report – Pfizer Limited 2020

• (f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008; (Not applicable for the period under review )

• (g) Securities and Exchange Board of India (Issue and Listing of Non-Convertible and Redeemable Preference Shares) Regulations,2013; (Not applicable for the period under review )

• (h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;

• and Circulars / Guidelines issued thereunder.

and based on the above examination, I hereby report that, during the Review Period:

• (a) The listed entity has complied with the provisions of the above Regulations and circulars/ guidelines issued thereunder

• (b) The listed entity has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued thereunder insofar as it appears from my/our examination of those records.

• (c) There were no actions taken against the listed entity/ its promoters/ directors/ material subsidiaries either by SEBI or by Stock Exchanges ( including under the Standard Operating Procedures issued by SEBI through various circulars) under the aforesaid Acts/ Regulations and circulars/ guidelines issued thereunder in so far as it appears from my examination of those records.

• (d) There were no items for which the listed entity was ought to have taken any actions to comply with the observations made in previous reports:

Further, in terms of SEBI circular No. CIR/CFD/CMD1/114/2019 dated October 18, 2019 in respect of Resignation of statutory auditors from listed entities and their material subsidiaries, the listed entity has suitably modified the terms of appointment of the auditor to give effect to clause 6(A) and 6(B) of the circular.

Place : Mumbai Saraf and Associates Date : 27.05.2020 (Practising Company Secretaries) Digitally signed by KAMALAX GANAPAYYA SARAF FRN : S1988MH004801 KAMALAX DN: c=IN, o=Personal, 2.5.4.20=c2318f76e272bdb5413b5135d4be18b009d4 8d182b57b30d3d68329bb6e851c1, UDIN : F001596B000285847 GANAPAYYA postalCode=400022, st=MAHARASHTRA, serialNumber=7c9055b2251292cc41585dcf82a2295f1 b7a6a899e7e1e46404788fdd514fba3, cn=KAMALAX SARAF GANAPAYYA SARAF Date: 2020.05.27 13:38:02 +05'30' K.G.Saraf Proprietor FCS 1596 : CP 642

2 Saraf and Associates (Company Secretaries)