Introduction
What Is The Code?
Subway (which includes Subway Worldwide, Inc. and its subsidiaries and affiliates) has created an Employee Code of Business Conduct (the "Code") and policies designed to help you understand our values, comply with the law, and to simply do the right thing. Following the Code not only results in compliance with applicable laws and regulations, but it also protects the reputation of the brand and demonstrates our commitment to integrity.
Please note that the Code of Conduct applies to corporate employees of Subway. Subway® restaurants are owned and operated by independent franchisees and each restaurant is solely and independently responsible for its legal and regulatory compliance, including any employment related matters pertaining to the restaurant.
We have a responsibility to our fellow employees, franchisees, guests, and the public to act with integrity and lead by example.
You will be asked to annually affirm your commitment to integrity by acknowledging your agreement to the standards outlined in the Code. Please take this opportunity each year to recognize the compliance responsibility Subway places in each and every one of us, as Subway will take seriously any failure to act in accordance with the Code’s principles. Our success depends on each of us being accountable for doing the right thing.
At Subway, we must uphold the highest standards of integrity. Each of us has a role to play and is responsible for our individual actions. Take the time to read the Code carefully. Follow its standards and do your part to ensure the continued success of Subway for years to come!
The Basics
Why do we have a code? Who does it apply to? Will anyone know if I have read it?
The Code aims to describe some of the most critical rules all employees must follow and what to do if we think some have been broken or ignored. While the Code cannot encompass every legal or ethical issue, it provides guidance for questioning concerns that are not specifically stated and help you understand what we expect of you. Our success depends on each of us being accountable for doing the right thing.
Violations of the Code and our policies will be addressed promptly and may result in disciplinary action up to and including termination in accordance with applicable law. We may update the Code, our policies or adopt a new policy at any time to incorporate improvements or to comply with changes in the law or regulations. It is your responsibility to be aware of these policies and updates. We will make updates available on our HQ Intranet - SubHub. Managers have additional responsibilities and are expected to make sure that all of the employees that they supervise are aware of these policies and to promote compliance with them.
If you have questions concerning the Code, contact Human Resources at [email protected]
- To ensure compliance with applicable laws and regulations
- To uphold our company’s values and to protect our reputation
- To maintain a culture of accountability and ethical behavior
- To provide employees with a guide and reference to support decision making
- To protect the Subway brand
All employees, officers and company executives are expected to comply with the Code. In our Code and in our policies we may simply refer to “employee(s)” or “you”.
When you have questions about how to act, what to do, or what to consider in making a business decision consult the Code. We expect you to follow the Code and the policies referenced in it as well as any other policies that the company has adopted when you conduct business on behalf of the company (“company” or “we”).
We will ask you to acknowledge reading the Code annually. It is your responsibility to take the time to read the Code and associated policies carefully and ask questions if you are unsure how to act in a particular situation. Failure to read the Code or sign the acknowledgement does not excuse you from complying with it.
Include the Employee Code of Business Conduct in your day to day decision making
Use the Code to help guide you through any decisions that you make. Use it to think about all aspects of how your decision or action might impact us and the Subway brand. Ask yourself these questions to help guide your actions:
Is what I am planning to do consistent with the Code?
YES, NO, or MAYBE?
Will what I am thinking of doing raise legal concerns?
YES, NO, or MAYBE?
Does it follow our policies?
YES, NO, or MAYBE?
Does it benefit the Company or the Subway brand as a whole and not just a particular individual or group?
YES, NO, or MAYBE?
Would I feel okay if what I did was made public?
YES, NO, or MAYBE?
Our Code does not list every legal or ethical issue that you may encounter, but if the answer to any of these questions is “no” or even “maybe” that is a signal for you to stop and ask questions or seek advice. It is always better to ask before you act.
Speak Up! Report It
All employees are encouraged to ask questions, raise issues, and report their concerns without fear of retaliation.
Any suspected unethical, illegal or suspicious behavior must be reported immediately. The Compliance team will treat all reports seriously and investigate each report thoroughly. We do not tolerate retaliation against anyone who makes a good faith report of suspected misconduct or otherwise assists with an investigation or audit.
To report an issue or a concern or ask a question, use at least one of the following options:
Tell your Manager or Contact Human Resources at [email protected]
Visit speakup.subway.com or call the Compliance Line at 1-800-461-9330 (if you are located in the U.S.)
From outside of the U.S., check speakup.subway.com and select your country for the direct access dial instructions
Contact Compliance at [email protected]
Your report is confidential.
We will endeavor to keep your identity, the reported facts and the identity of the persons covered by the report, confidential. Your identity will not be disclosed beyond the authorized staff members competent to receive or follow up on reports without your consent, unless we are required to do so by law or by a judicial authority. You can also make a report anonymously through the Compliance Line, if local laws permit.
No Retaliation
If you report a concern in good faith in accordance with our No Retaliation Policy, you will not be subjected to any adverse employment action including:
- Unfair dismissal, demotion or suspension
- Unfair denial of a promotion, transfer or other employment benefit
- Bullying and harassment, either in person or online
- Exclusionary behavior
- Any other behavior that would single you out unfairly
Nothing in our Code prohibits you from communicating with a government agency about possible violations of laws or otherwise providing information to government agencies, filing a complaint with government agencies, or participating in government agency investigations or proceedings, and our Code does not require you to notify us when you do so.
We do not tolerate retaliation against individuals who report issues of potential policy or legal violations in good faith.
If any person believes they have witnessed or been the subject of a violation of this policy, they should report the matter immediately to Human Resources, Compliance, or speakup.subway.com.
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Reach out to our Compliance team if you have any questions.