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BUSINESS CONDUCT AND ETHICS POLICY

Policy Name: Business Conduct and Ethics
Discipline: All Employees
Applies To: All Employees
Effective: June 2007
At a Glance

The successful business operation and reputation for Fox Restaurant Concepts is built upon the principles of fair
dealing and ethical conduct of our employees. Our reputation for integrity, excellence and trust requires careful
observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the
highest standards of conduct and personal integrity.

The continued success of FRC is dependent upon our guests’, investors’ and employees’ trust and we are dedicated
to preserving that trust. Each employee owes a duty to FRC to act in a way that will merit the continued trust and
confidence of our employees, guests and investors.
FRC will comply with all applicable laws and regulations and expects all employees to conduct business in
accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or
unethical conduct.
In general, the use of good judgment, based on high ethical principles will guide you with respect to lines of
acceptable conduct. In situations, where it is difficult to determine the proper course of action, the matter should be
discussed openly with your immediate supervisor and with Human Resources.
Guidelines

Do the Right Thing
Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask yourself:
• Does what I am doing comply with FRC’s guiding principles, and company policies?
• Have I been asked to misrepresent information or deviate from a normal procedure?
• Would I feel comfortable describing my decision at a staff meeting?
• How would it look if it made the headlines?
• Am I being loyal to my family, my company and myself?
• What would I tell my child to do?
• Is this the right thing to do?

Open and Honest Communication and Setting the Tone at the Top
Management has the added responsibility for demonstrating, through its actions, the importance of business ethics
and conduct. Ethical behavior does not simply happen; it is the product of clear and direct communication of
behavioral expectations, modeled from the top and demonstrated by example.
Ultimately, our actions are what matters. At FRC, we want the ethics dialogue to become a part of daily work.

Our Code of Ethics
Compliance with Laws and Regulations
All employees must comply with the laws and regulations applicable to the locations we conduct business in.

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