Investor Relations

Conflicts of Interest

A conflict of interest can arise when an employee's personal interests affect or appear to affect an employee's loyalty to PLKI or judgment associated with any PLKI-related duties.

PLKI policy:

Employees are expected to act in the best interest of PLKI when conducting business on behalf of PLKI.

As a result:

  • Employees should never allow personal interests, especially financial interests, to conflict or even appear to conflict with PLKI interests.
  • When an actual or potential conflict situation arises, employees or partners must immediately report the situation.
  • An employee who desires to be a Franchise Partner would be unable to avoid a conflict of interest with his/her PLKI releated duties and would be expected to resign his/her position with PLKI in order to become a Franchise Partner.
  • Any direct or indirect financial interest (excluding mutual funds or owning less than one percent of the stock of a publicly traded company) by an employee in any business venture, which competes with, is a supplier of goods and services to, or is a customer or agency of PLKI is not authorized without the prior written approval of the Chief Compliance Officer.
  • An employee may not serve as an officer, director, partner or consultant of, or work for, any business venture, which competes with, is a supplier of goods and services to, or is a customer or agency of PLKI without the prior written approval of the Chief Compliance Officer.
  • An employee is prohibited from serving in an auditing capacity or within the "chain of command" over a member of his or her immediate family. For purposes of this policy, "immediate family" is defined as relatives (by blood or marriage, i.e., spouse, child, stepchild, parent, grandparent, brother, sister, aunt, uncle, niece, nephew, grandchild, in-laws) or person residing at the same residence (i.e., roommates, domestic partner). "Chain of command" is defined as all positions that report directly or indirectly through a direct report to the same restaurant general manager, business unit or operating company vice president.
  • Agents or suppliers with an employee who is an immediate family member of a PLKI employee are not permitted to do business with PLKI without the prior written approval of the Chief Compliance Officer.

Gifts and Entertainment

PLKI policy:

We will never knowingly accept business obtained through illegal or improper methods.

As a result:

Employees may not offer or accept bribes, kickbacks, extravagant gifts, special privileges or personal favors.

Note:

Entertainment and token gifts may be given or accepted if they:

  • are consistent with local, social and business customs;
  • are not prohibited by applicable laws or regulations;
  • are not prohibited by the policies of the recipient's employer;
  • are not considered lavish, extravagant, immoral or frequent;
  • are not intended to improperly influence or have the appearance of improperly influencing a business decision;
  • conform to standards set in the PLKI Honor Code; and
  • if made public, they would not embarrass PLKI or its employees.

In addition:

Entertainment and gifts over $100.00 in value may create the appearance of impropriety. It is incumbent upon you to "do the right thing" in order to avoid any potential or perceived conflict of interest that can result when giving or accepting entertainment and gifts. When it is unclear whether you should give or accept a gift, discuss it with your supervisor or the Chief Compliance Officer. If your refusal would embarrass the other person, especially in an international setting where providing entertainment and gift-giving is lawful and customary, you may accept on behalf of PLKI and should immediately report it to your supervisor. In turn, the supervisor will discuss the situation with the Chief Compliance Officer so that PLKI can determine the proper manner for handling the gifts.

Improper Influence

Outside Interests and Employment

PLKI policy:

Employees must not engage in outside interests or employment that represent a conflict of interest with their obligations to PLKI.

As a result:

  • You and your immediate family may not maintain any interest in a private company doing business or competing with PLKI.
  • You and your immediate family may not maintain any interest greater than five percent (5%) in any public company doing business or competing with PLKI.
  • You may not compete in any way with PLKI.
  • You may not attempt to sell products or services to PLKI or solicit our employees or customers.
  • You may not engage in any activities that might interfere with your ability to carry out your duties to PLKI.

Employee Personal Time

PLKI policy:

  • Unless authorized or permitted in advance, an employee's personal time activities may not involve the PLKI name, assets, materials or facilities.
  • These activities also may not impair an employee's job performance, affect PLKI's reputation, or conflict with the business interests of PLKI.

As a result:

  • You should not use your PLKI position, training or experience to promote personal activities.
  • You are otherwise free to use your personal time as you see fit for all legal endeavors including service, religious and charitable activities.