McDonalds SWSGD English v4.0

McDonald’s
Supplier Workplace Accountability
McDonald’s
Supplier Workplace Standards
&
Guidance Document
Welcome McDonald’s Suppliers
At McDonald’s, suppliers are an integral part of our System.

Together, every day we serve more than 65 million customers an assured supply of high-quality products each time
they visit one of our 38,000 McDonald’s restaurants around the world. That’s a significant achievement, which
highlights the value of the supply chain and the people who work in it.
One of our strengths as a supply chain is our shared commitment to a strong Code of Conduct, and our alignment
on what we expect from suppliers under the Code. That’s what this document is all about.
This document is aimed at assisting you—our suppliers, agencies, facilities, and subcontractors—in understanding
and living up to McDonald’s standards, and ensuring that your own supply chains also adhere to these standards.
As Ray Kroc said in 1957, “The basis for our entire business is that we are ethical, truthful, and dependable. We are
business people with a solid, permanent, constructive ethical program that will be in style 20 years or 30 years from
now, even more so than it is today.”
Thank you for embracing these standards and complying with all applicable national and local laws and regulations
in the everyday operations of your business. There is no limit to what we can do for our customers when we operate
from the same values as we continue to work together.
Chris Kempczinski
President & CEO
Table of Contents
Welcome McDonald’s Suppliers.....................................................................................................................................................2

Table of Contents..............................................................................................................................................................................3
McDonald’s Supplier Code of Conduct.........................................................................................................................................4
How to Read this Document ...........................................................................................................................................................6
Management Systems ..................................................................................................................................................................... 7
Business Integrity.............................................................................................................................................................................11
Grievance Mechanisms ................................................................................................................................................................. 15
Employment Practices: Involuntary Labor................................................................................................................................. 19
Underage Labor/Young Workers ................................................................................................................................................ 28
Freedom of Association................................................................................................................................................................ 32
Anti-Discrimination and Fair Treatment ................................................................................................................................... 33
Wages and Benefits & Employee Discipline............................................................................................................................. 35
Working Hours and Rest Days ..................................................................................................................................................... 38
Workplace Environment ............................................................................................................................................................... 40
Environmental Management ....................................................................................................................................................... 49
McDonald’s Auditable Standards by Chapter........................................................................................................................... 50
Definitions by Chapter .................................................................................................................................................................. 68
Note
The McDonald’s Supplier Workplace Standards & Guidance Document (SWSGD) is intended only to provide
information to McDonald’s suppliers on our standards. The supplier, not McDonald’s, is responsible for reading
and understanding the provisions of this Document and for abiding by and implementing them in their own
facilities. Moreover, the supplier, not McDonald’s, is responsible for ensuring that their employees, vendors,
and others in their supply chain meet the expectation of the SWSGD. No provision of this Document, including
McDonald’s right to conduct an audit of the supplier, confers any right on a supplier, employees of a supplier,
vendors of any supplier, and/or any other person or organization in the supplier’s supply chain, which are
enforceable against McDonald’s.
The SWSGD is not intended to and does not create any joint employer relationship. Suppliers are independent
employers and each one is unique. Suppliers alone are solely and exclusively responsible for all employment
matters in their workplaces, including setting all terms and conditions of employment, including hiring, firing,
discipline, supervision, staffing, scheduling, wages and benefits. McDonald’s Corporation and its majority-
owned subsidiaries have no control over employment matters at supplier facilities.
Supplier Workplace Standards & Guidance Document | Version 4 | Effective September 1, 2021 3
McDonald’s Supplier Code of Conduct and the SWA Program
All suppliers and their facilities are required to adhere to McDonald’s Supplier Code of Conduct and this Supplier
Workplace Standards and Guidance Document. McDonald’s Supplier Workplace Accountability (SWA) Program
helps to ensure fair and ethical workplace standards in every corner of our supply chain through engagement,
training, and on-site verification. While McDonald’s reserves the right to request an SWA audit of any supplier’s
facility in the McDonald’s System, McDonald’s uses a risk-based approach to determine where it conducts on-site
SWA audits. While all supplier facilities may be subject to an SWA audit, the majority of these on-site audits occur
at sites that:
• Manufacture or distribute products such as food and packaging for McDonald’s, its franchisees
and/or Developmental Licensees (“DL”) that is destined for a McDonald’s restaurant or distribution
center.
• Manufacture products to specifications (i.e. recipes, formulas, patents) set by McDonald’s, such as
fish/chicken coating suppliers, as well as seating, décor (including Ronald), signage, active play
equipment, ESSD (Environmentally Socially Sustainable Development) and equipment for
restaurants, etc.
• Manufacture or distribute products which are exclusive to McDonald’s.
• Manufacture products where McDonald’s Brand, trademarks or images are visible or displayed on the
packaging or the product itself.
• Key Considerations:
 Facilities that suppliers often don’t consider during the facility identification process include
those that manufacture or produce outer cartons, inner plastic bags, poly bags, tray-liners, and
uniforms where McDonald’s Brand, trademarks or images (e.g. Ronald McDonald) are visib le.
These facilities also need to be included.
 Where other assessments are conducted to McDonald’s specifications or guidelines: Animal
Health & Welfare Audit (currently beef, lamb, pork & chicken), Toy Safety, SQMS, DQMP.
Country-Specific Prohibitions
Supplier facilities in the following countries are prohibited from supplying to the McDonald’s System:
• Bangladesh: Goods imported from Bangladesh will not be accepted into the McDonald’s System.
• Brazil: Goods imported from Brazil into the McDonald’s System may not include goods or raw materials
that originated from sites that are listed on the Cadastro de Empregadores que tenham submetido
trabalhadores a condições análogas à de escravo or “Lista suja” (“Dirty List”), which lists individuals or legal
entities known to exploit labor under conditions analogous to slavery in Brazil.
• North Korea: Goods imported from North Korea will not be accepted into the McDonald’s System, nor will
any goods made or transported using North Korean labor, even if in a location outside of North Korea.
Anyone found to be importing goods for use in the McDonald’s System in violation of the above country-specific
prohibitions may be suspended as an approved supplier to the McDonald’s System.
How to Read this Document
The objective of McDonald’s Supplier Workplace Standards and Guidance Document (“SGD” or this “Document”) is
to clearly explain McDonald’s supplier standards so that McDonald’s suppliers:
• Respect workers’ rights and provide working conditions that are in compliance with all applicable laws and
regulations and McDonald’s standards.
• Implement lasting improvements that provide tangible benefits to both their workforce and their business.
This Document explores McDonald’s Supplier Code of Conduct standards and how to improve conformance
through a management system lens. This means each issue or risk area (e.g., involuntary labor, underage labor, or
overtime) and the legal and Code requirements to which you must adhere, are discussed in terms of what
elements of a management system a company needs to have in place to prevent such issues from arising or
recurring—specifically: policies, procedures, resources, monitoring, and corrective action.
This Document is designed to serve as a technical tool for your Human Resource, Production, Social Responsibility,
and other managers to:
• Benchmark what policies, processes, and procedures you have in place.
• Add or strengthen risk controls where you find gaps.
• Check how effectively the controls are working and adjust them as needed.
This Document coexists with the SWA Handbook, which is intended to simplify and clarify the SWA Engagement
Process for McDonald’s Supplier Relationship Managers (SRMs) and suppliers.
How is this Document organized?

The introduction section of this Document contains explanations of the following:
• McDonald’s Management System Standards – suppliers are required to have a closed-loop and self-
improving management system.
• Recommended Plan-Do-Check-Act (PDCA) model – a management system model for taking requirements
and building them into the facility’s day-to-day processes, with an emphasis on corrective action for areas
that require attention.
• Recommended Five-Whys Framework – a best practice framework to identify and remediate the root
causes of non-compliances. The framework helps suppliers identify multiple root causes for each
noncompliance, as well as finite actions to address these root causes, to ensure that changes to
management systems are complete and sustainable.
Each chapter thereafter highlights one Code element (e.g., Anti-Discrimination), and has the following content:
• McDonald’s Supplier Code of Conduct Standard (orange highlighted section).
• McDonald’s requirements with respect to each such standard.
• Implementation Guidance: How to use the Plan-Do-Check-Act (PDCA) model to comply with Code
standards and requirements.
• Implementation Guidance: Further clarifications of the McDonald’s requirements, as well as illustrative
examples and case studies to support compliance.
At the end of this Document you will find:
• An audit checklist based on McDonald’s standards and requirements organized by Code element, and the
severity level of each non-compliance.
• A list of useful definitions of terminology used herein.
How was this document developed?

Verité, Inc., an independent, non-profit, civic society organization, helped develop this Document based on Verité’s
20+ years of experience working collaboratively with companies of all sizes and production models to develop
doable and durable solutions to the issues discussed in the chapters below. Verité has developed similar tools for
dozens of global corporations seeking to support their suppliers in sustainable continuous improvement.
Management Systems
McDonald’s Requirements on Management Systems
Suppliers must establish a management system to ensure compliance with all applicable laws and regulations,
and McDonald’s standards and requirements under the Code and SGD.
The following table presents the key elements of a management system needed in order for you to manage
common issues by anticipating risks, proactively addressing typical root causes, and eliminating them
permanently.
Policies • Must be clearly written and up to date.

• Must include owner and designated person in senior management accountable for
achieving the policy objective.
Procedures • Must be clearly written and up to date.

• Must have specific work instructions explaining how to implement a policy—more
detailed than a high-level policy, these are meant to instruct the reader on how to do a
certain process.
Communication • Must happen for all policies and procedures; policies and procedures that are not
and Training communicated are ineffective.
• Must be for all staff, but levels of communication could happen in different forms and
formats, with different levels of details, as relevant to an individual’s role.
• Must be in language(s) that workers can understand.
• Must include a verification method, such as a test or a demonstration of a specific job
skill to ensure understanding and correct implementation.
Documentation • Must be maintained to support day-to-day work and to demonstrate that policies and
procedures are being followed.
• Must also be maintained to show how issues are rectified.
Monitoring • Must be conducted on an ongoing basis to measure how well policy objectives are
being achieved, and the efficacy of specific procedures, communication and training,
and corrective actions.
Corrective Action • Must identify the root causes of issues, implement proper controls to prevent
and Continuous recurrences, and include a senior management-level review of the overall system, as
Improvement well as integration of changes in the day-to-day business.
• Must include methods for:
o Tracking and managing data.
o Issuing reports which summarize the information collected, what was learned,
and recommended changes.
o Implementing changes and corrective actions to policies, procedures,
documentation, training, and roles and responsibilities.
Plan-Do-Check-Act (PDCA) Management System Model
• Policy
• Procedures
• Requirements
• Communication
• Risk Assessment and Training
• Improvement • Documentation
Objectives 1. Plan 2. Do
What are the How do we
expectations? achieve these
expectations?
4. Act 3. Check
What needs Are we on
to change? track?
• Corrective Action
Process and
Continuous
Improvement • Monitoring
There are a number of models suppliers may choose to follow when implementing their management system.
McDonald’s does not require the use of a specific model. For the purposes of this Document, we will use the most
widely recognized model called the PLAN-DO-CHECK-ACT (PDCA) cycle as a way to illustrate best practice
management system concepts.
PDCA leads companies, including suppliers, facilities, subcontractors, and agencies, through the process of:
• Building a foundation of organizational commitments and objectives to avoid or manage certain risks
(Plan).
• Establishing a structure of procedures and risk controls to meet these objectives (Do).
• Continually improving operations by monitoring (Check).
• Adjusting to close gaps that would allow issues to arise or recur (Act).
Implementing the PDCA Cycle to Meet McDonald’s Requirements
The diagram below illustrates how the PDCA cycle can be used to meet McDonald’s requirements.
.
 Policies, taking into account the following:  Clear, written procedures, describing who does what and how – ex: procedures
o Requirements – applicable laws, regulations, customer requirements. on checking an applicant’s age by reviewing government-issued identification.
o Risk Assessment – internal and external factors, conditions, and practices Documents should have creation date and revisions numbers and dates and
that can hinder a company’s ability to achieve policy commitments, such former policies should be archived for reference.
as prevalence of migrant labor in a location with informal recruitment  Defined responsibilities and accountabilities, ensuring procedures are
agents that charge high fees, leading to forced labor followed by assigning an owner and a member of senior management that has
o Improvement Objectives – established targets for improvement, oversight – ex: assignment of staff to “own” grievance procedures, as well as
achievement of which is measured over time senior management oversight of the efficacy of the procedures.
 Communication and training on policies and procedures, on how to do one’s
job effectively, provided in the language(s) of the workers, also taking into
account those that have a lower level of education, and asking workers to sign
an acknowledgement of understanding and commitment to uphold principles
– ex: Posting the company’s policy on freedom of association and collective
bargaining on notice boards; training maintenance staff on how to perform
preventative maintenance of machine guarding.
 Maintaining documentation, to ensure that procedures are performed
consistently and to demonstrate conformance – ex: copies of regulatory
permits, self-inspections and audits, records of training.
 Monitoring, including verification, such as worker feedback processes,

 Corrective action and continuous improvement, including root cause incident investigations, and routine self-assessments and audits, should
analysis and senior management review, should take into account the be documented and reviewed. Additional monitoring examples include:
following elements: o Implementing a worker grievance mechanism, with regular review of
o Suitability of current policies—are they in line with law and customer grievances for trend analysis
standards? o Measuring efficacy of training
o Achievement of objectives—are actions on track to meet targets? o Establishing Key Performance Indicators (KPIs) for key processes,
o Status of corrective action plans, from external audits/inspections, such as the number of corrective actions completed on time, or
customer audits, and internal reviews – are they addressed in a timely working hours per employee in line with local law
manner, and have issues been addressed comprehensively? o Utilizing continuous monitoring equipment to monitor air quality,
o Employee engagement – are results of worker surveys taken into account, wastewater
and are grievances effectively addressed?
o Supply chain management – has the facility effectively engaged suppliers
on human rights, EHS, and business ethics performance? Are suppliers
meeting expectations?
Corrective Action and Continuous Improvement
A critical element of any management system is the development of corrective actions to drive continuous
improvement in a facility, referenced under “Act” of the PDCA cycle. In order to develop effective corrective
actions, suppliers must first identify the true root cause of any non-compliance. The Five Whys methodology,
further described below, is a best practice recommendation for root cause analysis.
Five Whys Methodology (Best Practice Recommendation)

