YUM! GLOBAL CODE OF CONDUCT

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YUM! GLOBALCODE OFCONDUCT

YUM! GLOBAL CODE OF CONDUCTTABLE OF CONTENTSI Leadership Message.4II. Our Commitment to Integrity.5Our Commitment to Integrity Together.5What is the purpose of this Code?.5Who is required to follow this Code?.5What are my responsibilities as a Yum! employee?.5What role do managers and supervisors have?.6Does the Code explain all of the standards I need to know?.6What about different laws in different countries?.6Who is authorized to amend or waive any of the provisions in this Code?.6What actions could constitute a violation of this Code?.7What are the consequences for violating the Code?.7How will compliance with the Code be monitored and enforced?.7III. Our Commitment to Our Customers, Restaurants, Franchisees and the Marketplace.8Our Commitment.8Food Safety And Product Quality.8Customers.9Franchisees .9Fair Competition.9Gifts And Entertainment.10Working With Suppliers.12Global Commerce.13IV. Our Commitment to Our Shareholders.14Our Commitment.14Corporate Opportunities.14Conflicts Of Interest.15Insider Trading.16Accurate Financial Reporting.18Safeguarding Assets and Confidential Information.19Records Management.20Go totable ofcontents2Champion the CUSTOMER EXPERIENCEDeliver— Be —RESULTS,FOCUSEDover timeHUNGRYovernight and— and stay —Believe in—ALL—PEOPLEServe up TRUSTin every biteAdopt and share theMAKE THE WORLDRecognize WINS,big and smallBETTERBEST IDEASLead with smart, heart and COURAGE

YUM! GLOBAL CODE OF CONDUCTV. Our Commitment Our Employees.21Our Commitment.21Equal Opportunity.21Mutual Respect and Dignity.21Fair Labor Practices.22Employee Health and Safety.22Substance Abuse.23Privacy and Confidentiality.23Anti-Corruption.24Community and Political Involvement.26Accurate Communication and Disclosure.27VI. Resources for Making the Right Choices.29How To Spot Ethical Dilemmas.29When To Get Help.29Where To Get Help.30The Yum! Integrity Helpline – The Speak Up helpline.31How the Yum! Integrity Helpline (The Speak Up helpline) .32Investigations.32Non-Retaliation Policy.33Appendix A.34Yum! InternationalAnti-Corruption Policy.34Index.37Important Disclosure: This Code of Conduct does not alter other terms and conditions of your employment with Yum! or anyof its subsidiaries, nor does it create any contractual rights for any employee, shareholder, customer, supplier, consumer, orcompetitor.Go totable ofcontents3Champion the CUSTOMER EXPERIENCEDeliver— Be —RESULTS,FOCUSEDover timeHUNGRYovernight and— and stay —Believe in—ALL—PEOPLEServe up TRUSTin every biteAdopt and share theMAKE THE WORLDRecognize WINS,big and smallBETTERBEST IDEASLead with smart, heart and COURAGE

YUM! GLOBAL CODE OF CONDUCTI. A MESSAGE FROM DAVID GIBBS,YUM! BRANDS CEOMore than ever before, employees and customers expect companies to do the right thing. We’re fortunate that thisis how we’ve always operated at Yum!, and we are committed to doing more and better. Our strategy is to unlockpotential for growth and good.This happens by staying focused on our priorities and living our values. The Yum! Global Code of Conduct outlinesour standards for working and is aligned with our values. We must act in an honest and ethical manner in all of ourbusiness practices, and hold ourselves accountable to all of our stakeholders.Thank you for your commitment to leading with integrity as we build the world’s most loved, trusted and fastestgrowing restaurant brands.Our Values – Leading Our Culture to Fuel ResultsChampion theCUSTOMEREXPERIENCEServe upTRUST inevery biteCollaborate toadopt and sharethe BEST IDEASDeliver RESULTS,overnight andover timeBe FOCUSEDand stayHUNGRYRecognizeWINS, bigand smallLead withsmart, heartand COURAGEBelieve inALL People Make theWorld BETTERGo totable ofcontents4Champion the CUSTOMER EXPERIENCEDeliver— Be —RESULTS,FOCUSEDover timeHUNGRYovernight and— and stay —Believe in—ALL—PEOPLEServe up TRUSTin every biteAdopt and share theMAKE THE WORLDRecognize WINS,big and smallBETTERBEST IDEASLead with smart, heart and COURAGE

YUM! GLOBAL CODE OF CONDUCTII. OUR COMMITMENT TO INTEGRITY Know the standards of conduct that apply to your job and activitiesas part of Yum!. Follow these standards – always. Ask if you are ever unsure what is the right thing to do.What is the purpose of this Code?Yum! is committed to conducting business in accordance with the letter andspirit of the law and the highest standards of ethical business conduct.In today’s global business climate, the standards and expectations forresponsible conduct are more demanding than ever. Yum!’s Global Code ofConduct gives us all direction to navigate that environment.Our Commitmentto IntegrityOur Commitment to Integrity TogetherWhat are my responsibilities as a Yum!employee?You are responsible for becoming familiar with and following the Codeand the standards within that apply to your job whether that job is withYum! KFC, Pizza Hut, Taco Bell or The Habit. New employees will beasked to certify their commitment to adhere to the standards of conductcontained in this Code. Many of our employees are required to certifytheir continued compliance with the Code on an annual basis.You are also responsible for seeking advice when needed, raisingconcerns, and reporting potential violations of this Code tomanagement.You will be doing your part when you:The Code provides an introduction to important laws and policies that applyto everyone who works for Yum! or one of its brands throughout the world.The Code is also a global resource that helps each of us: Know when to ask for advice, and Know where we can go for guidance if we are ever unclear about theright course of action.Who is required to follow this Code?The Code applies to employees of Yum! Brands, Inc. and of its wholly ownedsubsidiaries (KFC, Pizza Hut, Taco Bell and The Habit) (collectively, “Yum!”or the “Company”), regardless of title, stature or tenure. This includes ourboard of directors, managers and individual contributors globally.Unless otherwise indicated, all references in this Code to employee(s) shallbe interpreted a references to both employee(s) and director(s). Stay Informed. Understand and comply with the policiesand standards that apply to your job and our Company;participate in required and voluntary ethics and compliancetraining sessions; and work with your colleagues to help othersbecome familiar with the applicable requirements. Seek Guidance. This Code does not provide all theanswers, and you are not expected to know all the answers. Youare expected to ask for help and consult with others when theappropriate course of action is unclear to you. Stand Firm. Never compromise our standards (or yourpersonal integrity) to meet other goals. If an opportunity to cutethical corners presents itself, know that you are expected to dothe right thing and you have the full support of managementin doing so. Surface the Issues. You have an obligation to speakup if something doesn’t seem right. Don’t assume thateverybody else doing it makes it okay, that managementalready knows about it, or that someone else will take care of it.Aside from raising concerns, you are also encouraged to bringforward ideas that will help us better manage our complianceresponsibilities.Go totable ofcontents5Champion the CUSTOMER EXPERIENCEDeliver— Be —RESULTS,FOCUSEDover timeHUNGRYovernight and— and stay —Believe in—ALL—PEOPLEServe up TRUSTin every biteAdopt and share theMAKE THE WORLDRecognize WINS,big and smallBETTERBEST IDEASLead with smart, heart and COURAGE

