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.

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. “We all represent the Denny’s brand Managers must make sure they and their Franchisees should be treated honestly, and it’s important that we act with employees review and follow this Code. ethically and with respect. integrity and deliver respect to each Managers must keep an open-door We abide by our franchise agreements. other, our franchisees, our guests policy so employees feel comfortable Employees are not authorized to and our community. Doing the right communicating their questions and waive or alter any term of the and honorable thing supports our concerns. Retaliation against an franchise agreement without prior individual feelings of well-being and employee who has raised an issue in good approval from the Legal Department. self-respect. I have great pride in faith by managers or other employees The Legal Department must be working for a company that has such will not be tolerated. consulted before terminating a high standards and we all should Denny’s managerial employees are not franchise or threatening or commencing strive to meet or exceed them. These allowed to manage someone with whom an unlawful detainer proceeding. Guiding Principles set the path.” they have a family, romantic or dating Without prior approval from the Legal Michael Furlow relationship to avoid conflicts of interest Department, no person is authorized Senior Vice President, and misunderstandings. Such relationships to promise anything to potential Chief Information Officer may influence or appear to influence franchisees that is in addition to or

7 contrary to the information in the Denny’s sponsored event is not offering circular, including statements tolerated. At certain company events, about sales, costs or income. alcohol consumption may be permitted if FOR EXAMPLE approved in advance by a vice president Jessie clocks out for his meal break, SAFETY or an executive officer of the Company. but his manager, Paula, insists Jessie Denny’s is committed to maintaining a You are part of Denny’s family and we complete side work while off the safe work environment. We must comply are here to help you. If you feel that clock. Paula has violated company with all occupational safety and health you have developed an addiction to policy by asking Jessie to work off laws. Employees are expected to attend or dependence on alcohol, illegal or the clock and will be reprimanded all required safety training sessions and prescription drugs, please contact your up to and including termination. work diligently to follow all operating Human Resources representative. For Jessie should report all time worked practices and procedures designed to more information, see the “Alcohol and and should report Paula’s actions keep yourself and others safe. Drug-Free Workplace” policy. to Jessie’s supervisor, and the We work hard to be accident-free and Ethics and Compliance Hotline to create an environment in which all WAGES AND HOURS at (844) 954-3349. team members are safe. We are thankful for all that you do and Please immediately report all accidents, are committed to paying you properly. injuries and unsafe practices or conditions Always accurately record and maintain to your immediate supervisor. records showing your time worked. Never work off the clock or skip your DRUGS AND ALCOHOL assigned meal or rest breaks. As part of our commitment to a safe and Denny’s is committed to following healthy work environment, Denny’s every law and regulation concerning hours prohibits being impaired physically or worked and pay, including the hours and mentally by drugs or alcohol in the duties of minors, paying overtime and workplace. Being under the influence, minimum wage. For further information, possessing, distributing or using illegal see the “Employee Time Records,” drugs or alcohol on company time, “Hours of Work-Support Center” and while on company property or at any “Rest & Meal Periods” policies.

8 EMBRACE OPENNESS Denny’s is committed to having a workforce made up of varied experiences, backgrounds and viewpoints. Being open and receptive to new ideas and perspectives helps us to best understand, serve and accommodate our guests.

INTEGRITY HARASSMENT Having integrity means doing the right Employees must create an environment thing—even when it isn’t easy or popular. free of harassment and always report any FOR EXAMPLE Employees must be honest, patient, form of harassment. We will not tolerate Janile’s co-workers have begun respectful and law-abiding. These values harassment in our workplace by an making off-color remarks about will continually lead us to be a better employee, supervisor, guest or supplier. Janile’s sexual orientation. employer while providing superior service This includes harassment based on age, She feels uncomfortable and to our guests. race, color, religion, disability, national offended by the remarks. Janile’s origin, gender, sexual orientation, co-workers are breaking Denny’s VALUING DIVERSITY gender identity or expression, ancestry, anti-harassment policy. Janile Denny’s embraces the strengths and citizenship, military status or any other should report this behavior to her talents that come from having a characteristic protected by law. workforce with diverse backgrounds. supervisor and her Human Harassment can take various forms; for We will not tolerate discrimination in our Resources representative or by purposes of this Code, harassment workplace by an employee, supervisor, calling the Ethics and Compliance includes, but is not limited to, use of racial guest or supplier. Discrimination based Hotline at (844) 954-3349. or ethnic slurs, offensive remarks, bullying, on age, race, color, religion, disability, Additionally, any Denny’s inappropriate jokes, unprofessional national origin, gender, sexual orientation, employee who has witnessed electronic communications (including gender identity or expression, ancestry, such conduct should report it. communications on social networking citizenship, military status or any other websites) and other visual, verbal or characteristic protected by law is physical misconduct. prohibited.

