Employees

Our commitment to “doing what’s right” is the driving force behind our Code of Business Ethics and Conduct. The Code serves as a guide to ethical conduct for our employees around the world. Every year, all employees who work in our global restaurant support centres, in field-based roles or in one of our distribution and manufacturing facilities are required to certify that they have read the Code in its entirety and that they are committed to abide by it at all times in their day-to-day work.

The Code references our approach to Human Rights: Every person – no matter where they live or their circumstance – deserves to be treated with dignity and equality. Doing what’s right means that our key business strategies are led with the highest standards of ethics, honesty and integrity. We touch the lives of millions of people across our franchisees’ operations, our supply chains, and our corporate offices, so we have a key role to play in protecting human rights, promoting safe workplaces, and promoting fair labour practices across our business. Employees have a responsibility to report any known or suspected violations of human rights and address any negative human rights impacts related to the Company, its franchisees or suppliers. Employees must also be aware of and adhere to international standards to avoid impacts to human rights through the business they conduct on behalf of the Company.

The Code is central to Restaurant Brands International’s ethics and compliance program, but it doesn’t act alone. Restaurant Brands International also maintains a comprehensive framework of policies and programs that support our commitment to ethical conduct. Some highlights include the following:

• Our Commitment to Team Members forms the common foundation of the workplace policies that are upheld in our Company-owned restaurants around the world. While this document does not apply to Burger King®, Tim Hortons®, Popeyes® or Firehouse Subs® restaurants owned and operated by franchisees or to the employees employed at those franchised restaurants, our franchisees are legally and contractually required to comply with all applicable laws in their jurisdictions where they operate, and in the spirit of the values that our brands represent, we encourage them to adopt policies and to operate their businesses in a manner that is consistent with the commitments set out in Our Commitment to Team Members.
• Our Anti-Bribery Policy prohibits any action that would violate anti-bribery or anti-corruption laws in the countries in which Restaurant Brands International and its brands do business, and requires employees to take all responsible steps to prevent violations. Employees who may interact with government officials on behalf of the Company are also required to participate in regular training on the topic of anti-corruption and the Company’s policy.
• Consistent with the Code, our Conflict of Interest Policy requires employees to avoid engaging in activities that conflict with the Company’s interests or create a perceived conflict, and to disclose any circumstances that may pose a conflict of interest. It supplements the Code by providing additional guidance and information regarding specific areas that may affect Company employees in their business activities.
• Our Non-Discrimination, Anti-Harassment and Equal Employment Policy reinforces the Company’s commitment to a work environment in which all individuals are treated with dignity and respect. The Policy makes clear that Restaurant Brands International and its subsidiaries prohibit and will not tolerate discrimination or harassment of any kind, whether on the basis of race, color, ethnicity, sex, religion, national origin, citizenship, pregnancy, familial status, sexual orientation, disability, age, military service status, gender identity, expression or reassignment, genetic information or any other characteristic protected by law.
• Our Whistle Blowing Policy provides for the receipt and treatment of complaints received by RBI with respect to violations of the Code of Business Ethics and Conduct, as well as other RBI policies and controls. Under the Policy, the General Counsel is responsible for conducting the investigation of any complaint received and reporting to the Audit Committee. The Audit Committee is responsible for overseeing the secure reporting process and determining what action should be taken with respect to a complaint, provided the General Counsel may take action directly for immaterial complaints. The Whistle Blowing Policy is available in the “Investors—Corporate Governance” section of our website at rbi.com.
• Our quarterly compliance training program helps to ensure that our employees know and understand our key policies and how they apply in their day-to-day work. And because compliance is so central to our business, this training is tied in to our annual bonus program – employees who fail to complete their mandatory compliance training lose out on the opportunity to earn a full bonus for that year.

Our General Counsel and Chief Ethics and Compliance Officer monitors compliance with these Codes and reports any violations to the Board.

The Code, these policies and the Company’s compliance training program all reinforce the obligation of employees to speak up if they know of or suspect any violations of the Code, Company policy or the law. Employees are encouraged to report any violations to their manager, a member of the People or Legal department or the Company’s Chief Compliance Officer.

In situations where it is preferable or necessary to provide an anonymous report in confidence, the Company encourages employees to use its ethics hotline, hosted by a third-party hotline provider, EthicsPoint. Where requested, the information provided to EthicsPoint is sent to the Company by EthicsPoint on a totally confidential and anonymous basis.

Once received by the Company, all reports are taken seriously, and reviewed and acted upon promptly and appropriately.

Employees who report concerns in good faith are not subject to discipline or retaliation of any kind.

Executives and Board

In addition to the Code of Business Ethics and Conduct, our Board has adopted the following Codes:

• Code of Ethics for Executive Officers. This Code of Ethics is applicable to our senior executives to promote the highest ethical standards in RBI’s operation of its global business and the activities of senior management. Our senior executives certify compliance with the Code of Ethics for Executive Officers on an annual basis
• Code of Conduct for Directors. This Code serves to acknowledge the Board’s responsibility for promoting an ethical culture through the actions of its members and the effective oversight of our compliance programs, policies and procedures. Our Board members certify compliance with the Code of Conduct for Directors on an annual basis.

Our General Counsel and Chief Ethics and Compliance Officer monitors compliance with these Codes and reports any violations to the Board.

Furthermore, each of the Code of Ethics for Executive Officers and the Code of Conduct for Directors contemplates that questions or concerns under the Code, as applicable, can be brought directly to the Chairman of the Board.

Vendors

At Restaurant Brands International, we also believe that our commitment to “doing what’s right” simply can’t be achieved without the same commitment from the vendors and suppliers that provide the ingredients in our food, the equipment used to make it and many other critical inputs into our business. That’s why we’ve established a Code of Business Ethics and Conduct for Vendors that sets forth the basic requirements that must be met by all vendors, including their employees, officers, agents and subcontractors, who are approved to do business with us.

All approved vendors will be required to certify their compliance with the Vendor Code through self-assessment questionnaires, prioritizing the highest risk vendors in 2020. Our compliance approach is supplemented with verification audits conducted for a sample of priority vendors. If RBI determines that a vendor has violated the Vendor Code, RBI may terminate its business relationship with the vendor or require the vendor to implement a corrective action plan. Additional details about vendor compliance and reporting violations can be found in the Vendor Code of Conduct on page 7.

Some of the highlights related to working conditions and compliance are as follows: