Copyright 2016. No quotation or citation without attribution.
UCSD - GPS CASE 16 - 04

3rd Party Monitors Spur Action in
McDonald’s Chinese Food Safety Protocols

By: Nickolaus Erickson

School of Global Policy and Strategy, UC at San Diego
Prepared for Professor Peter Gourevitch
Course on Corporate Social Responsibility
Winter 2016

Copyright 2016. No quotation or citation without attribution.
“The basis for our entire business is that we are ethical, truthful, and dependable.”– Ray Kroc, 1958

On July 20th, 2014, an undercover reporter for Dragon News secretly filmed workers at
the food processing plant Shanghai Husi Foods handling food with bare hands and adding “foulmeat” into processing machines. The exposé presented in stark relief the Chinese government’s
deficient food safety inspection mechanisms as well as the negligence of the plant’s US-basedowner, OSI Group. Among the affected companies were McDonald’s, KFC, and Starbucks.
Fortunately, no health issues were reported. In spite of McDonald’s strides in supply-chaintransparency and a long-standing, trusted reputation the company’s brand remained vulnerable toinconsistent global standards. What followed from this incident was a deeper reflection by
McDonald’s on the compliance and food safety of its food suppliers.
The Chinese market, with consumers emboldened by information exchange technology
and social media services, increasingly placed pressure on food companies to credibly address
food safety concerns. Foreign companies are the subject of further scrutiny if they are suspectedof illicit activities.

What factors led to the Shanghai Husi Foods incident?

Why had

McDonald’s and OSI’s official monitoring mechanisms failed to detect Shanghai Husi Foods
activity? From what source did McDonald’s receive pressure to change its corporate behavior?
How has this pressure translated into a response by McDonald’s to ensure food safety and rule
compliance? What company can serve as a parallel to the incident McDonald’s faced? How
might McDonald’s response have been expanded or improved?

Copyright 2016. No quotation or citation without attribution.
Shanghai Husi Foods Incident:
Shanghai Husi Food became a wretched ordeal for its parent company OSI Group LLC(OSI), a US-based meat processor, as well as client-companies like McDonald’s and KFC.
Media reports on the incident followed different narratives: that US restaurants, for example
McDonald’s, and OSI had been victims of China’s crackdown on foreign companies. Primarily
from the Chinese media OSI was blamed as being negligent in its Chinese operations in addition
to the company having its own record of food quality and food safety issues. The Shanghai Husi
incident appeared to show problems in OSI’s monitoring and screening mechanisms. How did
the problem facing OSI reach this scale? Why did McDonald’s initially sustain its ties with OSI
during and immediately after the Shanghai Husi incident?
OSI’s decentralized business model promoted greater autonomy for Chinese managers
yet the company failed to standardize its reporting mechanisms. From interviews with US
employees of the company, their explanation is that OSI did not know what local Chinese
managers were doing nor could they assess their actions. (Cendrowski, par. 5) In spite of OSI’s
allowance of autonomy, the company did not properly and frequently audit its Chinese
subsidiaries. Further, the company did not standardize its subsidiaries’ reporting mechanisms:
company documents in Chinese subsidiary plants were written only in Chinese and were nottranslated into English. (Cendrowski, par. 12) These weaknesses in auditing and monitoring
likely provided an environment at OSI plants where unsanitary and non-compliant activity had
greater likelihood to occur.
Though other US restaurants such as KFC and Starbucks immediately cut ties with OSI,
McDonald’s stayed with OSI-owned Husi Foods divisions during and after the crisis. In a press
statement McDonald’s declared, “We and our suppliers have a decades-long proven track record

