Standards of Business Conduct the Promise of the Golden Arches

Standards of Business Conduct The Promise of the Golden Arches

“The basis for our entire business is that we are ethical, truthful and dependable.” “The basis for our entire business is that we are ethical, truthful and dependable. It takes time to build a reputation. We are not promoters. We are business people with a solid, permanent, constructive ethical program that will be in style…years from now even more than it is today.” — Ray Kroc, 1958

2 Standards of Business Conduct 3 McDonald’s Values

We place the customer experience at the core of all we do Our customers are the reason for our existence. We demonstrate our appreciation by providing

them with high quality food and superior service, in a clean, welcoming environment, at a great M c value. Our goal is QSC&V for each and every customer, each and every time. d ’ s Value Donal

We are committed to our people We provide opportunity, nurture talent, develop leaders and reward achievement. We believe that a team of well-trained individuals with diverse backgrounds and experiences, working together in an environment that fosters respect and s drives high levels of engagement, is essential to our continued success. We aspire to be our customers’ favourite We believe in the McDonald’s System McDonald’s business model, depicted by the place and way to eat. “three-legged stool” of owner/operators, suppliers, and company employees, is our foundation, and the To achieve this mission, balance of interests among the three groups is key. our actions as individuals and as a system must We operate our business ethically reflect our Values. Sound ethics is good business. At McDonald’s we hold ourselves and conduct our business to high standards of fairness, honesty, and integrity. We are individually accountable and collectively responsible.

We give back to our communities We take seriously the responsibilities that come with being a leader. We help our customers build better communities, support RMHC, and leverage our size, scope and resources to help make the world a better place.

We grow our business profitably McDonald’s is a publicly-traded company. As such, we work to provide sustained profitable growth for our shareholders. This requires a continuing focus on our customers and the health of our system.

We strive continually to improve We are a learning organization that aims to anticipate and respond to changing customer, employee and system needs through constant evolution and innovation.

4 Standards of Business Conduct 5 TABLE OF CONTENTS 7

ocial Responsibility Standards Environmental ResponsibilityNutrition and Well-BeingSustainable Supply Chain the Shine on our Arches Keeping People/Your Extended Team People/Your Network Extended Information Policies/Your Reporting Suspected Violations of the Community and Giving Back Community and Giving Back Activities Political Corporate S Antitrust Competition and Fair Practices Trade Inside Information and Securities Trading Communicating with the Public Government Inquiries Corporate Governance and Internal Controls Internal Investigations Reporting Concerns 35 44 Our Communities Our Communities 33 34 35 35 35 Growth Profitable 37 38 39 39 39 Continuous Improvement 41 41 42 Resources Additional 43 43 43 The relationship that exists between McDonald’s and each of its between McDonald’s and each relationship that exists The means that either party to employees is employment at will. This the employment relationship may terminate the relationship at any time for any reason, with or without cause or prior notice. Nothing in the Standards of Business Conduct creates any contractual rights between McDonald’s, its employees or any third party. McDonald’s reserves the right to determine how the Standards apply to any particular situation, and to amend or modify the Standards as appropriate without prior notice or agreement. applicability of any amendments or modifications to an The individual employee will depend on the circumstances and applicable law. 32 36 40 43 S ONTENT F C etter and Spirit of the Law and Friends Doing Business with Family Outside Employment and Gifts, Favours & BusinessOutside E ntertainmentInvestments O LE Acting in the Best Interest of the System Company Assets Protecting Conflicts of Interest Business Records and Communications L The International Business Anti-Bribery The Standards of Business Conduct The Applicability of Standards and Waivers Amendments Publication, Management Commitment of Additional Responsibilities Accountability Personal Business Integrity Line Quality and Safety Product Confidential Information Marketing Data Personal Against Retaliation Protection Human Rights and the Law Respect and Dignity Inclusion and Diversity Alcohol and Drugs 9 9 9 McDonald’s System Ethics Introduction Our Customers Our People 21 21 owner/Operator Relationships 22 supplier Relationships 25 26 26 26 27 28 28 electronic Communications Usage 29 10 10 10 11 open Communication/ 13 14 14 15 17 employment Experience 17 18 18 19 19 Workplace safe 19 30 30 30 other Business Arrangements 20 24 8 supervisory Employees 12 16 TAB

Standards of Business Conduct

6 INTRODUCTION 9 rs ct u d ive d Wa ss Con ne ards en an ts si d an dm t f Bu en f S ards o lity o on, Am d ti a abi an t lic b e S u Photo: Milan, Italy P the Standards of Business current version of The Conduct will be posted and Amendments will maintained on the McDonald’s website at www.mcdonalds.com. In the extremely unlikely also be posted on the website, as required by applicable law. event that a waiver of the Standards of Business Conduct for executive officers would it must be approved by the Audit Committee be in the best interests of the Company, Because the of McDonald’s Corporation, and disclosed promptly as required by law. the website for Standards of Business please check Conduct are revised periodically, the most recent version. Th Standards of BusinessThese Conduct and legal are a guide to the ethical a complete is not This family. share as members of the McDonald’s responsibilities we It is not a summary of all every ethical issue that might arise. rulebook that addresses is not a contract, and it does apply to McDonald’s business. It laws and policies that the Standards of Business Conduct Rather, not replace good judgment. give us right decisions. us to resources to help us make the guidance and direct Applic Standards of BusinessThese Conduct apply to employees of McDonald’s worldwide. Non-employee members Corporation and its majority-owned subsidiaries of McDonald’s Board for the of Directors must abide by the Code of Conduct Board is posted and maintained of Directors of McDonald’s Corporation, which at Standards do not apply to The the McDonald’s website at www.mcdonalds.com. of the as members employees. However, our owner/operators, suppliers or their to be aware of the Standards, to develop their McDonald’s System, we expect them consistent with the spirit of the Standards own policies and procedures that are shared complying with the Standards. This and to fully support our employees in earn our reputationcommitment will help ensure that we that conducts as a company business with integrity. ON UCTI OD TR N I

