Papa John's International

In their response, the company included their U.S. and U.K Antibiotics Policy, however, these are not yet publicly available. The company indicated in their response that it will make both policies available online by Summer 2019. The only publicly available commitment on antibiotics is a 2016 press release on their transition to antibiotics-free grilled chicken pizza toppings and poppers.

PJI's commitments on antibiotics in the US are for chicken only. The company has confirmed that its commitment covers all chicken sourced for U.S. operations. For UK operations, PJI makes no reference to particular species and instead refers to raw meats. However, the company has confirmed that it covers all species.

Both U.S. and UK operations are covered by PJI's country policies on antibiotics. The U.S. is the company's main market, representing over 90% of the company's total revenue.

In the US, the company has committed to a no antibiotics ever approach, which includes the following: • To provide customers with RWA (Raised without Antibiotics) grilled chicken toppings and poppers; and • Moving towards a conversion of their chicken wing supply to antibiotics free. Currently, almost half their chicken wings are raised without human and animal antibiotics as well as fed a 100% vegetarian diet. PJI's states that it is committed to moving to 100% antibiotic free chicken wings as soon as there is enough available supply. In the UK, the company has committed to ensuring its ingredient partners comply with EU Regulations relating to the use of medicines in farm animals. PJI therefore states that: • Antibiotics may only be used for therapeutic purposes (ie. for the treatment of disease) under advice from an Authorised Veterinarian; • Our suppliers must follow EU Regulations when prescribing antibiotics, and the EU Guidelines place tight restrictions on the use of Critically Important Antibiotics so that they are only used when it considered absolutely necessary by the Veterinarian (following sensitivity testing and the use of relevant epidemiological data); and • Veterinarians may prescribe colistin under very limited circumstances, and even this usage is now targeted for reduction in the next few years.

PJI only has targets in place for its US operations. The company has previously stated that it achieved its commitment to transition all grilled chicken pizza toppings and chicken poppers to being antibiotics free by Summer 2016. This commitment has been met. For its US operations, the company is now working towards being 100% antibiotic free on its chicken wings depending on supply availability. PJI has stated that more than 65% of their domestic wing supply and 75% of their domestic chicken supply is no antibiotics ever. However, the company has given no indication by when it hopes to achieve this target.

No information provided and/ or available.

PJI stated in its response to FAIRR, that all its U.S domestic protein suppliers are audited annually as part of the company's animal welfare compliance process and all suppliers follow current Federal guidelines. However, the company has indicated that moving forward, poultry audits across all suppliers will include antibiotics use. No indication has been provided whether this will consist of internal audit only or will involve a third-party. For UK operations, the company states that all partners are required to audits their suppliers of meats and other ingredients to ensure legal compliance as well as adherence to PJI standards. No further information is provided on whether these audits are internal or third-party audits. For the UK, PJI has confirmed that it is exploring third party options for auditing antibiotics use, however, this has yet to be finalised. Based on the information provided for both markets, PJI's approach to monitoring and verifying supplier compliance is currently focused on internal audits only.

Papa John's International responded to the investor letter providing some insights, but incomplete answers to the investor questions. The company has not met with the investor coalition. PJI responded by sending its policy attached in an email, it is available here.