The Equality and Human Rights Commission (EHRC) has taken the rare step of extending and strengthening its legal agreement with McDonald’s Restaurants, signalling the seriousness of the watchdog’s concerns about workplace sexual harassment across the fast-food chain and its franchise network.
This escalation should worry every employer. This isn’t the first time regulators have stepped in after uncovering systemic failings. Previous cases have shown the same pattern: when harassment is allowed to persist, when preporting isn’t trusted, and when oversight breaks down, regulators step in hard. The strengthened McDonald’s action plan sits squarely in that trend, demonstrating how quickly obligations can expand once an organisation is found to have allowed harmful behaviours to persist, particularly towards younger or vulnerable workers.
A response to widespread failures
The extension follows the BBC’s 2023 investigation that uncovered more than 100 allegations of harassment, assault, racism and bullying inside McDonald’s restaurants, including cases involving workers as young as 17. The original Section 23 agreement was signed in February 2023, but the severity of further allegations pushed the EHRC to demand a more targeted, operationally grounded action plan.
The watchdog has now confirmed it will monitor McDonald’s and its franchise network closely to ensure safeguards are functioning. With 80–90% of McDonald’s UK restaurants run by franchisees, this case underscores how regulatory accountability now extends beyond corporate headquarters and into wider operating models, particularly where brand owners exert influence but lack strong central oversight.
What the strengthened plan requires
The extended agreement forces McDonald’s to overhaul its safeguarding, reporting and training systems. Key measures include:
New safeguarding framework
- A new safeguarding policy aligned to the risks faced by younger and vulnerable workers.
- An external safeguarding plan designed with specialist input, to be implemented across all corporate and franchised restaurants.
Strengthened complaints infrastructure
- An external audit of the centralised complaints-handling unit.
- Independent investigations for complaints lodged against managers.
- A 24/7 chatbot to make reporting easier for frontline staff.
- Clearer communications encouraging workers to speak up early.
Serious training and cultural expectations
- Updated and expanded harassment training for managers and franchisees, with new content on social media and grooming risks.
- Regular risk assessment reviews during restaurant inspections.
- Use of quarterly staff surveys to flag concerns and measure cultural progress.
Franchisee accountability
- All franchisees will be asked to formally commit to implementing appropriate safeguarding policies, systems and culture-building measures.
This is a significant escalation. It reflects the EHRC’s shift towards more prescriptive, ongoing oversight, not just one-off assurances.
What this means for employers
The McDonald’s case demonstrates the new compliance reality: policies alone are not enough. Regulators expect evidence of functioning systems, independent oversight, and a culture that prevents harm, not merely responds to it.
For compliance teams, the implications are clear:
1. Safeguarding must be part of harassment compliance
Particularly where young workers, apprentices, interns or part-time staff are present, safeguarding and harassment prevention now overlap. Organisations should integrate both into their risk assessments, investigations framework and training.
2. Franchise and multi-site models must ensure consistency
The EHRC is scrutinising whether brand owners actively enforce standards across their network. If your business operates with franchisees, licensees or distributed teams, you need a plan for consistent training, monitoring and action.
3. “Accessible reporting” is no longer optional
Anonymous reporting, digital channels, rapid triage and independent case handling are becoming baseline expectations. If staff cannot safely report concerns, regulators will take notice.
4. Investigations must be demonstrably independent
Complaints against managers or senior staff should not be handled in-house at the same location. Independent HR partners, external investigators or centralised complaints units are best practice.
5. Regulators are now measuring culture
McDonald’s must use staff surveys to track culture shifts, a clear signal of the EHRC’s expectations that employers monitor employee sentiment, trust and safety perceptions continuously.
What you should do now
- Review your harassment, bullying and safeguarding policies to ensure they reflect current expectations and cover vulnerable worker risks.
- Audit your reporting channels and check whether staff genuinely trust them.
- Ensure investigations are independent, especially when senior staff are involved.
- Refresh manager training, with practical scenarios and updated guidance on digital behaviours, power dynamics and grooming risks.
- Strengthen your monitoring processes, including surveys, risk assessments and site reviews.
VinciWorks offers training, reporting tools and culture-measurement solutions on sexual harassment and safeguarding built to meet the standards regulators are now enforcing. Learn more.
