Standards of Business Conduct The Promise of the Golden Arches 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 3 McDonald’s Values We place the customer Our customers are the reason for our existence. We demonstrate our experience at the core appreciation by providing them with high quality food and superior of all we do service, in a clean, welcoming environment, at a great value. Our goal is QSC&V for each and every customer, each and every time. We are committed We provide opportunity, nurture talent, develop leaders and to our people reward achievement. We believe that a team of well-trained Dear McDonald’s Colleague, individuals with diverse backgrounds and experiences, working together in an environment that fosters respect and drives high We’re a restaurant company – and so much more. For 60 years, a core set of values levels of engagement, is essential to our continued success. has guided everything we do at the Golden Arches. I’m proud of our commitment to ethics and our best-in-class reputation. We believe in the McDonald’s business model, depicted by the “three-legged stool” of owner/operators, suppliers and company employees, is our foundation, As we evolve toward a modern, progressive burger company delivering a contemporary McDonald’s System and the balance of interests among the three groups is key. customer experience, we must continue to hold ourselves to the highest standards. Today’s environment is complicated. Complex laws and regulations, and even new We operate our Sound ethics is good business. At McDonald’s we hold ourselves and conduct our business to high technologies, can make discerning right from wrong more difficult than ever. That’s business ethically standards of fairness, honesty, and integrity. why our Standards of Business Conduct articulate our moral responsibilities and shine a light on the appropriate conduct in challenging scenarios. We are individually accountable and collectively responsible. In addition to following the Standards, open dialogue is critical. Ask questions and We give back to our We take seriously the responsibilities that come with raise issues, even when that’s not easy. Our business and brand will be stronger communities being a leader. We help our customers build better when you do. communities, support RMHC, and leverage our size, scope and resources to help make the world a better place. Thank you for your commitment to McDonald’s – and for the actions you take that translate into simple, easy enjoyment for our customers. We grow our business McDonald’s is a publicly-traded company. As such, we work to provide profitably sustained profitable growth for our shareholders. This requires a continuing focus on our customers and the health of our system. We strive continually We are a learning organization that aims to anticipate to improve and respond to changing customer, employee and system needs through constant evolution and innovation. Steve Easterbrook President and CEO We aspire to be our customers’ favorite place and way to eat. To achieve this mission, our actions as individuals and as a system must reflect our Values. 4 5 Table of Contents The Standards of Business Conduct 9 Business Arrangements 29 9 Applicability of Standards 9 27 Gifts, Favors and Business Entertainment 30 INTRODUCTION Publication, Amendments and Waivers 9 ETHICS CONTINUED Outside Investments 31 Management Commitment 10 Electronic Communications Usage 31 Additional Responsibilities of Supervisory Employees 10 Business Records and Communications 32 Personal Accountability 10 The Letter and Spirit of the Law 32 Open Communication /Business Integrity Line 11 Financial Crime, Money Laundering and Anti-Terrorism Laws and Regulations 33 Product Quality and Safety 13 Export / Import Controls 33 13 Walking the Talk 13 Anti-Corruption 34 OUR CUSTOMERS Confidential Information 14 Community and Giving Back 37 Marketing 15 37 Political Activities 37 Trade Secrets 15 OUR COMMUNITIES Corporate Social Responsibility & Sustainability 38 Data Privacy and Protection 16 Employment Experience 19 Environmental Responsibility 39 19 Protection Against Retaliation 19 Nutrition and Well-Being 39 OUR PEOPLE Seek Assistance From McDonald’s 19 Sustainable Supply Chain 39 Employment Practices 20 Fair Competition and Antitrust 41 41 Trade Practices 42 Human Rights 20 PROFITABLE GROWTH Respect and Dignity 20 Inside Information and Securities Trading 42 Dating 20 Communicating with the Public 43 Inclusion and Diversity 21 Subpoenas and Government Inquiries 43 Corporate Governance and Internal Controls 45 Safe Workplace 21 45 Alcohol and Drugs 21 CONTINUOUS IMPROVEMENT Internal Investigations 45 Reporting Concerns 46 23 Acting In McDonald’s Best Interest 23 People / Your Extended Team 49 McDONALD’S SYSTEM Owner / Operator Relationships 23 49 Policies / Your Extended Information Network 49 Supplier Relationships 24 ADDITIONAL Reporting Suspected Violations of the Standards 50 Protecting Company Assets 27 RESOURCES 27 Fraud 27 Keeping the Shine on Our Arches 50 ETHICS Conflicts of Interest 28 Frequently Asked Questions 51 Disclosing Conflicts of Interest 28 Index 53 Related Persons 28 Conflict of Interest Guidelines 28 Doing Business with Relatives The relationship between McDonald’s and each of McDonald’s reserves the right to determine how Nothing in the Standards is intended to prohibit and Friends 29 its employees is known as “employment at will.” the Standards apply to any particular situation, employees from discussing wages, terms or other This means that either party to the employment and to amend or modify the Standards as conditions of employment, or to affect employees’ Nepotism 29 relationship may terminate the relationship at appropriate without prior notice or agreement. The rights to report matters to governmental any time for any reason, with or without cause or applicability of any amendments or modifications authorities in accordance with applicable law. Outside Employment and Other prior notice. Nothing in the Standards of Business to an individual employee will depend on the Conduct creates any contractual rights between circumstances and applicable law. McDonald’s, its employees or any third party. 6 7 Introduction Our success depends on each of us accepting personal responsibility for doing the right thing. The Standards of Publication, Amendments Business Conduct and Waivers These Standards of Business Conduct are a guide The current version of the Standards of to the ethical and legal responsibilities that we Business Conduct will be posted and share as members of the McDonald’s family. maintained on the McDonald’s website at This is not a complete rulebook that addresses www.mcdonalds.com. Amendments will also every ethical issue that might arise, and is not be posted on the website, as required by a summary of all laws and policies that apply applicable law. Waivers of the Standards for to McDonald’s business. It is not a contract, executive officers must be approved by the and it does not replace good judgment. Rather, Audit Committee of the Board of Directors and the Standards give us guidance and direct us to disclosed promptly as required by law. Because resources to help us make the right decisions. the Standards are revised periodically, please check the website for the most recent version. Applicability of Standards These Standards of Business Conduct apply to employees of McDonald’s Corporation and its majority-owned subsidiaries worldwide (referred to in these Standards as “McDonald’s” or “the Company”). 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, non-controlled affiliates, or any of their directors or employees. However, as members of the McDonald’s system, we encourage them to develop their own policies, procedures, training programs and certifications 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 maintain our reputation as a company that conducts business with integrity. 8 INTRODUCTION 9 Management Commitment Additional Responsibilities McDonald’s management is committed to living of Supervisory Employees up to high standards of ethical behavior. Those employees who have supervisory authority The McDonald’s Board of Directors oversees over others are in positions of trust and influence. the Company’s commitment to ethics and Therefore, they have special responsibilities under compliance with legal standards. To help our the Standards of Business Conduct to maintain an employees live up to our Standards of Business ethical work environment and to lead by example. Conduct, McDonald’s has established the Global They must ensure that the employees who report Compliance Office. This office is responsible to them understand and follow the Standards for overseeing the Company’s compliance with and complete all required compliance and ethics the Standards and other McDonald’s policies. training. In addition, they must communicate relevant McDonald’s policies to employees and assist