Restaurant Brands International : 2025 RBI Modern Slavery Act Report

Published: 2026-04-23 06:41:11 ET QSR

Published on 04/23/2026 at 06:41 am EDT

Restaurant Brands International

2025 Modern Slavery Act Report

Restaurant Brands International Inc. ("RBI") is a Canadian corporation listed on the the New York Stock Exchange (NYSE: QSR) and the Toronto Stock Exchange (TSX: QSR). We are the sole general partner of Restaurant Brands International LP ("RBI LP"), an Ontario limited partnership listed on the Toronto Stock Exchange (TSX: QSP), which in turn holds the entities that ultimately own and franchise the Tim Hortons®, Burger King®, Popeyes®

and Firehouse Subs® brands (the "RBI Brands") around the world. Consequently, we are

one of the world's largest quick service restaurant companies with over 33,000 restaurants in over 120 countries and territories as of December 31, 2025.

Over 90% of RBI Brand restaurants are owned and operated by franchisees as of December 31st, 2025. RBI Brand franchisees are independent business owners who separately own and operate their businesses and who employ the team members working in their restaurants. We grant franchisees the right to operate restaurants using our trademarks, trade dress and other intellectual property, uniform operating procedures, consistent quality of products and services and standard procedures for inventory control and management. For each franchised restaurant, the relevant RBI Brand generally enters into a franchise agreement covering a standard set of terms and conditions applicable to franchisees, including the requirement for franchisees to comply with all applicable laws in connection with the operation of the restaurant and to purchase products and services from suppliers and distributors approved by the relevant RBI Brand. Indeed, franchisees for each of our RBI Brands are required to order the majority of products used in the operation of their restaurants, including equipment, ingredients, packaging and uniforms, among others, from these approved suppliers and approved distributors.

For clarification, the Burger King®, Popeyes® and Firehouse Subs® brands approve third-party suppliers and distributors for use in their respective systems, and the Burger King® and Popeyes® brands work with supply chain purchasing cooperatives for certain markets. None of the Burger King®, Popeyes® or Firehouse Subs® brands produces goods in Canada or elsewhere or imports goods produced outside Canada; therefore, the entities owning and franchising the Burger King®, Popeyes® and Firehouse Subs® brands are not included in this joint report. However, for our Tim Hortons® business in Canada, which includes Tim Hortons® restaurants with a menu that includes coffee, baked goods, hot and cold specialty drinks, breakfasts, sandwiches, wraps, flatbread pizzas and more, we operate a vertically integrated supply chain in which we manufacture, warehouse, and distribute certain food and restaurant supplies to Tim Hortons® restaurants. TDL also manufactures its own coffee, as well as fillings and fondants for baked goods.

Accordingly, this is a joint report for RBI, RBI LP, The TDL Group Corp., a British Columbia corporation ("TDL Group Corp.") headquartered in Toronto, Ontario and franchisor of the Tim Hortons® brand in Canada, and Tim Hortons Advertising and Promotion Fund (Canada) Inc., ("Advertising Fund") (TDL Group Corp. together with Advertising Fund, RBI and RBI LP, the "Company"), which have an obligation to publish a report under Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act. This joint report refers to the fiscal year ended December 31, 2025, and describes the steps taken by the Company in 2025 to prevent and reduce the risk of forced labour and child labour within their operations and supply chain. RBI and RBI LP, as holding companies, substantially rely upon the efforts of TDL and Advertising Fund (collectively, "TDL"), as the operating businesses in Canada, for purposes of managing and monitoring its supply chain operations and compliance programs. Therefore, when we use "our" or "we" throughout this report, we mean TDL.

The remainder of this report addresses our activities in connection with our vertically integrated Tim Hortons® supply chain.

Identification of business risks, including risks related to human rights in connection with our Procurement and Quality assurance processes, is part of our enterprise risk management procedure ("ERMP"). The Audit Committee of the RBI Board of Directors has oversight over the ERMP, and an assessment is conducted annually and regularly updated and presented to the Audit Committee.

Overall, we have not found that a significant risk of child or forced labour exists in the majority of our Tim Hortons® business operations. In certain isolated categories of our supply chain where risks of forced labour or child labour exist, we take steps to assess and mitigate this risk. These categories include:

For more information about how we mitigate child and forced labour risks in our supply chain, please see Due Diligence and Remediation Measures.

RBI has in place a number of policies relating to human rights and ethical conduct and mechanisms for employees to raise concerns related to human rights violations.

RBI's Code of Business Ethics and Conduct ("Code") outlines its expectations for employer and employee conduct, including human rights at a high level. This policy applies to all employees who work in the Company's global restaurant support centres, field operations team, distribution centres and manufacturing locations. All applicable employees are required to certify that they have read the Code and will comply with its standards on an annual basis.

As a complement to the Code, RBI's Commitment to Our Team Members provides employees of Company-owned restaurants with an overview of workplace policies. This includes our zero-tolerance policy on forced or involuntary labour and guidelines for young workers that align with local laws. This policy was developed based on the principles of the United Nations Universal Declaration of Human Rights and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work.