Copyright 2016. No quotation or citation without attribution.
of providing safe, quality food to our customers worldwide.” (Patton, par. 3) McDonald’s
reluctance to sever ties with OSI stemmed from the restaurant’s close and long-lasting
relationship. OSI Group headquarters is located 25 miles from McDonald’s US headquarters andthe meat processor had been McDonald’s first supplier when the company started business in
1955. (Cendrowski, par. 19) When McDonald’s entered China in the 1990s OSI came as well,
McDonald’s said it would stay with its long-term supplier in Asia and the US. (Hornby, par. 19)
McDonald’s appears to have approved of OSI’s initial response to the incident on July 20th,“Husi is taking swift action by investigating what happened and overhauling its safety
procedures. We have been in direct contact with OSI’s global leaders…they are sending their top
food safety experts to China to provide expertise on operations.” (Patton, par. 3) However, bylate July McDonald’s had considered suspending its partnership with OSI, seeking alternate
suppliers such as Keystone Foods and Cargill Inc. (Burkitt, par. 2) McDonald’s said it had taken
time for the company to perform “due diligence on alternative suppliers” and it awaited theresults of the Chinese government’s investigation into OSI. On July 25th, days after OSI’s
announcement that the company will set up quality control centers, McDonalds “completely
stopped using all Husi food products at restaurants” in China citing customers’ “worries about
Husi’s products.” (Kyodo, par. 6)
The exposure of McDonalds by 3rd party monitors galvanized public attention on the
failings of official monitoring mechanisms of the company. Though the footage provided by thereporters was obtained from an unofficial source, McDonald’s initial supportive response set it instark contrast to other food companies like KFC and Starbucks who immediately severed ties
with OSI Group. Though food safety laws had been made stricter in recent years, regulatory
monitoring had failed to catch this incident.

Furthermore, McDonald’s own supply chain

Copyright 2016. No quotation or citation without attribution.
monitoring had failed to alert the company of such Husi Foods’ activity. 3rd party monitors suchas the Shanghai Dragon News undermined OSI and McDonald’s control of sensitive information.
Energized by the exposed fallibility of the highly regarded McDonald’s, Chinese consumers
demanded an immediate, credible response by McDonald’s. Consumer pressure came in theform of boycotts, avoidance, and negative commentary on social media and internet commentarysites.

Customer Pressure Against McDonald’s Partnership with OSI Group Chinese Divisions
In a country plagued by food safety scandals, the Shanghai Husi Foods incident struck
Chinese consumers as a troubling surprise. Foreign brands such as McDonald’s were attractive
to Chinese consumers partly due to popular views that the companies are operated at higher
standards than domestic Chinese businesses. (Hornby, par. 4) China’s food safety has improved
since 2008 when state-owned Sanlu group, the largest milk-powder company, was discovered tohave contaminated milk formula with melamine tainted-milk which saw six infants’ deaths andabout 300,000 reported illnesses. (Burkitt, par. 11; Yeung, p. 10) Concerns about food safety
have been rising increasingly, a 2013 Pew Research survey of 3,200 Chinese consumers where
38% said food safety was a “very big problem,” an increase from 12% in 2008. (Pew, 2013)
Immediately following the Shanghai Husi Foods incident on July 20, a Sina Shanghai online
survey performed on July 22 of 25,000 respondents found that 77% believed the restaurant
brands affected had been aware of Husi’s “faulty practices” and 69% said they would no longer
eat at restaurants run by Western companies; 39% said they did not care about the latest foodscandal and that they were used to poor food safety standards. (Zhang, par. 3) In spite of anenvironment known for poor food safety concerns, McDonald’s suspension announced before aCopyright 2016. No quotation or citation without attribution.
full investigation and improvements OSI plants drew from the McDonald’s concern of the very
likely negative impact of “customer worries” on McDonald’s current and future market position.
By August McDonald’s had reported that its global sales had fallen 14.5% in the Asia/PacificMiddle-East/Africa segment driven by the food scandal as customers boycotted U.S.-owned
restaurants. (Forbes, par. 10; Parsons, par. 1)

Sources of McDonald’s Rule and Standards Compliance Framework
McDonald’s restaurant system depends on the strength of three fundamental pillars of
support to ensure the company’s high standards are implemented system-wide: franchisees,
employees, and suppliers.

Though franchisees enjoy some autonomy they must follow

McDonald’s “principles of quality, service, cleanliness and value.” (Kroc, par. 8) Employees aremonitored by franchise managers who ensure appearance, hygiene, cleanliness and foodpreparation standards are followed according to McDonald’s company standards. (Business
Operations, par. 2) Lastly, Suppliers must acknowledge and follow McDonald’s “Code of
Conduct,” and share the codes with facilities within supply chains, review and share training
material as well as provide supplier guidance documents and identify all facilities that fall within
the supplier’s scope. Supplier’s facilities must complete training and review documentation, pay
and complete annual self-assessments, complete baseline audits and schedule follow-up on-site
audits with McDonald’s. (Code of Conduct, p. 7) Suppliers are also responsible for prompt
reporting of actual or suspected violations of law, their Code and Standards, as well as Supplier
Guidance documentation. Weakness or non-compliance in any of the above pillars threatens
McDonald’s company reputation and business operations.

Copyright 2016. No quotation or citation without attribution.
Changes Made in Response to Consumer Food Safety Concerns
In an attempt to assuage the food safety consumers of Chinese consumers McDonald’s
publicly announced and implemented steps to regain trust in its food safety commitment. An
important step was the company’s shift away from its trusted partner OSI which led tounprecedented shortages in meat and produce for McDonald’s in the following weeks andmonths. The shift away from OSI Group had also been unusual as McDonald’s has reliedheavily on longstanding relationships despite instances of code violation. Dan Gorsky, a senior
vice president of McDonald’s North America Supply Chain commented on McDonald’s
approach to suppliers, “We truly love it when suppliers bounce back from their poor
performance periods. In every instance that I can think of, the supplier has become a stronger,
more robust, more focused, more competitive and innovative business partner.” (Vitasek, par.
15) For the Chinese consumers McDonald’s severing of its connections with OSI Group served
as admittance that the food safety issue had exacted a credible internal change.
Though an internal change of food providers was a necessary step, McDonald’s alsoestablished itself as a source for food safety information. In addition to store remodeling and an“advertising blitz” (Burkitt, 2014), unlike on its US and Japanese websites the company has
published detailed supplier and compliance information.

On McDonald’s Chinese website

internet users can view business licenses, delivery inspection reports and testimonials. (SeeAppendix 1 and 2 for Screenshots and Food Inspection Report)
In addition to overhauling its food-safety strategy, McDonald’s has also announced it
would add unannounced audits of facilities coordinated with third-party auditors. (Burkitt, Sept.
2014)

McDonald’s also said it would create anonymous hotlines for suppliers and theiremployees to report on unethical or noncompliant practices. Additionally, the company would

Copyright 2016. No quotation or citation without attribution.
dispatch quality-control specialists to all meat-production facilities supplying McDonald’s.
(Burkitt, 2014) Lastly, the company said it had created a new head of food safety in China who
would report to McDonald’s CEO. These internal processes and staff changes made publicsought to achieve some reputation re-building after confidence in McDonald’s previous internalmechanisms and staff had shown such glaring deficiencies. In spite of these changes,
McDonald’s reputation still carried a negative image: several months after the Husi Foods
incident the company still saw losses in global sales: revenue fell 11% in Q1 2015 from a year
earlier. (Nicolaou, par.2)

An E.coli Outbreak Response at Jack in the Box
On January 15,1993 the Washington State Health Department alerted Jack in the Boxpresident Robert Nugent that an outbreak of E.coli had been attributed to hamburgers purchased
at Jack in the Box restaurants. (Crisis Communication, par. 1) In the ensuing weeks four had diedand several hundred had been affected by E. Coli poisoning linked to Jack in the Box. Initially
Jack in the Box avoided responsibility, pointing out that the infected customers had eaten at otherfast food restaurants. On January 18th the company announced it had taken measures to ensure
all menu items were prepared in accordance with Department of Health advisories. (par. 3) On
January 21st Jack in the Box assumed some responsibility by announcing that the E. coli hadcome from contaminated meat from their supplier, Vons Companies. Vons responded sayingthat “We continue to be confident that Vons processing did not contaminate the meat. Healthauthorities have made it clear that proper cooking would have prevented this tragedy.” (par. 9)
The E.coli was linked back to Jack in the Box for its use of burners that did not cook hamburger
meat at high enough temperatures to fully kill the contaminants. (Court, par. 11) Monthly sales

Copyright 2016. No quotation or citation without attribution.
fell 35% from a year in January and the negative effect lasted long beyond 1995 with sales 20%
lower than in 1993. (par. 12) Avoiding responsibility and shifting blame did not change thecustomer’s problem that the food was making people sick.
A comparison to Jack in the Box’s response to its own food safety incident can provide a
useful benchmark in judging McDonald’s actions. After the incident the company apologized
early and often as well as detailing internal changes the company was making in its own
advertising. (Court, par. 35) These changes included replacing its meat processor, finding new
suppliers, developed a company-wide microbe testing from suppliers, and stricter restaurant
cooking and preparation standards.

