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The Board of Directors has adopted a Code of Ethics (the “Code of Ethics”), which is designed to ensure that the Company’s business is conducted with integrity and applies to all of the Company’s directors, officers and employees, including the principal executive officer, principal financial officer and principal accounting officer. Our Code of Ethics sets forth the Company’s standards and expectations regarding business relationships, franchisee relations, compliance with applicable legal and regulatory requirements, business conduct, conflicts of interest, use of Company assets, confidential information and information retention and reporting. In February 2026, the Board of Directors approved an amended and restated version of the Code of Ethics to, among other things, reflect current best practices and evolving regulatory expectations in certain areas, and further enhance understanding of the Company’s values and standards of ethical business practices.

The Code of Ethics is available on our Governance website at

www.irwendys.com/esg/governance

. Any amendments to or waivers from the Code of Ethics that are required to be disclosed by applicable SEC rules will also be posted on the Company’s website.