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

Dear Fellow McDonald’s Employee, 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 For more than 50 years McDonald’s has been a company guided by them with high quality food and superior service, in a clean, welcoming environment, at a great M core values. Our founder, Ray Kroc, built this great company on the seven basic c D

value. Our goal is QSC&V for each and every customer, each and every time. o principles that continue to guide our behaviour, actions and decisions every day: n a l d ’ s V

 We place the customer experience at the core of all we do We are committed to our people We provide opportunity, nurture talent, develop leaders and reward achievement. We believe  We are committed to our people that a team of well-trained individuals with diverse backgrounds and experiences, working a lu  We believe in the McDonald’s System together in an environment that fosters respect and es  We operate our business ethically drives high levels of engagement, is essential to our continued success.  We give back to our communities We aspire to be our customers’ favourite  We grow our business profitably We believe in the McDonald’s System place and way to eat.  We strive continually to improve McDonald’s business model, depicted by the “three-legged stool” of owner/operators, suppliers, Inherent in each value is our commitment to be ethical, truthful and dependable. and company employees, is our foundation, and the To achieve this mission, This commitment is articulated through our Standards of Business Conduct. balance of interests among the three groups is key. our actions as individuals In today’s environment of complex laws and regulations, the Standards provide and as a system must direction for many of the complicated areas we face. We operate our business ethically reflect our Values. In addition to abiding by the Standards, we must continue to openly communicate by Sound ethics is good business. At McDonald’s asking questions and raising issues, even when doing so might be difficult. we hold ourselves and conduct our business to high standards of fairness, honesty, and integrity. The McDonald’s name is trusted and respected around the world. Each of us, We are individually accountable and collectively responsible. from the crew room to the boardroom, is an ambassador for McDonald’s in all that we say and do. Your commitment to doing what’s right keeps the shine on the We give back to our communities Arches worldwide. We take seriously the responsibilities that come with being a leader. We help our customers build Thank you. 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 James Skinner growth for our shareholders. This requires a continuing focus on our customers and the health Chief Executive Officer 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 Growth Profitable 37 38 39 39 39 Continuous Improvement 41 41 42 Resources Additional 43 43 43 35 The relationship that exists between McDonald’s and each of its of and each between McDonald’s 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 its employees or any third party. rights between McDonald’s, reserves the right to determine how the Standards McDonald’s 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 T EN T ON 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 McDonald’s Ethics Introduction Our Customers Our People 21 21 owner/Operator Relationships 22 supplier Relationships 25 26 26 26 27 28 28 sage electronic Communications U 29 30 30 30 10 10 10 11 open Communication/ 13 14 14 15 17 employment Experience 17 18 18 19 19 Workplace safe 19 other Business Arrangements 20 24 8 Employees supervisory 12 16 TAB

Standards of Business Conduct

6 INTRODUCTION 9 ct u d aivers n o d W ess C n an nts si dards dme n ta n n, Ame lity of S dards of Bu n ta licatio b u Photo: Milan, Italy P the Standards of Business current version of The Conduct will be posted and Amendments will website at www.mcdonalds.com. maintained on the McDonald’s 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 the Board disclosed promptly as required by law. of Directors, and the website for Standards of Business please check Conduct are revised periodically, the most recent version. The S Standards of BusinessThese Conduct and legal are a guide to the ethical is not a complete 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 and it does business. It is not a contract, apply to McDonald’s 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 Applicabi Standards of BusinessThese Conduct apply to employees of McDonald’s worldwide. Non-employee members Corporation and its majority-owned subsidiaries Board of Directors must abide by the Code of Conduct for the of McDonald’s maintained is posted and Corporation, which at Board of Directors of McDonald’s Standards do not apply to The website at www.mcdonalds.com. the McDonald’s of the as members employees. However, our owner/operators, suppliers or their Standards, to develop their System, we expect them to be aware of the McDonald’s 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 ine is Line is Integrity Business McDonald’s The week, 365 7 days a staffed day, 24 hours a experienced by an outside firm days a year hone 1-800- sensitive calls. P in handling within the United States.261-9827 Reverse if outside the U.S. Interpreters are charges report anonymously, available. Callers may be made to identify them. and no attempt will that however, should know, Anonymous callers difficult to follow up on it is sometimes more issues raised anonymously. e n n/ rity Li icatio g un ess Inte comm n n e si p o 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 or lobal Compliance Office 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 You can also call the McDonald’s Office. Business Integrity Line, a toll-free telephone calls on line reserved specifically for employee ethics and compliance issues. Bu lity untabi cco nal A Perso actions of our of the world, each the rest To we must do our and McDonald’s, represents reputation times to uphold the best at all of our of us success depends on each Our Company. responsibility for doing the accepting personal obligation to stop accept the right thing. We that could harm customers, or prevent actions reputation, and to the System or McDonald’s 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.