Standards of Business Conduct

8 INTRODUCTION 11 The McDonald’s Business Integrity Business McDonald’s The days a 7 Line is staffed a day, 24 hours week, 365 firm year by an outside days a calls. in handling sensitive experienced Phone 1-800-261-9827 the United within States. the U.S. if outside charges Reverse Callers may report Interpreters are available. and no attempt will be made to anonymously, know, identify them. Anonymous callers should it is sometimes more difficult to that however, raised anonymously. follow up on issues ne on/ ti a rity Li ic un mm o ss Integ c ou can also call the McDonald’s ne si open Bu and we speak honestly At McDonald’s, raise listen for understanding.openly and We even if they are difficult. questions or issues, violation of the Standards If you know of any of Business Conduct or of any applicable for reporting the you are responsible law, violation immediately. are a number of ways to raise issues. There law has been violated, If you believe that a lobal Compliance Office or consult with the G other For the Legal Department immediately. matters, you can talk to your direct supervisor contactor another member of management, or Human Resources or the Global Compliance Office. Y Business Integrity Line, a toll-free telephone calls on line reserved specifically for employee ethics and compliance issues. lity abi ount onal Acc rs e P actions of our of the world, each the rest To we must do our McDonald’s, and represents reputation times to uphold the best at all of our of us on each Our success depends Company. responsibility for doing the accepting personal obligation to stop accept the right thing. We that could harm customers, or prevent actions reputation,the System or McDonald’s and to occur. actions as soon as they report any such the law or the Employees who violate Standards of Business Conduct are subject to disciplinary action, up to and including termination of employment.

es .S. .S. U iti l ent s ployee Em mmitm egal department or the the or department egal L y y ent Co ffice, the employees can also also can employees the ffice, or rvis O m

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of Supervisors must maintain open and honest two-way communication with employees. means encouraging employees to ask This questions, make suggestions and report must follow supervisors wrongdoing. Finally, up on allegations of wrongdoing that are brought to their attention and take appropriate corrective or disciplinary action. Those employees who have supervisory employees who Those of trust authority over others are in positions they have special Therefore, and influence. responsibilities under the Standards of Business Conduct to sustain an ethical work environment and to lead by example. They report to must ensure that the employees who them understand and follow the Standards and ethics complete all required compliance and training. In addition, they must communicate relevant McDonald’s policies to employees and assist them in understanding policies. such Human Resources department for any help. Human Resources department for any Re sponsibi onal Additi oversees the Company’s commitment to ethics ethics to commitment Company’s the oversees help legal standards.and compliance with To up to our Standards ofour employees live established has BusinessMcDonald’s Conduct , This office is Office. the Global Compliance Company’s the overseeing for responsible other and Standards compliance with these Apart from the GlobalMcDonald’s policies. Compliance Company’s the contact McDonald’s management is committed to living management is McDonald’s The behaviour. ethical of standards high to up the in Directors of Board McDonald’s Manage Standards of Business Conduct

10 our customers 13

ety d Saf RS E reat tasting and safe food. Child-friendly Happy Meal Meal Happy Child-friendly safefood. and tasting reat G ployee OM m T Quality an ct u d’s e d o fellow employees.” fellow Walking the Talk Walking toys. These have long been hallmarks of McDonald’s, and fundamental have long been hallmarks of toys. These to promise. brand our beverages we serve to our to ensuring that the foods and McDonald’s is committed test and track customers are safe. working with our suppliers who monitor, means This to ensure the safety we have a comprehensive program ingredients. In addition, of items. Our safetyall toys and promotional and quality standardsfood, beverages, for all applicable government requirements. toys and promotional items meet or exceed consumers and ensure the safety support additional measures to help protect We of our responsibility as a good corporate view this as part of local food supplies. We to the continuing growth and profitabilitycitizen, and we know it is also essential of our business. employee to follow all applicable safetyIt is the responsibility of every McDonald’s of a Notify your manager if you become aware and hygiene policies and procedures. problem relating to the safety of our products. Pr restaurants. Clean every single day and “We are representing “We —McDonal the McDonald’s brand with every word, every R CUS R message that we give to our customers—and to our OU e r r e m o t e Co th

at e Cus e th c e en ac ri l e p p All We Dof All x We E o

Standards of Business Conduct

12 our customers 15 Miguel only discusses potentially discusses potentially Miguel only or trade secret confidential in the information with those a need to know, Company who have of information to and limits distribution group. the smallest possible confidential Carol always puts drawer information in a locked lunch. when she goes to laptop unattended Ritu never leaves her else. anyone with password her shares or she leaves her workstation, Whenever or her computer she either locks it off. switches Since Joe’s job involves employees’ personnel files, he always keeps them cabinet. in a locked Rita always obtains a signed confidentiality agreement from prospective vendors before providing them with information about McDonald’s. rotection of Protection Proper Information: Confidential      a t AccessMCD ou must never use any such any such ou must never use onal Da vailable on McDonald’s Intranet Intranet McDonald’s on vailable McDonald’s Golden Arches McDonald’s Golden Arches Code: Policies & Standards Code: Policies A rs e P of our value the privacy respect and We and franchisees, customers and employees, maintain their when handling confidentiality must means that you This personal information. customer and franchisee treat all employee, personal data with care and respect, while access and guarding against inappropriate disclosure. Y datapersonal benefit or in any other for inappropriate way. What is confidential is confidential What Question: information? all information is Confidential Answer: that might be non-public information or harmful to the of use to competitors if disclosed. owner of the information Examples would include information or operations that on business plans general public are not known to the or competitors. a Question: I just returned from regional meeting where I learned about McDonald’s exciting new product plans and excellent financial results that will be announced soon. I am very proud of McDonald’s success and am eager to share the or answer news. Can I tell my family, questions if a reporter contacts me? not information has No. This Answer: been released to the public and is confidential. Unauthorized disclosure could have serious consequences. example,For McDonald’s could be placed at a competitive disadvantage Never or exposed to legal liability. disclose confidential Company information to reporters or anyone outside McDonald’s. on ti rma fo ng ential In fid keti

Mar Our brand promise begins even before our customers enter our restaurants, with advertising and marketing that is truthful, tastefulof the world’s most and worthy of one well-known retail brands. McDonald’s Golden Code:Arches Policies & Standards contains information on our commitment to how and what we communicate in our advertising and marketing, as well as our legal and trademark policies and standards. Take precautions against accidentally Take For disclosing confidential information. never discuss it example, mark it appropriately, secured. in public places and keep your laptop Never send confidential information through e-mail unless you have taken precautions to ensure it is safe. Information is a valuable asset. Do not is a valuable asset. Information to anyone information disclose confidential not discuss it and do outside McDonald’s, who do not have with McDonald’s employees know the information. a business need to may include, for Confidential information example, unpublished sales and financial Company changes, information, major formulas and methods, product or operating estatemarketing and real plans, research results, employee data, and information about and relationships with suppliers, franchisees as confidential any information others. Treat if it could be helpful to competitors, breach or the privacy of employees, franchisees customers, or be harmful to the McDonald’s System if publicly disclosed. Con Standards of Business Conduct