The company published advertisements in Washington

newspapers with toll-free numbers for customers to learn about the company’s cleanup efforts.
Furthermore, President Nugent apologized on televised commercials and the company later
offered to pay affected customers’ medical costs. (par. 36) Jack in the Box, after its earlier facesaving avoidance and denial approach, admitted responsibility and accepted the costly
responsibility of legal fees and internal restructuring. To underline its commitment to foodsafety Jack in the Box sought to assure the public that the company had gone above and beyond
what compliance and rules required by food safety regulators.

An Evaluation of McDonald’s Response
McDonald’s public and emphatic assurances to its Chinese consumers sought to fix thegap in monitoring that had been exposed by the Dragon News reporting. McDonald’s provided
both external modifications to its business practices, for example opening company documents topublic view, modifying store design, and repeated apologies and advertisements highlighting

Copyright 2016. No quotation or citation without attribution.
internal changes the company implemented. Internally the company appointed new heads ofdepartments, increased lines of communication, and increased monitoring mechanisms. These
measures were all deemed necessary so as to remain a competitive and attractive restaurant in the
Chinese market as well as to maintain the company’s global brand image.

An incident

highlighting the company’s food safety failings threatens not only the local business operations
but also risks contamination of the company’s global brand image.

From the Chinese

consumer’s perspective McDonald’s had taken the necessary steps to make assurances of thecompany’s food safety after the incident had concluded. More than a year later the company
sales had recovered worldwide rising 8.9% in Q3 of 2015. (Gensler, par. 5)

Recommendations for Improvements for Monitoring Agents
Outside observers to McDonald’s may feel powerless to change the company’s corporate
behaviors. However, the fallout from the Dragon News investigative footage indeed spurred
McDonald’s and other restaurant chains in China to take significant and public actions to reestablish their reputations. McDonald’s in China has taken the path towards greater transparency
in reporting on its supply chain and suppliers. Effective transparency measures take time to becredibly received and must be consistently applied. Monitors such as food safety reporters andgovernment auditors should press to increase their access to the company’s facilities to ensure
continued compliance. Certainly more compliance issues will be discovered as health andhygiene standards must continuously filter from management to staff. Paradoxically greater
visibility of the McDonald’s operations, however, has another consequence: while viewers seethat no illicit substances have been added or that the meat has not been tampered with, viewing

Copyright 2016. No quotation or citation without attribution.
the processing large amounts of dead animals can still be unsettling. (New, par. 9; See Appendix
3)
Government and 3rd party monitors of McDonald’s food safety should continue to probe
the company on its aim to promote global standards at its worldwide operations. Operating
globally without proper implementation strategies threatens companies and their affiliates torisks of rule non-compliance as OSI Group found. Monitors of McDonald’s food safety should
investigate its new operations in different countries to determine if the company is indeed
implementing an adaptive strategy which considers risks and threats within the new environment.
For McDonald’s own monitors the company should continue to share information related
to its suppliers and how the company handles its food. McDonald’s in China lost its reputation
for food safety because of an inadequate application of its monitoring mechanisms. For theforeseeable future, the company will need to provide constant factual assurances of the safety of
its food or risk losing revenues to competitors and lower restaurant attendance.

Conclusion
In the competitive fast food industry in China, loss of market share and a lowered
reputation in the eyes of consumers could severely disadvantage the company while driving
consumers to rival restaurants. 3rd party monitors such as the Dragon News’ investigative
reporter can spur large companies like McDonald’s to change business operations by exposing
non-compliant activity. The 3rd party monitor was sufficiently empowered by having their story
carried on a major news provider. Though McDonalds did not swiftly distance itself from OSIGroup, it took credible steps such as improving its internal operations and auditing procedures asCopyright 2016. No quotation or citation without attribution.
well as making public the company’s internal operations for consumers to view. With future
revenues and its reputation at stake in the country, McDonald’s saw the cost of these food safetycompliance improvements as a necessary component for doing business in China. Furthermore,as a global brand, failure to fully commit to changes in China would threaten the company’s
reputation as a safe food provider in other countries.