FOR EXAMPLE Kayla, a Denny’s server, tells Rehan, a Denny’s hostess, that she does not serve older guests. Kayla is engaging in age discrimination and is breaking Denny’s policy. Rehan should report this behavior to his supervisor and his Human Resources representative or by calling the Ethics and Compliance Hotline at (844) 954-3349.

9 SEXUAL HARASSMENT Physical, verbal or visual sexual harassment is not acceptable. Examples of unacceptable sexual behavior include, but are not limited to: • Sexual advances • Sexually explicit language and off-color jokes • Sexually suggestive looks or comments • Unwelcome or unnecessary physical contact • Displaying sexually suggestive pictures or objects • Offering or conditioning an employment benefit in exchange for sexual favors • Sexual harassment towards employees through social networking websites For more information, see the “Anti-Harassment” policy. If you witness or are subject to discrimination, harassment or disrespectful behavior on behalf of a co-worker, supervisor, guest or supplier, please immediately report the situation to any of the following: (1) Immediate Supervisor (2) Human Resources (3) the Ethics and Compliance Hotline at (844) 954-3349. POLITICAL INVOLVEMENT way perceived as representing Denny’s COMMUNITY AND POLITICAL Denny’s supports the right of its and that their personal contributions are employees to participate in political at their own expense. Denny’s will not INVOLVEMENT activities. Contributing to any political reimburse employees for their personal COMMUNITY INVOLVEMENT activity is entirely voluntary; you should political contributions. Denny’s is committed to increasing the never feel pressured by anyone at quality of life in the communities that we Denny’s to contribute to political “At Denny’s, we are committed serve. We regularly contribute money activities in any way. to advancing diversity, equity and and other resources to not-for-profit Employees’ community and political inclusion in our restaurants, our organizations serving our communities. involvement should not interfere with workplace and our communities. We encourage every employee to their work performance or responsibilities Our “Non-Negotiable Rules We Live support the charitable organizations of at Denny’s. Employees must ensure that By” dictate that everyone is their choice and to volunteer for their personal activities are not in any welcome at Denny’s, everyone is community activities. treated like our favorite guest and everyone is shown kindness and respect. Every day, we strive to uphold these values to make Denny’s a better business, a better employer and a better member of the diverse communities we serve.”

April Kelly-Drummond Head of Diversity, Equity, Inclusion & Multicultural Engagement

10 PROUD OF OUR HERITAGE Since 1953, we have served good food at a fair price. Some of the most basic ways we show pride in our heritage are simple—by treating others ethically and by following the law.

FOOD SAFETY Providing safe food to our guests is critical. As a food service company, our guests’ well-being depends on our food safety practices. Without exception, every food safety law and regulation must be followed. Employees may never make claims on behalf of Denny’s about our products unless that claim has been approved by the Chief Food Safety Officer. FOR EXAMPLE Andy, a Denny’s cook, was Prohibited practices include, but are approached by Channel Five News not limited to: “Food safety and food quality are asking about the magical healing critical to the bottom line and the ® • Agreeing with competitors not to powers of Denny’s Grand Slam. success of our Denny’s brand. The deal with vendors, distributors or Andy is prohibited from speaking Denny’s HACCP (Hazard Analysis other competitors. for Denny’s on the subject without and Critical Control Points) system • Agreeing or consulting with approval from Denny’s Chief Food depends on educating and training competitors regarding prices, terms, Safety Officer. management and employees in the products or conditions of sale or importance of their role in producing production. safe/quality products. We will not HIRING SUPPLIERS • Agreeing with competitors regarding compromise on food safety or food When hiring suppliers, employees should bids to be submitted during an auction. quality in our restaurants. It’s the one always strive for the best possible value • Agreeing with competitors to split fundamental element that we bet for Denny’s. This usually requires territories or guests. our business on every day!” considering the price, quality, service, We respect our competitors and want conditions of the proposed deal and to compete fairly. We don’t want Mike Starnes soliciting competing bids from competitors’ confidential information. Vice President, Brand Protection, potential suppliers. Should you come into possession of a Quality and Chief Food We expect our suppliers to abide by competitor’s confidential information, Safety Officer our Supplier Code of Conduct, which is report it immediately to the Ethics and available on our public website. Compliance Hotline at (844) 954-3349. advertising or publicity materials. Denny’s is committed to using truthful and COMPETITION ADVERTISING accurate advertising that complies with Antitrust and competition laws protect The Federal Trade Commission and state all applicable laws. Any advertising copy consumers, encourage fair competition laws and regulations prohibit the use of released by the Company shall contain and must be followed by all employees. false or misleading information in any truthful and accurate representations of