Similarly, RBI's Code of Business Ethics and Conduct for Vendors ("Vendor Code") sets out RBI's basic requirements for ethical supplier conduct. The Vendor Code covers expectations for working conditions, including zero tolerance for forced labour and a requirement to adhere to all relevant child labour laws and International Labour Organization standards. It also states that suppliers should adhere to the basic principles in RBI's Code . Under the Vendor Code's terms, we retain the right to conduct unannounced audits of supplier facilities or records at any time.

Suppliers and distributors for our approved products are required to comply with the Vendor Code, as stipulated in our terms and conditions of supply and/or distribution, as a condition of doing business with the Tim Hortons® brand.

It is important to note that the Code and Commitment to Our Team Members above do not apply to Tim Hortons® restaurants owned and operated by franchisees or to the employees employed at those franchised restaurants. Our franchisees are, however, legally and contractually required to comply with all applicable labour laws in the jurisdictions where they operate. Failure to comply with relevant laws can lead to termination of their franchise agreement.

We encourage employees of RBI, and suppliers, to report violations of the Code or Vendor Code, including under the terms of those respective documents and under RBI's Whistleblowing Policy.

Employees of the Company and suppliers of Tim Hortons® restaurants are encouraged to report violations of either the Code or Vendor Code via a third-party EthicsPoint hotline, where reports can be submitted anonymously, or in the case of employees, reports can also be made to a supervisor, the chief ethics and compliance officer, a people business partner, or a lawyer in the legal department, as applicable. RBI does not tolerate retaliation against good faith reporting of potential violations. RBI monitors all complaints closely and works to ensure that complaints are investigated and addressed, as appropriate.

Complaints, including those received through the hotline, are also reported to the Audit Committee of the Board of Directors. Validated violations can result in termination of employment with respect to the Company's employees. See Due Diligence and Remediation Measures for more information on how we review vendor and/or franchisee compliance.

RBI follows all labour laws in the jurisdictions in which we operate and investigates any claims of noncompliance that arise, as appropriate. See Grievance Mechanisms for more information. Since our franchisees are independent business owners, it is their legal responsibility to safeguard against the use of child or forced labour and address all employment-related concerns of their workforce. Legal and regulatory compliance are

required conditions under franchisees' contractual relationship with TDL. In cases where a franchisee is alleged to be violating labour law, we will review the circumstances, and in certain cases, may engage a third-party investigator to assess the allegations. Based on the results of the review or investigation, we will ensure that the franchisee remediates the circumstance or, where appropriate, we will terminate the franchise agreement.

In our supply chain, we carry out due diligence, in the form of audits and assessments, to identify human rights violations in the categories we have determined are at higher risk for child or forced labour, particularly Coffee and Retail Merchandise and Uniforms. Based on the results of these audits and assessments, we remediate any issues that arise.

Coffee

The coffee supply chain is highly complex, with most of the world's coffee farmers being smallholder, family farms. More than 12.5 million farms globally are under five hectares, as of 2022.1 The supply chain requires a multilayered approach to increase access for

‌1 Coffee yield stability as a factor of food security. (2022).

smallholder farmers in the global market. Most buyers of large volumes of coffee, like Tim Hortons, cannot, therefore, feasibly procure directly from individual farms. We purchase our coffee through importers and exporters which liaise between TDL and coffee farmers to procure coffee within our specifications. Over the past twenty years, we have collaborated with a number of not-for-profits and governmental organizations, including Technoserve, HRNS, Enveritas and Global Affairs Canada, that work towards promoting responsible agricultural practices, including aspects that would address the risk of child and forced labour.

To further reduce the risk of child and forced labour, commencing in 2020, we began partnering with Enveritas to assess 100% of our coffee bean purchases with respect to the 2019-2020 crop year and each year thereafter, under a set of social, economic, and environmental indicators, including child labour and forced labour. Enveritas' child labour evaluation looks for three key priorities2:

Children under the legal minimum working age are not employed;

Minors do not engage in dangerous work; and

If children help their families, it does not interfere with their access to education. Its forced labour evaluation also has three components3:

Workers can leave freely;

Workers' spouses and children are not required to work; and

Identity papers, payments, or other properties are not withheld to force workers to remain at work.

Enveritas is a non-profit organization that conducts farm-level social assessments, enhanced using geospatial analysis and real time data analytics of coffee farms. Enveritas conducts tens of thousands of these assessments each year, and then aggregates the data using statistical methodologies to evaluate risks for farms in different geographic areas.

They then verify traceability of our coffee purchase each year and produce scorecards of the risks in those locations, including child or forced labour. Based on the resulting risk scores, we complete continuous improvement activities that seek to address the identified risks - including supplier engagement, participation in collaborative initiatives, progress transparency, and direct farmer support programs. Enveritas assesses 100% of our direct coffee purchases every year and also conducts verifications of a portion of our dry mills every year.