14 OUR PEOPLE 17 on ti alia e c Rest t n gai rien expe t on A men cti te o Employ nurture talent, leaders and reward achievement. develop provide opportunity, We and experiences, individuals with diverse backgrounds believe that a team of We and drives high levels of an environment that fosters respect working together in to our continuing business success. engagement, is essential Pr strictly prohibit retaliation employees against retaliation.McDonald’s protects We raise a concern or cooperate in an against employees who report misconduct, have acted in good faith and with a investigation, provided that the employees provided is true. Anyone who retaliatesreasonable belief that the information will be including termination of employment. If you subject to disciplinary action, up to and of retaliation,believe that you have been the subject contact Human Resources, the Office. Legal Department or the Global Compliance ple Peo r Ou

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Standards of Business Conduct

16 OUR PEOPLE 19 ou cannot ugs ou cannot distribute ou cannot distribute Dr d ou cannot work under the influence ou cannot work under Question: Several of my co-workers often tell distasteful jokes, but I am not jokes these them telling comfortable McDonald’s Does me. to offensive are this? allow No. Respect for people is Answer: a long-standing McDonald’s value. Since you are not comfortable talking to your colleagues about the need for this inappropriate behaviour to stop, raise your concerns with your supervisor or Human Resources. If you wish to report anonymously, call the Business Integrity Line at 1-800-261-9827. ol an hol co l any drugs or alcohol at work. Y any drugs or alcohol alcohol on Company possess or consume McDonald’s-sponsored premises except at alcohol is authorized. social events where A cannot employee, you As a McDonald’s drugs in the use alcohol or illegal possess or in any job-related or while engaged workplace, Y activity. or any substanceof alcohol, illegal drugs that from performing your job could prevent you Y safely effectively. and rsity ive e c d D kpla r on an si e Wo lu c Saf are committed to providing a safe We and healthful working environment for our require all employees to abide employees. We by safety and to take rules and practices the necessary themselves precautions to protect everyone’s and their fellow employees. For employees must immediately report safety, accidents and unsafe or conditions practices to their immediate supervisors. In diversity and is committed to McDonald’s respect We for everyone. equal opportunities of attributes and perspectives the unique we rely on these diverse every employee, and us build and improve our perspectives to help and business relationships with customers diversity of our embrace the partners. We customers and employees, franchisees, and work hard to make sure business partners, feels welcome. everyone at McDonald’s equal treatment and McDonald’s provides regard equal employment opportunity without age, gender, religion, colour, to race, ethnicity, physical or mental national origin or ancestry, sexual orientation,disability, military status This or any other basis protected by law. policy applies to our employees, applicants, vendors independent contractors, franchisees, and suppliers. It also applies to all aspects of McDonald’s dealings with customers and to our employment decisions, including recruitment, hiring, placement, development, benefits, promotion, training, scheduling, compensation and termination. ity gn i d D Guidelines AccessMCD McDonald’s Human Resource Operating Operating Resource an ct vailable on McDonald’s Intranet Intranet McDonald’s on vailable pe A s Re the world throughout of our employees Each fairness, respect to be treated with deserves opportunity for provide equal We and dignity. employees and applicants. have the right to McDonald’s employees is free from harassment, work in a place that sexual or otherwise, intimidation or abuse, physical violence. We or acts or threats of or physical conduct do not tolerate verbal person, unreasonably that demeans another work performance interferes with another’s or or creates an intimidating, abusive, hostile offensive work environment. harassment purposes of this policy, For includes slurs, offensive remarks, jokes, visual, electronic communications, and other verbal or physical conduct that could create an intimidating, hostile or offensive work environment. In addition to the above, “sexual harassment” requests includes unwelcome sexual advances, of a for sexual favours and other conduct sexual nature. these topics, see: more information on For w e La d th an hts es. Jerry should report g i Jerry and his supervisor, supervisor, his and Jerry Question: together on businessDavid, travel travel, they time Each frequently. quite small personal items to David charges card Express American Company his charges. David’s of aware is Jerry and someone let to like would Jerry using improperly is David that know his Company credit card, but he is it Is job. his affect will this that afraid David’s report to responsibility Jerry’s questionable charges? Y Answer: without fear activities David’s charging of retaliation. He has several options. He can report David’s charging activities directly to David’s supervisor, contact the Global Compliance Office, or if he prefers to report anonymously, he can contact the Business Integrity Line at 1-800-261-9827. man R

Hu support fundamental human rights for We will not employ underage all people. We prohibit or forced labourers. We children respect physical punishment or abuse. We the right of employees to associate or not to associate with any group, as permitted by and in accordance with applicable laws and comply with employment laws regulations. We in every market where we operate. Standards of Business Conduct

18 McDONALD’S SYSTEM 21

st e r ps Inst te m onshiti e t s Rela or t Sy ONALD’S Be a D r c ’s d n M Ope / l r ondon, United Kingdom a ng i ne Photo: L Acti gain personal for never McDonald’s, of benefit long-term the for act We friends. or to favour family or Ow their potential in a by helping owner/operators achieve built our great System We treating them with did this by with McDonald’s. We positive business relationship our Treating and difficult ones. through good times honesty, respect, fairness and a key to our success, and is the responsibility owner/operators right continues to be of all employees. or their employees, Standards do not apply to McDonald’s owner/operators These our we expect women. However, who are independent business men and owner/operators to maintain high standards of integrity and to abide by all laws regarding human rights, applicable laws and regulations, including workplace safety and worker compensation and treatment. Don c M

m e e t s th Sy n i ’s e d v l e i a Don c M We Bel

Standards of Business Conduct

20 McDONALD’S SYSTEM 23

McDonald’s for Suppliers AccessMCD and Code of Conduct Conduct of Code www.mcdonalds.com vailable on McDonald’s Intranet Intranet McDonald’s on vailable A Do McDonald’s suppliers suppliers McDonald’s DoQuestion: complete the and owner/operators with compliance of certification annual the Standards of Business Conduct? suppliers No. However, Answer: are expected and owner/operators as those to uphold similar principles and support outlined in the Standards in complying McDonald’s employees . In addition, with the Standards to operate their they are expected businesses ethically and abide by all applicable laws and regulations. ps onshi ti Rela r e i

roc knew the importanceroc knew strong of building We regularly review and update our sourcing We and sustainability ensure it activity to strive consistently meets our standards. We to work with suppliers that are committed to our universal business in a principles of doing responsible and ethical manner. s a global company, McDonald’s does As a global company, business with suppliers from many countries of diverse cultural, social and economic circumstances. McDonald’s is committed to fair employment practices and strives to provide a safe, healthful and productive work environment for its employees. who In turn, we strive to work with suppliers means our suppliers are share our values. This expected to share our support of fundamental rights for all people: to treat their employees with fairness, respect and dignity and to follow practices that promote health and safety. McDonald’s bases its relationships with McDonald’s bases efficient and fair suppliers on lawful, Standards of practices. Although these Business Conduct do not apply to our our suppliers to adhere suppliers, we expect to applicable legal requirements in their with business relationships, including those and their employees, their local communities McDonald’s. In addition, all of our suppliers are required to affirm our Code of Conduct for Suppliers. s a supplier to the first McDonald’s, Ray to the first McDonald’s, As a supplier K do. still We with suppliers. relationships fairly and treat our suppliers respectfully, We expect our suppliers to treat us in and honestly, the same way. Suppl Standards of Business Conduct