YUM! GLOBAL CODE OF CONDUCTIf you manage or supervise others, you have been placed in a specialposition of trust. To maintain that trust, you should: Be a Positive Role Model. Lead by example. Show whatit means to act with integrity in your everyday decisions andactions. Take responsibility and be accountable for your conductand that of your team. Raise Awareness and Understanding. Use yourknowledge of our business to help those around you identify andaddress ethics and compliance risks. Set Appropriate Goals. Deliver and reinforce themessage that everyone must operate in line with these standardsof conduct, no matter what other objectives are set. Do notestablish goals that you know will compromise our values andstandards. Be Responsive. Respond appropriately to anyone whoraises a compliance or ethics-related concern, enlisting otherresources as necessary. Monitor the conduct of those yousupervise, and if that conduct is not in line with our standards,take action in a fair, appropriate and consistent manner.Our Commitmentto IntegrityDoes the Code explain all of the standardsI need to know?What role do managers andsupervisors have?The Code is the cornerstone of our commitment to integrity – it provides abasic overview of many of the issues that might arise. But the Code cannotanticipate every issue that may come up or describe every law or policy thatmay apply to a situation you encounter. Other policies and procedures notdescribed in this Code also apply to Yum! employees. Keep in mind thateverybody’s role is different, so whether you work in restaurant operations,in another field-based position or at a restaurant support center or otheroffice, make sure you know the rules and policies that apply to you. If youare ever unsure, you should discuss any concerns with your supervisor orsomeone in your Law Department.What about different laws in differentcountries?Yum! is a global company, and we respect the laws in every country wherewe do business. While we respect local cultures and customs, we have aresponsibility to uphold the same high standards of integrity everywhere,so we must adhere to the standards within our Code of Conduct whilefollowing local laws.If you believe that any provision of the Code may be interpreted as differingfrom an applicable law, regulation, or other Company policy, please consultyour Law Department or a member of your management team. When indoubt, apply the more stringent standard.Who is authorized to amend or waive any ofthe provisions in this Code?This Code of Conduct may be amended or modified by the Board ofDirectors of Yum! Brands, Inc. Waivers of this Code as to an executive officeror a member of the Board of Directors may only be granted by the Board ofDirectors or a committee of the Board with specific authority. Amendments,modifications and waivers will be disclosed as required by the SecuritiesExchange Act of 1934 and the rules thereunder and the applicable rules ofthe New York Stock Exchange.Go totable ofcontents6Champion the CUSTOMER EXPERIENCEDeliver— Be —RESULTS,FOCUSEDover timeHUNGRYovernight and— and stay —Believe in—ALL—PEOPLEServe up TRUSTin every biteAdopt and share theMAKE THE WORLDRecognize WINS,big and smallBETTERBEST IDEASLead with smart, heart and COURAGE

YUM! GLOBAL CODE OF CONDUCTHow will compliance with the Codebe monitored and enforced?The following are some examples of actions that may subject employees todisciplinary action under the Code:The Code of Conduct is more than just a description of our standards ofconduct. It is the centerpiece of a global ethics and compliance programwhich supports our Values and is supported by our Board of Directors andsenior leaders. The following functions play a key role in its oversight andenforcement: Violating applicable laws, regulations or Company standards. Directing or encouraging others to violate applicable laws, regulationsor Company standards. Failing to report known or suspected violations of applicable laws,regulations or Company standards. Failing to monitor the conduct of subordinates, agents or vendors forwhom you have oversight responsibility. Being uncooperative or untruthful during an investigation. Retaliating against others for raising or reporting a Code of Conductcompliance concern, or other ethics concern, in good faith. Other conduct inconsistent with a business environment of highintegrity and commitment to compliance with the law.Our Commitmentto IntegrityWhat actions could constitute a violation ofthis Code? The Yum! Compliance Oversight Committee provides strategicdirection for the compliance program of the Company andmonitors results. The Audit Committee of the Board assists and advises the Boardon the Company’s ethics and compliance program, includingreceiving reports from management on compliance with thisCode, as appropriate.These oversight mechanisms help ensure that the Code of Conduct isenforced consistently across the business and that individuals at all levelsare held accountable for their conduct.What are the consequences for violatingthe Code?Anyone who violates our Code or its underlying policies may be subject todisciplinary action. While the specific type of disciplinary action will be basedon the specific circumstances and severity of each case, it may include one ormore of the following: Verbal and/or written warning. Suspension. Demotion. Reduction in compensation. Disqualification from incentive compensation. Termination. Civil penalties.In addition to these actions, when an illegal act has been committed, theCompany may refer the matter to law enforcement. Violations of law cantrigger legal actions against you, your colleagues, or the Company with seriousconsequences.Go totable ofcontents7Champion the CUSTOMER EXPERIENCEDeliver— Be —RESULTS,FOCUSEDover timeHUNGRYovernight and— and stay —Believe in—ALL—PEOPLEServe up TRUSTin every biteAdopt and share theMAKE THE WORLDRecognize WINS,big and smallBETTERBEST IDEASLead with smart, heart and COURAGE

