The Code of Conduct’s expectations for Suppliers related to appropriate human rights and labor practices include: 

1. Hiring Practices: Employing only those individuals who are legally authorized to work. Age, identity and legal right to work is verified for each employee. 

2. Minimum Age Requirements/Child Labor: Prohibits underage child labor as defined by local, state/provincial and federal agencies. In the United States, follows rules set forth by the Fair Labor Standards Act (FLSA) and other applicable laws, which set wages, hours worked and safety requirements for minors (individuals under age 18). Internationally, we encourage adherence to standards and Conventions set forth by the International Labour Organization (ILO) or similar local authority. 

3. Healthy and Safe Work Environment: Provision of a safe and healthy workplace in compliance with applicable local, state/provincial and federal laws and regulations. 

4. Housing: If housing is provided for employees, facilities must be constructed and maintained in accordance with applicable laws, regulations and housing codes. 

5. Voluntary Employment: Employment only of individuals whose presence in the workplace is voluntary. Consistent with ILO Conventions and Recommendations on forced labor, there should be no utilization of or engagement with factories or production facilities that force work to be performed by unpaid or indentured laborers, or those who must otherwise work against their will. 

6. Working Hours and Time Off: All employees work in compliance with applicable laws and regulations and with published industry standards pertaining to the number of hours and days worked. 

7. Wages and Benefits: Employers fairly compensate and provide wages, benefits and overtime premiums to their employees that comply with applicable laws and regulations, account for all hours worked, and match or exceed the local minimum wages and benefits in the relevant industry. 

8. Discrimination and Harassment: Provision of equal opportunity to employees in compliance with state/provincial and federal laws. Provision of a work environment free of any form of discrimination or harassment. 

9. Freedom of Association: Respect for the right of employees to join legal organizations of their own choosing. Must not threaten or penalize employees as a result of any lawful efforts to organize or bargain collectively. 

For purposes of the third-party reviews, we have evaluated and subsequently authorized several human rights and labor practice frameworks that are generally consistent with the expectations set forth in the code. Some of the certifications more commonly used today include the Equitable Food Initiative, SA8000, and SEDEX/SMETA. From time to time, we have been asked by certain stakeholders about participation by Wendy’s and our suppliers in the Fair Food Program. Wendy’s considers the Fair Food Program to be an acceptable assurance that would meet the requirements set forth in the code; however, at the present time, none of our suppliers use the Fair Food Program framework. As we have previously shared, since 2019 we have been sourcing tomatoes for our North America restaurants exclusively from indoor, hydroponic greenhouses while our understanding is that the Fair Food Program operates in the outdoor, field-grown tomato sector.