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Sup ervisory

n dditio 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 policies to employees and relevant McDonald’s assist them in understanding policies. such A McDonald’s management is committed to management is McDonald’s high standardsliving up to behaviour. of ethical Board of Directors oversees McDonald’s The and commitment to ethics the Company’s help standards.compliance with legal To up to our Standards our employees live has of Business Conduct , McDonald’s established the Global Compliance Office. the office is responsible for overseeing This compliance with these Standards Company’s policies. and other McDonald’s of a Man Standards of Business Conduct

10 our customers 13

d Safety RS E reat tasting and safe food. Child-friendly Happy Meal Meal Happy Child-friendly safefood. and tasting reat ality an G OM ployee m T Quct u d’s e fellow employees.” fellow Walking the Talk Walking Prod restaurants. Clean fundamental and to McDonald’s, have long been hallmarks of toys. These promise. brand our to our that the foods and beverages we serve is committed to ensuring McDonald’s 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 quality standards and beverages, for food, 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. follow all applicable safety employee to It 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. 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

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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 job involves employees’ Since Joe’s 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     ata AccessMCD nal D McDonald’s Golden Arches Golden Arches McDonald’s Code: Policies & Standards Code: Policies Available on McDonald’s Intranet Intranet McDonald’s on Available Perso 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 any such must never use disclosure. You 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. could be example,For McDonald’s placed at a competitive disadvantage Never or exposed to legal liability. disclose confidential Company information to reporters or anyone outside McDonald’s. n formatio l Inntia ng fide n o

Marketi Our brand promise begins even before our customers enter our restaurants, with advertising and marketing that is truthful, most tastefulof the world’s 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, not have employees who do with McDonald’s 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. C Standards of Business Conduct

14 OUR PEOPLE 17 n ce iatio l eta R st n erien xp e

t ai n Ag n oyme Empl 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 Protectio retaliation strictly prohibit retaliation. protects employees against We McDonald’s 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 or the Global Compliance Office. ple Peo r Ou

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Standards of Business Conduct

16 OUR PEOPLE 19 ugs Dr d n a 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 a Answer: Since value. long-standingMcDonald’s 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 call the Business report anonymously, Integrity Line at 1-800-261-9827. l l coho Al illegal or use alcohol or may not possess You engaged workplace, or while drugs in the not work may You activity. in any job-related of alcohol, illegal drugs under the influence or any substance that could prevent you from safelyperforming your job and effectively. or alcohol may not distribute any drugs You or consume may not possess at work. You premises except at alcohol on Company where social events McDonald’s-sponsored alcohol is authorized. iversity d D place n n a ork sio lu c Safe W 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 and provides equal treatment McDonald’s 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 dealings with customers of McDonald’s 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 McDonald’s Resource Operating Operating Resource ect an p Available on McDonald’s Intranet Intranet McDonald’s on Available es R the world throughout of our employees Each fairness, respect to be treated with deserves opportunity for provide equal We and dignity. employees and applicants. to employees have the right McDonald’s 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 d the Law an hts 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? Jerry should report Yes. Answer: activities without fear charging David’s of retaliation. He has several options. charging He can report David’s supervisor, activities directly to David’s 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

ps m est Interest e nshi atio l t e s R NALD’S B DO c Sy d’s n M erator /Op l er ondon, United Kingdom a ng i n w cti Photo: L or to favour family or friends. or to favour family or A gain personal for never McDonald’s, of benefit long-term the for act We O their potential in a by helping owner/operators achieve built our great System We did this by treating them with We with McDonald’s. 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. owner/operators or their employees, Standards do not apply to McDonald’s 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

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Standards of Business Conduct

20 McDONALD’S SYSTEM 23

McDonald’s McDonald’s for Suppliers AccessMCD and Code of Conduct Conduct of Code www.mcdonalds.com Available on McDonald’s Intranet Intranet McDonald’s on Available 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 employees in complying McDonald’s . In addition, with the Standards to operate their they are expected businesses ethically and abide by all applicable laws and regulations. ps nshi atio l e R ier