22 ETHICS 25 ts e Ass pany pany m ng Co cti e t o property, information or property, position for personal gain. action that involves theft, fraud, embezzlement, extortion or misappropriation of property. security or integrity of Company information or software. security or integrity of Company information our policy regarding confidentiality. that are inappropriate, illegal or may violate unless donate, sell or dispose of any Company property Do not loan, borrow, specifically authorized by charge. the officer in never use Company never take part in any in a way that could compromise the never use Company computers or networks to access, receive or transmit materials never use Company computers or networks ou are responsible for proper use and protection of Company assets, and must use for proper use and protection of Company ou are responsible   Pr must safeguardAll McDonald’s employees assets, including our most Company protect our brand is to prevent the brand. One of the ways we valuable asset: our intellectual property. McDonald’s name, trademarks or other improper use of the Y and responsibility business purposes. Exercise good judgment them only for legitimate that you receive in assets, and do not abuse any privileges in your use of Company assets, vehicles, office Company assets include financial your position at McDonald’s. software, telephone and internet services, supplies, equipment, computers, networks, voice mail and e-mail.    ETHICS y

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Standards of Business Conduct

24 ETHICS 27

ou must then disclose the One of my vendors asked One of my Question: they that conference a at speak to me all pay to offered has and sponsoring are this offer? Can I accept of my expenses. Maybe. If your supervisor Answer: agree to speak at the approves, you can McDonald’s conference. However, allow vendors to pay generally does not for employees. travel and hotel costs Discuss the invitation with your situation depends supervisor since this and circumstances.on the specific facts refusing country, my Question: In be can associate business a from gift a should I do considered an insult. What and gift expensive an offered am I if not do I if offence cause will I that know accept it? If it is customary to exchange Answer: gifts in the local culture and you believe that you will harm McDonald’s business relationships if you do not accept a gift, you may accept the gift on behalf of the Y Company. gift to your supervisor to determine appropriate disposition, or you may contact the Global Compliance Office for guidance. Is cash or a cash equivalent; Is excessive in value; Could be construed as a bribe or payoff; or any laws or regulations. Violates Is inconsistent with customary business practices;

    ifts, Favours & Business Entertainment Business & Gifts, Favours anything bribes or provide will not pay We or appear to may influence of value that of another. the judgment or actions influence kickbacks or accept bribes, will not seek We exercise good We or any improper payments. in providing business judgment and moderation respect the gifts or entertainment. We with which policies of other organizations we do business. purpose of business gifts and The entertainment in a commercial setting is to create goodwill and sound working relationships. Company employees, following applies to The immediate family members of Company working employees, and agents or third parties on behalf of the Company: give or accept any gift, Do not offer, entertainment or other personal benefit if it:  If you are not certain whether any gift, about proposed gift or other personal benefit is appropriate, you must consult your supervisor and the Legal Department before taking any action. es, it probably would. My brother owns a owns My brother Question: that he believes can company and less supply higher-quality supplies to McDonald’sexpensive Can we than the current vendor. use his company? Maybe. Always notify Answer: or the individual your supervisor, purchasing responsible for making relationship decisions, of any close of our vendors as you have with any well as disclosing the potential conflict of interest to the Global Compliance situation will be reviewed Office. Each on a case-by-case basis. Question: I have developed a friendship with a supplier and am considering entering into a partnership with him in a business venture unrelated to McDonald’s. this violate CompanyWould policy? Y Answer: Even if you are able to keep your personal and financial dealings from affecting your judgment on behalf of others may perceive the Company, that you are biased. Before taking any action, you must discuss your plans with both your supervisor and the Global Compliance Office. st e r ou must disclose f Inte ou are responsible for disclosing ou are responsible o licts f

Outside Employment and Other Business Arrangements All of us have a primary duty to advance McDonald’s interests. Outside employment or other business arrangements must not interfere with this obligation. As a McDonald’s employee, you may not accept or receive compensation or business from any supplier entity with whom you are conducting business on behalf of McDonald’s. any potential conflict of interest to both any potential conflict of interest to both your supervisor and the Global Compliance Office. Also, be very cautious about sharing work information with relatives or friends who in for competitors, or have business interests samecompetitors. The holds true if you have family or friends who work for McDonald’s or suppliers, vendors, service providers owner/operators, or have business interests companies. in such Doing Business with Family and Friends have A conflict of interest may arise when you any business dealings with family members or close personal friends. Y ach of us must avoid any situation in which in which avoid any situation of us must Each might cause or financial interests our personal avoid must to be divided. We our loyalties of a conflict of interest even the appearance to doubt our fairness that might cause others Y or integrity. conflict of interest any actual or potential the situation to the Legal Department or by any Office, and abiding Global Compliance eliminate or control to you on placed conditions for conditions may include, the conflict. Such example, removing you from decision-making dispose on behalf of McDonald’s or having you conflict. of the outside interest that creates the Con Standards of Business Conduct

26 ETHICS 29

AccessMCD Management Policy McDonald’s Records Records McDonald’s vailable on McDonald’s Intranet Intranet McDonald’s on vailable A void exaggeration, colourful language, lmost all business records, including e-mail e-mail including records, all business Almost become subject to records, may and computer of litigation or in the course public disclosure governmental are also Records investigations. often obtained the media. outside parties or by truthful concise, you should be clear, Therefore, recording any information. and accurate when A and derogatory guesswork, legal conclusions, of people and their motives. characterizations in accordance with Handle all documents McDonald’s Records Management Policy. Contact the Legal Department if you have any doubt about whether to save or destroy a document.