11 all information, including prices, quantities, content and times. RECORD MAKING AND KEEPING Denny’s leadership and investors rely on our records. Denny’s requires every department to provide honest and accurate record keeping and financial reporting. All financial records, books and accounts must accurately reflect financial transactions and events and conform to generally accepted accounting principles. No document or record may be misleading or falsified and no undisclosed accounts of assets may exist. FRAUD We are committed to operating with the highest integrity. Denny’s employees must not participate in reporting, internal accounting controls purpose of influencing an official act or deceptive, dishonest or fraudulent or any auditing matter. Employees must decision in order to obtain an improper activities. Fraudulent activities include report the situation and may do so by advantage. The term “foreign official” concealing, altering or falsifying mailing a written statement describing includes “any officer or employee of a information. Actions such as altering the suspected activity to Denny’s Audit foreign government or any department, sales reports and misstating Denny’s and Finance Committee of the Board agency, or instrumentality thereof, or financial information are prohibited. If of Directors at the following address: of a public international organization, you become aware of any fraudulent Denny’s Corporation or any person acting in an official activity, it is your responsibility to Audit and Finance Committee capacity for or on behalf of any such report that information to your 3422 Old Capitol Trail government or department, agency, or immediate supervisor or the Ethics and PMB# 1996 instrumentality, or for or on behalf of Compliance Hotline at (844) 954-3349. Wilmington, DE 19808 any such public. Accepting or soliciting a bribe is not FINANCIAL IRREGULARITIES BRIBERY permitted. Nothing of value may be If you believe that there has been any We do not tolerate bribery or other given or received in violation of the inaccuracy in Denny’s records, report the corrupt practices. Never bribe anyone Foreign Corrupt Practices Act of the situation immediately. Any employee for any reason. Bribery of public officials United States Code. may, in good faith, anonymously and in the U.S. and abroad is illegal. You may confidentially report concerns of not pay, promise or authorize a suspected misconduct, irregularity, abuse payment, directly, indirectly or through or illegal activity in connection with a third party, to a public U.S. official, FOR EXAMPLE Denny’s accounting practices, financial foreign official or political party for the Madison, a Denny’s Support Center employee, is in charge of reviewing expense reports for the members of her group. Lately, Madison has noticed that Esteban, a fellow Denny’s employee, has had unusually high expenses. On reviewing Esteban’s latest report, Madison realizes that he is reporting false expenses and fraudulently collecting more from Denny’s than he is entitled. It is Madison’s responsibility to report her concerns.