The Five Whys methodology is a tool to establish the root cause for why a non-compliance occurs. Behind each
non-compliance, there is a grouping of “whys” that come together to make the non-compliance possible. For
each of these reasons, there are corresponding finite actions that can be taken to rectify this root cause, with
multiple root causes being addressed simultaneously. The example below illustrates this concept related to
workers not wearing the personal protective equipment (PPE) provided to them, in this case, gloves.
Root Causes Finite Actions to Consider
1st 1. Workers report that gloves do not (none – not yet arrived at a root cause)
Why fit and are more of a nuisance.
2nd 1. Workers have not been properly 1. Measure workers for gloves.
Why fitted for gloves. 2. Solicit workers’ feedback on suitability of different
2. Workers also did not provide types of gloves.
feedback on this point.
3rd 1. No procedures for Job Safety 1. Create procedures for Job Safety Analysis.
Why Analysis. 2. Create procedures for measuring workers gloves
2. No procedure to measure workers’ (also see point above).
hands before providing PPE.
4th 1. Health and Safety Manager was 1. Provide training for Health and Safety Manager on
Why not aware of legal requirements or Job Safety Analysis.
best practice to conduct Job 2. Define Job Safety Analysis as part of HS Manager’s
Safety Analysis. job.
2. HS Manager did not know this was 3. Provide training for HS Manager on suitability of PPE
part of their job. and PPE fitting requirements.
3. HS Manager also did not know of
need to ensure that PPE fit users’
hands.
5th 1. Site is not aware of resources for 1. Review site’s system to obtain local laws and Client
Why local laws and Client requirements.
requirements. 2. Create process to communicate these
2. There is no process to requirements, including updates, to relevant staff.
communicate requirements to
relevant staff.
As you can see from the above example, once you reach the “5th Why” you have uncovered the true root cause or
causes of the noncompliance as well as the actions you must take to address the noncompliance. Please note the
intermediate root causes and actions that are discovered along the way are just as important. Thus, the supplier
should work with a facility to address all intermediate and ultimate root causes in order to effectively close out
each non-compliance found during an internal review or external audit.
Business Integrity
McDonald’s Supplier Code of Conduct Standards
Compliance with Law: Suppliers' business activities shall comply with applicable laws and regulations in the
countries and jurisdictions in which they operate. This Code applies to activities in the locations where suppliers'
goods are produced, where any related services are performed, and where the goods enter the supply chain.
Anti-Bribery: Suppliers shall not engage in any form of bribery, kickbacks, corruption, extortion, or
embezzlement. Suppliers shall not take any action that would violate, or cause McDonald's to violate, any
applicable anti-bribery law or regulation, including the U.S. Foreign Corrupt Practices Act.
Audits and Assessments: McDonald’s reserves the right to audit compliance with this Code. Audits are facility
inspections that include employee interviews and a review of supplier records and business practices. Such
audits are conducted by McDonald’s or its approved audit firm. If an audit identifies a violation of this Code,
suppliers shall act promptly to correct the situation to McDonald’s satisfaction.
Books and Records: Suppliers shall maintain accurate and transparent books, records, and accounts to
demonstrate compliance with applicable laws and regulations and this Code.
Confidentiality: Suppliers shall safeguard McDonald's information by keeping it secure, limiting access, and
avoiding discussing or revealing such information in public places. These requirements extend even after the
conclusion of a supplier's business relationship with McDonald's.
Whistleblower Protection: Suppliers are responsible for prompt reporting of actual or suspected violations of
law, this Code, the Standards of Business Conduct for McDonald's employees, or the McDonald's Supplier
Workplace Standards and Guidance Document. This includes violations by any employee or agent acting on
behalf of either the supplier or McDonald's. Such programs shall protect worker whistleblower confidentiality and
prohibit retaliation.
McDonald’s Requirements on Business Integrity
Policies Processes
Compliance with • Suppliers must possess all legally required business licenses and certificates.
Law
• Copies of applicable laws should be made available in a language understood
by the workforce, as per legal requirements.
• A system should be in place to receive timely updates to applicable laws and to
implement changes as necessary.
• Suppliers should designate management representatives to be responsible for
monitoring compliance with laws, including making sure everyone understands
and follows the standards set forth in the Code and SGD.
Anti-Bribery • Suppliers are expected to comply with all applicable anti-bribery and corruption
legal requirements, including the US Foreign Corrupt Practices Act (“FCPA”)
which makes it unlawful to give anything of value to government officials, state-
owned entities, political parties, party officials, or political candidates for the
purpose of obtaining or retaining business.
• Suppliers are required to prohibit all forms of corruption—including bribery,
kickbacks, extortion, and embezzlement. In short, no one should offer or accept
bribes or other means of obtaining undue advantage, including to or from
anyone acting on behalf of McDonald’s, such as third-party auditors conducting
on-site assessments.
• Suppliers and their employees are expected to notify McDonald’s immediately
through the McDonald’s Business Integrity Line if you become aware of any
issues involving possible bribery, corruption, extortion, or embezzlement.
Audits and • Suppliers must permit auditing to verify compliance with the Code as required.
Assessments Audits are facility inspections that include employee interviews and a review of
supplier records and business practices and the site walk-through. The auditor
is to have access to all areas of the facility. Access is to include but not be
limited to all production areas, offices, and, where provided, dormitories and
canteens/ cafeterias.
Books and • Suppliers must maintain accurate and detailed books, records, and accounts in
Records accordance with applicable legal and regulatory requirements, utilizing
Generally Accepted Accounting Principles (GAAP) to demonstrate compliance
with applicable laws, regulations, and the Code.
• Suppliers are expected to maintain records that are honest, accurate, and
complete.
• The Facility must not train, coerce, or incentivize workers – also known as
employee coaching – to provide information to the auditor that does not
accurately represent the true situation onsite.
• Records should be completed accurately and in a timely manner. There must
not be any false or misleading entries on any records, or any separate accounts
not reflected on the facility’s books.
Gifts, Favors, and • Like McDonald’s employees, suppliers are prohibited from accepting gifts,
Entertainment favors, entertainment, or other personal benefits from those with whom they do
business in connection with your work as a McDonald’s supplier, because doing
so could improperly influence, or appear to influence, business decisions.
Conflicts of • Suppliers must keep business decisions fair and transparent by avoiding
Interest conflicts of interest.
• Situations must be avoided where suppliers or their employees could profit
personally as a result of a relationship with someone connected to McDonald’s
business. Any situations that might appear to be a conflict of interest must be
immediately disclosed.
Confidentiality • Suppliers are expected to implement and adhere to adequate controls which
ensure the privacy and protection of information and intellectual property
belonging to McDonald’s, McDonald’s suppliers, and third parties, and that such
information is not shared with anyone who is not authorized.
• Suppliers must safeguard McDonald’s information by keeping it secure, limiting
access, and avoiding discussing or revealing such information in public places.
• Suppliers must respect the intellectual property rights of others and take
appropriate steps to safeguard the information of third parties. These
requirements extend even after the conclusion of a business relationship with
McDonald’s.
• Suppliers should seek guidance from McDonald’s if there are any questions
about whether information possessed is confidential.
Standards of • While the McDonald’s Standards of Business Conduct (“SBC”) does not apply
Business directly to suppliers, suppliers should ensure that its employees adhere to these
Conduct same ethical standards.
• Suppliers should notify McDonald’s if they become aware (or suspect) that a
McDonald’s employee, or anyone acting on McDonald’s behalf, is involved in a
violation of a law, regulation, or policy.
• McDonald’s takes violations of the SBC seriously, and ask that any potentially
unethical or illegal behavior by a McDonald’s employee, supplier, or auditing
firm is immediately brought to our attention.
Subcontracting • Supplier must inform McDonald’s if a subcontractor—offsite—is used for any
part of the production process.
Home Workers • The use of home work is not allowed. For purposes of this standard, home work
refers to work performed by non-management workers who are directly
involved in the manufacture of a product.
Whistleblower • Suppliers must have a program in place to protect whistleblower confidentiality
Protection and prohibit retaliation.
Business Integrity: PDCA Best Practice Examples
The following is best practice guidance for how a supplier can use the PDCA model to comply with McDonald’s Business Integrity requirements.
 Policies:  Procedures:
o Written public statement that ethical business practice is a core value, o Method to routinely identify, track, and apply relevant bribery and
supported by the owner, board, and senior management, and the company corruptions laws, regulations, and standards
will not participate in or tolerate any kind of bribery or corruption o Channel for whistleblowers to report allegations of unethical behavior
o All allegations of ethical misconduct reported to the company will be without fear of retaliation
thoroughly investigated and addressed o Process to investigate allegations of unethical behavior, and undertake
 Company encourages employees, contractors, suppliers to report allegations remediation
of ethical misconduct and will protect whistleblowers from any kind of  Communication and Training:
retaliation o Communicating company’s ethics policy and procedures to all employees
in new employee orientation training, and periodically thereafter
o Training all employees, onsite contractors, and recruitment agents on how
to report allegations of unethical business conduct
o Prominently displaying the business ethics policy, non-retaliation policy,
and allegation reporting procedure in the language(s) understood by the
employees
 Documentation:
o Records of allegations of unethical business conduct and their
investigation and resolution
o Records of self-assessments of compliance with company’s ethics policy
 Corrective action and continuous improvement:  Monitoring:

o Root cause analysis of any business integrity issues uncovered o Self-audit of business integrity processes and procedures
during monitoring or through the whistleblower process
on regular basis
 Ongoing, periodic senior management review for overall system o Interview or survey workers and business partners to find
preventing business integrity issues out if they are aware of and comfortable with the
company’s procedure for reporting allegations of unethical
business conduct
Grievance Mechanisms
McDonald’s Supplier Code of Conduct Standard
Suppliers shall create internal programs for handling reports of workplace grievances, including anonymous
reports.
McDonald’s Requirements on Grievance Mechanisms

• People should feel safe to talk to management about reporting concerns they have, and should
receive a timely investigation to their report without fear of retaliation.
• The grievance mechanism should gather and respond to complaints about the reported issue, which
may be based on law, contract, explicit or implicit promises, your policies, customary practice, or
general notions of fairness.
• The grievance mechanism should allow for reporting all issues, which may include harassment,
discrimination, abuse, bribery, and potential conflicts of interest, working conditions, accidents, or
safety issues.
• The facility should allow for suggestions to be provided on ways in which it could improve standard
practices in order to be more effective within the workplace.
• Methods should be available which allow for confidential and anonymous reports. 1 F
0
1
Special Notice for Suppliers Located in France: French suppliers need to be in compliance with local laws and regulations,
especially with the CNIL unified authorization n AU004 dated December 8 2005 amended by deliberation n° 2010 -369 of
October 14, 2010. If you either suspect or are aware of a violation of law at your company or by a McDonald's employee in one
of the following areas: finance, accounting, banking, anti -corruption or anti-competition, please contact McDonald's France at
the following email address: Alerte.professionnelle@fr.mcd.com .
Grievance Mechanisms: PDCA Best Practice Examples
The following is best practice guidance for how a supplier can use the PDCA model to comply with McDonald’s Grievance Mechanism requirements.
o Workers are provided a confidential and anonymous grievance channel o Allowance for informal, formal, confidential, and anonymous grievances
o There is no retaliation or negative consequences for workers filing a o Ability for workers to report a grievance against a supervisor to a person
grievance other than that supervisor, including someone outside of the same
o All workers – including part-time, contracted, temporary, apprentice, and management reporting chain
intern staff – have access to the company’s grievance channel. o Grievance management is timely and predictable, and the status can be
checked
o Grievance resolution may be appealed
o Situation is monitored to prevent post-grievance reprisals
 Communication and Training:
o Training for all on how to use the grievance channel
o Commitment to worker confidentiality in grievance process
o Technical training for staff that will receive and manage grievances
 Documentation:
o Of grievances filed, with corresponding investigation reports and
outcomes.
 Corrective Action and Continuous Improvement:

o Root cause analysis (RCA) conducted in grievance cases to
 Monitoring:
o Tracking and trend analysis of grievances filed, identifying
identify grievances with a common root cause to address the
issue at the root. multiple grievances that have a common root cause
o Surveying workers on the level of trust in the grievance
process, and their willingness to use the system
Grievance: Implementation Guidance (Best Practice)
Essentials of an Effective Grievance Process
Below we have provided helpful information on how to set up and maintain a best practice reporting mechanism
for grievances.
An effective grievance mechanism is one that is trusted by its workforce and is based on the eight principles
contained in the UN Guiding Principles on Business and Human Rights (below):
Principle Definition
Accessible • Grievance process is known to all.
• Adequate assistance provided to those who face barriers.
Predictable • Clear and known procedure with indicative time frames for each
stage, possible outcome(s) available, and means of monitoring
implementation.
• Employees know what will happen if they file a grievance.
Transparent • Parties to a grievance are informed about its progress; enough info
provided about mechanism's performance to build confidence and
meet external needs.
• Employees are able to know where they are in a process and have faith
that this indication of where they are in the process is correct.
Compatible With • Responses consistent with standards of customer Codes of Conduct

Internationally- and legal requirements. Suppliers should also look to ILO Conventions
Recognized Human and UN Guiding Principles for further guidance.
Rights Standards
Continuous Learning • Process draws on relevant measures to identify lessons for improving
the mechanism and preventing future grievances and harms.
• Addresses common root causes of grievances to prevent recurrence.
Legitimate • Enables trust from stakeholder groups for whose use the process is
intended, and ensures process is consistent and equitable.
• Employees confirm that they trust the grievance mechanism.
Effective Grievance Process Flow: Best Practice Guidance

The chart on the next page shows a best practice example of an effective grievance mechanism that
incorporates the 8 principles mentioned above.
Employment Practices: Involuntary Labor
Suppliers shall not use any form of slave, forced, bonded, indentured, or involuntary prison labor. They shall not
engage in human trafficking or exploitation, or import goods tainted by slavery or human trafficking. They shall
not retain employees’ government-issued identification, passports, or work permits as a condition of
employment.
McDonald’s Requirements on Employment Practices: Involuntary Labor

