Are McDonald's Operators "Insiders"?

Do McDonald's Operators possess the necessary clout to be corporate "insiders"? Keep 
in mind this entire subject centers around one activity - trading shares of the company. 

Here's how website Investopedia defines insiders.

"Insider is a term describing a director or senior officer of a company, as well as any
person or entity that beneficially owns more than 10% of a company's voting shares.
For purposes of insider trading, the definition is expanded to include anyone who 
trades a company's shares based on material nonpublic knowledge. Insiders have to
comply with strict disclosure requirements with regard to the sale or purchase of the 
shares of their company."

Since there are no Operators on the McDonald's board of directors or as senior officers I'd suggest that any McDonald's Operator who owns 10% or more of McDonald's voting shares should refrain from communicating with Wall Street analysts.

Others still have their first amendment rights.

Here's what the Securities and Exchange Commission says

Here's the Investopedia link

Again, this about trading shares of companies. It's not about someone you trust asking,
"How's business?"
.