ons ti a ic un Re cords ness Comm d I have my own business and own I have my Question: internet. the my business over do a lot of using my McDonald’sI have been search to send e-mail and computer business on my own the internet for my break and after work.lunch this okay? Is No. Using Company equipment Answer: to pursue or and/or internet service business is conduct non-McDonald’s not acceptable. Make false entries or alter receipts on Make false entries or alter receipts on expense reports; or assets; Maintain undisclosed or unrecorded liabilities, funds or “off the book” assets; Improperly record or fail to record items that should be expensed; or Make any entry that intentionally hides or disguises the true nature of any transaction. enter false information on time sheets; alter or falsify quality or safety results; understate or overstate known liabilities        Busi Shareholders count on McDonald’s to provide honest and accurate information and to make responsible business decisions based on reliable records. All financial books, reflect records and accounts must accurately transactions must also and events. They conform both to generally accepted accounting internal principles and McDonald’s system of ensure the accuracy of all controls. To McDonald’s records, you must never: an

AGE US

S S ON TI A AccessMCD IC IC IC UN McDonald’s Electronic Communications Policy vailable on McDonald’s Intranet Intranet McDonald’s on vailable A verything related to McDonald’s e-mail and and e-mail McDonald’s to related verything through received and sent e-mail mployee COMM ON CTR ELE E systems, communications electronic other and informationincluding all communications McDonald’s on sent or saved received, created, Company. the of property the is systems, E including e-mail andCompany computers, internet third-party using activity search internet and search to subject is providers, service regardless notice, without or with monitoring, are systems Company’s the whether of theaccessed in or out of the office, or whether Company’s the through pass communications and periodically will Company The server. individual of monitoring perform randomly employee usage. these reasons, employees For materialhave no personal right to privacy in any created, received, saved or sent using the Company’s e-mail or computer systems, service internet third-party through including in privacy of expectation an nor providers, complying to addition In communications. such must employees all requirements, these with Electronic read and comply with McDonald’s available is Communicationswhich Policy, on AccessMCD.

Finally, do not make a personal investment do not make a personal investment Finally, in an entity if the investment may affect or appear to affect your judgment on business decisions relating to that enterprise. Be mindful of potential conflicts that may arise in investments in private and public companies, and be sensitive to any insider trading issues that may be associated with investments in public companies. (See “Inside Information on page 39 of this and Securities Trading” Standards booklet for more information.) Do not take personal advantage of business or or business of advantage personal take not Do discovered are that opportunities investment information property, Company of use the through indirectly or directly includes This position. or rights tobuying, leasing or otherwise acquiring might McDonald’s if materials or property any also be interested in pursuing the opportunity. utside Investments Outside may not own a substantialEmployees McDonald’s, or any competitor of interest in doing entity that is currently any business with or seeking to do business business, rule applies to both direct McDonald’s. This As per the applicable and indirect ownership. laws in the U.S., “Substantial interest” is an greater than 5% of the ownership interest total worth of the employee and immediate net greater than 1% of the family members, or outstandingin equity securities for investments “substantial definition of The a public company. interest” may vary from country to country. Laws, a person As per Indian Income Tax has “substantial interest” if he is a beneficial equity owner of at least 20% or more of the capital or total power in the company. voting for investments in may be an exception There which mutual funds or managed accounts in the investment. employees do not choose Standards of Business Conduct

28 ETHICS 31 .S. .S.

U ”) has PA .S. official, official, .S. U Photo: Munich, Germany or a request PA .S. law that makes it it makes that law .S. U . If you have any PA . We do not tolerate . We PA also requires that all PA is not a simple task. PA is a a is y r PA e Foreign Agents Agents Foreign Intranet AccessMCD vailable on McDonald’s rib A Policy for Selection of Policy -B Anti U.S. three decades, the more than For Practices Act (“FC Corrupt Foreign operations business McDonald’s to applied FC The globally. a crime to pay or offer to pay anything of value,a crime to pay or offer non- any to indirectly, or directly including employees of state-owned companies, companies, state-owned of employees including or anyone acting on behalfpolitical candidates and is applicableof a public organization of ventures joint and subsidiaries all to FC Companies. The system a maintain companies publicly-traded thatof internal controls and books and records accurately reflect every transaction. All employees, agents, consultants, representatives and joint venture partners controlled its or McDonald’s of behalf on acting subsidiaries must fully comply with the provisions of the FC of violations. Compliance is a condition employment or association with our Company. Interpreting the FC situations fall into the are times when There “grey areas” of the FC questions regarding the FC for payment, contact the Global Compliance Office or the Legal Department. see: more information on Anti-Bribery, For egal egal L ss ne si

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irit o e organizations that support terrorists; and Require that transactions not being are used for money laundering. any way with unsanctioned boycotts; Restrict trade with certaincountries;

ur first and most fundamental obligation in fundamental most obligation and first ur h

prohibit dealings that could aid terrorists or ensure that companies do not cooperate in     Though we are a Company incorporated we are a Company Though in India, some U.S. laws may apply to our business even being outside the U.S. Among these are laws that: McDonald’s complies with all applicable laws McDonald’s complies with all applicable and regulations wherever we do business. Almost every country in the world prohibits of making payments or offers of anything parties value to government officials, political or candidates in order to obtain or retain must never pay commissions business. We or fees to dealers, distributors, agents, finders or consultants that are used as a bribe or kickback. Inte O obey to is business do we where place every both applies This law. the of spirit and letter the and to third partiesto McDonald’s employees If you have our Company. acting on behalf of you matter, any of legality the about concern a the with consulting for responsible are T Sp any potentially illegal actsDepartment before have taken place. Standards of Business Conduct

30 OUR COMMUNITIES 33 k c ng Ba d Givi ity an un es iti mmun mm Co We to our local communities. long, proud tradition of giving back McDonald’s has a strengths. As leaders in thing to do, and that it is one of our great know it is the right on our neighbourhoods, people and we have a positive influence social responsibility, the environment. millions of dollars and and owner/operators donate employees Our Company, charitablecountless hours to those that around the world, particularly organizations the occasion when disasters also rise to strike, We of children. address the needs and disasterworking with owner/operators, suppliers to assist relief organizations victims and relief workers. Ronald McDonald House Charities (“RMHC”) and its local Chapters have a special year McDonald’s restaurants Each dollars raise millions of place in our philanthropy. for RMHC causes. McDonald’s helps defray RMHC’s and other children’s general and administrative costs and certain incur to raise other costs it would otherwise funds and deliver program services. Co ur O