• McDonald's requires suppliers to ensure the freedom of all human beings to accept or leave a job
voluntarily in their supply chains. Involuntary prison, forced, bonded, or indentured labor, as well as
human trafficking and slavery, are strictly and explicitly prohibited. All suppliers and their facilities
must have hiring and workplace practices in place that provide voluntary employment with
reasonable freedom of movement to access basic liberties for all workers. Suppliers and facilities
shall not retain employees’ government-issued identification, passports, or work permits as a
condition of employment.
• Suppliers must have a documented process to stay up-to-date and compliant with all applicable laws
related to involuntary labor.
• Suppliers must have a documented process to check all publicly-available national governmental
lists or registries that document forced labor violations, such as, but not limited to, Brazil’s Ministry of
Labor and Employment Registration of Employers who violate Article 149 of Brazil’s Criminal Code.
• Suppliers and their facilities shall ensure that third-party agencies, recruitment firms, labor brokers
and subcontractors provide people employment under voluntary conditions, and that they comply
with McDonald’s Code of Conduct, this Document, and the law.
• Facilities and recruitment/employment agencies must not charge fees to those dispatched to the
facility.
• Suppliers and their facilities shall employ workers who are legally authorized to work in their location
and facility, and are responsible for validating employees’ eligibility to work status through
appropriate documentation.
• All standards also apply to temporary workers, as well as indirect and contracted service provider
employees, as well as regular workers.
• The use of prison labor is not allowed in the supply chain, including work release or out-working
programs with prisoners leaving prison to work during stipulated times onsite at a factory and
returning to the prison after each shift, or the arrangement of subcontracting to a prison.
McDonald’s strictly prohibits involuntary labor in our supply chain and thus, in order to guard against it, requires
our suppliers and their supply chains to ensure that: (1) workers do not pay fees in connection with their
employment; (2) they provide workers with written contracts in a language fully understood by the workers at the
point of recruitment; and (3) they do not keep or withhold any government-issued identification, monetary
deposits, or other collateral as a condition of employment.
As a McDonald’s supplier, you and your manufacturing facilities should recruit and hire workers directly wherever
practicable. When working with third-party recruitment agencies and hiring indirect workers, including migrant
workers, you must implement policies and processes to ensure the following occurs:
Policies Processes
Select agencies who Select agencies that operate ethically at all stages of the recruitment process in
operate ethically accordance with both sending country and receiving country laws and the
McDonald’s Supplier Code of Conduct, and that do not engage in deceptive, fraudulent,
corrupt, or collusive conduct. This scope also includes the actions of sub-agents that
may be involved in the recruitment process of migrant workers. Agents should be
legally-licensed in the countries in which they operate.
Map out origins of Map out both the country corridors and the agency pairings through which your
migrant labor and fees migrant workers come to the facility. It is important to understand that the migrant
paid worker’s journey, including fees charged, sub-agents involved, modes of transport and
housing used, will depend on the management systems of the agencies that are
involved in the agency pairing and the laws of the sending country and receiving
country in the country corridor.
Monitor the practices Monitor these practices in order to ensure no worker is forced to work as a result of
of the agencies’ deception, intimidation, coercion, or debt. If requested, third-party agencies should
worker recruitment allow for auditing under the SWA program. If your agency is unwilling to be audited to
and selection McDonald’s standards, or is unwilling to remedy a violation of McDonald’s standards or
law, your relationship with the agency must be terminated.
Conduct in-take Conduct these interviews to ensure that no fees, expenses, or deposits in connection
interviews with with their employment, were paid by the workers, with the exception of specific
agency workers allowable expenses per the chart below detailing allowable and prohibited expenses.
In-take interviews should be conducted by the facility with the worker within five (5)
days of the worker’s arrival onsite.
Reimburse fees paid If workers paid prohibited fees, the supplier facility must ensure that a plan for
reimbursement of the workers begins, with the first payment to take place within 30
days of employment in line with the Reimbursement of Recruitment Fees section
below. Reimbursement may come from the supplier, the facility, or the relevant
agency, but the supplier facility is responsible to ensure timely reimbursement. The
supplier facility should make a reasonable effort to repay all fees paid by migrant
workers employed onsite. If this is not financially feasible, then at a minimum, the
facility must repay fees the worker paid under the worker’s current contract, in both the
sending and receiving country. This policy applies as of the effective date of this
Document, meaning that the workers’ contracts in force on that date and any contracts
beginning thereafter are in scope for reimbursement. It is not permissible for the
supplier to sign new contracts with migrant workers for the purposes of avoidance of
repayment of recruitment fees.
For example, the below employees were all hired in Vietnam for roles in Taiwan. They paid
fees in the sending country, as well as monthly management fees in Taiwan which have
been continuously charged since their hire dates.
Employee Sending Country Fees Receiving Country Fees
Employee A was
employed under a N/A - Fees were charged All monthly management
previous contract which with the previous fees starting Jan 1, 2021,
expired, and signed a new contract, so they are out at the start of her current
contract that started Jan of scope contract
1, 2021.
Employee B was newly
All monthly management
hired on Dec 1, 2020, so All fees charged in
fees starting Dec 1, 2020,
his/her contract from that Vietnam for the contract
at the start of her current
date is the current starting Dec 1, 2020
contract
contract.
All fees charged in
Employee C was not hired All monthly management
Vietnam for the contract
until Apr 1, 2021. fees starting Apr 1, 2021
starting Apr 1, 2021
The facility must maintain documentation, signed and acknowledged by the worker, to
show the calculation of fees paid by that worker, the total fees reimbursed to that
worker, and the date(s) of repayment.
Ensure that prior to Written contracts should be in a language the workers understand, and they should
deployment from their voluntarily sign the contract. Contract terms and conditions must be explained to
sending country, illiterate workers in a language fully understood by the workers. At least five (5) days
migrant workers are prior to deployment, migrant workers should be provided with a copy of the executed
provided with a contract of employment. It is not acceptable to have migrant workers sign contracts
written contract of upon departure at the airport. The use of supplemental agreements, or the p ractice of
employment contract substitution are strictly prohibited. In countries in which there is a
requirement to have a written employment contract in both the sending country and
receiving country, meaning there must be two (2) contracts by law, the stipulations of
both contracts should be harmonized to the greatest extent possible to represent one
(1) uniform agreement, and either contract must be equally favorable to the worker.
Contracts must explicitly prohibit the charging of any recruitment-related fees.
Ensure valid visas and Ensure that valid visas and work permits are in place for migrant workers prior to them
work permits are in commencing work onsite at the facility.
place
Workers must retain This includes documents such as passports, identity papers, travel documents, and
possession and other personal legal documents at all times. The only permitted exception is after
control of their workers’ arrival in the receiving country, at which time there is a short term need to
personal identity make original identity documents available to government agencies for the processing
documents of visas, work permits or other legally mandated purposes. Migrant workers must be
provided with individual secure storage for identity documents, such as passports,
identity papers, travel documents, and other personal legal documents.
Workers must have Workers should have sole control over their bank accounts except for the direct
sole control over their deposit of wages or compensation payments. Except where expressly required by the
own bank accounts; receiving country law, the supplier or supplier facility must not deduct or require any
suppliers must not workers to pay deposits or security payments. If a deposit is required by the receiving
make any deductions country law, the deposit must be paid by the employer or agent and a receipt must be
or require deposits or issued to the worker. Under no circumstances should a worker be required to make a
security payments deposit in any form.
Workers’ freedom of This applies during or outside of work hours, except where necessary for worker safety.
movement must not There must be no restriction on their access to basic liberties such as toilets, drinking
be restricted water, or medical care. Workers should be free to return home during leave without
penalty of termination.
Develop and This should prohibit reprisals against workers for information provided on recruitment
implement a non- fees or expenses paid by them, deception, intimidation or coercion in any other form,
retaliation policy that during the recruitment, selection, hiring, or employment processes. Migrant workers
prohibits reprisals must not be threatened with denunciation to authorities to force them into
employment or preventing them from terminating their employment, at any time,
without penalty. This, as well as other migrant worker-related policies, must also be in a
language understood by the workers, and must be explained to illiterate workers.
Arrange and pay for You must arrange and pay for the repatriation of migrant workers – who travel from
repatriation of migrant another country for the job – at the conclusion of their contract or in the event that you
workers terminate the contract for any reason, except due to documented gross misconduct or
illegality, before the contract end date. You must not penalize migrant workers for
voluntarily terminating their employment contracts at any time. Examples of penalties
include, but are not limited to, withholding of wages, bonuses, or allowances already
earned, early termination fines, or deductions.
Ensure that all human This applies for all workers, hired directly or indirectly, including migrant workers. All
and workplace rights workers should receive equal pay for equal work, and should be provided safe and
are respected for all healthy working and living conditions. All overtime must be voluntary.
workers
According to standard industry practice, the below chart lists out fees that can and cannot be paid by the worker
during the recruitment and employment process.
Employer-Paid Fees and Expenses

(Fees that Cannot Be Charged to the Worker)
Situation Local/Resident Worker Foreign or Internal Migrant Worker
Before job  Recruitment and service fees  Recruitment and service fees (application,
offer (application, background and background and reference checks,
reference checks, recommendation, recruiting, skills testing,
recommendation, recruiting, language interpretation or translation fees,
skills testing, language interviewing, selecting, hiring, placement, and
interpretation or translation processing).
fees, interviewing, selecting,  Cash deposits and bonds.
hiring, placement, and
processing).  Medical examinations and tests.
 Cash deposits and bonds.

 Medical examinations and tests.
After job offer  Additional skills tests.  Additional skills tests.

accepted
 Additional certifications.  Additional certifications.
 Medical examination and tests.  Medical examination and tests.
 Transportation and lodging  Pre-departure training or orientation (including

costs and fees if worker is mandatory language lessons).
required to move to another  Documentation (e.g., passport and visa) permits,
location. fees and associated costs, including renewals for
 Other Legal Requirements. continued employment.
 Foreign migrants: Transportation and in-transit
lodging costs and fees from regular place of
residence to facility and to return to habitual place
of residence at end of employment.
 Other legal requirements.
Start of  Arrival and onboarding.  Arrival and onboarding.

employment
 Medical exams, tests, and  Medical exams, tests, and immunizations.
immunizations.  Other legal requirements.
 Other legal requirements.  Ongoing or additional agent or employer fees and
 Ongoing or additional Agent or costs (administrative, service, equipment, tools, ID
Employer administrative, badges, apparel).
service, equipment, tools,
apparel fees.
 Relocation costs if required to
move to another site.
End of  Return transportation to place  Foreign migrant workers—return transportation to
employment of residence (if relocation was home in sending country.
required as a job condition).
 Early termination fees if worker gave adequate
 Early termination fees if worker notice.
gave adequate notice.
Fees that May Be Paid by the Worker

Situation Local/Resident Worker Recruited Foreign or Internal Migrant Worker
Before job  Items for the interview:  Items for the interview:
offer  Copies of resumé/CV.  Copies of resumé/CV,
 Copies of documents and  Copies of documents and certificates
certificates (e.g., birth (e.g., birth record, school diploma, etc.),
record, school diploma,  Job qualification costs
etc.). (e.g., degree, certification as welder or electrician).
 Job qualification costs  Transportation and lodging for the interview
(e.g., degree, certification as (unless requested and arranged by the recruiter).
welder or electrician),
 Transportation and lodging for
the interview (unless requested
and arranged by the recruiter),
 Initial passport, visa, residency

permit to be a legal resident.
After job offer  Replacement of passport, visa,  Replacement of passport, visa, work permits, ID
accepted work permits, ID badges, etc. badges, etc. due to fault of worker.
due to fault of worker.
 Transportation and lodging
costs (from worker’s residence
in country to the work location)
unless the worker is required to
relocate.
Start of  Housing and food, if disclosed  Housing and food, if disclosed in employment
employment in employment contract, at or contract, at or below market price, and meets H&S
below market price,and meets standards.
H&S standards.
End of  Reasonable early termination  Internal Migrants—return transportation to regular
employment for not giving adequate notice. place of residence.
 Reasonable early termination fee for not giving
adequate notice.
Reimbursement of Recruitment Fees
According to standard industry practice, the following three-step process should be followed for fee
reimbursement:
1. Find out whether workers paid any fees that should have been paid by your company or your recruiter(s).
• Review the list of fees and expenses that should be
covered in your service agreement with your
recruitment agent(s). Find out whether workers paid any
prohibited fees.
• Interview newly hired workers and ask if they paid any
fees and expenses. They are unlikely to have kept
Make a reimbursement plan.
records or been given receipts, but will be able to
report any significant amounts paid. Note: Workers
are often told by the recruiter that if they tell the Reimburse workers.
employer they paid any fees or expenses, their
contract may be terminated and they may be
blacklisted for future overseas work.
• Request documentation from the agent(s) showing that they paid each fee and expense required to
recruit and hire all workers recruited through these agencies for all agency pairing and corridors.
• If your recruitment agents cannot provide receipts or other evidence that they paid the listed fees and
expenses on behalf of the worker, you can assume that workers did. NOTE: Workers may report fees paid
informally to sub-agents, such as middlemen, so the amounts reported by workers and what the
recruitment agent paid may not tally up to consistent totals. However, the burden of proof on fees is on
the contracting agent; when the reported amounts are higher than what is supported by documentation,
you should err on the side of reimbursing the worker for the larger amount.
2. Make a Reimbursement Plan
Isolated cases are straightforward. However, it is more common to find that numerous workers have paid a
wide range of fees.
• For large groups of workers with significant variation, calculate the average amount paid. Maintain
documentation to show how this average was calculated for migrant workers’ reference in the next step.
• If all workers that came in one (1) batch of recruitment (see below) all reported paying USD 600, except for
a small proportion who reported paying USD 450, ignore the outliers of USD 450 and reimburse workers at
a rate of USD 600.
• Make a separate calculation for each batch of workers recruited. For example, if you hired Filipino workers
in May and September, along with Vietnamese workers in September, you should make three (3) separate
calculations to reflect the different fees paid by each group.
• Separate calculations should also be undertaken if different recruitment agents were involved. In the
above example, with workers coming from the Philippines in May (from Agency A), in September (from
Agency B and Agency C), and from Vietnam in September (from Agency D), all coming to one (1) receiving
country agency in Taiwan, Agency E, then there should be four (4) batches of workers for the calculation,
one (1) from each Agency in the sending country, with agency pairings A-E, B-E, C-E, D-E.
3. Reimburse Workers
o Communicate to the affected workers the reimbursement amount, how the amount was
calculated, when and how the reimbursement will be made.
o Make all reimbursements via direct deposit to workers’ bank accounts with documentation that
the worker received and understood the calculation and acknowledged the amount to be
reimbursed.
o Payments should be made (by the agent or supplier) within 30 days of start of employment.
Employment Practices: Involuntary Labor: PDCA Examples (Best Practice)
The following is best practice guidance for how a supplier can use the PDCA model to comply with McDonald’s Employment Practices requirements.
o Migrant workers will be in possession of their passports and other personal o Recruitment procedure ensures that there is no difference between a job
identity documents and will be provided with individual secure storage. offer letter in the worker’s sending country, and the offer letter and/or
o All policies relevant to migrant workers must be available in a language contract in the receiving country. There should be no differing content that
fully understood by the migrant workers to ensure understanding. is unfavorable to the worker.
o Training staff responsible for screening third-party labor agencies to
ensure that due diligence is performed to mitigate upstream risks
o Providing new-hire orientation training to all newly-arriving workers
covering the company’s workplace policies and procedures, worker’s rights
and responsibilities; all training should have a focus on addressing forced
labor risks.
 Documentation:
o Service agreements with recruitment agencies that include the amount
paid by the company to the recruiter to bring migrant workers into the
country, including agency service fees, and with a prohibition on charging
fees from the worker as part of recruitment.
 Corrective Action and Continuous Improvement:  Monitoring:

o Conducting a root cause analysis (RCA) of any issues uncovered o Establishing Key Performance Indicators (KPIs) on the following:
during monitoring of migrant workers, including of possible causes of  Workers reporting paying fees
discrepancies between worker reports of understanding of job o Workers reporting they were promised a job different than the
requirements and compensation, as well as of fees paid. RCA should one actually available
keep in mind that a root cause of discrepancies may be fraud on the
part of labor agents in the sending and/or receiving countries.
Employment Practices: Involuntary Labor: Implementation Guidance (Best Practice)
Best Practice Contents of a Migrant Worker Contract
It is best practice for the signed contract of employment to include the following terms:
• Migrant worker’s full name, date of birth, and sending country address.
• Passport number or equivalent government issued identification number.
• Emergency contact Information.
• Supplier name and address.
• Name, address, and other contact details of the labor broker signing the contract of emp loyment on
behalf of Supplier.
• Nature of work and address where it will be performed.
• Supplier policies regarding:
o Forced or involuntary labor.
o Recruitment fees and expenses.
o Identity document retention and safekeeping.
o Deposits or security payments mandated by receiving country law.
• Contract start and end dates.
• Provisions for contract renewal, if applicable.
• Provisions for repatriation.
• Provisions for voluntary early termination of contract by worker with and without reasonable notice.
• Grounds for involuntary termination by supplier.
• Detailed summary of living conditions, including costs (if any) for meals and accommodation.
• Expected regular working hours, overtime hours; frequency of rest days and holidays that comply
with the requirements of applicable laws and regulations, the McDonald’s Supplier Code of Conduct,
and Supplier Workplace Standards and Guidance Document.
• Clearly defined regular, overtime, and holiday wage rates, including maximum allowable overtime
hours that comply with the requirements of applicable laws and regulations, the McDonald’s Supplier
Code of Conduct, and Supplier Workplace Standards and Guidance Document.
• Any applicable bonuses, allowances, or other cash compensation.
• Pay practices including frequency, methods, and pay slips.
• Descriptions of work-related benefits, including medical and social insurance benefits, and sick,
emergency, and annual leave.
• Quantitative estimates and line item descriptions of each anticipated wage deduction.
• Estimates of the minimum and maximum net pay the migrant worker can expect to receive each
month. Maximum net pay shall be based on an upper limit of 60 hours per week.
• Clear prohibition of charging any fees related to recruitment.
Underage Labor/Young Workers
McDonald’s Supplier Code of Conduct Standards
Suppliers shall ensure that no underage labor has been used in the production or distribution of their goods or
services. A child is any person under the minimum employment age according to the laws of the facility’s country,
or, in the absence of law, under the minimum age for completing required education.
McDonald’s Requirements on Underage Labor/Young Workers