12 Before offering any gifts or other limited. Courtesies could even include are protected by the National Labor business courtesies to a foreign official simple items such as meals and Relations Act. For more information, or if you know of a situation where a entertainment. These laws are often see the “News Media” policy. bribe occurred or was attempted, complex and impose serious civil and contact the Ethics and Compliance criminal penalties for violations on SOCIAL MEDIA Hotline at (844) 954-3349. To learn both the company and employees Denny’s appreciates the value created more, please see Denny’s Foreign participating in improper practices. through social media and participates Corrupt Practices Act Policy. Contact the Legal Department if you on Facebook, Twitter and other social are unsure whether a particular networking websites. Be aware that, as GOVERNMENT CONTRACTS activity is appropriate. a Denny’s employee, your behavior on In pursuing business with governments social media presents certain risks and of various countries, the standards of COMPANY COMMUNICATIONS carries certain responsibilities. conduct and prohibited practices may AND THE PRESS differ from those adhered to in To ensure that the Company delivers commercial business. For example, in the FOR EXAMPLE an appropriate, unified message about U.S., the giving of business courtesies Terrell, a Denny’s supervisor, events that may occur at our restaurants, from the government is severely witnesses a newsworthy incident in Denny’s has designated certain his restaurant. A local newspaper authorized spokespersons to make calls the restaurant and Terrell FOR EXAMPLE public statements to the news media answers the phone. The reporter Willie, a Denny’s accountant, on behalf of Denny’s. In situations that on the phone is “calling for a discovers that improper reporting draw attention to the Denny’s brand, comment from Denny’s.” Terrell of foreign currency numbers it is imperative that one person speaks should indicate that he is not a has inflated earnings from our for Denny’s to avoid giving misinformation company spokesperson and international business. Willie to the media. No one else is authorized should not provide a report of immediately reports the problem to speak to the press on behalf of the incident to the newspaper. to his supervisor, Tiana, who Denny’s without express approval Terrell should ask for the acknowledges the mistake and from Investor Relations or the Legal reporter’s contact information promises to rectify the problem. Department. To alert Denny’s of a and call Denny’s news media hotline A month after his conversation situation that may receive negative (CALM) at 1 (800) 786-7475. with Tiana, Willie learns that she media attention, please call the CALM line at 1 (800) 786-7475. The CALM line purposefully ignored his report. Please make sure you are thoughtful is an internal means of communication Willie may anonymously report when sharing online, especially if your and should not be given to the media. the irregularity by dropping a comments involve your work with Nothing in this section is intended to letter in the mail to the Audit and Denny’s. Additionally, always be clear address or prohibit employee Finance Committee. that the views and opinions you express communications with third parties that are your own. As stated in the Company Communications and the Press section, never speak directly on behalf of Denny’s, as we have a team dedicated just for that. For more information, please see Denny’s “Social Media” policy. ENVIRONMENT Denny’s recognizes the need to carry out our activities in an environmentally responsible manner. Denny’s employees and its suppliers must abide by all environmental laws, rules and regulations. C.A.L.M. Crisis Assistance Line for Management

13 HUNGRY TO WIN At Denny’s, we are constantly looking ahead and striving for more. In reaching and exceeding our goals, we must make sure to always follow Company rules and do the right thing.

MATERIAL NON-PUBLIC INFORMATION Through your work, you may acquire material non-public information about Denny’s or other companies. “Material” information is any information likely to affect the price of stock and securities or is likely to be considered important by reasonable investors, including speculative investors. “Non-public” information is any information that has not been properly disclosed. Information is properly disclosed only when it is released broadly to the general marketplace and the investing public has the time to absorb the information. Examples of material non-public information may include, but are not limited to, information about: • Sales and earnings results • Mergers or acquisitions • Ongoing litigation • Management changes • Marketing plans. or communications made to a person respond to a “market rumor,” members Denny’s is committed to timely, who owes Denny’s a duty of trust or of management should respond with a consistent, fair and credible confidence. Otherwise, no disclosure of firm “it is the Company’s policy not to dissemination of information to the material non-public information should respond to market rumors” and they public, in keeping with legal and be made without first consulting the should do so consistently, without regard regulatory requirements, to enable Legal Department. However, should to whether the particular rumor may be orderly behavior in the capital markets. Denny’s release material non-public good or bad, true or false. Such inquiries As a result, Denny’s has strictly defined information to an investor or securities should be reported immediately to the channels for properly releasing market professional other than under General Counsel, Chief Financial confidential Company information to the special circumstances referred to Officer or head of Investor Relations. the public. We never release material, above, then it is our policy to immediately Further information regarding non-public information to any third publicly disclose such information. disclosures may be found in the party except under special circumstances Unless Denny’s is the source of a “market “Disclosure of Information to Investors, such as communications made pursuant rumor,” there is generally no duty to Securities Market Professionals and to signed confidentiality agreements respond to the rumor. When asked to the Media” policy.