‌2 Enveritas. (2024). Sustainability standards for coffee producers (p. 11).

‌3 Enveritas. (2024). Sustainability standards for coffee producers (p. 12).

Through exporters and NGOs, using a theory of change methodology, we have designed and implemented farmer support programs at farm-level. These are proven strategies that aim to mitigate poverty and improve the livelihoods of farmers and their families. A key component of this work is mitigation of social compliance issues at the farm level, including child labour risks and improving labour standards.

Examples of our intervention strategies have included opening childcare centres for the children of farmers or farm workers, which includes education and other activities while their parents are working on the farm, implementing Child Labour Monitoring Remediation Systems (CLMRS), a youth climate pioneers program, and training adults on appropriate activities for minors. Since January 1, 2021, we have supported over 56,000 farms with farmer support programs.

Retail Merchandise and Uniforms

For our Retail Merchandise and Uniform category, we require all approved suppliers and facilities to pass a social compliance audit before production of any product manufactured specifically for Tim Hortons® can begin. For seasonal items and low-volume orders, we review third-party social audits for each facility. For orders of 50,000 units or more, we review existing social audits and commission our own audit. These audits are conducted onsite following SA8000 standards which include a visual inspection, review of documentation, and private interviews of randomly selected employees.

Among other things, auditors look for:

the presence of child or forced labour;

that worker health and safety measures are in place;

that reasonable working hours are being respected; and

clean, safe facilities for workers.

Social audits are conducted once per year for relevant facilities. If critical non-compliances are found during audits conducted prior to onboarding a new supplier, we will not onboard or work with that supplier. For alleged critical non-compliances in relation to child or forced labour of an existing supplier, we will stop production with that supplier and conduct an investigation to validate the claim. For non-compliances flagged during an audit, we review the documentation. For non-compliances that are flagged outside of an audit, we will request a third-party auditor to carry out a social audit of the facility. For facilities with validated critical non-compliances, we cease production and terminate our contract with that supplier.

In our high-risk categories, we have not established that vulnerable families have experienced a loss of income at this time.

We conduct quarterly compliance trainings for all corporate employees, which encompasses those in our global restaurant support centres, field operations teams, and salaried employees in our distribution centres and manufacturing locations. Each year, one of these quarterly trainings is dedicated to our Code of Business Ethics and Conduct ("Code") which includes human rights topics. As part of the training, employees must acknowledge that they have read the Code and will abide by it at all times. We incentivize completion of this training by linking its completion to employees' annual bonuses.

For hourly employees in our distribution centres and manufacturing facilities, we conduct reviews/trainings on compliance-related topics. These employees are also required to annually sign a form confirming that they have read the Code and will comply with it. In 2025, over 99% of active above-restaurant employees completed compliance training and/or acknowledged having read the Code and agreeing to comply with it.

For our Tim Hortons Coffee Operations team and suppliers, we have partnered with Enveritas to launch a social compliance online training program specifically geared towards identifying social compliance issues at farm level. All our green bean suppliers and their teams have completed and passed the training program, along with our Tim Hortons Coffee Operations team.

RBI is continuing to explore industry best practices to validate our approach to mitigating modern slavery risk in our businesses. In 2024, RBI became a member of Sedex, one of the world's leading organizations that partners with companies to create more socially and environmentally sustainable supply chains. Sedex assessments evaluate supplier site risk in four key areas: labour standards, health and safety, environment and business ethics.

RBI uses Sedex as part of its broader risk-based due diligence approach to identify, assess and monitor potential human rights risks in relevant supplier categories, alongside other due diligence and assurance. In our Retail Merchandise and Uniforms category, we use an industry-standard auditing approach, SA8000. For retail merchandise, we conduct our own

social audit, in addition to reviewing existing audit documentation, for orders exceeding 50,000 or more units.

For our sourcing of coffee, our partner, Enveritas, conducts annual verification during the crop cycle to measure social, economic, and environmental indicators for randomly selected farmers participating in our intervention programs and compares these results with similar data from farmers in the same region who are not participating in the programs. The performance and progress of our implementers are reviewed twice a year, while the effectiveness of their methodology in the field is measured once a year during the harvest cycle. As part of our continuous improvement methodology, we identify areas in our interventions where we may need to adjust. For example, starting in late 2023, we began measuring farmers' satisfaction with the program and the support they are receiving to identify opportunities for improvement.

Board of Directors of Restaurant Brands International Inc. In my capacity as a Director of Restaurant Brands International Inc., and not in my personal capacity, I make this attestation in accordance with the requirements of the Act. I attest that I have reviewed the information contained in the report for the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above. I have the authority to bind Restaurant Brands International Inc.

/s/ Ali Hedayat

Audit Committee Chair Lead Independent Director,

Restaurant Brands International Inc. January 28th, 2026

Restaurant Brands International

Disclaimer

Restaurant Brands International Inc. published this content on April 23, 2026, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on April 23, 2026 at 10:40 UTC.