YUM! GLOBAL CODE OF CONDUCTIII. OUR COMMITMENT TO OUR CUSTOMERS, RESTAURANTS,FRANCHISEES AND THE MARKETPLACEOur CommitmentQuestion:I work at a company restaurant, and I’ve seen that cleaning procedures arenot being followed properly. People want to get home after the restaurantcloses, so they are just rinsing out some equipment, rather than cleaningpursuant to the standards that are posted in the restaurant. Should I do orsay anything about this?Answer:Food Safety And Product QualityFood safety and product quality are at the heart of how we do business andachieve our vision of a world with more Yum!. We seek to always exceedour customers’ expectations by providing the highest quality products insurroundings that are clean, attractive, safe and comfortable.The integrity of our products depends on employees always following foodsafety practices that comply with our brands’ high standards and all legal,quality and contractual requirements. We should not allow anything, includingcost, to interfere with this commitment. Food safety is everyone’s responsibility.Yes, you should report the situation to your supervisor, restaurant manageror to the Yum! Integrity Helpline (the Speak Up helpline). We cannot riskcompromising food safety because of cutting corners in our cleaningprocedures. That could endanger the integrity of our products and the safetyof our customers. If you are not satisfied with the response you receive fromyour line management, use any of the other reporting channels described onpage 31 of this document.Our Commitment to OurCustomers, Restaurants andthe MarketplaceYum! prioritizes serving delicious food that lives up to the trust our customersplace in us and works diligently to meet the highest safety and quality standardsin every aspect of our business – from sourcing and procurement to our foodpreparation and delivery. In all our business dealings, Yum! strives to be honestand fair. We will compete vigorously, but fairly, and in compliance with all lawsprotecting the integrity of the marketplace.Yum! Expectations: Follow all legal, quality and contractual requirements that govern howour products are manufactured. Only source materials and products that meet our specifications andcome from approved suppliers. Adhere to our food safety standards. Learn, follow and execute food handling and preparation procedures,including proper personal hygiene. Report anything that could compromise our food safety and productquality commitment.Speak up if You See Anyone: Cutting corners on food safety or product quality to meet production orperformance goals. Fabricating the results of food safety tests. Doing anything that could compromise our food safety and productquality commitment.Go totable ofcontents8Champion the CUSTOMER EXPERIENCEDeliver— Be —RESULTS,FOCUSEDover timeHUNGRYovernight and— and stay —Believe in—ALL—PEOPLEServe up TRUSTin every biteAdopt and share theMAKE THE WORLDRecognize WINS,big and smallBETTERBEST IDEASLead with smart, heart and COURAGE

