Code of Conduct

CODE OF CONDUCT CONTENTS INTRODUCTION 3 PROUD OF OUR HERITAGE 11 Letter from the CEO Food Safety Denny’s Guiding Principles Hiring Suppliers Introduction Competition Reporting Advertising Record Making and Keeping GUESTS FIRST 6 Respect Fraud Quality Financial Irregularities Privacy Bribery Government Contracts THE POWER OF WE 7 Company Communications and the Press Equal Opportunity Employer Social Media Respect Others Environment Manager Expectations Valuing Franchisees HUNGRY TO WIN 14 Safety Material Non-Public Information Drugs and Alcohol Insider Trading Wages and Hours Confidential Employee Information Approval to Contract EMBRACE OPENNESS 9 Spending Denny’s Money Integrity Equipment Valuing Diversity Intellectual Property Harassment Conflicts of Interest Sexual Harassment Community and Political Involvement CONCLUSION 21 GOT QUESTIONS? PLEASE CONTACT: Your supervisor, HR manager or the Ethics and Compliance Hotline at (844) 954-3349. NEED TO REFERENCE A POLICY? For more information on policies referenced in this Code, you may refer to your employee guidebook on Workday or request from your supervisor or HR manager. DENNY’S CODE OF CONDUCT June 2, 2021 EFFECTIVE Scan the QR Code or visit http://dennysmobile.ethicspoint.com/ to file a report. © 2021 Denny’s, Inc 2 DEAR DENNY’S TEAM MEMBER I am honored to present to you our Denny’s Code of Conduct. Our Denny’s Purpose and Denny’s Guiding Principles are interwoven throughout. They are in fact the essence of who we are as people, in a culture that respects and honors others and a great source of our pride at Denny’s. Together, Our Principles and Our People are why Denny’s is so special and why I am proud to lead this Company. Please read the Code and use it as a roadmap for your personal standards and business conduct. Doing the right thing is not always easy, but it is essential for the foundation of trust and to build lasting success. Thank you for being part of the Denny’s team and for your commitment to this Code. Our collective acts with integrity ensure prosperity now and for years to come, sharing the love and what we love the most, for We Love to Feed People at Denny’s! John Miller Chief Executive Officer 3 GUIDING PRINCIPLES Every hour of every day, we bring friends, family and communities together by serving up classic, affordable comfort food in a warm, embracing, come-as-you-are environment. Building on our position as the Classic American Diner, we will become the world’s largest most admired and beloved family of local restaurants. We will accomplish this by an unwavering commitment to our Guiding Principles. GUESTS FIRST HUNGRY TO WIN We are all seeking to enrich Work hard. No shortcuts. our guests lives. At Denny’s, we are never satisfied They’re not customers or consumers. standing still. We are always moving They are our guests and we invite forward, striving for more, hungry them into our homes with open for greatness. We are open to arms. They are the very reason we fresh, innovative thinking. We are in business and the center of believe we will succeed through everything we do. teamwork, accountability and pushing the boundaries of ourselves and our Brand. EMBRACE OPENNESS Invite others in. Build bridges. Open means so much more than THE POWER OF WE just being open for business 24/7. Honorable. Honest. It means being open to all people, Our Denny’s family is our most appetites and budgets. It says we important asset. We trust, support are open-minded and open to new and respect each other and work ideas. Honest, warm and inviting. together for the greater good. We Open is the way we think and act recognize the contributions of all and every hour of every day. empower each and every one of us to achieve great things. Together, we will celebrate our successes and PROUD OF OUR HERITAGE have fun doing it. What we do lives on after us. Plant trees whose shade you will never sit in. “Where will you be when you get where you’re going? We are the classic American diner How can you know that you’re taking the right road? and proud of everything that means. Follow the crowd and you can lose your identity. Since 1953, we have served quality Follow great Guiding Principles and wherever you are food and healthy portions at a fair going you will enjoy the journey more!” price. No matter where we are, our John Miller light is always on, inviting guests Chief Executive Officer around the world to a place where everyone is welcome. 