McDonald’s strictly prohibits underage labor in our supply chain and prohibits young workers (considered to be
between the ages of 15 to18) from performing any work which, by its nature or the circumstances in which it is
carried out, is likely to harm their health, safety or morals. Thus, as a McDonald’s supplier, you must implement
policies and processes to ensure the following occurs:
Verify age Maintain legally-accepted age verification records and ensure regular verification of the validity
at time of and completeness of proof-of-age records, including interviews with applicants as part of the
hire process. Records should include date of hire and a copy of age verification documentation, to
ensure all have reached legal minimum age when they commenced employment. All legal
requirements and McDonald’s requirements for young workers must be followed. If you use a
recruitment agency, you must ensure that they comply with legal requirements and McDonald’s
standards on underage labor/young workers.
Take Immediate Identify and retain service provider focused on underage labor prevention and
action if action remediation
underage
labor is Obtain Obtain the necessary details regarding the underage workers,
found necessary including names, ages and contact details of the underage
details workers and their parents/guardians and work with the underage
labor service provider to develop a remediation plan that ensures
the return of the underage worker to a safe environment with
either his or her parents, legal guardians, or other suitable care
provider.
Root cause The underage labor service provider must conduct a root cause
investigation investigation of the underage labor occurrence and create a
remediation plan that is signed by the parent/guardian of the
underage worker and all parties to the remediation plan and
should include the duties of each party in ensuring the success of
the remediation. Any costs associated with the remediation plan
must be paid by the facility, such as education, transportation,
and medical.
Terminate The employment relationship between the facility and the

employment underage worker(s) must be formally terminated and the facility
relationship; must compensate the underage worker’s family for at least the
compensate legal minimum wage the child would have earned. These wages
underage should be paid monthly (not as a lump sum) until the child has
worker’s reached the country’s legal minimum working age, or if no country
family legal minimum working age exists than the age of 14 can be used,
and these wages must be documented in the remediation plan
signed by all parties. In addition, the facility can also find
employment for another, older and unemployed family member
who meets the legal requirements to work, but this is not required.
Create a The facility must create a detailed and time-bound remediation

time-bound plan with their underage service provider to ensure the underage
remediation worker welfare at the production site in question. The remediation
plan plan should include a plan for the underage worker to attend
school or quality education, such as vocational training or formal
training, until (s)he is of legal working age. If there are any
expenses associated with transportation of the child or education
for the child, those expenses must be paid by the facility and
documented in the remediation plan. If the child’s employment at
the facility resulted in the need for medical treatment, the
remediation plan should include payment for this medical
treatment by the facility. In addition to the current case, the
remediation plan should include a plan to ensure that the
production site does not currently and will not in the future
employ workers under the legal minimum working age and will
work towards full compliance with McDonald’s Supplier Code of
Conduct and this Document. Structural solutions including better
age checks at factory level have to be established.
Ongoing Monitor The underage service provider and the facility must monitor the
support underage underage worker and the remediation plan after the underage
and worker and worker leaves the facility to ensure that the underage worker
monitoring remediation remains in school and that the plan is adjusted to meet the
plan underage worker’s changing needs.
Offer Once the underage worker turns the legal age for working, the
employment production site is required to offer employment in at least the
same position and under at least the same conditions.
Immediate Action Ongoing Support and Monitoring
 Identify and retain service provider for  Monitor child and remediation plan.
remediation of child labor.  Offer employment.
 Obtain necessary details.
 Root cause investigation.
 Terminate employment relationship;
compensate child’s family.
 Create a time bound plan.
Underage Labor/Young Workers: PDCA Examples (Best Practice)
The following is best practice guidance for how a supplier can use the PDCA model to comply with McDonald’s Underage Labor/Young
Workers requirements.
o Only individuals at or above the local minimum age will be hired o Verification of age of all job applicants using government-recognized
o Regardless of law, workers under the age of 18 will not be assigned night documents.
work, overtime work, or hazardous jobs, and shall be restricted from o Provision of health examinations and other legally-required protections for
hazardous production areas. young workers to prevent harm, exploitation, or abuse in the workplace, or
o Student workers, interns, or apprentices will not be used to fill jobs that in housing or transport.
are vacant due to labor shortage. o Assurance that students, interns, and apprentices are assigned work that
support their course of study, and that their work – including wages,
working hours, working environment, meets requirements of law.
o Training for staff to ensure recruitment, selection, and hiring meet young
worker laws, and prevent occupational hazards and prohibit overtime work.
o Job descriptions used for recruitment state the minimum hiring age and
restrictions for young workers.
 Documentation:
o Copies of age proof documentation
o Register of young workers so that hours and job assignments can be
systematically tracked
o Job descriptions clarify what types of work are hazardous, and/or may
require overtime
o Records of contracts with student workers, interns, legal guardians,
schools
 Monitoring:
o Monitoring of job assignments to prevent young workers from
 Corrective Action and Continuous Improvement: working overtime or working in positions that are hazardous
o Root cause analysis (RCA) conducted in cases in which workers were o Interviews with young workers at the time of placement to
hired with discrepancies in worker age and/or identity, identifying
verify that age documentation was checked, especially for
which aspects of the recruitment process allowed for discrepancies to workers employed through a third-party agency or schools with
go unchecked, such as limited competence in identifying falsified age apprenticeship programs
and identify documentation o Interviews to confirm age and prevent the use of falsified age
o RCA to identify reasons for which young workers were assigned work documentation
that was hazardous, or that required overtime
o RCA to clarify gaps in third-party-involved recruitment, such as through
agencies, school apprenticeship programs
Underage Labor/Young Workers: Implementation Guidance (Best Practice)
Child Labor Decision Tree
From Responsible Approaches to Child Labour in the Textile and Garment Industry, Save the Children Denmark and The Danish
Federation of Small and Medium-Sized Enterprises, 2006 .
Freedom of Association
Supplier shall respect the rights of workers to associate or not to associate with any group, as permitted by, and in
accordance with, all applicable laws and regulations.
McDonald’s Requirements on Freedom of Association

• Suppliers must treat all human beings equally, regardless of their association with unions or other groups, and must follow local law
regarding freedom of association and collective bargaining.
• Suppliers shall respect the rights of people to bargain collectively where such rights are established by law or contract.
• Representatives within the facility are freely elected without management interference.
Freedom of Association: PDCA Examples (Best Practice)

The following is best practice guidance for how a supplier can use the PDCA model to comply with McDonald’s Freedom of Association
requirements.
Policy that explicitly states that workers are free to associate or  Procedures:
not associate with any group, such as a legal worker o During recruitment or at the time of decisions on
organization, including a union, as permitted by and in employee promotions, avoid screening workers who
accordance with all applicable laws and regulations. support or have been involved with freedom of
association.
 Documentation:
o Collective Bargaining Agreement (CBA).

o Conducting a root cause analysis (RCA) of any issues o Periodic anonymous surveys regarding employee
uncovered with surveys regarding employees’ beliefs feelings on the company’s respect for freedom of
on their ability to freely associate, with the goal to solve association, and if employees feel that they will be
these issues at the root subject to discrimination for association with a
union.
Anti-Discrimination and Fair Treatment
Suppliers shall promote and maintain a workplace free from discrimination and treat their employees with
fairness, dignity, and respect. No form of physical, sexual, psychological, or verbal harassment or abuse shall be
tolerated.
McDonald’s Requirements on Anti-Discrimination and Fair Treatment

• Providing an environment free from discrimination is essential for maintaining a positive workplace
and complying with law. All individuals in the workplace are to be treated with fairness, dignity, and
respect.
• All employment decisions are based on job-related criteria and not on a person’s race, color, religion,
sex, sexual orientation, age, disability, national/ethnic/social origin, gender identity or expression,
union membership, political affiliation, marital or pregnancy status, pre-employment medical exams,
any other personal characteristics, or any basis prohibited by law.
• An exception to the above non-discrimination requirement includes health testing for communicable
diseases for people working within the canteen/cafeteria or where required by law in handling food or
food-safe production.
• There is no tolerance for any form of harassment, abuse, or intimidation in the workplace.
• Security practices are gender appropriate and non-intrusive.
Anti-Discrimination and Fair Treatment: PDCA Examples (Best Practice)
The following is best practice guidance for how a supplier can use the PDCA model to comply with McDonald’s Anti-Discrimination and Fair Treatment
requirements.
o All workers are treated equally and fairly o Job advertisements include only objective job requirements
o All recruitment, hiring, and employment decisions are based solely on o Procedures for advancement, rewards, demotion, probation,
objective competency criteria discipline, and termination are transparent and merit-based, using
o Workers are provided with reasonable accommodation for religious formal, standardized, objective performance criteria
practices o Procedures for security personnel to avoid invasive and/or gender-
o All forms of harassment, intimidation, verbal, and physical abuse, and other inappropriate techniques
inhumane treatment are strictly forbidden. o Procedures for reporting harassment/abuse, in line with established
o Security practices are gender-appropriate and non-intrusive grievance procedures
o No retaliation for reporting of harassment and abuse is tolerated.  Communication and Training:
o Company policies on anti-discrimination and workers’ rights are
easily accessible in language(s) that the workers understand
o Providing introductory training for new managers and supervisors
on policies, procedures, laws, forms of discrimination that can
happen in the workplace, and channels for reporting issues
o Communication with all workers on company’s policy on
harassment and abuse, at the time of onboarding and periodically
thereafter, including how to report these issues
o Awareness training on clear definitions and specific examples of
behavior that is not tolerated
o Company policy and local laws should be easily accessible in
language(s) that all workers understand
 Corrective Action and Continuous Improvement: o Technical training for managers and supervisors on recognizing
o Conducting a root cause analysis (RCA) of any issues uncovered during forms of harassment and abuse, conflict avoidance, and how to
monitoring of discrimination, harassment and abuse including analysis address issues
of trends of cases with similar root causes, with a focus on solving o Technical training for security personnel on techniques or
these issues at the root procedures that are non-invasive and gender-appropriate
 Documentation:
o Job advertisements with performance requirements, candidate
interview questions
 Monitoring:
o Performance evaluation criteria for transfers, promotions, wage
o Interviews with newly-hired workers to determine if they were asked questions in their
interviews that were not related to job skills and qualification, such as plans to have a increases, discipline, and terminations
family, attitude about unions, political affiliations, etc. o Documentation of training on harassment and abuse for all
o Exit interviews to include questions that evaluate if perceived discrimination was a
factor in turnover
o Periodic anonymous surveys of, and interviews with, workers and managers to
determine their level of awareness of definitions and manifestations of harassment
and abuse, and what is not allowed in the workplace
o Periodic anonymous surveys of workers on whether they have experienced or
witnessed such behaviors and know how to report incidents or concerns
Wages and Benefits & Employee Discipline
Suppliers shall ensure that their workers are paid lawful wages, including overtime, premium pay, and equal pay
for equal work without discrimination. There shall be no disciplinary deductions from pay.
McDonald’s Requirements on Wages and Benefits & Employee Discipline

• Compensation practices must comply with local law and are to be communicated to everyone so
they are aware of and understand those practices.
• Disciplinary policies are to follow all legal requirements and ensure all employees are treated
consistently, including no monetary deductions for disciplinary reasons.
• You must have a written disciplinary procedure outlining the steps of progressive discipline to correct
misconduct or unsatisfactory performance, and this procedure should not include monetary
deductions.
• Procedures must include an appeals process.
• Managers and supervisors are trained on appropriate disciplinary measures.
Wages and Benefits: PDCA Examples (Best Practice)
The following is best practice guidance for how a supplier can use the PDCA model to comply with McDonald’s Wages and Benefit s requirements.
o Workers paid at least the minimum wage, or the wage stipulated in their o Procedures to stay up to date on legal requirements regarding
contracts, whichever is higher wage payment
o Payment is in full and on time o Labor contracts and wage slips are provided to workers, with
o Piece rate workers receive their contracted wage, or the minimum wage, content in line with legal requirements
whichever is higher o Procedures ensure that benefits, including leave and social
o Overtime work performed, including on regular days, rest days, legal insurance, are provided in line with local law
holidays, is paid at a premium rate consistent with local law o Wages do not have deductions for uniforms, personal protective
o Legally-required benefits and social insurance are provided to workers equipment (PPE), tools, or other needed equipment
o Includes an explanation of disciplinary process, in line with laws and o Procedures to ensure that except for gross misconduct, no
customers’ Codes of Conduct worker is dismissed for a first offence
o Prohibition of monetary fines or deductions as a means of discipline o Procedures for managers and supervisors that emphasizes that
o Workers’ right of appeal minor offences can be managed through informal advice,
coaching, etc., before proceeding to formal disciplinary
procedures
o Disciplinary action should not be taken until the case has been
thoroughly investigated
o Workers have the right of appeal
o Communicating the company’s wages and benefits policy to all
workers before their employment starts, and before any changes
to their status are made
o Workers are trained on details of their wages
o Initial and periodic training for all on company’s discipline policy
and relevant laws, Codes, with special training for managers and
supervisors on managing performance
 Corrective Action and Continuous Improvement: o Publishing of disciplinary process in employee manual, posting of
o Conducting a root cause analysis (RCA) of: key elements of process in the workplace in language(s) the
 Trends in any cases that resulted in discipline, to identify cases that workers understand
are related, evaluate if disciplinary actions are having the desired  Documentation:
effect, and determine if cases can be reduced or eliminated through o Payroll registers for 12 most recent months for which wages have
changes in procedures, enhanced employee training been paid
 Any issues uncovered during monitoring of payroll calculations, o Pay slips in language(s) workers understand
including possible causes of repeated issues to solve them at the o Employment contracts with content in line with legal
root. requirements
o Disciplinary actions – with worker’s signature – with investigation
report, and appeals, if applicable.
 Monitoring:
o Routine audits of payroll for accuracy in calculation of wages
o Exit interviews to determine whether turnover is linked to issues related to calculation and payment
of wages
o Frequency and nature of cases resulting in disciplinary action, and the disciplinary action taken
Employee Discipline: Implementation Guidance (Best Practice)
Sample Process for Discipline and Termination
Below is an example of a good disciplinary process. Suppliers must decide for themselves what disciplinary
processes and procedures will work best for their businesses.
Sample: Formal Process for Discipline and Termination
Working Hours and Rest Days
Employees shall be allowed at least one day off every seven days, and any overtime worked shall be voluntary. If
local law allows, employees may voluntarily work overtime on rest days provided that they are allowed at least one
day off within the next seven days. Continuous working days are never to exceed 21 days without a rest day.
McDonald’s Requirements on Working Hours and Rest Days

• Positive workplace standards include providing reasonable work hours and rest days. National and
local laws usually set maximum work hours and minimum rest days. Regardless of law, everyone shall
be allowed at least one day off in every seven days. 2 1F
• Any overtime worked shall be voluntary. If local law allows, people may voluntarily work overtime on
rest days provided that they are allowed at least one day off within the next seven days.
• Working hours, rest breaks, and meal breaks fall within legal requirements.
• A defined workweek is communicated to and understood by all employees.
• Workers are given at least one day off, of no less than 24 consecutive hours, every seven days, with a
maximum of 12 days in a row of work with one (1) rest day at the beginning and one (1) rest day at the
end of a two (2)-week period being permitted, unless the law is more stringent.
Working Hours and Rest Days: Implementation Guidance

Working Days and Rest Days Permitted by McDonald’s Standard
McDonald’s requires one (1) day of rest in seven (7) days, or the legal requirement, whichever is more stringent.
The below calendar illustrates the maximum number of permitted working days in a row while still allowing a day
of rest every seven (7) days. The employee in the scenario below received a rest day on Sunday, 1st and Saturday,
14th of the month. There is a maximum of 12 days consecutive work in this situation. In some cases, this may not
be permitted by local law, and the facility should follow whichever is more stringent.
Sunday Monday Tuesday Wednesday Thursday Friday Saturday

1 2 3 4 5 6 7
Rest Day
8 9 10 11 12 13 14
Rest Day
Key
Day worked by employee
Rest Day
2 Day of rest may occur on the first day of one week and the last day of the following week for a total of 12 consecutive worki ng
days in between while still complying with this requirement.
Working Hours and Rest Days: PDCA Examples (Best Practice)
The following is best practice guidance for how a supplier can use the PDCA model to comply with McDonald’s Working Hours and Rest Days
requirements.
o Compliance with national laws, regulations, and Codes of Conduct on o Workers record their own working hours
working hours o Production planning and management of working hours have a
o Compliance with the aforementioned requirements on rest days, including system to alert the employer when maximum allowable hours
at least one (1) day, with 24 hours of consecutive rest, each seven-day will be reached
period  Communication and Training:
o Overtime is voluntary, and is conducted only with at least 24 hours of o Initial and periodic training for workers on the company’s
notice working hours requirements, including that overtime work is
voluntary
o Technical training for managers and supervisors on how to
manage working hours within legal limits
 Documentation:
o Accurate working hour records, maintained for minimum of 12
months for which wages have been paid, as well as for most
recent time for which wages have not yet been paid
o Collective Bargaining Agreements (CBAs) or other documents
that stipulated maximums of working hours, and rest day
provisions are in place
 Corrective Action and Continuous Improvement:
o Conducting a root cause analysis (RCA) of any issues uncovered during
monitoring of working hours, including time periods in which maximums  Monitoring:
are exceeded o Establishing Key Performance Indicators (KPIs) on overtime worked, with a focus
o RCA on instances in which workers felt that overtime was not voluntary, on when maximums are reached or exceeded
with focus on improvement in communication regarding company policy o Internal audit of time records for accuracy.
and expectations
Workplace Environment
Suppliers shall ensure that all workers receive communication and training on emergency planning and safe work
practices. In addition, suppliers shall have systems to prevent, detect, and respond to potential risks to the safety,
health, and security of all employees.
McDonald’s Requirements on Workplace Environment

