Standards of Business Conduct The Promise of the Golden Arches “The basis for our entire business is that we are ethical, truthful and dependable.” “The basis for our entire business is that we are ethical, truthful and dependable. It takes time to build a reputation. We are not promoters. We are business people with a solid, permanent, constructive ethical program that will be in style…years from now even more than it is today.” — Ray Kroc, 1958 2 Standards of Business Conduct 3 McDONALD’s VALUES We place the customer experience at the core of all we do Our customers are the reason for our existence. We demonstrate our appreciation by providing them with high quality food and superior service, in a clean, welcoming environment, at a great M c value. Our goal is QSC&V for each and every customer, each and every time. DONAL We are committed to our people D ’ S We provide opportunity, nurture talent, develop leaders and reward achievement. We believe VALUE that a team of well-trained individuals with diverse backgrounds and experiences, working together in an environment that fosters respect and S drives high levels of engagement, is essential to our continued success. We aspire to be our customers’ favourite We believe in the McDonald’s System McDonald’s business model, depicted by the place and way to eat. “three-legged stool” of owner/operators, suppliers, and company employees, is our foundation, and the To achieve this mission, balance of interests among the three groups is key. our actions as individuals and as a system must We operate our business ethically reflect our Values. Sound ethics is good business. At McDonald’s we hold ourselves and conduct our business to high standards of fairness, honesty, and integrity. We are individually accountable and collectively responsible. We give back to our communities We take seriously the responsibilities that come with being a leader. We help our customers build better communities, support RMHC, and leverage our size, scope and resources to help make the world a better place. We grow our business profitably McDonald’s is a publicly-traded company. As such, we work to provide sustained profitable growth for our shareholders. This requires a continuing focus on our customers and the health of our system. We strive continually to improve We are a learning organization that aims to anticipate and respond to changing customer, employee and system needs through constant evolution and innovation. 4 Standards of Business Conduct 5 TABLE OF CONTENTS 8 Introduction 32 Our Communities 9 The Standards of Business Conduct 33 Community and Giving Back T 9 Applicability of Standards 34 Political Activities A B 9 Publication, Amendments and Waivers 35 Corporate Social Responsibility LE Environmental Responsibility 10 Management Commitment 35 O 35 Nutrition and Well-Being 10 Additional Responsibilities of F C Supervisory Employees 35 Sustainable Supply Chain ON 10 Personal Accountability T 11 Open Communication/ 36 Profitable Growth EN Business Integrity Line 37 Fair Competition and Antitrust TS 12 Our Customers 38 Trade Practices 13 Product Quality and Safety 39 Inside Information and Securities Trading 14 Confidential Information 39 Communicating with the Public 14 Marketing 39 Government Inquiries 15 Personal Data 40 Continuous Improvement 16 Our People 41 Corporate Governance and Internal Controls 17 Employment Experience 41 Internal Investigations 17 Protection Against Retaliation 42 Reporting Concerns 18 Human Rights and the Law 18 Respect and Dignity 43 Additional Resources 19 Inclusion and Diversity 43 People/Your Extended Team 19 Safe Workplace 43 Policies/Your Extended Information Network 19 Alcohol and Drugs 43 Reporting Suspected Violations of the Standards 20 McDonald’s System 44 Keeping the Shine on our Arches 21 Acting in the Best Interest of the System 21 Owner/Operator Relationships 22 Supplier Relationships The relationship that exists between McDonald’s and each of its employees is employment at will. This means that either party to 24 Ethics the employment relationship may terminate the relationship at any time for any reason, with or without cause or prior notice. Nothing 25 Protecting Company Assets in the Standards of Business Conduct creates any contractual 26 Conflicts of Interest rights between McDonald’s, its employees or any third party. 