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32 OUR COMMUNITIES 35

Report AccessMCD and www.mcdonalds.com McDonald’s Worldwide Worldwide McDonald’s Corporate Responsibility vailable on McDonald’s Intranet Intranet McDonald’s on vailable A utrition and Well-Being and Well-Being Nutrition our to supporting are committed We range offer a well-being. We customers’ to meet our customers’ of menu choices provide preferences. We diverse needs and nutritional values of our information on the customers can choose offerings so that our dietaryitems that meet their needs and those of their families. Sustainable Supply Chain that profitably envision a supply chain We safe products without yields high-quality, supply interruption while leveraging our leadership position to create a net benefit by improving the ethical, environmental and economic outcomes. al al y it l e Soci e t a sibi por pon s r Co Re take that seriously the responsibilities We leverage our We being a leader. come with to help make size, scope and resources publish our place. We the world a better CorporateWorldwide Report Responsibility on the impacts of our to provide information our most recent initiatives business, as well as environment, nutrition in areas including the and sustainability. Environmental Responsibility McDonald’s is committed to environmental and everyone in the System has responsibility, a role to play in living up to that commitment. focus our efforts on areas where we We can have significant impact on critical environmental issues, including climate conservation natural resource change, and waste management. continuously listen, learn and invest in We innovations that can improve our environmental partner with other organizations footprint. We to raise environmental awareness. We work with our key suppliers to promote environmentally responsible practices in their operations.

ou must must ou Y therwise, it could could it therwise, O overnment Relations. Relations. overnment While attending a Question: While Angeles, in Los business function I had the opportunity to attend a $200-a-plate dinner in supporta of the nextpolitician running in election. of the dinner on I included the cost my expense report, but my supervisor Since the expense. will not approve McDonald’s the cost of meals covers on business, travelling for employees why would my supervisor not approve this dinner charge? cover not will McDonald’s Answer: not was it because expense this pre-approved by the head of G cover the dinner expense from funds. own your to donating were you that appear the candidate in your capacity as that and employee McDonald’s a supporting was McDonald’s this candidate. McDonald’s. Finally, do not use Company assets assets Company use not do Finally, McDonald’s. activities without for any political or resources of McDonald’s from the head prior approval Relations Department. Government ct for for ct A ffice before before ffice O s e . PA lobal Compliance Compliance lobal olitical contributions must olitical contributions G al Activiti ou must make it clear that your views

olitic ny request for political contributions to a single single a to contributions political for request ny ny political contribution made by the contribution made Any political in advance by the must be approved Company Relations Government head of McDonald’s support a Department. Any contribution must or ballot initiative that the political candidate determines head of Government Relations long-term interests of is beneficial to the McDonald’s. P laws and regulations comply with applicable is the contribution which in the jurisdiction in FC made, including the A thatcandidate, political party or ballot initiative will aggregate to more than U.S. $100,000 in of thea calendar year requires the approval the of president world the of area McDonald’s made. be will contribution the where market conform should regulations these However, which well, as requirements legal local the to may vary as per local jurisdiction. As per toIndian regulations, any contribution made the of 5% exceed not shall party political any per as calculated profits net average company’s Companies Indian the of provisions the P Employees may participate in personal political activity and are free to support political choosing. their of issues and candidates activity such in involvement any However, own your at and time own your on be must expense. Y three immediately preceding financial years. It isthree immediately preceding financial with the Legal Department necessary to check the as well as contribution. political the to committing of those not and own your are actions and Standards of Business Conduct

34 PROFITABLE GROWTH 37 st u WTH d Antitr O on an petiti le GRle m the production chain in different markets, in respect to production, supply, distribution, distribution, supply, production, to respect in markets, different in chain production the that fixes, controls or affects prices, products, terms of or affects prices, products, terms of that fixes, controls sale, costs, profits or profit distribution practices. margins, markets or market share, or whom they would otherwise transactto boycott suppliers or persons with business, or to bid or not to bid on business generally. causes or is likely of services, which acquisition or control of goods or provision on competition within India, unless such to cause an appreciable adverse effect distribution, storage, supply, agreement increases efficiency in production, of services. acquisition or control of goods or provision or informal agreement or understanding entering into any formal with competitors agreements or understandings or products, with competitors to allocate customers storage, distribution, to production, supply, entering into any agreement in respect or persons at different stages entering into an agreement with enterprises or levels of  ir CoFa or around the world have fair competition we operate in which Most of the countries protection laws in place to safeguardantitrust/consumer to the rights of consumers and complies with these at the best prices. McDonald’s supports the best products and Act and Monopolistic Protection Act, Competition laws. In India, the Consumer Practices (MRT generally prohibit: P) Act, among other things, Restrictive Trade    fitab o r Photo: Beijing, China P y l

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Standards of Business Conduct

36 storage, sale or price of, or trade in goods or  Respect the proprietary rights of Communicating with provision of services, including: Question: In the course of doing my others, including patents, copyrights the Public and trademarks; (a) tie-in arrangement; which includes any job at McDonald’s, I learned that one When McDonald’s provides information to agreement requiring a purchaser of goods, of our suppliers is about to announce  Do not accept, disclose or use information the news media, securities analysts and as a condition of such purchase, to purchase a breakthrough that should greatly that was disclosed to you in breach of a stockholders, we have an obligation to some other goods; increase the value of its stock. May confidentiality agreement; accurately and completely communicate the

I purchase shares of stock in the facts. To ensure accuracy and completeness, P (b) exclusive supply agreement; which includes  Do not disclose or use information that R supplier now before the news O any agreement restricting in any manner could be proprietary or confidential without employees receiving inquiries regarding FIT