• You must have systems in place to identify, prevent, and respond to potential risks to the safety,
health, and security of all persons (employees, visitors, and contractors). (See Guidance on Job Hazard
Analysis and Workplace Exposure Monitoring below)
• Communication and training is provided on emergency plans and safe work practices.
• A safe working environment is maintained at all times; including proactive measures, which protects
the safety of all. (See best practice guidance below for conducting an emergency vulnerability
assessment).
• You must comply with the Critical Health and Safety Incident Response Process detailed below for any
health or safety related incidents that result in serious injuries or fatality to an employee working in a
supplier’s facility.
• Exits should be marked, unblocked, and unlocked, and evacuation routes should be well marked,
sufficiently illuminated, clear of obstructions, and lead to safe and well-known assembly points. (See
further details regarding emergency exit requirements below)
• You use experts to regularly assess the physical and structural integrity of buildings to ensure these
structures are capable of housing the machinery and people within, ensuring the property is free of
conditions that may cause personal injury.
• The dormitory or other housing you provide (such as single dwelling homes, or apartments) includes
the same standard of living for all residents.
• The physical and structural integrity of living quarters are assessed by experts to guarantee that they
are capable of and suitable for housing people.
• Living quarters afford a minimum of approximately 20 square feet (1.8 square meters) per person,
which includes sleeping area and available floor space.
• Everyone should be provided with a secure locker of at least one cubic foot (0.3 cubic meters).
• Facility provides food that is properly cooked, free from spoilage, and is processed, prepared, handled,
and stored in a manner that protects against contamination.
• Food service personnel ensure that multi-use food preparation, serving equipment, and utensils are
properly cleaned before they are used.
Critical Health and Safety Incident Response (CHSIR) Process
Objective
The objective of the Critical Health and Safety Incident Response (CHSIR) Process is to ensure that
McDonald’s has a consistent methodology to address major health and safety incidents that occur within the
supply chain that could cause significant brand risk to McDonald’s and jeopardize assured
supply. McDonald’s will utilize the CHSIR process to ensure that the Supplier continues to comply
with McDonald’s Supplier Code of Conduct and this Document, minimizes supply-chain interruptions, and
protects McDonald’s brand reputation.
Defined Terms
Corrective and Preventative Action Plan (CAPA) – a supplier’s improvement plan to address identified issues
and noncompliance that identifies the root cause of a noncompliance as well as immediate and long -term
actions to sustainably correct the noncompliance and prevent it from reoccurring.
Critical Health and Safety Incident (Incident) – any health or safety related incident at a supplier’s facility that
results in serious injury or death of an employee, contractor or visitor; or major damage to the facility or the
environment. Critical health and safety incidents include, but are not limited to:
1. Fatality or serious injury of employee, contractor or visitor that occurs while on the supplier’s site;
2. Work place violence/shooting incident;
3. Fire, explosion or other cause of major property damage that impacts areas where workers are
present;
4. Hazardous chemical release that causes serious human or environmental injury or initiates legally
required public notification; or
5. Reputable media or NGO report that details the exposure of workers to grossly unsafe working
conditions or failure to mitigate recognized hazards that pose an extreme risk to workers health.
Critical Incident Letter (CIL) – a letter sent by McDonald’s to a supplier when a critical health and
safety incident occurs.
Non-compliance – a failure to meet McDonald’s standards as outlined in the Supplier Code of Conduct and
Supplier Workplace Standards and Guidance Document (SGD).
Root Cause Investigation: Investigation conducted by a Root Cause Investigator using a systematic method of
problem-solving to determine the underlying reasons for how and why such an event occurred and to identify
the steps needed to correct the cause of the problem so that it will not recur.
Root Cause Investigator – an individual with workplace health, safety and regulatory compliance experience
that includes having conducted multiple root cause investigations related to fatalities and serious injuries.
Serious Injury – any physical injury or illness, including loss of a body part or permanent disfigurement or that
requires inpatient hospitalization for a period in excess of 24 hours for reasons other than observation.
Supplier Relationship Manager (SRM) – McDonald’s employee who is responsible for the relationship with the
supplier and will be the main contact from McDonald’s during the CHSIR Process.
Supplier Workplace Accountability (SWA) Audit – a physical on-site inspection of a supplier’s facility and
documents performed by a third-party auditor to ensure compliance with the Supplier Code of Conduct and
the SGD.
Supplier Workplace Accountability (SWA) Auditor – professionals who are qualified by McDonald’s to perform
SWA Audits. SWA Auditors with specialized skills may be required depending on the incident.
Process Outline
The CHSIR Process has three phases and four steps:
1. Phase I – Initial Report and Response, first month post incident
1. Phase II – Audit and Mitigation, within six to nine months post incident
2. Phase III – Recovery, within one year post incident (if needed)
3. Consequences of Noncompliance with CHSIR Process
*Please note that if this incident occurred in a location that requires a more stringent health and safety
incident response by law, the more stringent process applies.
CHSIR Process Timeline

Phase I (Initial Response) - Within 1 Month of Phase II (Audit and Phase III (Recovery) –
Incident Mitigation) – Within 6 Within 1 Year of Incident
to 9 months of Incident
Report Respond to Root Cause CAPA SWA Re-
Incident to Critical Incident Investigation SWA Audit Conducted Submitted, audit
McDonald’s Letter within five Starts Reviewed Conducted
within 48 (5) working days of and Accepted
hours receipt.
Phase I – Initial Response

o Supplier reports an Incident within 48 hours of the occurrence to their McDonald’s SRM and copies the
swa@us.mcd.com email address.
o McDonald’s SRM emails Critical Incident Letter (CIL) to supplier within 6 to 8 business days of
initial notification of the Incident. Supplier response required within 5 business days of receipt. If the
Incident is a fatality or serious injury, supplier must conduct a Root Cause Investigation and report the
overall findings and the supplier’s corrective action plans to the SRM. The Supplier should initiate the
Root Cause Investigation within 30 days post Incident. It is highly recommended that Supplier engage
an external and independent Root Cause Investigator to perform the Root Cause Investigation. If
requested, referrals for qualified Root Cause Investigators can be provided by the Global SWA Team.
Phase II – Audit and Mitigation

1. The Global SWA Team works with supplier to schedule an SWA Audit within 6 to 9 months
post Incident.
2. SWA Audit performed by SWA Auditors. If non-compliances are found during an SWA
Audit, supplier submits a CAPA plan per the normal SWA process. The CAPA plan will be accepted or
rejected by the SWA Auditor within 30 days from the SWA Audit. If CAPA plan is rejected, and supplier
is unwilling to devise a sufficient and acceptable CAPA, then proceed to Consequences of Non-
compliance with CHSIR Process.
3. After the SWA Audit, the supplier will receive the SWA report. An SWA Re-Audit is required
when amber (prompt action required) or red (immediate action required) non-compliances are cited.
If SWA Re-Audit is required, then proceed to Phase III – Recovery.
Phase III – Recovery
1. The Global SWA Team works with supplier to schedule SWA Re-Audit.
2. SWA Auditor(s) perform SWA Re-Audit. If the supplier is found to be in compliance, then proceed as
per the regular SWA program protocol; otherwise, proceed to Consequences of Non-compliance with
CHSIR Process.
Consequences of Non-compliance with CHSIR Process

Consequences related to non-compliance with the CHSIR Process are determined by the Global SWA
Team. Consequences may include, but are not limited to, an extension of time to correct
deficiencies, being placed on extended suspension of product shipment, or if a raw material
supplier, removal from approved supply list to the system, or termination as a supplier to McDonald’s.
Requirements on Emergency Exits

Emergency exits should be side-hinged and open in the direction of evacuation. If emergency exits that have a
different design, such as sliding exit doors, are expressly permitted by local law for use as emergency exits, these
exits will be acceptable under the McDonald’s SWA process, if these exits meet the additional requirements
outlined in this Document.
All exits should meet the following criteria:
• Can be opened from the inside by one (1) person alone, without assistance.
• Can be opened within 10 seconds.
• Can be opened with no more than two (2) actions, e.g., [1] turn the thumb-turn latch, [2] open the door.
• If powered, can be opened in the event of a power cut.
Non-Straightforward Emergency Exits

While McDonald’s requirement for exits is that exits open in the direction of travel, McDonald’s categorizes exits
that do not meet this requirement, but are still expressly permitted by local law, as non-straightforward exits. For
these types of exits, they are permissible as long as they meet the specific requirements outlined below, in
addition to the four (4) requirements above.
Doors opening inwards  Door opening inwards does not block an established egress route.
 Door will not be used by more than 50 employees at any given time.
Sliding doors  Items should not be stacked near the door to prevent the items from
falling on the door’s tracks and blocking the path for the door to open
in an evacuation, such as after an earthquake.
 Track for sliding door does not protrude from the floor and present a
trip hazard.
Rolling doors  Door can be opened within 10 seconds to a height that would allow a
person to evacuate.
Two (2) consecutive  Door can open immediately without running through the “air shower”
powered doors (air shower or other special cycle in the event of an emergency
pass-through doors)  All people working onsite have been trained on how to open this door
immediately during an emergency, which may not follow the normal
operation of the door, e.g.: by pushing an emergency “open” button,
manually pushing the door open
Two (2) Consecutive Powered Doors (Air Shower Pass-Through Doors)

This refers to doors that have two (2) doors to prevent dust or bugs from entering the
workplace. The design of these doors is such that the first door opens and closes
behind the user, and then an “air-shower” may run to dislodge dust or bugs from the
user’s clothing. During this cycle, both the first door and the second door are closed. At
the completion of this cycle, the second door opens, allowing the user to pass through
into the area following the door.
Because of the design of these doors, they are not ideal for use as an emergency exit. If
this type of door has been designated as an emergency exit, the exit must meet the special requirements noted
above.
Workplace Environment: PDCA Examples (Best Practice)
The following is best practice guidance for how a supplier can use the PDCA model to comply with McDonald’s Workplace Environment requirements.
o Policy establishing health & safety procedures and requirements in your o Documenting health and safety training needs, as well as a method to
facility ensure that training resources stay up to date
o Establishment of emergency response team  Communication and Training:
o All workers receive job-specific EHS training
o Training on prevention of potential transmission of communicable
diseases
o Posting of reminders for PPE, confined spaces
o Markings for firefighting equipment to ensure that the location is visible
even if the equipment itself is blocked
o Posting of Safety Data Sheets (SDS) in areas in which chemicals are used
and stored
 Documentation:
o Permits for buildings and special machinery

o Conducting a root cause analysis (RCA) of any issues uncovered during o Maintenance issues are identified
monitoring of working environment, with a focus on solving these issues o Regular internal checks to ensure exits and emergency evacuation
at the root pathways are not blocked or locked
o Timely maintenance action for areas that need repairs o Regular internal checks to ensure that firefighting equipment is not
blocked and is in good repair
o Air quality, noise, and temperature monitoring
o Regular internal checks to ensure the use of PPE
Workplace Environment: Implementation Guidance
Best Practices on Job Hazard Analysis
McDonald’s requires you to have systems in place to identify, prevent, and respond to potential risks to the safety,
health, and security of all persons (employees, visitors, and contractors). The following optional best practice
guidance highlights five (5) key steps you may consider for conducting a thorough and effective analysis of those
job hazards.
5 Steps to an Effective Job Hazard Analysis
 New or changed jobs and processes.

 High injury or illness rate.
Select Job to  Complex jobs.
Analyze
 Observe or video employee perform job.

 Record all discrete tasks or actions.
Break Job  Limit to no more than 10 tasks.

Into Tasks
 Identify hazards for each task.
 Ask questions about potential for slips and falls, physically

Identify demanding work, noise, exposure to chemicals, etc.
Hazards
 Identify most effective ways to control hazards.

 Apply control hierarchy of: 1) eliminate the hazard;
2) replace the hazard; 3) isolate the hazard;
Develop 4) change work practices; and 5) provide PPE.
Controls
 Incorporate findings in job instructions/procedures.

 Train affected employees.
Document &  Monitor effectiveness of controls.
Communicate
Best Practices on Workplace Exposure Monitoring

McDonald’s requires you to have systems in place to identify, prevent, and respond to potential risks to the safety,
health, and security of all persons (employees, visitors, and contractors). The following optional best practice
guidance highlights an example of a workplace exposure monitoring process for conducting a thorough and
effective analysis of potential health hazards in the workplace.
Workplace Exposure Monitoring Process
Emergency Vulnerability Assessment Tool
Best Practices on Emergency Vulnerability Assessment

McDonald’s requires a safe working environment to be maintained at all times; including
proactive measures which protect the safety of all. This optional best practice, Emergency
Vulnerability Assessment Tool, helps the facility to measure the probability and severity of an
event, the resources and planning in place to prevent that event, and the overall relative risk
of the event occurring.
Environmental Management
Suppliers are responsible for managing, measuring, and minimizing the environmental impact of their facilities.
Specific focus areas include:
 Air emissions,
 Waste reduction, recovery, and management,
 Water use and disposal, and
 Greenhouse gas emissions.
McDonald’s Requirements on Environmental Management

McDonald’s commitment to environmental leadership is rooted in both how we and our suppliers operate. In
addition to proactively managing their own operations, suppliers should influence their supply chains for
increased sustainability. We expect suppliers in all categories to have a robust sustainability program that is
focused on the suppliers’ biggest sustainability impacts with commitments to drive ambitious sustainability
outcomes.
In addition to the environmental standards in our Code, McDonald’s Global Sustainability Sourcing Guide (GSSG)
houses all expectations for self-managed excellence in sustainability for suppliers in all categories, including
specific commodity requirements. Suppliers should reference the GSSG for more information and to ensure
compliance to those requirements.
McDonald’s Auditable Standards by Chapter
McDonald’s verifies the following points during an SWA audit:
(Red): Severe – Immediate Action Required, Corrective and Preventive Action Plan Required
(Amber): Major – Prompt Action Required, Corrective and Preventive Action Plan Required
(Yellow): Minor – Corrective and Preventive Action Plan Required
Business Integrity
Requirement
Requirement Details
Section
Compliance with and Agreements are in place with outside employment agencies and sub-contractors that provide people who work
Knowledge of Laws directly or indirectly for the facility to ensure they are in compliance with expectations, including: working hours,
minimum age for working, compensation, benefits.
Copies of all valid business licenses and permits applicable to the business are available onsite.
Management systems are in place to ensure timely updates of changes in law.
Management representative is designated to ensure compliance with laws, including making sure everyone
understands and follows the Customer Expectations.
Bribery, Corruption, Facility complies with laws prohibiting bribery, corruption, extortion, and embezzlement, and the US Foreign Corrupt
Extortion and Practices Act (FCPA).
Embezzlement There are no attempts of bribery reported by the auditor.
Audits and Suppliers must permit auditing to verify compliance with the Code as required. Audits are facility inspections that
Assessments include employee interviews and a review of supplier records and business practices. The auditor is to have access to all
areas of the facility. Access is to include but not be limited to all production areas, offices, and, where provided,
dormitories and canteens/ cafeterias.
The facility must not coach, coerce, or incentivize workers to provide information to an auditor that does not accurately
represent the true situation in the facility.
Documentation and The facility must not maintain any fraudulent documentation or duplicate sets of records with the intent to deceive any
Recordkeeping third party.
Twelve (12) months of accurate and complete records are retained at all times.
Worker handbook, legal postings are in the language(s) of the workers.
Gifts, Favors and Facility signs and complies with the audit firm's audit integrity documentation, such as a gifts and gratuity policy.
Entertainment
Subcontracting Facility informs the Customer of use of a subcontractor for any part of the Customer’s production.
Home Work Facility does not use home work.
Requirement Section Requirement Details
Grievance Mechanisms Workers can report suggestions and grievances anonymously.
The facility fully investigates worker suggestions and grievances.
The worker suggestion and grievance processes are effective and aligned with local law.
There is no retaliation for workers that have reported suggestions or grievances.
Worker suggestion and grievance processes are outlined in written policies and procedures in the language(s) of the
workers. Written policies and procedures include the following:
 What the worker making the suggestion or grievance can expect from the process.
 Timeline for further communication.
 Assurance of confidentiality in making the report.
 Anti-retaliation policy.
There is/are person(s) identified to manage the worker suggestion and grievance processes. These processes also
include input from all levels of people to ensure that the processes function properly.
The facility communicates the worker suggestion and grievance policies and procedures to all people in the relevant
language(s).
The facility has an internal verification process to review the worker suggestions and grievances. This process analyzes
trends in suggestions/grievances to undertake corrective and preventative actions to address issues at the root.
Employee Practices: Involuntary Labor