14 trading days after any public INSIDER TRADING announcement by the Company, CONFIDENTIAL EMPLOYEE It is illegal for employees to use material including the filing of reports with INFORMATION non-public information when deciding the Securities and Exchange Denny’s strives to keep our employees’ to buy or sell securities such as stock, Commission and other regulatory information private and secure. bonds or options of Denny’s or any other authorities. Confidential employee information company (known as “insider trading”). includes employees’ social security It is also illegal to share insider • Confining your trading activity to numbers, phone numbers, birth dates information with someone else so they the 45-day periods beginning two and other employee data protected can buy or sell securities (known as full trading days following the release by law. Employees should exercise “tipping”). If you obtain material of annual or quarterly financial results. caution when handling confidential non-public information about our If you have any questions or concerns employee information and never disclose Company or any other company in the about insider trading, see the such information in public places or course of your employment, you should “Insider Trading Guidelines” policy or online forums. Denny’s abides by all consider it confidential and refrain contact the Ethics and Compliance applicable consumer protection laws. from trading securities based on the Hotline at (844) 954-3349. information. For more information, see the “Management of Employee If you are unsure whether the Information” policy. information of which you are aware is FOR EXAMPLE material and non-public, you should Tyler, a Denny’s Support Center APPROVAL TO CONTRACT resolve the question before trading, employee, overhears a Denny’s Only sign a contract on behalf of recommending trading or divulging the executive discussing the incredible Denny’s after all the following are met: information. If there is any doubt, you earnings performance that Denny’s should consult the Ethics and • The contract has been approved by has yet to announce for this quarter. Compliance Hotline at (844) 954-3349. the Legal Department (if you are Tyler has acquired material Our executive officers are subject to using an approved Denny’s form non-public information and U.S. the following restrictions and could be contract, you don’t need further securities law and our Company a consideration as you determine your Legal approval unless you have made policy prohibit Tyler from buying responsibility under this section: changes to the form contract, you Denny’s stock before the earnings have reason to believe changes • Not undertaking any trade are announced. should be made or you are using it transaction until at least two full

15 for something other than its intended purpose). • You have reviewed the contract, understand its terms and have decided that entering into the contract is in Denny’s best interest. • You are authorized to enter the contract under company policy. For more information, review the “Financial Approval” policy. SPENDING DENNY’S MONEY We must generate a good return on the money we spend. When you spend Occasionally, some of Denny’s assets as a Denny’s employee are Denny’s money on Denny’s behalf or submit an may be sold to employees. Such sales property. Without prior approval from expense for reimbursement, make sure must be properly approved by an the Legal Department, you may not that the cost is reasonable, directly officer of the Company. All reveal confidential information on related to company business and confidential electronic information the internet through any means, supported by appropriate must first be permanently deleted by including blogging, chatting, email documentation. Denny’s has issued a our Information Technology or social networking. Travel and Entertainment Expense Department. Likewise, we must respect the Policy intended to define guidelines for intellectual property of others and INTELLECTUAL PROPERTY business travel and reimbursement of may not use protected third-party Denny’s intellectual property (for related expenses and to help assure intellectual property without proper example, our recipes, promotional control of those expenses. For more written consent. information regarding reimbursable calendars, trademarks, trade secrets, purchases, see the “Travel and know-how, planned projects, sales and How to keep our information Entertainment Expense” policy. If you other data) is valuable. Always protect confidential: are unsure whether you should spend our intellectual property and remember • Require suppliers and consultants Denny’s money or request an expense that Denny’s owns the work you to maintain strict confidentiality of reimbursement, ask your supervisor produce for us to the extent permitted any Denny’s non-public information. or submit a question to the Ethics and by law. This means the ideas, processes • Be alert to inadvertent disclosures Compliance Hotline at (844) 954-3349. and inventions you provide for Denny’s and securely handle confidential information. EQUIPMENT “When I was young my father taught • No employee has the authority to We have a responsibility to use company me to play chess. He first taught me release confidential information to property for Denny’s business and not the fundamental rules; develop your anyone outside of Denny’s without for any improper or unlawful use. back pieces first, control the middle express approval. Company property includes, but is not of the board, don’t move a pawn un- • Employees separated from Denny’s limited to, Denny’s equipment, corporate less you have a good reason and so on. must return any confidential funds, software, office supplies and I was taught that as long as I followed information prior to leaving work. inventory. You are responsible for the rules, even if I couldn’t quite see • Non-public financial information maintaining Denny’s property under your the end game, when I got to the end should be sent to franchisees in control and should take reasonable steps game, the fact that I followed the accordance with Denny’s to protect it from theft, loss or damage. rules would put me in a much stronger Franchisee Communication Policy. For further information, see the “Use position. Chess and life are very much of Information Resources and the same; if one follows the rules, like Communication Systems” policy. our Guiding Principles, even if we don’t FOR EXAMPLE Denny’s reserves the right to examine see the results right away, one can Ling, a Denny’s Human and monitor any and all content on be sure that in the future they will be Resources manager, uses a Denny’s Denny’s equipment. Denny’s employees successful because of that commitment computer to email her son. Ling should have no expectation of privacy to our Guiding Principles.” should have no expectation of when using Denny’s systems such as Ramon Torres privacy and Ling’s email may be corporate-owned phones, computers Vice President, reviewed by Denny’s without and corporate email and other Operations Services Ling’s knowledge or permission messaging systems.