4 INTRODUCTION Denny’s Code of Conduct is a guide to our ethical and legal responsibilities. The Code and its underlying policies are meant to present some of the Denny’s policies and procedures regarding standards of conduct, all built upon our five Guiding Principles. We expect all Denny’s employees to abide by the Code. Your hard work and dedication will help us remain one of the world’s most admired and beloved family restaurants. ENFORCEMENT OF THE CODE Denny’s enforces the Code through careful supervision, consistent discipline for violations and implementing appropriate remedial measures. Nothing in this Code affects the at-will nature of your employment. REPORTING RAISING A CONCERN If you are ever in a situation in which you think there is or might be something wrong, including a possible violation of the Company’s policies or applicable laws or regulations, you have a duty to report it. When you raise a concern, it helps us correct specific problems and identify areas that require improvement. You may choose to remain anonymous while raising a concern. If you believe that a violation has taken place, report the situation promptly to your supervisor, Human Resources manager or by calling the Ethics and Compliance Hotline at (844) 954-3349. Additionally, if you have reason to believe that there has been inaccurate accounting or you suspect misconduct or an irregularity in the Company’s financial reporting, please see the Financial Integrity section for further reporting options. WHAT TO EXPECT | NO RETALIATION Denny’s takes reports of misconduct seriously. We investigate allegations of misconduct and take appropriate disciplinary actions. If you are ever involved in an internal investigation, you must cooperate fully and provide all requested documentation. You can report any violation of this Code without fear of retaliation. Denny’s does not permit retaliation against anyone who, in good faith, reports or participates in an investigation of a possible violation. Good faith means that you have made a genuine and honest attempt to provide accurate information, even if it turns out you were mistaken. 5 GUESTS FIRST Our guests are the reason we have been in business for over sixty years. We strive to exceed our guests’ expectations and make them feel welcome and valued every time they step through our doors. RESPECT PRIVACY Every Denny’s guest must be treated As a service corporation, Denny’s If you are a witness to the misuse of with respect and dignity. We will not regularly encounters guests’ private guests’ private information, please tolerate discrimination, harassment or information, such as names, e-mail immediately report the situation to any other form of disrespect towards addresses, phone numbers and credit your immediate supervisor or by calling guests. card information. Denny’s abides by all the Ethics and Compliance Hotline at applicable consumer protection laws. (844) 954-3349. QUALITY Denny’s guests expect quality service and food. Every employee should strive to provide a quality experience for every guest, every time. Short-cutting quality service or food is not acceptable. By making sure each guest has a great experience, we help ensure that they will keep coming back to see us. “Denny’s is a domestic and international treasure. Our guests have relied upon on our tasty comfort food, friendly service and comfortable environment for generations. The reason we have had this kind of brand loyalty and stability resides in the Guiding Principles we strive to live up to each and every day.” Steve Dunn Senior Vice President, Chief Global Development Officer 6 THE POWER OF WE Denny’s success is dependent on the character of our employees. Denny’s is committed to providing a productive, safe and fair work environment to every employee. We each have a responsibility to our co-workers to make our workplace safe and enjoyable. Managers will lead by example and have an open door for employees to voice their ideas and concerns. EQUAL OPPORTUNITY EMPLOYER Denny’s provides equal employment opportunities in hiring, promotions, wages, benefits and all other privileges, terms and conditions of employment without regard to age, race, color, religion, disability, national origin, gender, sexual orientation, gender identity or expression, ancestry, citizenship, military status or any other characteristic protected by law. For more information, see the “Equal Employment fosters growth and development and employment decisions. For more Opportunity” policy. promotes the value of our team’s information, see the “Employment of diversity. We expect our employees Relatives” and “Favoritism and RESPECT OTHERS to treat our guests, suppliers and Fraternization” policies. As part of Denny’s team, we expect competitors in the same way. In all your employees to treat each other with business activities, you should be honest, VALUING FRANCHISEES respect and dignity. Employees should respectful and honorable. We strive to maintain great relationships create a positive work environment that with our franchisees. Franchisees are is free of harassment and discrimination, MANAGER EXPECTATIONS our most important business partners Denny’s managers lead by example. and are an essential part of our success.

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