Requirement
Requirement Details
Section
Involuntary No one is locked in or guarded for the purposes of preventing exit from the facility.
Labor Workers are allowed to leave their employment at any time, without being penalized financially and without potential
loss of residency.
Workers do not feel threatened or afraid that something bad will happen to them or their families if they leave their job.
Workers feel free to leave the workplace at the end of the working shift.
Workers are free to move around the workplace, take restroom and water breaks when needed. Permission is given to
leave the facility under reasonable circumstances, such as for personal or family emergencies, without disciplinary
penalty.
Sites producing for the Customer have not sourced from and are not on a publicly-available national governmental list
or registry that documents forced labor violations.
Workers are free to decline overtime work, and without monetary disciplinary action.
Workers are aware of the overtime policy upon hire: communicated expected overtime hours per day/ week/ month,
conditions, and procedures to opt out.
Supplier has a documented process to verify that they are not sourcing from a site on a publicly-available national
governmental list or registry that documents forced labor violations.
Supplier has a documented process to stay up-to-date and compliant with all applicable laws related to involuntary
labor.
Migrant Labor Workers should be free from direct or indirect payment of any fees, fines, taxes, bribes, kickbacks, deposits, or bonds for
the purpose of recruitment or placement.
Fees paid by workers are reimbursed within 30 days of employment.
Terms of employment outlined at the time of recruitment will not differ in any way from what was being provided at the
facility, including type or work stated. The employment relationship should be free from contract substitution.
Workers should be free from pressure, coercion, or threats in any way into accepting a job or to maintain employment,
such as threat of denunciation to authorities, law enforcement.
Facility’s partner labor agencies must allow verification of practices, including through auditing. Facility must terminate
collaboration with agencies that refuse this requirement.
Workers must retain possession and control of their personal identity documents, except for when there is a short -term
need to make original identity documents available to government agencies for the processing of visas, work permits,
or other legally-mandated purposes.
Each migrant worker must be provided with individual secure storage, to which only the worker has access, for identity
and other legal documents.
Workers must have sole control over their own bank accounts and there should be no compulsory savings programs in
place for workers.
Facility must pay for repatriation of migrant workers in all cases, including if their employment terminates prior to the
end of the contract, except for in cases of documented gross misconduct or illegality. Workers should also not be
penalized by deduction of wages, including deduction of bonuses, for early termination of their contracts.
Migrant workers receive pay that is equal with local workers for equal work.
The employment agency will have signed employment contracts with ALL people, local and migrant, which have been
dispatched to the facility. The contract will be in a language understood by the person signing , and the facility and
agency are responsible for ensuring the contract is understood by the signee. Contracts for migrant workers must be
signed at least five (5) days prior to deployment.
There should be one (1) uniform contract signed by workers. For labor supply country corridors in which both the
sending country and receiving country require different legal stipulations to be outlined in the contracts, the contract
content is harmonized to the greatest extent possible, and the contracts must be equally favorable to the worker.
Facility can demonstrate that migrant labor agencies are licensed on both the sending and receiving country sides.
Food and housing for migrant workers should be charged at a rate that is at or below market price.
Reimbursements of recruitment fees takes into account the actual fees paid by workers; or, in cases in which there are
largely divergent reports of fees paid, reimbursement uses an average of fees in the same country corridors and
agency pairings while also taking into account outliers that may have paid more fees due to specific circumstances.
Facility follows the reimbursement guidance provided in this document.
Facility has mapped out country corridors, agency pairings, fees charged, sub-agents involved, modes of transport, and
modes of housing for migrant workers along their journey from their home to the facility.
Facility has a system to stay up to date on the laws for the sending and receiving countries in the facility’s migrant labor
supply chain.
Facility monitors the practices of agencies’ worker recruitment and selection processes to ensure compliance.
Facility conducts intake interviews with migrant workers within five (5) days of arrival at the facility to map out fees paid
by workers as well as other aspects of the recruitment process to ensure agency compliance.
Facility maintains documentation, signed and acknowledged by the worker, to show the calculation of fees paid by that
worker, the total fees reimbursed to that worker, and the date(s) of repayment.
There should be a non-retaliation policy that prohibits reprisals from the facility, sending country agency, or receiving
country agency, against workers for reporting information on recruitment fees or other unethical practices in the labor
supply chain.
Migrant worker-related policies must be written in the language(s) understood by the migrant workers.
Employment Status Accurate and complete documentation, i.e., work permits, I-9s in the US, labor market opinions (LMOs), etc., is used for
all people to verify legal status to work, and the facility maintains documentation of these records for the length of time
required by the law, or 12 months from the last date of the worker’s employment, whichever is more stringent.
The facility has contractual requirements on its suppliers, employment agencies, labor brokers, subcontractors to be in
compliance with labor laws and regulations.
Labor contracts comply with legal requirements).
The labor contract is current and a signed copy is provided to the person signing; contract should be written in the
language of the workers.
Prison Labor Facility does not use prison labor.

Requirement
Requirement Details
Section
Underage Labor/Young All employees at or above the legal age required by local law, or at least 14 (if law is less stringent).
Everyone within the facility is historically at or above the age requirement by local law at time of hire. Management
Workers system has successfully prevented the facility from hiring workers that are currently of the working age but were below
the working age at the time of hire, otherwise known as historical underage labor.
Underage labor is remediated in line with this standard.
Facility reviews, validates, and/or has a process to maintain legal proof of age documentation, upon hire.
Facility registers young workers with the local labor department, including work permits, as required by law.
Facility provides occupational health and safety education and training to all young workers and apprentices.
Facility provides regular health examinations for young workers, apprentices, as required by law, with fees paid by the
facility.
Facility provides special protection restrictions (working hours, working in coordination with school hours, working
night shift, dangerous work, or handling hazardous substances which may harm physical, spiritual, moral, or social
development) for protected groups, such as young workers, apprentices, as required by law.
Apprenticeships are designed to impart knowledge and programs follow all legal requirements.
There are policies and procedures in place to prohibit the hiring of underage labor, and the assignment of hazardous or
overtime work to young workers.
Training is provided to staff involved in recruitment to support effective review of age and identity documentation, on-
boarding interviews to verify age at time of hire, and maintenance of copies of age and identity documents.
Facility tracks, analyzes trends in recruitment of workers with discrepancies in age or identity documents, identifies
root causes for these non-compliances related to training, and modifies training and communication to all to prevent
future issues.
Standard
Requirement Details
Section
Freedom of Association Facility does not require and/or discourage union membership as a condition of hire or continued employment.
Suppliers shall respect the rights of people to bargain collectively where such rights are established by law or contract.
Representatives within the facility are freely elected without management interference, in accordance with local law.
Representatives in worker associations include non-management employees, if required by law.
Representatives are allowed to carry out activities relating to workers' rights and interests without management
interference and are given access to the workplace in order to carry out their representative functions, all in
accordance with law.
There is a written policy in the language(s) of the workers on freedom of association and collective bargaining at the
facility.
The facility communicates the policy regarding freedom of association and collective bargaining to the workers.
The facility has a system to stay up to date on legal requirements related to freedom of association and collective
bargaining.

Requirement
Requirement Details
Section
Anti-Discrimination and Facility is free from discrimination in the areas of recruitment, training, working conditions, job assignment, standard
Fair Treatment wages, non-standard wages such as bonuses, opportunity to work overtime, benefits, promotions, discipline,
termination, and retirement in these areas: race, color, age, gender, gender identification and expression, sexual
orientation, ethnicity and national origin, disability, pregnancy, religion, political affiliation, union membership, marital
status, medical condition, or any other personal characteristics.
Facilities should ensure all are treated equally regarding benefits, dormitory, and/or canteen/cafeteria privileges.
There is an anti-discrimination policy that prohibits discrimination on the basis of any attributes including: race, color,
age, gender, gender identification and expression, sexual orientation, ethnicity and national origin, disability,
pregnancy, religion, political affiliation, union membership, marital status, medical condition, or any other personal
characteristics.
There are procedures that ensure that decisions made on hiring, working conditions, job assignment, salary –
including bonuses, promotion, opportunity to work overtime, benefits, discipline, termination, and retirement, are
based on suitability for the job, merit, and job performance, rather than personal characteristics.
The facility has communicated the general anti-discrimination policy to all working onsite; the facility has also
communicated to relevant staff, such as managers, Human Resources, etc., additional specific requirements on anti-
discrimination that are relevant to their work.
Harassment and Abuse Facility is free from sexual, psychological, and physical harassment and abuse; intimidation; verbal harassment; and
bullying.
Security practices are gender-appropriate and non-intrusive.
Unwanted sexual attention does not occur.
There is an anti-abuse policy at the facility that covers sexual, psychological, and physical harassment and abuse;
intimidation; verbal harassment; and bullying.
The facility has communicated the general anti-abuse policy to all working onsite; the facility has also communicated
to relevant staff, such as managers, Human Resources, etc., additional specific requirements on anti-abuse that are
relevant to their work.
There is a documented procedure for reporting abuse that reminds all working onsite to file reports using the
established grievance mechanism.
Requirement
Requirement Details
Section
Wages & Benefits Minimum wage is paid to everyone according to local/national law, or industry benchmark if local law is silent.
Wages paid meet legal requirements on compensation.
Regular and overtime working hours are paid as per local/national laws, collective bargaining agreements, individual
employment contracts, and applicable overtime agreements.
Workers are paid on time and in full each pay period, as per law.
Workers are paid directly or pay is sent to a bank account under the worker’s name. Cash payments are acceptable as
long as the worker signs to verify receipt.
Payroll receipts are provided to all.
Payroll receipts clearly indicate regular and overtime hours, compensation and benefits, taxes, deductions, and
allowance, are designed in accordance with local laws, and in the language(s) of the workers.
Statutory benefits mandated by law are provided in accordance with local/national law, including but not limited to
retirement benefits, severance pay, health insurance, social insurance, leave (i.e., annual, family, sick,
maternity/paternity, etc.), and holidays.
Facility pays legally mandated withholdings to the appropriate government agency (agencies).
Facility maintains and/or ensures that they have a process to access and make available complete payroll records,
including correct wage calculation including hourly, piece rate, agency, and subcontract workers, etc.
If an approved government issued waiver was obtained for extending working hours, the hours and wages for the
total working hours are calculated and paid correctly.
If allowed by law, deductions made from wages (e.g., food, housing, utilities) are reasonable. All people, including
local and migrant workers, are able to opt out of these benefits unless they are mandated by law. In absence of law,
total combined charges for food, housing, utilities should be no more than 50% of minimum wage and must be
outlined in work contract.
The facility has postings on wages and benefits, as required by law.
There is an internal audit process to ensure that wages are calculated correctly.
The facility tracks and analyzes trends of errors in wage calculations, and identifies root causes for the prevention of
these issues in the future.
Employee Discipline Facility does not use monetary disciplinary practices.
Facility consistently applies the discipline process.
Facility complies with all applicable laws regarding disciplinary practices.
Facility clearly communicates rules, regulations, and disciplinary process and procedures in language(s) understood
by all, at the time of hire, and updates this communication as required.
Facility’s discipline process includes a process for appeals.
Facility maintains written records of disciplinary investigations and actions, including appeal process and outcomes.
Managers and supervisors are trained on appropriate disciplinary measures.
Facility tracks disciplinary actions, analyzes trends in non-compliances that resulted in disciplinary action, identifies
root causes for these non-compliances related to training, and modifies training and communication to all to prevent
future issues.

Requirement
Requirement Details
Section
Working Hours and Rest Workers do not work more than 21 consecutive days. 3 3F
Days Workers do not work more than 18 consecutive hours.