is public? A B the purchaser in the course of his trade consulting the Legal Department; McDonald’s activities, results, plans or its Answer: No, for two reasons. First, position on public issues must refer the LE G from acquiring or otherwise dealing in any  Do not use unethical or illegal methods to request to the Communications Department, goods other than those of the seller or any this would be a conflict of interest. gather information about other companies; R or the department for your area that deals O other person; You are not allowed to use information WTH  Do not steal trade secret information, acquired solely as a result of your with public issues. This applies to all public (c) exclusive distribution agreement; which or persuade past or present employees relationship with McDonald’s for statements, including those made on internet includes any agreement to limit, restrict of other companies to disclose trade personal benefit. Second, using this bulletin boards and chat rooms. If you answer or withhold the output or supply of any secrets; and information could be insider trading, a question from a public source with consent goods or allocate any area or market for which is illegal. You may not buy  Do not take any action that could create an from the Communications Department, be sure the disposal or sale of the goods; or sell shares based on non-public appearance of an improper agreement to stay within your level of knowledge and get (d) refusal to deal; which includes any information you receive about with competitors. help if you are unsure of the correct answer. agreement which restricts, or is likely to McDonald’s or other companies in Inside Information and restrict, by any method the persons or Government Inquiries the course of your employment Securities Trading classes of persons to whom goods are at McDonald’s. McDonald’s cooperates with government sold or from whom goods are bought; Information that has not been made available to agencies and authorities. Forward all requests the public and that a reasonable person would (e) resale price maintenance, which includes for information (other than routine requests) to consider important in making an investment any agreement to sell goods on condition the Legal Department immediately to ensure Trade Practices decision is commonly called inside information. that the prices to be charged on the that we respond appropriately. All information Information about competitors and suppliers Inside information also includes information resale by the purchaser shall be the prices provided must be truthful and accurate. Never is a valuable asset. We respect the rights of that relates to other public companies’ stock. stipulated by the seller unless it is clearly mislead any investigator, and never alter or competitors and suppliers, and we will act Examples of inside information would be stated that prices lower than those prices destroy documents or records subject to fairly toward them in the marketplace. We significant upward or downward revisions to may be charged. an investigation. strive for competitive advantages through earnings forecasts, significant restructurings, Competition laws also govern our relationships superior research, marketing, execution, quality management changes and important product with suppliers and owner/operators. Employees and service — never through unethical or or litigation developments. who work with supplier councils or local questionable business practices. We do not It is illegal to buy or sell securities of any advertising cooperatives should consult the Legal engage in unfair or illegal trade practices. company, including McDonald’s, based on Department about any fair competition or antitrust The following rules apply when McDonald’s inside information. It is also illegal to inform issues. If you have a question about these issues or anyone working on our behalf gathers or others about inside information, or to make or any other discussion, decision or action that uses information concerning competitors stock buying or selling recommendations to has potential antitrust implications, consult the or suppliers: others based on such information. Legal Department before taking any action.

38 Standards of Business Conduct 39 CONTINUOUS IMPROVEMENT 41 s ol nal Contr r ent m d Inte ve e an o s c on ti nan r mpr ga ve o sti mployees are required to live up to the letter and spirit of our system our of spirit and letter the to up live to required are Employees te G ra nal Inve po r r nuous I ou are required to disclose any ou may not discuss anything about the investigation with any person, either inside ou may not discuss anything about the relevant information in a complete and to and truthful manner, cooperate fully with the authorized investigation team throughout the course of the investigation; and or outside of McDonald’s, without the express consent of those authorized to or outside of McDonald’s, without the conduct the investigation; If you interfere with or provide false information in the course of the investigation, you may be subject to disciplinary action, up to and including termination of employment. y y   Co independent Board corporate governance begins with an believe that effective of We We performance on behalf of shareholders. monitors the Company’s Directors which protect designed to of internal controls and reporting mechanisms also have a system management and the Board of the Company and to provide the assets and operations McDonald’s Audit Committee of and timely information. The with accurate, honest oversight in connection with outside auditor provide independent Corporation and its the Company’s financial statementsthe preparation of and the Company’s internal systems. control fully with any audit or investigation. of internal controls, and to cooperate Inte If you become aware of McDonald’s takes allegations of misconduct very seriously. asked to provide information or to assist with an an internal investigation, or if you are apply: internal investigation, the following rules  Conti

y ll a nu ti ve e Con o mpr Striv o I We t

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40 ADDITIONAL RESOURCES 43

e n i y l y ce Office tegrit In L 60522-4567 ess n si l Compoba lian ES . Box 4567 .O. Box 4567 Reporting Suspected of the Standards Violations Gl P Oak Brook, I Phone: 630-623-3522 630-623-7125 Fax: or [email protected] or Bu 1-800-261-9827 Line is staffed Business Integrity The by a live operator from an outside 7 days 24 hours a day, company, Calls are a week, 365 days a year. free, confidential and may be made Interpreters are anonymously. always available. ou can obtain copies of McDonald’s Y Standards of Business Conduct from Human your egal Department for Resources or the L lobal Compliance Office. area or from the G RC d ESOU e d team k e d olicy r d o en olicy olicies & Standards t x E etw

r r exten ONAL R ou on N Y / ti s e rma ici olicy for Selection of Foreign Agents olicy for Selection of Foreign our supervisor our officer-in-charge fo Code of Conduct for Suppliers Human Resource Operating Guidelines Records Management P Corporate Responsibility Report Worldwide Human Resources Internal Audit Business Integrity Line 1-800-261-9827 eople/you ol P electronic Communications P Code: golden Arches p y management another member of y legal Department employee Assistance Programs (EAP) ach of us must personally stand for these values, but still, we are stronger when acting together in in together acting when stronger are we still, but values, these for stand personally must us of ach In        ADDITI E are a good place to start. resources it. These them. Get support if you need our goal of upholding P         P through Copies of these policies are available or AccessMCD:www.mcdonalds.com There may be additional policies that serve There as resources. Employees are expected to be aware of and comply with additional policies that govern their job.

Office Employee calls (may choose to (may choose remain anonymous) Information forwarded to Global Compliance Line Business Integrity Gloria Santona Corporate Executive Vice President, General Counsel and Secretary S N R E C ON R O NG C guidance or Office directly: Office provides Issue is resolved e-mail, fax or mail RTI investigates issue Employee contacts Global Compliance Global Compliance face-to-face, phone, face-to-face, phone, question or concern question EPO R Employee makes informed decision Employee has ethics or compliance has ethics or compliance Employee Haydee Olinger President Corporate Vice Chief Compliance Officer other manager

direct supervisor or direct supervisor or mployee speaks with Employee speaks with

