What are key considerations in preparing a COVID-19 vaccine policy for a multinational non-healthcare, non-critical infrastructure employer?

With COVID-19 vaccines beginning to become available, multinational companies should understand the safety and efficacy of the various vaccines that are or will be available in countries where they operate and any relevant laws and regulations regarding vaccinations. These regulations or requirements may vary regarding who is eligible, whether vaccination can be mandated, whether vaccination is provided by local public health authorities or private entities, and whether an employer can directly vaccinate its employees.  Current information about vaccination by country is available.1 Companies should develop education and communication programs including an explanation of how vaccines work and that encourage vaccination. These programs should also explain why public health measures need to continue even once vaccinations have been administered. Organizations should maintain policies that support work from home and paid sick leave, along with facemask use, handwashing, and physical distancing.

The following elements should be included in a vaccine policy for a multinational non-healthcare, non-critical infrastructure employer:

Educate employees on the benefits of vaccination: Address how vaccines work, safety and efficacy of vaccines, concerns and myths.

Continuing infection control measures: Address the need for all employees, whether vaccinated or not, to continue to wear facemasks, and maintain physical distance at work and in their personal lives until it is determined that it is safe to discontinue these requirements. Similarly, handwashing and disinfection need to continue.

Access to vaccines: Provide information on when and how employees will be able to access vaccines. While the process will vary by country, most will likely adopt an approach similar to the US with the vaccine becoming available in phases.2 Initially vaccines will be made available for healthcare workers and residents of long-term care facilities, after which essential workers and those over age 75 would be eligible. Workers for non-healthcare, non-critical infrastructure employers would then be eligible for vaccination, beginning with persons aged 65-74 years, and those aged 16-64 with high-risk medical conditions. This would be followed by all persons aged ≥16 years not previously recommended for vaccination.3

Determine whether the company will become a point of distribution (POD) for vaccines: If so, communications and procedures need to be developed.

Ensure that cost is not a barrier to vaccination: While an increasing number of countries have indicated that vaccines will be available at no cost, companies should provide coverage for vaccines in countries in which they operate where it is not free.

Requirements for travel: As business travel resumes, some countries may require proof of immunization. Determine how the employer can assist business travelers in procuring the necessary documentation or vaccine passport. Determine how employees who have not been vaccinated but are required to travel for their job will be accommodated.

Voluntary or Mandatory: Determine whether vaccination will be strongly encouraged and voluntary or mandated for any part of the workforce. If mandatory vaccination is considered, there should be a full understanding of the relevant laws and regulations, as well as whether any collective bargaining agreements are in place.4,5 In the US, the EEOC updated their guidance on December 16, 2020 to indicate that mandatory vaccination is permissible with the caveat that reasonable accommodations must be available for qualified employees (including employees with disabilities and with religious objections).

Determine if vaccination will be incentivized: Some organizations may consider this option instead of mandating vaccination.

Tracking: Determine if vaccination status will be tracked and develop procedures.

Encourage Influenza Vaccination: Workers should continue to be encouraged to get vaccinated for influenza during the appropriate season based on geography. 

Be Context Sensitive: Coordinate with local clinical and public health authorities in countries where vaccination is not generally available. Be prepared to explain any social inequity in which corporate employees are vaccinated when only limited supplies are available for community members. WHO addresses issues of social equity regarding access to vaccination.7

Educate and motivate supervisors and managers:
Complement individual worker oriented education with incentives for managers to permit and encourage vaccination (e.g., encourage paid time off for vaccination or any potential short term complications).

Periodic Updates: The plan should be reviewed and updated regularly as this is a rapidly changing topic.


  1. Coronavirus (COVID-19) Vaccinations, https://ourworldindata.org/covid-vaccinations 
  2. CDC, COVID-19 Vaccination Program Interim Playbook for Jurisdiction Operations, Version 2.0, October 29, 2020, https://www.cdc.gov/vaccines/imz-managers/downloads/Covid-19-Vaccination-Program-Interim_Playbook.pdf 
  3. Dooling K, Marin M, Wallace M, et al. The Advisory Committee on Immunization Practices’ Updated Interim Recommendation for Allocation of COVID-19 Vaccine — United States, December 2020, MMWR Morb Mortal Wkly Rep. ePub: 22 December 2020. DOI: 
  4. Flood ZJ, Mandatory COVID-19 Vaccination In Employment, National Law Review, Volume X, Number 358, December 7, 2020. https://www.natlawreview.com/article/mandatory-covid-19-vaccination-employment
  5. Legal and Practical Considerations for Employers Weighing COVID-19 Vaccination as a Condition of Continued Employment, https://www.jonesday.com/en/insights/2020/12/legal-and-practical-considerations-for-employers-weighing-covid19-vaccination 
  6. EEOC. What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws: Technical Assistance Questions and Answers - Updated on Dec. 16, 2020, Section K. https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws
  7. COVAX: Working for Global Equitable Access to COVID-19 Vaccines, https://www.who.int/initiatives/act-accelerator/covax

Return to Forum

The Forum does not necessarily represent an official ACOEM position. The Forum is intended for health professionals and is not intended to provide medical or legal advice, including illness prevention, diagnosis or treatment, or regulatory compliance. Such advice should be obtained directly from a physician and/or attorney. Questions are answered with the best available data or recommendations at the time.