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. As a global company, McDonald’s does McDonald’s As a global company, business with suppliers from many countries of diverse cultural, social and is economic circumstances. McDonald’s 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 bases its relationships with McDonald’s efficient and fair suppliers on lawful, these Standards of practices. Although 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 In addition, all of our suppliers McDonald’s. are required to affirm our Code of Conduct for Suppliers. As a supplier to the first McDonald’s, Ray to the first McDonald’s, As a supplier importance knew the Kroc of building strong 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 ssets A y n a p om ng C 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   Protecti employees must safeguard our most Company assets, including All McDonald’s our brand is to prevent the brand. One of the ways we protect valuable asset: our trademarks or other intellectual property. name, McDonald’s improper use of the and must use use and protection of Company assets, are responsible for proper You judgment and responsibility business purposes. Exercise good them only for legitimate that you receive in assets, and do not abuse any privileges in your use of Company office assets include financial assets, vehicles, Company 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

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 don’t I if offense cause will I that know accept it? If it is customary to exchange Answer: gifts in the local culture and you believe business that you will harm McDonald’s relationships if you do not accept a gift, you may accept the gift on behalf of the must then disclose the You 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 whom 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 before taking any action. 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 will be reviewed situation 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? it probably would. Yes, 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. oflicts Interest f n

Outside Employment and Other Business Arrangements All of us have a primary duty to advance interests. Outside employment McDonald’s 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. Doing Business with Family and Friends you have A conflict of interest may arise when any business dealings with family members must disclose or close personal friends. You any potential conflict of interest to both your supervisor and the Global Compliance sharing Office. Also, be very cautious about 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 Each 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 even must to be divided. We our loyalties a conflict of interest that the appearance of to doubt our fairness or might cause others for disclosing any are responsible You integrity. conflict of interest situation actual or potential and abiding to the Global Compliance Office, on you to control by any conditions placed conditions Such or eliminate the conflict. may include, for example, removing you from or decision-making on behalf of McDonald’s that having you dispose of the outside interest creates the conflict. C Standards of Business Conduct

26 ETHICS 29

AccessMCD Management Policy McDonald’s Records Records McDonald’s Available on McDonald’s Intranet Intranet McDonald’s on Available Almost 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 exaggeration,Avoid colourful language, 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.

ns icatio ecords un R ess n 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; Enter false information on time sheets; Alter or falsify quality or safety results; 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. n understate or overstate known liabilities        Busi to Shareholders count on McDonald’s provide honest and accurate information and to make responsible business decisions books, based on reliable records. All financial reflect records and accounts must accurately transactions must also and events. They conform both to generally accepted accounting system of internal principles and McDonald’s ensure the accuracy of all controls. To records, you must never: McDonald’s a

E G USA

AccessMCD IC IC S NS ICATIO UN McDonald’s Electronic McDonald’s Communications Policy Available on McDonald’s Intranet Intranet McDonald’s on Available N ECTRO L E COMM and e-mail McDonald’s to related Everything systems, communications electronic other and informationincluding all communications McDonald’s on sent or saved received, created, Company. the of property the is systems, through received and sent e-mail Employee 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 e-mail or computer systems, Company’s 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 Finally, or in an entity if the investment may affect appear to affect your judgment on business decisions relating to that enterprise. Be arise in mindful of potential conflicts that may 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 investment opportunities that are discovered through the use of Company property, includes directly information or position. This or indirectly buying, leasing or otherwise acquiring rights to any property or materials might also be interested in if McDonald’s pursuing the opportunity. Outside Investments Outside may not own a substantialEmployees or McDonald’s, any competitor of interest in doing entity that is currently any business with or seeking to do business business, applies to both direct rule This McDonald’s. “Substantialand indirect ownership. interest” greater than 5% of the is an ownership interest total worth of the employee and immediate net greater than 1% of the family members, or outstandingin equity securities for investments exception may be an There a public company. funds or managed for investments in mutual do not choose employees accounts in which the investment. Standards of Business Conduct

28 ETHICS 31 A”) has A”) P A or a request Photo: Munich, Germany P A. If you have any

P A. We do not tolerate A. We A is not a simple task. P P A is a U.S. law that makes P Intranet AccessMCD ribery Available on McDonald’s on McDonald’s Available A also requires that all publicly-traded A also requires that P Policy Global Anti-Corruption -B Anti U.S. three decades, the more than For (“FC Practices Act Corrupt Foreign operations business McDonald’s applied to FC The globally. offer to pay anything of it a crime to pay or to any non-U.S. value, directly or indirectly, employees of state-ownedofficial, including candidates or anyone companies, political a public organization. acting on behalf of FC The companies maintain a system of internal controls and books and records that accurately reflect every transaction. All employees, agents, consultants, representatives and joint venture partners or its controlled acting on behalf of McDonald’s 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 “gray 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 ess n si d n a nal Bu