Standards of Business Conduct

42 Keeping the Shine on SUPPLEMENT TO THE STANDARDS OF country of residence without prior written Our Arches Stop and Reflect BUSINESS CONDUCT RELATING TO THE approval of the General Counsel of McDonald’s U.S. FOREIGN CORRUPT PRACTICES ACT Corporation. In addition, no entertainment or gifts No policy, booklet, committee or compliance McDonald’s expects its employees to comply may be offered, or travel expenses paid, to any office can guarantee good, ethical behaviour.  Is it legal? Is it right? with applicable local laws and to maintain high government official without prior written approval Only each one of us can. It is up to every  Will customers, co-workers, friends ethical standards at all times. The Standards of your Legal Department or Area of the World person who is a part of McDonald’s to keep and family approve? of Business Conduct apply to McDonald’s General Counsel. our good name shining by doing the right  Will I feel good about my employees in the United States and in all other 3. Books and Records. Employees must help things the right way. decision tomorrow? If the answer to all these questions is countries of the world in which McDonald’s to ensure that corporate books and records “yes” — then you are on the right track. operates. This supplement emphasizes and accurately and fairly reflect in reasonable detail clarifies aspects of the Standards relating to the all transactions and dispositions of assets. United States Foreign Corrupt Practices Act McDonald’s prohibits creating or maintaining Frequently Asked Questions about the Global Compliance Office: (“FCPA”), a U.S. anti-bribery law that applies undisclosed or unrecorded funds or assets for Question: What are my options for reporting you will be given a number that you can to McDonald’s Corporation, its subsidiaries, any purpose. No employee shall participate an issue or concern? reference when you call back for an update. joint ventures and its officers, employees, in falsifying any accounting or other business representatives and agents. record. All employees must respond fully and Answer: You can contact the Global Question: How will I know whether my issue 1. Payments to Government Officials.N o truthfully to any questions from McDonald’s Compliance Office in many ways: was addressed? employee of McDonald’s Corporation or any Corporation’s internal or independent auditors. 1. Meet face-to-face with member of Global Answer: The Global Compliance Office subsidiary or joint venture shall offer or make any Compliance staff initiates investigations. We work with payment to secure, maintain, or direct business 2. Call Global Compliance: 630-623-3522 many other departments including Human to any government official. G“ overnment 3. Fax to Global Compliance secure fax line: Resources, Internal Audit and Security when Official” would include employees of any 630-623-7125 conducting investigations and bringing them foreign government, government agency, public 4. Mail hard copy to Global Compliance to closure. When you call to follow up on international organization or political party. secure address: your question or concern, we will give you “Government Official” would also include any P.O. Box 4567, Oak Brook, IL 60522-4567 an answer or tell you that appropriate action political official or candidate for public office, or 5. E-mail to Global Compliance secure has been taken. We must respect all parties any person acting in an official capacity for or e-mail: [email protected] involved in an investigation, so the amount of on behalf of any of the above. The FCPA also 6. Business Integrity Line: 1-800-261-9827 information that we can provide will be different prohibits payments made indirectly through a Question: If I call the Business Integrity Line, in each situation. third party, especially if it is likely or certain that will I have to give my name? the payment or offer of payment will be made Question: What if someone makes a to a government official for the purposes of Answer: No. Your call goes to a third party false accusation? influencing the official’s acts or decisions. who will listen to your questions and concerns Answer: It depends. We are very thorough without collecting identifying information. 2. Cash and Third Party Country Payments in our investigations and we respect all or Gifts. To avoid even the appearance of Question: How do I get an answer to my employees. No disciplinary action will be impropriety, no payments to any third party question or concern if you do not know taken without a full investigation. However, an shall be made in cash other than documented my name? employee who knowingly makes a false report cash disbursements. No corporate check shall Answer: When you call the Business Integrity will be subject to discipline, up to and be written to “cash”, “bearer” or third party Line, case numbers are assigned to all including termination. designees of the party entitled to payment. No contacts. If you choose to report anonymously, payments shall be made outside the recipient’s

44 Standards of Business Conduct 45 Calls to the McDonald’s Corporation Business Integrity Line notes in the United States. In order to contact the McDonald’s Corporation Business Integrity Line in the United States, please locate the local AT&T Direct Access Number for the country you are calling from on the list below:

American Samoa...... 1-800-225-5288 Korea (Korea Telecom)...... 00-729-11 Australia (Telstra)...... 1-800-881-011 Korea (ONSE)...... 00-369-11 Australia (Optus)...... 1-800-551-155 Korea (DACOM)...... 00-309-11 Bahrain...... 800-00-001 Bahrain (Cellular)...... 800-000-00 Lebanon (Beirut)...... 426-801 Bahrain Lebanon (US Military Bases)...... 800-000-05 (outside Beirut)...... 01-426-801 Brunei...... 800-1111 Macau...... 0800-111 China (PRC-South, Malaysia...... 1-800-80-0011 Shanghai-Telecom)...... 10-811 Mauritius...... 01-120 China (PRC-North, New Zealand...... 000-911 Beijing CNCG)...... 108-888 Pakistan...... 00-800-01-001 Cyprus ...... 800-900-10 Philippines (Digitel, Globe, Egypt (Cairo)...... 2510-0200 Philcom, Smart)...... 105-11 Egypt (Outside Cairo)...... 02-2510-0200 Philippines (PLDT)...... 1010-5511-00 Fiji...... 004-890-1001 Reunion Island...... 0800 99 0011 Guam...... 1-800-225-5288 Saipan...... 1-800-2255-288 Hong Kong Saudia Arabia...... 1-800-10 (Hong Kong Telephone)...... 800-96-1111 Singapore (SingTel)...... 800-011-1111 Hong Kong (New World Telephone)...... 800-93-2266 Singapore (StarHub)...... 800-001-0001 India...... 000-117 Slovakia ...... 0-800-000-101 Indonesia...... 001-801-10 South Africa...... 0-800-99-0123 Israel (Bezeq)...... 1-80-949-4949 Sri Lanka (Colombo)...... 2-430-430 Japan (KDDI)...... 00-539-111 Sri Lanka (outside Colombo)...... 112-430-430 Japan (Softbank Telecom)...... 00-663-5111 Syria...... 0-801 Japan...... 00-441-1111 Taiwan...... 00-801-102-880 Japan (NTT)...... 0034-811-001 Thailand...... 001-999-111-11 Jordan...... 1-880-0000 Thailand...... 1-800-0001-33 Turkey ...... 0811-288-0001 U.A.E...... 0-800-121

The mark ^ appearing in some TT Direct codes means “await second dial tone”. After you locate this number, please follow the following instructions: Make sure you have an outside line (if using a public phone, make sure it can be used to make international calls). STEP 1: Enter the AT&T Direct Access Number for the country you’re calling from. STEP 2: When you hear the English-language voice prompt or series of tone prompts, enter your toll-free McDonald’s Business Integrity Line number: 800-261-9827 (DO NOT press “1” or “0” before dialling the telephone number). STEP 3: The call will be connected to McDonald’s Business Integrity Line. 47 The following trademarks used herein are owned by McDonald’s Corporation and its affiliates; McDonald’s, the Golden Arches Logo, the McDonald’s Building Designs, QSC&V, RMHC, Happy Meal, i’m lovin’ it, Ronald McDonald House Charities and Hamburger University.