Regular and overtime hours are within allowable limits under applicable law and/or collective bargaining agreement .
Total working hours do not exceed 80 hours in a work week, regardless of law.
Rest and meal breaks are provided in line with local law, employee contracts, and applicable collective bargaining
agreements.
The facility provides at least one (1) day off of 24 consecutive hours every seven days, with no more than 12
consecutive days of work with one (1) rest day at the beginning and one (1) rest day at the end of a two (2) -week period
being permitted. If law, the employment contract, or collective bargaining agreements are more stringent, then the
more stringent requirement should be followed. Special restrictions are respected for protected groups, such as
pregnant workers, workers with disabilities, with regard to working hours, rest days, as required by law.
Facility has a system in place to record working hours accurately and consistently.
If a manual time system is used, people acknowledge personally the manual recording of actual working hours by
signature or initials at least once per week. For hand-written attendance records, actual time in and time out must be
included, and all workers must sign and acknowledge at least once per week (“tick” or other symbols are not
acceptable).
The facility tracks and analyzes trends in excessive working hours, identifying the root cause, to prevent these issues
from occurring in the future.
3 McDonald’s
standard for rest days is that one (1) rest day is provided in seven (7) days; if consecutive workdays exceed 21 days, the finding in the Audit Summary Report
(ASR) will be escalated to Red.
Workplace Environment
Requirement
Requirement Details
Section
Emergency An established “Environment, Labor, Health & Safety Committee” is in place with the following:
Training and  Composed of members from variety of shifts, functions, and personnel.
Communication  Has assigned management sponsor.
 Has process for implementing safety committee recommendations.
 Meets at least quarterly, or more frequently as required by law.
 Meeting outcomes are documented and communicated to rest of organization.
Documented procedures identify health and safety training needs, including:
 Appropriate training materials and methods for all people within the facility.
 Mechanism for controlling, updating relevant documents to ensure they are accurate, up to date.
All workers are provided job-specific health and safety training prior to starting a job, and periodically in line with local
law. This minimally includes:
 Hazard recognition, and how to report.
 Safe operation of machinery.
 Proper inspection and use of PPE.
 Safe handling of waste, hazardous materials, and operating equipment.
All people working in the facility, including third-party contractors, who perform authorized maintenance and
servicing activities receive appropriate training on lock-out/ tag-out procedures and practices, prior to conducting
any work. This includes:
 Overview of the relevant lock-out/ tag-out process.
 Understanding site-specific energy controls.
 Dangers of overriding or ignoring lock-out/tag-out procedures.
The facility should establish an emergency response team. Everyone part of this team should be trained on the
proper use of fire extinguishers.
All individuals within the facility are knowledgeable and informed of fire prevention procedures, which include:
 Hot work permits.
 Storage and handling of combustible materials.
 Good housekeeping.
 Fire hazard identification.
Training is provided on the prevention of potential transmission of communicable diseases. Training includes:
 Symptoms and modes of transmission.
 Methods to reduce exposure.
 Applicable PPE selection.
 Actions to take in an emergency including reporting.
 Post-exposure evaluation.
 Signs, labels, and color-coding used to prevent and control exposure.
Facility trains everyone on reporting unsafe conditions/hazards within the workplace, and in the event of an injury or
illness on the job.
The facility tracks injuries, accidents, and near misses, and maintains and acts upon these records.
Training records are maintained for at least 12 months.
Safe Workers are provided adequate working space to avoid potential safety hazards.
Working Work areas have adequate lighting, ventilation, and temperature controls.
Conditions Facilities are kept clean and maintained in good condition, including walkways and aisles, yard and storage areas, lifts
and stairways.
Internal and external (third-party, government) building inspections conducted as required by local law; external
inspection immediately following events that may affect structural integrity, such as:
 Significant changes in structural loading weight and purpose of use.
 Movement of heavy equipment onto work floors previously not fitted with that equipment.
 At the time of worker complaints regarding structural integrity.
 Addition or demolition of parts of the building.
 As needed when identified by regular maintenance checks.
 After catastrophes, such as fires, tornados, corrosive chemical spills, tornados, earthquakes, tsunamis,
hurricanes/typhoons, after termite infestation.
Maintenance issues are identified and repairs implemented in a timely manner.
Maintains all legally required construction licenses and building permits to develop new or restore existing facilities (if
required by law), and follows permit requirements during operations.
Facility determines, posts, and adheres to allowable floor loading weights.
Maximum load limits are conspicuously marked on all cranes, slings, hoists, and lifts ensuring those maximum loads
are followed; hoist hooks are equipped with a safety latch to prevent accidental release of the load.
Electrical Electrical systems and wiring are maintained in safe condition, including the following elements:
 Panels receive regular maintenance.
 Panels are covered and easily accessible.
 Wiring is insulated and covered.
 Wiring does not present a trip or overhead hazard.
Qualified electricians are available to monitor electrical systems and provide maintenance as needed.
Water/ All water, inside or outside of the facility drains properly to prevent standing water, and reduce hazards of slipping or
Air/Noise/ breeding of insects.
Temperature Air quality is monitored for the health and safety of all people within the workforce.
Air pollution control systems, such as spray paint booths, are maintained in a safe and proper working condition and
are of a design appropriate and adequate to the pollution hazard they are controlling.
Air discharge—such as dust, fumes, gas, mist, odor, smoke, vapor, pollen, soot, carbon, acid, or particulate matter, or
any combination thereof—is controlled with a system designed for the specific pollutant(s) to minimize air pollution
to protect all people. Examples of stationary sources of air pollution include:
 Furnaces, boilers, water heaters, and emergency generators that burn fossil fuel, such as natural gas or fuel oil.
 Spray booths for painting and finishing that have ducts to the outside.
 Solvent cleaning stations.
Noise and temperature levels are monitored for the health and safety of all.
Facilities with machines that utilize rotating parts should conduct vibration monitoring, as required by law or the
manufacturer’s recommendations, and maintain records of this monitoring.
Confined Confined or enclosed workspaces (such as tanks, pits, boilers, silos, vaults, enclosed conveyors, process vessels, and
Workspace manholes) are identified, with related hazards evaluated, before people are allowed to enter.
All confined spaces are identified by a posted sign which requires those entering to follow established entry
procedures. All safety signage should be posted in language(s) understood by the workforce, as necessary.
Only authorized and trained people are permitted to enter confined-space areas or to assist another person with work
in a confined-space area.
Potential Risk of Provides functioning fall protection when work is performed that exposes workers to a potential fall of greater than
Loss of Life/ 1.8 meters (approximately 6 feet). Examples of fall protection are:
Limb or Function  Guardrails.
 Safety nets.
 Personal fall arrest systems, such as full body harnesses or lifelines.
Every open-sided floor or platform 1 meter (approximately 39 inches) or higher should be guarded by adequate railing
on all open sides, except where there is an entrance to a ramp, stairway, or fixed ladder.
Loading docks above 1 meter (approximately 39 inches) in height are to have a demarcation, such as a chain, to
prevent falls.
Emergency Exits are a permanent fixture in the building.
Preparedness Exits are not blocked, permanently or temporarily.
Exits are not locked.
 Can be opened from the inside by one (1) personal alone without assistance, and within ten (10) seconds.
 Can be opened with one (1) hand.
 Can be opened with no more than two (2) actions: e.g., [1] turn the thumb-turn latch, [2] open the door.
 If exits are powered, can open in the event of a power cut.
 Exits may only be locked if they can be opened meeting all of the above criteria and this is expressly permitted
by local law.
Exits should open in the direction of travel, unless exits with another type of design are expressly permitted by local
law. If permitted by local law, those exits must meet all of the following relevant criteria:
 For doors opening inwards:
o Door opening inwards does not block an established egress route.
o Door will not be used by more than 50 employees at any given time.
 For sliding doors:
o Items should not be stacked near the door to prevent the items from falling on the door’s tracks and
blocking the path for the door to open in an evacuation, such as after an earthquake.
o Track for sliding door does not protrude from the floor and present a trip hazard.
 For rolling doors:
o Door can be opened within ten (10) seconds to a height that would allow a person to evacuate.
 For two (2) consecutive doors in a row, such as in an air shower to prevent dust and bugs, or for all power -
operated doors:
o Door can open immediately without running through the air shower or other special cycle in the event of
an emergency.
o All people working onsite have been trained on how to open this door immediately during an emergency,
without following the normal operation of the door, e.g., push an emergency open button, manually slide
the door open.
There are sufficient secondary emergency evacuation exits for production floors, office areas, warehouse/storage
buildings, and canteen. A secondary exit must be provided for all spaces unless local law permits only one (1) exit. If
local law is silent on the requirement for secondary exits, the facility should follow international standards. 4 4F
Exit route doors must also be free of decorations or anything that could distract from their function as exit route
doors.
Each route beyond the exit must not be blocked and must safely lead to an adequate assembly point to
4 If local law
is silent on the requirement for a secondary exit, follow guidance in Section 1006, International Fire Code (IFC) 2018 “Numbers of Exits and Exit Access
Doorways.” The facility should be prepared to demonstrate to the Auditor the type of building, its occupancy, and the number of exits re quired as per the IFC.
accommodate the building occupants likely to use the exit route. Assembly points must not be blocked.
Exit route doors should be marked in the language(s) understood by workers. Exit signs shall be readily visible from
any direction of egress travel.
The path to exits and within exits shall be marked by readily visible exit signs to clearly indicate the direction of egress
by occupants. All doors along the exit route shall be marked by exit signs.
Doors located next to/near emergency exits that may be mistaken for emergency exits should be marked with signs
that state “Not an Exit” in the language(s) understood by the workers.
Exit doors must not lead to a drop-off higher than 18cm (approximately 7 inches); drop-offs must be marked, and the
markings must be clearly understood by all people working onsite.
Exit doors should not open to an area shared with vehicle or machine traffic; but if shared, there is a lane demarcated
for vehicle or machine traffic.
Exit paths do not lead to areas with hazardous chemicals or machinery. Direction of egress is marked to lead workers
away from these hazardous areas. All people working onsite have been trained on the meaning of these markings.
Handrails should be of uniform height, sturdy, easy to grip, and should not affect the use of the stairs.
All firefighting equipment is free from blockage.
A fire detection and alarm system that is distinct, audible, and if required by nature of the facility, visible. Alarm
system activation buttons and alarm speakers and/or lights are located in all areas of the workplace and tested
regularly to ensure proper working order.
Firefighting equipment is current and correct for the nature of operations in terms of quantity and the correct class to
extinguish the types of fire hazards present in the facility.
Firefighting equipment is marked in the language(s) understood by the workers to indicate the location of this
equipment should the equipment not be readily visible.
Firefighting equipment is mounted and installed according to law.
Emergency lighting is maintained and in working order. To ensure continued illumination for not less than 90 minutes
in case of primary power loss, the sign shall be connected to an emergency power system.
A comprehensive emergency and evacuation plan for any type of emergency situations, including, but not limited to,
the following: fires, medical emergencies, environmental accidents, natural disasters, active shooters, air raids, and
civil disobedience; the plan should also be in compliance with all laws. The plan should reflect the risks that affect the
facility.
All people working at the facility should be trained and tested on the plan no less than once per year, and the facility
should also communicate relevant procedures to visitors and contractors.
Emergency evacuation drills based on the comprehensive emergency plan are conducted at least once per year, or
more often if required by law, on all shifts. Drills should include evacuation without power.
Emergency evacuation plans are posted, indicating users’ physical location with “you are here” in language(s)
understood by those within the workplace.
Facility has a site coordinator assigned to assist facility management in assuring that all elements of the fire
protection and emergency preparedness program are in place and working. The coordinator receives training in
emergency preparedness planning and is familiar with all elements of the facility’s emergency plan.
Facility has required fire inspection certification(s), and these are current.
All incidents and emergencies are investigated in order to identify root causes, and a strategy developed and
implemented to prevent recurrences.
Personal Proper PPE is provided free of charge, including replacements as required to all people within the workplace.
protective Management monitors to ensure the provided PPE is inspected, worn, and used correctly.
Equipment (PPE) PPE is to be provided for any of the following conditions:
 Eye/ face protection should be provided where there is potential for injury.
 Foot protection: Adequate footwear is to be worn at all times. The facility provides protective shoes/boots
where foot injuries could occur.
 Hearing protection should be provided to reduce the noise exposure to less than 85 decibels (dB).
 Hand protection should be provided to adequately protect against potential injury.
 Protective clothing should be provided to prevent exposure to hazards such as: chemicals, lacerations,
punctures, cold, burns, or blood.
 Head protection, such as hardhats, should be provided to protect against falling objects or other striking or
impact hazards.
 Respiratory protection should be provided where the potential for inhalation exposure to harmful types of
airborne contaminants could occur. People with any type of respiratory conditions should not be assigned to
areas where respirators are required.
 Infectious material exposure: Where the potential for exposure to infectious materials exist, PPE is to be
provided, as well as appropriate handling procedures communicated, to prevent the transmission of diseases.
 All visitors are provided with appropriate PPE when entering or working in areas where signage indicates PPE is
required. Safety and PPE requirements are communicated to visitors upon arrival at the site.
All are trained on why they need to wear PPE, how to use it correctly, and the benefit.
Facility has installed signage visible where PPE is to be worn, in language understood by all.
Machine Safety Special appliances, equipment, and machinery, i.e., forklifts, cargo lifts, boilers, pressure vessels, furnaces, etc., has
been properly registered and affixed with a registration certificate as required by law.
The operators of all special equipment, i.e., forklifts, cargo lifts, boilers, electrical devices, etc., and machines are
properly trained in safe operating procedures, AND are licensed, where applicable.
Potentially dangerous parts of machinery are covered with appropriate machine safeguards and these guards are
properly maintained.
Machines have proper emergency stop switches, where applicable.
Power isolation equipment (i.e., lockout/ tag out) is used during maintenance repair
Exposures to safety hazards are evaluated, identified, and controlled.
The facility follows requirements for the maintenance, inspection, and operation of all equipment, appliances, and
machinery according to industry standards, manufacturer recommendations, or applicable law.
Medical Care There must be adequately trained staff to handle medical emergencies, with people with current qualifications in first
aid and CPR on each shift. There should be at least two (2) people trained in first aid, and two (2) people trained in CPR,
or 1% of the facility workforce, whichever is greater, on each shift.
First-aid kits are fully stocked and readily accessible to all, with expiration dates of products therein checked
periodically, and expired materials replaced promptly.
Medical and/or occupational health exams are provided as required by law.
A documented process to prevent the transmission of communicable diseases from contact with bodily fluids is
implemented. The process should include identification of job classifications that might have exposure to blood -
borne pathogens, such as nurses, first aid personnel, or cleaning staff.
Approved medical professionals and/or a first aid treatment room on site, if required by law.
The facility has implemented a program to identify, evaluate, and control exposure to workplace hazards, such as
manual handling, heavy lifting, highly-repetitive tasks, machine operation, chemical handling, and other physically
demanding jobs, to prevent work-related injuries.
Records are kept for work related injuries and accidents.
Chemicals and Chemicals are properly labeled, used, stored, and maintained in a manner that prevents leaks and inadvertent mixing
Hazardous of incompatible materials by using appropriate secondary containment in line with the requirements in Safety Data
Materials Safety Sheets (SDS).
All chemicals used at the facility are registered for the intended use or as allowed under local law.
Emergency eyewash and showers are readily available where corrosives and chemicals are used and stored; and in
line with the recommendations provided in SDS Emergency, eyewash and showers are inspected weekly and records
of inspections are kept.
Facility disposes of carcinogens, toxins, and hazardous wastes in a manner that protects the health and safety of all
as well as the environment.
Liquid propane gas tanks and cylinders, acetylene tanks, and chemical storage areas are safely located away from
sources of ignition such as sparks, flames, heat, and flammable materials, are properly vented, and in a secured area
at a reasonable distance from all human beings to prevent safety hazards.
Safety data sheets (SDS) are readily available in the work areas where chemicals are used or kept in a place where
they are accessible by workers and are in language(s) understood by the people using the chemicals.
The facility and/or hired third-party vendor has a valid business permit to engage in the collection, storage, and
disposal of hazardous wastes.
Hazardous wastes (including chemicals, combustibles, flammables) are properly handled, stored, and disposed.
Periodic monitoring and review of risks related to chemical and hazardous material safety is conducted in all areas to
determine if exposures are properly controlled and below established limits.
A high-level risk assessment regarding chemicals and hazardous materials is completed to determine and prioritize
areas of high risk.
Restroom/ Facility provides an adequate number of toilets based on the number of employees, AND separated by gender, with
Toilet Facilities labels as required by law.
Toilet facilities meet local hygiene requirements, including sinks with running water and soap.
Toilet facilities are cleaned and serviced regularly to ensure they remain in sanitary condition. Potable drinking water
is available.
Dormitory or provided housing 5 is structurally sound and in good repair. Internal and external (third-party,
5F
government) building inspections conducted as required by local law; external inspection immediately following
events that may affect structural integrity, such as:
 Significant changes in structural loading weight and purpose of use.
 Movement of heavy equipment onto work floors previously not fitted with that equipment.
 At the time of worker complaints regarding structural integrity.
 Addition or demolition of parts of the building.
 As needed when identified by regular maintenance checks.
 After catastrophes, such as fires, tornados, corrosive chemical spills, tornados, earthquakes, tsunamis,
hurricanes/typhoons, after termite infestation.
Dormitory/ There are sufficient secondary emergency evacuation exits for the dormitory or housing. A secondary exit must be
Provided Housing provided for all spaces unless local law permits only one (1) exit. If local law is silent on the requirement for secondary
exits, the facility should follow international standards. 6 Exits are a permanent fixture in the building.
F
6
Exits are not blocked, permanently or temporarily.

