2.12 Business Practices/Ethical Code of Conduct
Purpose
THE COMPANY is committed to conducting business with honesty, integrity, professionalism, and respect. This Ethical Code of Conduct outlines the standards expected of all Team Members to protect our guests, coworkers, vendors, and the reputation of THE COMPANY and SUBWAY®. All Team Members are required to comply with this Policy as a condition of employment.
Professional and Ethical Behavior
Team Members are expected to act with professionalism and uphold THE COMPANY’s values at all times. This includes acting with honesty and integrity, treating others with respect, following all Company policies, and performing duties in a safe and ethical manner. Behavior that negatively impacts guests, coworkers, operations, or THE COMPANY’s reputation is prohibited.
Honesty, Accuracy, and Transparency
Team Members must be truthful in all work-related interactions. This includes cash handling, timekeeping, food preparation, guest communication, safety reporting, and documentation. Falsifying records, lying to management, withholding information, or misrepresenting facts violates this Policy.
Compliance With Laws and Regulations
Team Members must follow all applicable federal, state, and local laws, including wage and hour laws, child labor regulations, ADA and accommodation requirements, anti-discrimination and anti-harassment laws, privacy laws, and all SUBWAY® brand standards. Illegal activity on or off premises that affects THE COMPANY may result in corrective action.
Conflicts of Interest
Team Members must avoid situations where personal interests conflict—or appear to conflict—with the interests of THE COMPANY. Examples include accepting gifts or favors from vendors, using Company resources for personal benefit, or having outside employment that interferes with availability or performance. Any potential conflict must be disclosed immediately.
Confidentiality and Information Protection
Team Members must protect sensitive and confidential information, including guest data, Team Member information, payroll or financial data, operational strategies, security procedures, and any nonpublic SUBWAY® brand materials. Sharing or mishandling confidential information—intentionally or unintentionally—is prohibited.
Workplace Integrity and Property Protection
THE COMPANY’s property, equipment, supplies, food, cash, and digital systems must be safeguarded at all times. Team Members must not steal, misuse, waste, or negligently damage Company property. This includes protecting POS equipment, keys, access codes, documents, cleaning chemicals, and food inventory.
Accurate Recordkeeping
All business records must be complete, accurate, and maintained according to Company procedures. This includes timecards, cash logs, deposits, food safety logs, equipment temperature logs, inventory sheets, incident reports, and other operational records. Altering or falsifying records violates this Policy and may result in termination.
Anti-Bribery and Anti-Corruption Standards
Team Members must not engage in bribery, kickbacks, gifts-for-favors, or improper payments to guests, vendors, contractors, inspectors, or coworkers. Even minor gifts that appear to influence business decisions are prohibited.
Proper Use of Company Systems and Technology
Company systems and technology—including POS equipment, mobile devices, scheduling systems, and communication tools—must be used only for authorized business purposes. Team Members must protect passwords, avoid accessing systems without permission, and never install unauthorized software or applications on Company devices.
Guest Experience and Hospitality
Ethical conduct includes delivering safe, accurate, and respectful service to every guest. Team Members must follow all SUBWAY® food preparation standards, sanitation rules, portioning requirements, and hospitality expectations. Guests must always be treated with courtesy, regardless of circumstances.
Substance Use and Fitness for Duty
Team Members must report to work sober, alert, and ready to perform job duties safely. The use of drugs, alcohol, or any impairing substance during working hours, or reporting to work impaired, is strictly prohibited.
Reporting Ethical Concerns
Team Members are expected to report any violation of this Policy or any conduct that appears dishonest, unsafe, illegal, or unethical. Reports may be made using the Complaint/Incident Reporting Form, to a Manager, or to the Director of Operations. All reports will be reviewed promptly and confidentially to the extent permitted by law.
Protection From Retaliation
THE COMPANY strictly prohibits retaliation against any Team Member who makes a good-faith report, requests an accommodation, raises safety or compliance concerns, or participates in an investigation. Retaliation is a serious violation and will result in corrective action.
Accountability and Discipline
All Team Members are responsible for complying with this Policy. Violations may result in corrective action up to and including termination of employment. Managers and Supervisors have an enhanced responsibility to model ethical behavior, protect Company assets, and enforce this Policy consistently.