16 GIFTS AND ENTERTAINMENT business courtesies, including meals CONFLICTS OF INTEREST Use your best judgment and follow and entertainment, may be It is important to realize that because the guidelines below when receiving permissible if: you work for Denny’s, you influence our gifts. Unsolicited, non-cash gifts and business and have access to confidential • It will not affect or appear to affect information. As a Denny’s employee, your business judgment your personal interests may not interfere FOR EXAMPLE • It is a commonly accepted business or appear to interfere with your ability courtesy John, a chef in Denny’s test kitchen, to make sound business decisions on • It is “nominal” both in value and recently worked on a product Denny’s behalf. When you are in a frequency development team for a delicious situation where you could pursue • There is an understanding that you new pancake creation, ‘Bonkers personal interests for you or your friends are in no way obligated by your Bananas,’ which incorporates or family at the expense of Denny’s, acceptance of the gift cutting-edge technology to increase our shareholders or our guests, you may • You did not ask for the gift the fluffiness of a pancake while have a conflict of interest. Employees • The gift is not cash or a cash maintaining the consistency of the and officers must always avoid possible equivalent, such as a gift card, loan bananas. John’s boss, Emily, told conflicts of interest and take the or stock everyone involved not to discuss the necessary steps to avoid the appearance new product with anyone outside of If questions or concerns arise, please of a conflict of interest. the team before the product contact the Ethics and Compliance If there is an appearance of a conflict launches. A week later, John takes a Hotline at (844) 954-3349. of interest, you must: position at Pete’s Pancake Cottage, A “nominal” gift is one that is (1) Fully disclose all relevant facts to a leader in the field of pancake insignificant and is reasonable to receive your supervisor and (2) not influence technologies. His first week on the given the situation. Gifts that are in or be within the decision-making job, John realizes that he accidentally excess of a nominal amount or could process. held onto a copy of the ‘Bonkers appear to affect your personal Bananas’ recipe that he threw in his judgement should be reported using There are common relationships and bag before leaving Denny’s. John the “Gifts and Entertainment Disclosure circumstances that can create or should return the recipe and refrain Form” in Workday to determine whether appear to create a conflict of interest. from sharing it because it is the or not it is permissible. If the gift is Several common scenarios that can intellectual property of Denny’s. determined to be impermissible upon give rise to a conflict of interest are review, one of the following actions will given below. be required: (1) return the gift or pay the value of the gift to the giver, (2) pay the value of the gift to a charity supported by Denny’s or the giver, (3) donate the gift to charity or (4) divide the gift among an employee group, if appropriate. Occasionally vendors will offer to pay for items such as travel, lodging,

FOR EXAMPLE Ebony, a Denny’s employee in Purchasing, has a working relationship with several of her suppliers for dairy products. Jason, a supplier of milk from New York, dropped by her office to ask for more of Denny’s business. Jason leaves a box on her desk with a expensive watch. Ebony may not accept the gift because acceptance would appear to cloud her judgment for what is best for Denny’s.