Exits are not locked.
 Can be opened from the inside by one (1) personal alone without assistance, and within ten (10) seconds.
 Can be opened with one (1) hand.
 Can be opened with no more than two (2) actions: e.g., [1] turn the thumb-turn latch, [2] open the door.
 If exits are powered, can open in the event of a power cut
 Exits may only be locked if they can be opened meeting all of the above criteria and this is expressly permitted
by local law.
Exits should open in the direction of travel, unless exits with another type of design are expressly permitted by local
5 If childcare
facilities are present, they should follow the requirements outlined here for housing.
6 If local law is silent on the requirement for a secondary exit, follow guidance in Section 1006, International Fire Code 2018 “Numbers of Exits and Exit Access Doorways”.
law. If permitted by local law, those exits must meet all of the following relevant criteria:
 For doors opening inwards:
o Door opening inwards does not block an established egress route.
o Door will not be used by more than 50 employees at any given time.
 For sliding doors:
o Items should not be stacked near the door to prevent the items from falling on the door’s tracks and
blocking the path for the door to open in an evacuation, such as after an earthquake
o Track for sliding door does not protrude from the floor and present a trip hazard
Exit route doors must also be free of decorations or anything that could distract from their function as exit route
doors.
Each route beyond the exit must not be blocked and must safely lead to an adequate assembly point to
accommodate the building occupants likely to use the exit route. Assembly points must not be blocked.
Exit route doors should be marked in the language(s) understood by workers. Exit signs shall be readily visible from
any direction of egress travel.
The path to exits and within exits shall be marked by readily visible exit signs to clearly indicate the direction of egress
by occupants. All doors along the exit route shall be marked by exit signs.
Doors located next to/near emergency exits that may be mistaken for emergency exits should be marked with signs
that state “Not an Exit” in the language(s) understood by the workers.
Exit doors must not lead to a drop-off higher than 18cm (approximately 7 inches); drop-offs must be marked, and the
markings must be clearly understood by all people working onsite.
Exit doors should not open to an area shared with vehicle or machine traffic, but if shared, there is a lane demarcated
for vehicle or machine traffic.
Exit paths do not lead to areas with hazardous chemicals or machinery. Direction of egress is marked to lead workers
away from these hazardous areas. All people living in the dormitory have been trained on the meaning of these
markings.
Handrails should be of uniform height, sturdy, easy to grip, and should not affect the use of the stairs.
Firefighting equipment is current and correct for the nature of operations in terms of quantity and the correct class to
extinguish the types of fire hazards present in the facility.
Firefighting equipment is marked in the language(s) understood by those living in the dormitory to indicate the
location of this equipment should the equipment not be readily visible.
Firefighting equipment is mounted and installed according to law. All firefighting equipment is free from blockage.
Emergency lighting is maintained and in working order. To ensure continued illumination for not less than 90 minutes
in case of primary power loss, the sign shall be connected to an emergency power system. A fire detection and alarm
system that is distinct, audible, and if required by nature of the facility, visible. Alarm system activation buttons and
alarm speakers are located in all areas of the dormitory and tested regularly to ensure proper working order.
Emergency evacuation plans and routes are posted, indicating users’ physical location with “you are here” in
language(s) understood by those within the dormitory. Emergency evacuation drills based on the comprehensive
emergency plan are conducted at least once per year, or more often if required by law. Drills should include
evacuation without power.
The physical condition of buildings and surrounding property such as walls, floors, and sidewalks are to be maintained
free of damage that can cause personal injury.
Residents are permitted to exit and/or re-enter the dormitory freely during their personal time.
The dormitory is separate from the production and warehouse building,
Dormitories are clean and well maintained.
Living space (per resident) is adequate (separated by gender, adequate temperature, ventilation and lighting, not
overcrowded).
Provided with an adequate number of clean toilet and shower facilities, potable water.
Facility’s dormitory provides all living there with an individual storage area for each occupant.
Canteen/ Facility maintains a valid and current food handler health certificate for food preparation p ersonnel, as required by
Cafeteria law.
Services 7 7F Facility maintains a valid and current food permit/ hygiene certificate for the kitchen, as required by law.
Correct hygienic practices such as hand washing are used.
People found to have communicable diseases, such as Hepatitis B or tuberculosis, are not allowed to work in the food
service area.
Dining halls/break rooms, if provided, are clean and well maintained.
Canteen/dining hall provides enough seating.
Food safety training is required for everyone who works in the canteen/ cafeteria.
Physical exam records are on file for everyone within the canteen/ cafeteria, as required by law.
Environmental Management
Standard Section Requirement Details
Environmental All required permits, licenses and/or registrations for discharge/disposal are current and available: e.g., greenhouse
Management gas emissions (GHE); solid waste disposal; water use and/or abstraction; wastewater effluents treatment or
discharge; air emissions; and hazardous substance management.
Facility is free from any environmental violations resulting in monetary penalties and/or non-monetary sanctions in
the past 12 months.
7 All Emergency Preparedness requirements from production areas apply to the canteen.
Definitions by Chapter
Management Systems
Management System How a company gets things done. It is made up of interdependent policies, processes, and procedures organized to enable a
company to achieve its business objectives (quality products, on-time delivery, profitability) and meet Code of Conduct
expectations.
Policy Statement of commitment to what the company hopes to achieve. For example, “our company will not work with suppliers
who employ child labor.”
Process Major part of the system, consisting of a set of actions that together make up a business function. For example, the
recruitment, selection, and hiring process is designed to hire the right person for the job at the right time.
Procedures Step-by-step descriptions of how a job or task within a process is done, by whom, and when. For example, a procedure to
verify the age of a job applicant is part of the recruitment process. Also referred to as “controls.”
Risk Controls Procedural steps or improvements made to address the possibility of an unintended outcome. For example, steps to validate
the authenticity of an applicant’s proof of age documentation are designed to reduce the risk of hiring an underage worker.
Business Integrity
Anything of Value Can include money, kickbacks, favors, gifts, lavish entertainment, airfare and hotel costs, and other items.
Conflict of Interest When someone has competing personal or professional financial interests or obligations that could wrongly influence that
person’s decision-making.
Whistleblower Informant who reports suspected wrongdoing within an organization in the hope of stopping it. A whistleblower can be from
within the organization itself, from a supplier or customer, or from the general public. Persons who act as whistleblowers are
often the subject of retaliation by their employers.
Home Work Work carried out by a person in his or her home or in other premises of choice, somewhere other than the workplace of the
employer for remuneration which results in a product as specified by the employer. For purposes of this standard, home work
refers to work performed by non-management workers who are directly involved in the manufacture of a product.
Grievance A perceived injustice, which may be based on law, contract, explicit or implicit promises, company policy, customary practice,
or general notions of fairness.
Grievance Mechanism Series of processes and steps for identifying and, wherever possible, resolving concerns that have been raised by workers.
Employee Practices: Involuntary Labor
Agency Pairing Pairing of sending country and receiving country agencies through which the migrant worker came. There could be one (1)
country corridor, Vietnam-Taiwan, with three (3) Agency pairings—Agency A in Vietnam to Agency B in Taiwan, Agency C in
Vietnam to Agency B in Taiwan, and Agency C in Vietnam to Agency D in Taiwan (A-B, C-B, C-D).
Contract Substitution Practice by which a migrant worker is asked to sign one (1) version of a contract, typically with more favorable terms, and t hen
another contract, usually upon arrival in the receiving country, and this contract has less favorable terms. This is also called
“contract bait-and-switch.”
Country Corridor Pairing of countries for labor sourcing, the sending country plus the receiving country. Workers coming from Vietnam to
Taiwan are in the country corridor Vietnam-Taiwan.
Debt Bondage When workers must continue to work in order to repay a debt to a labor broker, their employer, or another third-party.
Forced Labor Defined by the International Labour Organization (ILO) as “all work or service which is exacted from any person under the
menace of any penalty and for which the person has not offered himself voluntarily.” It is a serious violation of a fundamental
human right. Work is involuntary and is considered forced labor when a person has entered into a job against their will and
cannot leave that job without facing a penalty or a threat of penalty. Penalties can include actual or threats of physical
violence, withholding of identity documents or wages, threats of deportation, and imposing fees that are impossible to repay.
Human Trafficking Process of bringing workers into a situation of exploitation through a series of actions, including deceptive recruitment and
coercion.
Indentured Labor When workers are bound to their employer with or without an employment agreement and are not able to leave at will.
Migrant Labor Workers that have relocated for a specific role and job in a location other than the worker’s hometown. This is different than a
situation in which a migrant relocates to another location in order to find work and then subsequently finds work in that area.
Recruitment Agents Private agencies, labor brokers, labor recruiters, and any third-party agencies involved in the recruitment, selection, hiring,
housing, transportation, and/or in some cases, the management of migrant workers in either the sending or receiving
country.
Receiving Country Country in which the supplier’s facility is located and at which the foreign migrant worker is working.
Sending Country Migrant worker’s country of origin and citizenship.
Slavery A form of indentured labor in which an employer or a labor broker exercises (perceived) power of ownership over a worker.
Sub-agents Third-parties other than the recruitment agent to facilitate recruitment, selection, hiring, and/or transportation of foreign
workers. They include, but are not limited to, middlemen, travel agents, and transportation providers.
Apprentice Someone who is working at a site but the work is designed to impart knowledge. Apprenticeship schemes that do not impart
knowledge are known as “false apprenticeships,” and the apprentice working under this type of a scheme would be subject to
all requirements that apply to regular workers, including paying wages that may be higher than what an apprentice would
earn under a true apprenticeship scheme. Facilities should avoid false apprenticeships and not rely on this type of support to
cover purely labor needs.
Historical Underage A worker that is currently of the legal working age, but was hired when they were below the working age. This represents a
Labor major gap in the facility’s management system to prevent child labor and is therefore noted as such.
Underage Labor A worker that is not of the legal working age, otherwise known as child labor.
Young Worker A worker that is of the age required to legally work, but under 18.
Collective Bargaining Refers to the way employers and worker representatives reach agreements on working conditions, wages, overtime,
grievance procedures, and worker involvement in workplace affairs in accordance with local/national law. The result of this is
typically a Collective Bargaining Agreement (CBA).
FOE In some locales, statements permitted by law regarding unions; stands for:
 Facts – providing facts about unions and union involvement.
 Opinions – providing opinions about unions and union involvement.
 Examples – providing true examples of situations that have occurred with unions or union involvement.
Freedom of Allowing workers to form and join trade unions, worker associations, and worker councils or committees of their own
Association choosing, consistent with and in accordance with local law.
Peaceful Assembly Refers to the right of workers to come together and collectively express their ideas to management related to the terms and
conditions of employment in accordance with local law. An “assembly” is an intentional and temporary gathering in a private
or public space for a specific purpose and includes demonstrations, inside meetings, strikes, processions, rallies, or even sits-
ins.

Bullying / Intimidation Persistent pattern of mistreatment from others in the workplace that causes either physical or emotional harm. It can include
such tactics as verbal, non-verbal, psychological abuse and humiliation.
Harassment Any inappropriate conduct toward another person that creates an intimidating, hostile, or offensive work environment.
Regular or Base Wage What is paid to workers on an hourly, weekly, or monthly basis for their regular work hours. This rate is usually a legal
minimum wage set by the government or an industry benchmark wage and should be specified in the workers’ employment
contracts. In some locales, base wage may include non-discretionary bonuses.
Hourly Rate Amount of money paid for every hour worked. It is the monthly regular/base wage divided by the number of regular working
hours. This is typically the basis used to calculate wages for hours that require special premia, such as workday, rest day, and
holiday overtime.
Piece Rate Rate paid for a set number of units of work produced or harvested.
Overtime Rate Amount of money paid for any work beyond regular hours; must be at the premium rate required by the country law.
Disciplinary Any deductions from a worker’s wages, including from bonuses—except for full attendance bonus—as a means of
Deductions punishment.

Overtime Work Hours Hours worked beyond the number of regular hours in a day or week. Overtime can be performed either before or after the
worker’s normal workday or shift.
Regular Work Hours The hours worked during the normal workday. Local law typically sets the limit of regular hours to between 40 and 48 per
week. Working hours are defined by law and may include time moving to and from the work area, donning personal protective
equipment (PPE) and uniforms, and other activities. The facility should track working hours following the way they are defined
by local law.
Rest Time Rest and meal breaks from work during the normal workday or the full day off each week. Both rest breaks and rest days are
typically required by local law.
Seventh Day of Rest One (1) rest day in a total of seven (7) days. McDonald’s Code of Conduct allows for the movement of rest days to allow for a
total of 12 consecutive days of work, with a moved rest day on both sides of this period. If local law is more stringent than the
seventh day of rest requirement, then supplier is to follow local law.
Working Hour Records Records that the employee uses to record the hours that they work. Auditors may review these records, as well as shift
schedules and work arrangements, production records, other electronic time keeping data, and overtime approval records.
Working Environment
Emergency Plan Procedures for responding to an emergency, such as a fire, explosion, or a chemical spill. An emergency plan is necessary to
keep order and minimize the effects of the emergency event.
Engineering Control The use of physical/engineering methods to eliminate or minimize the hazard. Examples of engineering controls include
ventilation, elimination, enclosure, and substitution.
Hazard A physical condition, object, or agent that has the potential to cause harm to a worker and/or to cause damage to property or
environment.
Incident Investigation Systematically gathering and analyzing information about an incident for the purposes of identifying and addressing root
causes to prevent a recurrence of the incident.
Industrial Hygiene The anticipation, recognition, evaluation, and control of health hazards in the work environment that may cause harm to
worker health. Also known as occupational hygiene.
Non-straightforward While McDonald’s requirement for exits is that exits open in the direction of travel, McDonald’s categorizes exits that do not
Emergency Exits meet this requirement, but are still expressly permitted by local law, as non-straightforward exits. For these types of exits,
they are permissible, as long as they meet specific requirements.
Personal Protective Any device worn by a worker to protect against hazards, by acting as a barrier between the worker and the hazardous agent.
Equipment (PPE) Some examples are: respirators, gloves, ear plugs, hard hats, safety goggles, and safety shoes.
Risk The likelihood that a harmful effect such as an accident or occupational disease will occur.
Risk Assessment Process of quantifying the frequency or probability of a harmful effect or event (e.g. exposure to a hazardous agent, harm to a
worker during work activities) and is one of the first steps in risk management.
Safe Work Practices Process of quantifying the frequency or probability of a harmful effect or event (e.g., exposure to a hazardous agent, harm to a
worker during work activities) and is one of the first steps in risk management.
Workplace Inspection A regular check of a workplace or work area to identify health and safety hazards and to recommend corrective action.

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McDonald’s

Supplier Workplace Accountability

At McDonald’s, suppliers are an integral part of our System.

Welcome McDonald’s Suppliers.....................................................................................................................................................2

How is this Document organized?

How was this document developed?

Policies • Must be clearly written and up to date.

Procedures • Must be clearly written and up to date.

 Monitoring, including verification, such as worker feedback processes,

Five Whys Methodology (Best Practice Recommendation)

Root Causes Finite Actions to Consider

McDonald’s Supplier Code of Conduct Standards

 Corrective action and continuous improvement:  Monitoring:

McDonald’s Supplier Code of Conduct Standard

McDonald’s Requirements on Grievance Mechanisms

 Corrective Action and Continuous Improvement:

Compatible With • Responses consistent with standards of customer Codes of Conduct

Effective Grievance Process Flow: Best Practice Guidance

McDonald’s Supplier Code of Conduct Standard

McDonald’s Requirements on Employment Practices: Involuntary Labor

Employer-Paid Fees and Expenses

Situation Local/Resident Worker Foreign or Internal Migrant Worker

 Cash deposits and bonds.

After job offer  Additional skills tests.  Additional skills tests.

 Transportation and lodging  Pre-departure training or orientation (including

Start of  Arrival and onboarding.  Arrival and onboarding.

Fees that May Be Paid by the Worker

 Initial passport, visa, residency

 Corrective Action and Continuous Improvement:  Monitoring:

McDonald’s Supplier Code of Conduct Standard

McDonald’s Requirements on Underage Labor/Young Workers

Terminate The employment relationship between the facility and the

Create a The facility must create a detailed and time-bound remediation

Immediate Action Ongoing Support and Monitoring

McDonald’s Supplier Code of Conduct Standard

McDonald’s Requirements on Freedom of Association

Freedom of Association: PDCA Examples (Best Practice)

 Corrective Action and Continuous Improvement:  Monitoring:

McDonald’s Supplier Code of Conduct Standard

McDonald’s Requirements on Anti-Discrimination and Fair Treatment

McDonald’s Supplier Code of Conduct Standard

McDonald’s Requirements on Wages and Benefits & Employee Discipline

Sample: Formal Process for Discipline and Termination

McDonald’s Requirements on Working Hours and Rest Days

Working Hours and Rest Days: Implementation Guidance

Sunday Monday Tuesday Wednesday Thursday Friday Saturday

McDonald’s Supplier Code of Conduct Standard

McDonald’s Requirements on Workplace Environment

CHSIR Process Timeline

Phase I – Initial Response

Phase II – Audit and Mitigation

Consequences of Non-compliance with CHSIR Process

Requirements on Emergency Exits

Non-Straightforward Emergency Exits

Two (2) Consecutive Powered Doors (Air Shower Pass-Through Doors)

 Corrective Action and Continuous Improvement:  Monitoring:

5 Steps to an Effective Job Hazard Analysis

 New or changed jobs and processes.

 Observe or video employee perform job.

Break Job  Limit to no more than 10 tasks.

 Identify hazards for each task.

 Ask questions about potential for slips and falls, physically

 Identify most effective ways to control hazards.