YUM! GLOBAL CODE OF CONDUCTCustomersFair CompetitionYum!’s culture includes recognizing, valuing and respecting the diversity ofALL customers. You must not treat a customer differently because of race, color,creed, religion, age, gender, national origin, citizenship, marital status, sexualorientation, disability, military or veteran status, or any other legally protectedstatus.Our goal is to outperform our competition – fair and square. We strive to buildthe world’s most loved, trusted and fastest growing restaurant brands. Wehave a great formula for success — we need not, and will not, resort to unfair,unethical or dishonest means to win.FranchiseesIt also means that our franchisees respect Yum! and its brands, upholding ourstandards of integrity in their restaurant operations, as well as following foodsafety and other brand standards. Though this Code does not apply directly tofranchisees and their employees, Yum! expects franchisees to establish andenforce their own standards and practices to ensure integrity in their operationsand a consistent customer experience.Yum! Expectations: Compete on the merits of our products and customer service andmake no attempts to restrain or limit competition. Differentiate Yum! from its competitors based only on factualcomparisons. Only present or advertise truthful information about our productsand restaurants. Avoid contacts with competitors that may create the appearance ofimproper arrangements, side deals, or informal agreements.Yum! Expectations: Treat franchisees with respect and fairness.Our Commitment to OurCustomers, Restaurants andthe MarketplaceBeing the World’s Most Loved, Trusted and Fastest Growing Restaurant brandsmeans we must have positive, strategic relationships with our franchisees, ourmost important partners. We treat franchisees fairly and have open and honestcommunication.We strictly adhere to “competition” laws (called “antitrust” laws in the UnitedStates) — laws that create the foundation for free markets around the world.Competition laws generally prohibit anti-competitive agreements, such asagreeing with competitors to set prices or divide markets, and other conductthat undermines fair and open markets. Select vendors, suppliers and other third parties only on the meritsof their products, making it clear we expect full and fair competitionfor our business. Openly and honestly communicate with franchisees. Protect the confidential information of franchisees. Hold confidential information about Yum!, as well as its customersand suppliers, in the strictest confidence.Speak up if You See: Franchisee information being misused or improperly disclosed.Speak up if You See Anyone: A franchisee being treated unfairly. Violations of the law or business standards, such as food safety or anticorruption, in franchise operations. Having agreements or discussions with a competitor involving: Prices, pricing formulas, costs or profits. Marketing plans or sales territories.Question: Terms or conditions of sale.My friend’s daughter is working part-time at a restaurant run by a Yum!franchisee. She has told me that they are keeping and cooking raw foodmaterials after the expiration date. Should I let someone know about this? Market share, sales capacity, or production volumes.Answer:Yes, as food safety is being compromised and the well-being of customers isput at risk. Also, Yum!’s reputation, as well as the brands’, could be damaged.Contact someone at the brand’s complaint line, the brand Quality Assurance orfood safety teams or the management team, so the situation can be properlyevaluated and appropriate measures taken. Allocation of customers or product lines. Suppliers, sourcing or distribution methods. Engaging in unfair or deceptive business practices. Gathering information about competitors through inappropriate,misleading or dishonest means. Making false or unsupported negative statements about ourcompetitors’ products or businesses.Go totable ofcontents9Champion the CUSTOMER EXPERIENCEDeliver— Be —RESULTS,FOCUSEDover timeHUNGRYovernight and— and stay —Believe in—ALL—PEOPLEServe up TRUSTin every biteAdopt and share theMAKE THE WORLDRecognize WINS,big and smallBETTERBEST IDEASLead with smart, heart and COURAGE

YUM! GLOBAL CODE OF CONDUCTGifts And EntertainmentRed Flag Situations:The following situations may give rise to competition law risks. Alwaysinvolve the Yum! Law Department before: Entering into joint ventures, mergers, acquisitions or marketing,purchasing or similar collaborative arrangements with competitors. Engaging in or coordinating activities with professional associations,such as those setting industry standards or establishing wagepolicies. Entering into agreements or understandings with competitors thatrelate to prices, terms of sale, market share or technologies.We make business decisions based on merit for the Company. Thus, asa general rule, never offer a busine

Feb 19, 2021 · subsidiaries (KFC, Pizza Hut, Taco Bell and The Habit) (collectively, “Yum!” or the “Company”), regardless of title, stature or tenure. This includes our board of directors, managers and individual

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