26 Doing Business with Family McDonald’s reserves the right to determine how the Standards and Friends apply to any particular situation, and to amend or modify the 26 Outside Employment and Standards as appropriate without prior notice or agreement. Other Business Arrangements The applicability of any amendments or modifications to an 27 Gifts, Favours & Business Entertainment individual employee will depend on the circumstances and 28 Outside Investments applicable law. 28 Electronic Communications Usage 29 Business Records and Communications 30 The Letter and Spirit of the Law 30 International Business 30 Anti-Bribery 6 Standards of Business Conduct 7 INTRODUCTION THE STANDArds OF BUsiNEss CONDUct These Standards of Business Conduct are a guide to the ethical and legal I responsibilities we share as members of the McDonald’s family. This is not a complete N TR rulebook that addresses every ethical issue that might arise. It is not a summary of all O D laws and policies that apply to McDonald’s business. It is not a contract, and it does U CTI not replace good judgment. Rather, the Standards of Business Conduct give us ON guidance and direct us to resources to help us make the right decisions. APPLicAbiLITY OF STANDArds These Standards of Business Conduct apply to employees of McDonald’s Corporation and its majority-owned subsidiaries worldwide. Non-employee members of McDonald’s Board of Directors must abide by the Code of Conduct for the Board of Directors of McDonald’s Corporation, which is posted and maintained at the McDonald’s website at www.mcdonalds.com. The Standards do not apply to our owner/operators, suppliers or their employees. However, as members of the McDonald’s System, we expect them to be aware of the Standards, to develop their own policies and procedures that are consistent with the spirit of the Standards and to fully support our employees in complying with the Standards. This shared commitment will help ensure that we earn our reputation as a company that conducts business with integrity. PUBLicATION, AMENdmENts AND WAIVErs The current version of the Standards of Business Conduct will be posted and maintained on the McDonald’s website at www.mcdonalds.com. Amendments will also be posted on the website, as required by applicable law. In the extremely unlikely event that a waiver of the Standards of Business Conduct for executive officers would be in the best interests of the Company, it must be approved by the Audit Committee of McDonald’s Corporation, and disclosed promptly as required by law. Because the Standards of Business Conduct are revised periodically, please check the website for the most recent version. Photo: Milan, Italy 8 Standards of Business Conduct 9 MANAGEMENT COmmitmENT PErsONAL AccOUNTAbiLITY OPEN COmmUNicAtiON/ The McDonald’s Business Integrity McDonald’s management is committed to living To the rest of the world, each of our actions BUsiNEss INTEGritY LINE Line is staffed 24 hours a day, 7 days a week, 365 days a year by an outside firm up to high standards of ethical behaviour. The represents McDonald’s, and we must do our At McDonald’s, we speak honestly and experienced in handling sensitive calls. McDonald’s Board of Directors in the U.S. best at all times to uphold the reputation of our openly and listen for understanding. We raise Phone 1-800-261-9827 within the United oversees the Company’s commitment to ethics Company. Our success depends on each of us questions or issues, even if they are difficult. and compliance with legal standards. To help accepting personal responsibility for doing the States. Reverse charges if outside the U.S. If you know of any violation of the Standards Interpreters are available. Callers may report I our employees live up to our Standards of right thing. We accept the obligation to stop N of Business Conduct or of any applicable TR Business Conduct, McDonald’s has established or prevent actions that could harm customers, anonymously, and no attempt will be made to law, you are responsible for reporting the O the Global Compliance Office. This office is the System or McDonald’s reputation, and to identify them. Anonymous callers should know, D violation immediately. U responsible for overseeing the Company’s report any such actions as soon as they occur. however, that it is sometimes more difficult to CTI There are a number of ways to raise issues. follow up on issues raised anonymously. ON compliance with these Standards and other Employees who violate the law or the If you believe that a law has been violated, McDonald’s policies. Apart from the Global Standards of Business Conduct are subject consult with the Global Compliance Office or Compliance Office, the employees can also to disciplinary action, up to and including the Legal Department immediately. For other contact the Company’s Legal department or the termination of employment. matters, you can talk to your direct supervisor Human Resources department for any help. or another member of management, or contact AdditiONAL RESPONsibiLitiES Human Resources or the Global Compliance Office. You can also call the McDonald’s OF SUPErvisORY EmPLOYEES Business Integrity Line, a toll-free telephone Those employees who have supervisory line reserved specifically for employee calls on authority over others are in positions of trust ethics and compliance issues. and influence. Therefore, they have special responsibilities under the Standards of Business Conduct to sustain an ethical work environment and to lead by example.