Whistleblower Policy

Compliance with internal policies is ensured by providing employees an avenue to participate and report any breaches of our policies. Under the Company's Code of Business Ethics, employees have the duty to report actual or perceived violations of the Company

Under the Company's Whistleblower Policy, a whistleblower is entitled to remain anonymous, to be safe from retaliation, including harassment or disciplinary action in connection with such reports. The appropriate Legal & Ethics office is tasked to coordinate with Human Resources for the implementation of measures to safeguard the anonymity and safety of the whistleblower. The reports are raised directly to Global Legal & Ethics and the appropriate Ethics Council within the region concerned, and are monitored by the Global Ethics Council and the Audit Committee.

To access a copy of the Whistleblower Policy, please click here.

For any violations of the Company's Code of Business Ethics and related policies, you may contact Global Legal & Ethics through the following:

Email: [email protected]

Mobile: +63 949 8891160

Mailing address: Global Legal & Ethics - Jollibee Foods Corporation, 6/F Jollibee Plaza, F. Ortigas Jr. Avenue, Ortigas Center, Pasig City

Training & Communications

Ethics Training is part of the New Employee Onboarding Program, which all new hires must undergo. Moreover, the Ethics Program includes yearly training sessions and refresher tests for all employees worldwide, which are developed and implemented as part of the Company's core curriculum for employees, through the collaboration of Global Legal & Ethics and Global Human Resources and Region HR offices. These interactive e-learning sessions are regularly conducted to ensure continued awareness of and compliance with the Code of Business Ethics and other related policies. Annual reminders on our policies are also sent to all employees who are required to accomplish yearly disclosure forms and declarations of compliance to ensure continued adherence with the Policy on Gifts and Policy on Conflict of Interest.

Policies

The key policies focused on ethics are the following:

• Anti-Bribery and Corruption Policy

  The Policy on Anti-Bribery and Corruption formalizes and operationalizes the Company's policy on compliance with laws on anti-bribery and corruption. It prohibits making or accepting any offer, promise, or gift of money or anything of value directly or indirectly from a party with whom the Company does business or who seeks to do business with the Company, for the purpose of influencing the recipient's decisions or actions in order to facilitate, obtain, or retain business. It likewise prohibits any payment by or on behalf of the Company if any portion thereof is intended to be used, directly or indirectly, for purposes contrary to applicable anti-bribery and corruption laws or the Policy on Anti-Bribery and Corruption. Through this policy, the JFC Group requires its directors, officers and employees to comply with anti-bribery and corruption laws applicable in the regions where they respectively do business and that may be applicable to them regardless of location.

  To access a copy of the Anti-Bribery and Corruption Policy, please click here.

• Policy on Gifts

  The Policy on Gifts prohibits giving or receiving gifts or favors, except in limited instances and subject to applicable laws. This policy includes an express prohibition on any cash as form of gift-giving and prohibits gifts that are or may be suggestive of any illegal activities. There is also an absolute prohibition on the giving or receiving of gifts or favors to or from those who are presently involved in any tendering, bidding, selection and approval process; those who do contract management and performance assessment of a person having or seeking a business relationship or transaction with the Corporation; and those who influence the hiring or employment process. A violation of this policy may result in disciplinary action corresponding to the nature and seriousness of the offense.

  To access a copy of the Policy on Gifts, please click here.

• Policy on Conflict of Interest

  In business dealings with outside parties, the Company takes steps toward ensuring that it is not subject to any conflict of interest and that dealings with suppliers and service providers are without favor or preference, other than the best interest of the Company. The Company's Policy on Conflict of Interest provides that every employee shall avoid interests, relationships, transactions or activities that may impair or appear to impair the performance of his duties to the best of his ability. Likewise, every employee is expected to exercise objectivity and impartiality when fulfilling his function, and to avoid circumstances that may compromise or appear to compromise such objectivity and impartiality.

  To access a copy of the Policy on Conflict of Interest, please click here.

• Supplier Code of Conduct

  The Company's commitment to lawful business practices is extended to our suppliers and third parties with whom we do business, who are contractually required to abide by the laws of the territories in which they do business and to immediately report violations of our Policy on Gifts, such as by offering or soliciting gifts in relation to third-party transactions.

  To access a copy of the Supplier Code of Conduct, please click here.

Monitoring

The Company, through its Internal Audit function, performs regular and special audits and reviews, audits and assesses the adequacy and effectiveness of the internal control system of all major areas of the Company in safeguarding that integrity of business dealings to verify, among others, that corporate funds are not misappropriated towards illicit transactions, bribes, or kickbacks that personally benefit employees or external parties. On the basis of the approved audit plans, internal audit examinations cover, at the minimum, the evaluation of the adequacy and effectiveness of controls that cover the Company's governance, major operations, and key information systems, including the reliability and integrity of critical financial and operational information, effectiveness and efficiency of major operations, protection of assets, and compliance with contracts, laws, rules and regulations. Internal Audit, under the supervision of the Company's Ethics Council, conducts further work whenever it is necessary. Our financial controls are also subject to annual external audits.