17 conference fees or event tickets. • Does not interfere with the employee’s Flying Biscuit, The Good Egg, Jimmy’s If you are offered such items, report job performance at Denny’s Egg, Keke’s, LePeep, Smitty’s, Sunset it to your supervisor and Denny’s • Is not detrimental to Denny’s best Grill and Swiss Chalet. Restaurant General Counsel. interest concepts evolve and new restaurants • Does not create an actual or open, so if in doubt, contact your GIVING GIFTS AND potential conflict of interest supervisor or Denny’s Legal Department. ENTERTAINMENT It may be acceptable for Denny’s Employees may not serve in any capacity For more information, see the employees to provide business-related with any competitor of Denny’s “Employment Outside the Company” courtesies and entertainment if it is (including franchisees of competitors) policy. or any company that partners with or authorized, job-related, customary in PERSONAL INVESTMENTS nature and not overly lavish or excessive. seeks to partner with Denny’s without A financial conflict of interest can arise prior written permission from the Legal when your judgment could be influenced BUSINESS OPPORTUNITIES Department. Employees’ spouses may or might appear to be influenced, by Business opportunities discovered not serve as a manager or in any other through your work for Denny’s belong the possibility of personal financial gain. influential capacity with any competitor Unless part of a publicly available mutual solely to Denny’s. You may not use of Denny’s or any company that Denny’s information, property or your fund, you may not own an interest in partners with or seeks to partner with any full-service restaurant in the position with Denny’s for personal gain Denny’s or a competitor of Denny’s or for the benefit of friends or family. “family dining” segment without prior without prior written permission from written permission from an executive FRIENDS AND RELATIVES the Legal Department. officer of the Company. Examples of There is a conflict of interest when you Denny’s competitors generally include restaurants in the “family dining manage or hire someone with whom breakfast and family dining restaurants, segment” include but are not limited you have a family, romantic or dating such as IHOP, Bakers Square, Black Bear relationship. Your relationship could Diner, Bob Evans, Carrows, Coco’s, influence or appear to influence, your Country Kitchen, Country Waffles, FOR EXAMPLE judgment. You may not supervise, Cracker Barrel, Eat ‘n Park, Farmer Boys, Chris works in Denny’s Finance directly or indirectly, any family Friendly’s, Frisch’s or Big Boy, Huddle Department. Chris’s wife, Sarah, members or any employee you are House, Lumberjacks, Lyon’s, Marie is offered an executive position dating or romantically involved with. Callender, Mimi’s, Norms Original with Waffle House. Chris must OUTSIDE EMPLOYMENT Pancake House, Perkins, Metro Diner, first obtain approval from the Employees may hold employment Ruby’s Diner, Shari’s, Shoney’s, Silver Legal Department before Sarah outside of their employment at Diner, Steak ‘n Shake, Village Inn, is able to accept the offer from Denny’s as long as such work: Waffle House, Weck’s, Another Broken Waffle House. Egg, Broken Yolk, Egg and I, First Watch,

18 to the examples of competitors listed This list of examples and prohibited CONCLUSION in the “Outside Employment” section conduct is for illustrative purposes. It is Thank you for reading Denny’s Code of of this Code. If you are unsure whether not exhaustive and does not contemplate Conduct! We are happy that you are part a particular investment is permissible, every nuance of conflicts of interest of the team and value your contributions you must seek the guidance of the or of the specific factual situations to Denny’s. Use the Code and the Legal Department before investing. that might arise. corresponding company policies and Unless part of a publicly available mutual REPORTING procedures as your guide and let us know fund, you are prohibited from owning If you are aware of a conflict of interest if you have any questions. We are always a substantial interest in any publicly or potential conflict of interest or are not here to help you do the right thing. traded business which is a supplier, sure about a particular situation, please franchisee or customer of Denny’s contact the Ethics and Compliance without prior written permission from Hotline at (844) 954-3349. an executive officer of the Company. As a general guide, a “substantial interest” includes ownership by you or FOR EXAMPLE your immediate family of more than James, a Denny’s employee, was five percent of a business or more than recently offered the opportunity five percent of the total assets of you to invest in a substantial portion of or your immediate family. You may not Cracker Barrel. Because Cracker own any interest in any privately-owned Barrel is a competitor of Denny’s, supplier, competitor or a company James must seek written approval seeking to do business with Denny’s of the investment from an without prior written permission from executive officer. an executive officer.