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irit of the Law organizations that support terrorists; and Require that transactions not being are used for money laundering. Ensure that companies do not cooperate in Ensure that companies do not cooperate any way with unsanctioned boycotts; Restrict trade with certaincountries; he

prohibit dealings that could aid terrorists or

    .S.-based company, many U.S. laws As a U.S.-based company, outside apply to our business both inside and the U.S. Among these are laws that: McDonald’s complies with all applicable laws McDonald’s 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. Inter Sp in fundamental most obligation and first Our obey to is business do we where place every both applies This law. the of spirit and letter the parties employees and to third to McDonald’s 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 Department before any potentially illegal actsDepartment before have taken place. Standards of Business Conduct

30 OUR COMMUNITIES 33 ngack B d Givi ity an un es iti mmun omm C local communities. We to our of giving back has a long, proud tradition McDonald’s 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 employees and owner/operators donate 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 restaurants raise millions of dollars year McDonald’s Each place in our philanthropy. helps defray RMHC’s general and causes. McDonald’s for RMHC and other children’s administrative costs and certainincur to raise funds other costs it would otherwise and deliver program services. Co ur O

o o ack t es mmuniti e B iv Co ur We G O

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32 OUR COMMUNITIES 35

Report AccessMCD and www.mcdonalds.com McDonald’s Worldwide Worldwide McDonald’s Corporate Responsibility Available on McDonald’s Intranet Intranet McDonald’s on Available 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. l l ity l Socia sibi n o porate p es Cor R 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 is committed to environmental McDonald’s 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.

overnment Relations. You must must You Relations. overnment While attending a attending While Question: Angeles, function in Los business opportunityI had the to attend a $200-a-plate in support dinner a of the nextpolitician running in election. of the dinner on I included the cost my expense report, but my supervisor the expense. Since will not approve McDonald’s meals the cost of covers traveling on business, for employees why won’t my supervisor this approve 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 could it Otherwise, 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. A. P ctivities olitical contributions must olitical contributions litical A

Any political contribution made by the contribution made Any political in advance by the must be approved Company Relations Government head of McDonald’s must support a Department. Any contribution or ballot initiative that the political candidate determines head of Government Relations long-term interests of is beneficial to the P McDonald’s. Po laws and regulations comply with applicable is the contribution which in the jurisdiction in FC made, including the political Employees may participate in personal activity and have a constitutionally protected issues right to support political candidates and any involvement However, of their choosing. on your own time and activity must be in such must make it clear at your own expense. You own and that your views and actions are your do not use Finally, not those of McDonald’s. Company assets or resources for any political activities without prior approval Government from the head of McDonald’s Relations Department. Any request for political contributions to Any request for political contributions a single candidate, political party or ballot U.S. initiative that will aggregate to more than the $100,000 in a calendar year requires area of the world approval of the McDonald’s president of the market where the contribution will be made. Standards of Business Conduct

34 PROFITABLE GROWTH 37 PNAD st u WTH d Antitr n an etitio p le GRO le om Entering into any formal or informal agreement or understandingEntering into any formal with competitors or affects prices, products, terms of that fixes, controls sale, costs, profits or profit market share, or distribution practices. margins, markets or Agreements or understandings or products, with competitors to allocate customers whom they would otherwise transactto boycott suppliers or persons with business, or to bid or not to bid on business generally.

air C F or around the world have fair competition we operate in which Most of the countries to safeguardantitrust laws in place of consumers to the best products at the rights other and complies with these laws. Among supports the best prices. McDonald’s generally prohibit: things, these laws   Competition laws also govern our relationships with suppliers and owner/operators. Competition laws also govern our relationships local advertising cooperatives or O Employees who work with supplier councils, the Legal Department about (Operators National Advertising Fund) should consult about these issues or any other discussion, antitrust issues. If you have a question implications, consult the Legal decision or action that has potential antitrust Department before taking any action. fitab Pro Photo: Beijing, China y l

r u w O o r ness Profitab ness We G Busi

Standards of Business Conduct

36 Trade Practices Inside Information and Communicating with Information about competitors and suppliers Question: In the course of doing my Securities Trading the Public is a valuable asset. We respect the rights of job at McDonald’s, I learned that one Information that has not been made available to When McDonald’s provides information to competitors and suppliers, and we will act of our suppliers is about to announce the public and that a reasonable person would the news media, securities analysts and fairly toward them in the marketplace. We a breakthrough that should greatly consider important in making an investment stockholders, we have an obligation to strive for competitive advantages through increase the value of its stock. May decision is commonly called inside information. accurately and completely communicate the

superior research, marketing, execution, quality I purchase shares of stock in the Inside information also includes information facts. To ensure accuracy and completeness, P ROFITAB and service — never through unethical or supplier now before the news that relates to other public companies’ stock. employees receiving inquiries regarding questionable business practices. We do not is public? Examples of inside information would be McDonald’s activities, results, plans or its

