Our Business
External Communication on Behalf of the Company
Only the Corporate Communications Department is authorized to represent the company to media. You should refer all requests for information or interviews to the Communications Department. If you are asked to speak or present at an event or conference, you must seek approval from your Manager and the Communications Department in advance. Only designated counsel are authorized to represent the company with legal authorities.
Use of Social Media
We respect your right to use social media for personal purposes. When communicating on social media you are responsible for complying with our Social Media Policy. You are accountable for any information you post online. Social media best practices can be found on our SubHub page.
Every Subway employee is a powerful ambassador of the Subway® brand and plays a key role in advancing our global mission to build a "Better Subway". Your words and actions have the power to influence the way people view and interact with the brand, as well as the livelihood of Subway team members around the world.
Social Media Engagement Guidelines
- Make your relationship with us known when posting online on issues related to us or the Subway® brand including any work-related issues or our products and include a disclaimer as outlined below
- Respect the privacy of your co-workers and refrain from publishing photos of them without their consent
- If you want to post pictures from a work event, you are encouraged to share what Subway has posted on LinkedIn as we have obtained all necessary approvals from the individuals involved.
- Ensure any information you post related to us or the Subway® brand is accurate
- Everything on the internet is discoverable, regardless of privacy settings. Before posting something about Subway, take an extra moment to confirm it is truthful and cannot be misrepresented.
- Comply with the rules of use and/or terms and conditions of the social media sites you use
- Respect all copyright and other intellectual property laws. For our protection as well as your own, it is critical that you respect the laws governing copyright, fair use of copyrighted material owned by others, trademarks and other intellectual property, including our copyrights, trademarks and brands
- Ensure that your social network profiles and related content are consistent with how you wish to present yourself to colleagues and guests
- Be aware that others will associate you with the Subway® brand when you make your relationship with us known
- “Pretext”, or pretend to be someone you are not online
- Use ethnic slurs, discriminatory remarks, personal insults, obscenity, or engage in any similar conduct that would not be appropriate or acceptable in our workplace
- Defame the Subway® brand, team members, guests or competitors
- Engage with negative comments on Subway accounts or on behalf of the brand
- Speak on our behalf or on behalf of the Subway® brand if you are not expressly authorized to do so
- Share confidential information about us or the Subway® brand, including information about business partners, vendors, customers or business strategy
- Misrepresent our products, services, or employees
- Use your company email address to link to personal social media accounts and efforts
- Create a link to our websites from your social media without identifying your relationship with us
- Commit the Subway® brand to any action unless you have the authority to do so
Conflict of Interest
Conflict of interest can occur when your personal activities, investments or associations compromises your judgment or ability to act in our best interests. You must disclose any relationships, associations or activities that could create actual, potential, or even perceived, conflict of interest (for example an ownership interest in a Subway franchise that is held by you or a family member) to Human Resources. For more information see our Conflict of Interest Policy.
Corporate Opportunity
A corporate or business opportunity is a chance to do business or enter into an agreement that you become aware of or have knowledge of because you are our employee. Because you work for us the opportunity or knowledge of it belongs to us and you may not take advantage of the opportunity or knowledge for your own benefit. As an employee you must progress our legitimate interests at all times. You (or indirectly your family) may not take personal advantage of opportunities or favors that are offered to you due to your position with us.
You may not: (a) take for personal gain opportunities that are discovered through the use of our property, information, or position, (for example if a landlord who knows you work for us makes you aware of the opportunity to lease a location that would be suitable for a Subway® restaurant you (or your family member) may not then lease that location for your (or your family’s) own benefit) or (b) accept discounts on personal purchases or a supplier’s or customer’s products or services unless such discounts are offered to all employees in general.
Complying with the Law
If a provision of the Code conflicts with applicable law, the law controls.
Because of our U.S. presence, our employees around the world may also be subject to U.S. laws. Other countries also may apply their laws outside their borders to our operations and employees. If you are uncertain what laws apply to you, or if you believe there may be a conflict between different applicable laws, consult your local regional counsel or the Legal Department before proceeding.
Privacy
Privacy is of the utmost importance and we strive to handle personal information with care. There are data privacy laws that regulate how to responsibly collect, store, use, share, transfer and dispose of personal information and we strive to comply with those laws everywhere we operate. If you handle any personal information as part of your job, including collecting personal information on our behalf, you must follow our Privacy Policy. Only use personal information in the way it is meant to be used and do not share it with anyone inside or outside of the company unless authorized to so. Review our Privacy Policy FAQs for more information on handling personal information.
Store all personal information securely and store it only for as long as it is needed for the purpose for which it was collected and in line with our Data Retention Policy.
Report all breaches of privacy, including the loss, theft of or unauthorized access to personal information, to [email protected]. Review our Privacy Breach Notification Policy for additional information.
Fair Competition and Antitrust
Most of the countries in which we do business in around the world have fair competition or antitrust laws in place to safeguard the rights of consumers to be able to obtain the best products at the best prices. We support and comply with these laws.
You are required to:
- Communicate the brand’s products and services in a manner that is fair and accurate, and that discloses all relevant information
- Familiarize yourself with our Fair Competition Policy and remain aware of the consequences of any violation of policies or laws governing fair competition
- Consult Compliance before engaging in any new practice that may affect fair competition
- Refrain from price fixing, bid rigging, and any other anti-competitive activities
- Use only publicly available information to understand business, guests, competitors, business partners, technology trends, and regulatory proposals and developments
- Advise your manager immediately of possible violations of fair competition.
Money Laundering
We comply with anti-money laundering laws. Money laundering is the process of taking illegally-gained proceeds from criminal or corrupt activities ("dirty money") and making it appear legal ("clean").
You must never knowingly aid money laundering or terrorist financing. You must take steps to prevent inadvertent use of our business activities for these purposes.
You must immediately report any unusual or suspicious activities or transactions, such as:
Attempted payments in cash or from an unusual financing source
Arrangements that involve the transfer of funds to or from countries or entities not related to the transaction or customer
Unusually complex deals that don’t reflect a real business purpose
Attempts to evade record-keeping or reporting requirements
Bribery and Facilitation Payments
We do not attempt to influence the judgement or behavior of a person in a position of trust by paying a bribe or kickback. This applies to persons in government as well as those in private business.
We do not permit facilitation (or “grease”) payments to government officials or private business in order to secure or speed up routine actions.
You are required to:
- Select third parties carefully and monitor them continuously to ensure they comply with the our anti-bribery policies
- Keep accurate books and records at all times and monitor that funds are not being used for bribery or facilitation payments
- Refuse any offer or request for an unlawful payment and report it immediately.
For more information, review our Anti-Corruption Policy.
Gifts and Entertainment
While gifts and entertainment among business associates can be appropriate ways to strengthen ties and build goodwill, they also have the potential to create the perception that business decisions are influenced by them. We are committed to winning business only on the merits of our products, services and people. We comply with all legal requirements for giving and receiving gifts and entertainment.
You must:
- Use sound judgment and comply with the law, regarding gifts and other benefits
- Never allow gifts, entertainment or other personal benefits to influence decisions or undermine the integrity of business relationships
- Never accept gifts or entertainment that are illegal, immoral or would reflect negatively on the company
- Never accept cash, cash equivalents, stocks or other securities
You may accept occasional unsolicited personal gifts of nominal value such as promotional items and may provide the same to guests and business partners. For more information, review our Gift Acceptance Policy.
When in doubt, you should check with Human Resources before giving or receiving anything of value.
Can't Find What You Need?
Reach out to our Compliance team if you have any questions.