Works Cited
Burkitt, Laurie. “McDonald’s Overhauls Food-Safety Strategy in China.” Wall Street Journla.
Pub. 2 Sept. 2014. Accessed 15 Mar 2016. < http://www.wsj.com/articles/mcdonaldsoverhauls-food-safety-strategy-in-china-1409643383/>
Burkitt, Laurie and Bunge, Jacob. “McDonald’s Could Reconsider Its Relationship With
Supplier OSI in China.” Wall Street Journal. Pub. 26 Aug. 2014. Accessed 13 Mar. 2016.
< http://www.wsj.com/articles/mcdonalds-could-reconsider-its-relationship-withsupplier-osi-in-china-1409055727/>
Burkitt, Laurie and Fujiwara, Megumi. “Worries Over Meat Supplier Spread to Japan.” WallStreet Journal. Pub. 22 July 2014. Accessed 14 Mar. 2016.
<http://www.wsj.com/articles/worries-over-meat-supplier-spread-to-japan-1406032815/>“Business Operations: What are your hygiene and cleanliness policies?” July 2015. Accessed 13
Mar 2016.
<http://www.mcdonalds.co.uk/ukhome/whatmakesmcdonalds/questions/running-thebusiness/business-operations/what-are-your-hygiene-and-cleanliness-policies.html/>“Case Study: Jack in the Box E. coli crisis.” Department of Defense Joint Course inCommunication. University of Oklahoma. Accessed 16 Mar 2016.
<http://www.ou.edu/deptcomm/dodjcc/groups/02C2/Jack%20in%20the%20Box.htm/>
Cendrowski, Scott. “Why McDonalds’ supplier failed in China.” Fortune. Pub. 2 Sept. 2014.
Accessed Mar. 13 2016. <http://fortune.com/2014/09/02/why-mcdonalds-supplier-failedin-china/>.
Court, Emma. “Why a deadly ‘90s burger epidemic matters to Chipotle today.” MarketWatch.

Copyright 2016. No quotation or citation without attribution.
Pub 14 Mar. 2016. Accessed 16 Mar. 2016. <http://www.marketwatch.com/story/why-adeadly-90s-burger-epidemic-matters-to-chipotle-today-2016-03-08/ >“Environmental Concerns on the Rise in China.” Pew Research Center. Pub. 19 Sept. 2013,
Accessed 14 Mar 2016. <http://www.pewglobal.org/2013/09/19/environmental-concernson-the-rise-in-china/>
Gensler, Lauren. “McDonald’s Worldwide Sales Rise, Fueled by Rebound in U.S. & China.”
Forbes. Pub. 22 Oct. 2015. Accessed 17 Mar.2016.
<http://www.forbes.com/sites/laurengensler/2015/10/22/mcdonalds-third-quarter-