engage in unfair or illegal trade practices. Answer: No, for two reasons. First, significant upward or downward revisions to position on public issues must refer the L E G earnings forecasts, significant restructurings, request to the Communications Department, The following rules apply when McDonald’s this would be a conflict of interest. ROWTH or anyone working on our behalf gathers or You are not allowed to use information management changes and important product or the department for your area that deals uses information concerning competitors acquired solely as a result of your or litigation developments. with public issues. This applies to all public or suppliers: relationship with McDonald’s for It is illegal to buy or sell securities of any statements, including those made on internet personal benefit. Second, using this bulletin boards and chat rooms. If you answer  Respect the proprietary rights of company, including McDonald’s, based on information could be insider trading, a question from a public source with consent others, including patents, copyrights inside information. It is also illegal to inform which is illegal. You may not buy or from the Communications Department, be sure and trademarks; others about inside information, or to make sell shares based on non-public stock buying or selling recommendations to to stay within your level of knowledge and get  Do not accept, disclose or use information information you receive about others based on such information. help if you are unsure of the correct answer. that was disclosed to you in breach of a McDonald’s or other companies in confidentiality agreement; the course of your employment Government Inquiries  Do not disclose or use information that at McDonald’s. McDonald’s cooperates with government could be proprietary or confidential without agencies and authorities. Forward all requests consulting the Legal Department; for information (other than routine requests) to

 Do not use unethical or illegal methods to the Legal Department immediately to ensure gather information about other companies; that we respond appropriately. All information provided must be truthful and accurate. Never  Do not steal trade secret information, mislead any investigator, and never alter or or persuade past or present employees destroy documents or records subject to of other companies to disclose trade an investigation. secrets; and

 Do not take any action that could create an appearance of an improper agreement with competitors.

38 Standards of Business Conduct 39 CONTINUOUS IMPROVEMENT 41 s l ntro o t nal C emen d Inter v o s cen a n nan gatio Goverorate nal Investi p You are required to disclose any You relevant information in a complete and to and truthful manner, cooperate fully with the authorized investigation team throughout the course of the investigation; and 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. You may not discuss anything about the investigation with any person, either inside may not discuss anything about the investigation You of those authorized to without the express consent or outside of McDonald’s, conduct the investigation; or

  C independent Board corporate governance begins with an believe that effective of We behalf of shareholders. We performance on 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 Audit Committee and its Board’s and timely information. The with accurate, honest with the preparation independent oversight in connection outside auditor provide internal control systems. financial statements and the Company’s of the Company’s the letter and spirit of our system of internal Employees are required to live up to audit or investigation. controls, and to cooperate fully with any Inter If you become aware of takes allegations of misconduct very seriously. McDonald’s asked to provide information or to assist with an an internal investigation, or if you are apply: internal investigation, the following rules  nuous Impr nuous ti Con

y all nu e v o mpr StrivCon e ti o I We We t

Standards of Business Conduct

40 ADDITIONAL RESOURCES 43

e n i y l y ce Office tegrit In L 60522-4567 ess n si l Compoba lian .O. Box 4567 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. Reporting Suspected of the Standards Violations Gl P Oak Brook, I Phone: 630-623-3522 630-623-7125 Fax: or [email protected] or Bu You can obtain copies of McDonald’s can obtain of McDonald’s copies You Standards of Business Conduct from Human your egal Department for Resources or the L lobal Compliance Office. area or from the G RCES ESOU ded olicy R ded team n n L olicy olicy olicies & Standards te A xte Ex r r e u n Network u o /Y /yo ple icies l formatio Code of Conduct for Suppliers Electronic Communications P Human Resource Operating Guidelines Records Management P Corporate Responsibility Report Worldwide Your supervisor Your management Another member of officer-in-charge Your Human Resources Internal Audit Business Integrity Line 1-800-261-9827 Employee Assistance Programs (EAP) P Code: golden Arches global Anti-Corruption P legal Department ON ADDITI        Each 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 Each are a good place to start. resources it. These them. Get support if you need our goal of upholding Peo         Po through Copies of these policies are available or AccessMCD:www.mcdonalds.com In 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 CER N OR NG CO guidance or Office directly: Office provides Issue is resolved e-mail, fax or mail investigates issue Employee contacts Global Compliance Global Compliance face-to-face, phone, face-to-face, phone, ORTI question or concern question P RE 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 Employee speaks with Employee speaks with

Standards of Business Conduct

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

44 Standards of Business Conduct 45 notes notes

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.