earnings/#1c5920dd2b1a/>
Hornby, Lucy and Munshi, Neil. “Rapid China expansion comes back to bite western foodchains.” Financial Times. Pub. 25 July 2014. Accessed 14 Mar. 2016.
http://s3.asiainspection.com/files/financial_times_07.2014.pdf
Parsons, Heidi. “Food Safety Fears Cause Consumers to Boycott Yum, McDonald’s Restaurants
in China.” Food Safety Magazine. Pub. 1 Aug. 2014. Accessed 14 Mar. 2016.
< http://www.foodsafetymagazine.com/news/food-safety-fears-cause-consumersto-boycott-yum-mcdonalds-restaurants-in-china/>
Patton, Leslie. “McDonald’s Sticks by Meat Supplier OSI after Yum Severs Ties.” Bloomberg
Business. Pub. 24 July 2014. Accessed 13 Mar. 2016.
<http://www.bloomberg.com/news/articles/2014-07-23/mcdonald-s-sticks-by-meatsupplier-in-china-while-yum-cuts-ties/>
McDonald’s Food Quality and Inspection File Database. Pub. 16 Mar 2016. Accessed 16 Mar
2016.<http://www1.mcdonalds.com.cn/list/quality/index.php?DocTypeId=61/ >“McDonald’s cuts ties with scandal-tainted-Chinese meat supplier.” Kyodo News International.
Pub. 28 July 2014. Accessed 13 Mar. 2016.
< http://www.globalpost.com/dispatch/news/kyodo-newsinternational/140728/mcdonalds-cuts-ties-scandal-tainted-chinese-meat-suppl/>.
“McDonald’s Faces Declining Sales in Asia After China Food Scandal.” Forbes/Trefis Team. 11
Sept. 2014. Accessed 14 Mar. 2016.
<http://www.forbes.com/sites/greatspeculations/2014/09/11/mcdonalds-faces-decliningsales-in-asia-after-china-food-scandal/#de088bc561eb/ >“McDonald’s Supplier Code of Conduct.” McDonalds Creative Services. Pub. Nov. 2012.
Accessed 13 Mar. 2016.
<http://www.aboutmcdonalds.com/content/dam/AboutMcDonalds/Sustainability/Library/Copyright 2016. No quotation or citation without attribution.
Supplier_Code_of_Conduct.pdf/>
New, Steve. “McDonald’s and the Challenges of a Modern Supply Chain.” Harvard Business
Review. Pub. 4 Feb. 2015. Accessed 10 Mar 2016. < https://hbr.org/2015/02/mcdonaldsand-the-challenges-of-a-modern-supply-chain/>Nicolaou, Anna. “McDonald’s sees drop in customers as scandals start to bite.” Financial Times.
22 April 2015. Accessed 17 Mar. 2016. < http://www.ft.com/intl/cms/s/0/cffb7934-e8ee11e4-87fe-00144feab7de.html#axzz436apJoM9/>“Standards of Business Conduct.” McDonald’s Creative Services. Pub. 2011. Accessed 13 Mar
2016.
<http://www.mcdonalds.com/content/dam/AboutMcDonalds/Investors/9497_SBC_International_EN-US%20v2%20final%20061311.pdf/>“The Ray Kroc Story.” From “Grinding it Out: The Making of McDonald’s” Kroc, Ray A.
(1977) and Love, John “McDonald’s: Behind the Golden Arches” (1995). Pub. 2009.
Accessed 13 Mar 2016.
<http://www.mcdonalds.com/us/en/our_story/our_history/the_ray_kroc_story.html/>.
Vitasek, Kate. “A Lesson in Maintaining Supply in the Wake of a Key Supplier Scandal.” Vested
Outsourcing, Inc. Pub. 23 Sept. 2014. Accessed 16 Mar. 2016.
<http://www.vestedway.com/a-lesson-in-maintaining-supply-in-the-wake-of-a-keysupplier-scandal/>
Yeung, Douglas and Cevallos, Astrid Stuth. “Attitudes Toward Local and National Government
Expressed over Chinese Social Media.” Rand Corporation. Pub. 2016. Accessed. 14 Mar.
2016.
<http://www.rand.org/content/dam/rand/pubs/research_reports/RR1300/RR1308/RAND_
RR1308.pdf/>
Zhang, Cece. “Half of mainland consumers no longer trust Western fast-food companies after
scandal.” South China Morning Post. Pub. 22 July 2014. Accessed 14 Mar. 2016.
<http://www.scmp.com/news/china/article/1557214/half-mainland-consumers-no-longertrust-western-fast-food-companies-after/ >Copyright 2016. No quotation or citation without attribution.
Appendix 1: McDonald’s Chinese Website Inspection and Business License
information (translated)Copyright 2016. No quotation or citation without attribution.
Appendix 2: Food Safety Inspection: Ming Foods. Co., (3/12/2016)(Exercept: E.Coli O157: None Detected: Result: Passed)

Copyright 2016. No quotation or citation without attribution.
Appendix 3: YouTube: Grant Imahara appears in McDonald’s Food Safety

Assurance video (US): Our Food Your Questions