The Walt Disney Company
STANDARDS OF BUSINESS CONDUCT
“In the end, the quality and integrity of our people and product
is paramount to us – it’s more important than anything we do.”
Robert A. Iger
© 2017 The Walt Disney Company
All rights reserved.
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Dear Fellow Disney Team Member,
Throughout the years, we have earned the trust
of guests, audiences, consumers and shareholders
because of our commitment to high standards in
everything we do, everywhere we operate. Integrity,
honesty, trust, respect, playing by the rules, and
teamwork – these define not only the operating principles
of our Company, but also the spirit of our diverse global
workforce and how we function.
Our Standards of Business Conduct provide the
information, the resources and the tools necessary to
conduct ourselves ethically and in compliance with the
law. As a Cast Member or employee you are expected to
read and be familiar with the Standards and to use them
to guide the way you act.
Always remember that in every interaction, you are the
face of our Company. Act responsibly in all of your
professional relationships, in a manner consistent with
the high standards we set for our business conduct, and
speak up whenever you have a question or concern. As
we continue to create Disney Magic, make sure your
actions reflect your pride in yourself, those you work with
and the Company.
Robert A. Iger
An Unparalleled
Commitment …
Standards of Business Conduct
Walt Disney Company
You have the right and the responsibility to protect our
Company from conduct that can threaten our day-to-day
operations, our reputation and our future growth.
The Guideline
is a resource for employees and Cast Members to
1) report questionable activities – including questionable
accounting or auditing matters; 2) report complaints regarding the
Company’s accounting, internal accounting controls or
auditing matters; 3) ask for guidance on any business
conduct-related issue; or 4) make the Company aware of any
suspected unethical or illegal conduct, or violation of our
Standards of Business Conduct or of any other Company policies.
Cast Members and employees in the United States
and Canada, may report online:
www.disneyguideline.com
Or call anytime, day or night:
800-699-4870
Concerns are addressed promptly and fairly. Our Company
does not tolerate any form of retaliation against anyone who
makes a good faith report of potential misconduct or helps
with an investigation. Reports are accepted anonymously
where permitted by law.
Note that all references in this document to the Guideline
refer to the information on this page.
Speak Up
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The Walt Disney Company
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Integrity: Our Standards
Why We Have Standards of Business Conduct
Who is Required to Follow the Standards What
the Standards Mean for You
Asking Questions, Sharing Concerns:
The Guideline
Trust: Our Commitment to Guests and
Customers
Safety
Quality
Protecting Privacy
Teamwork: Our Commitment to Each Other
Fairness, Dignity and Respect
A Diverse Workforce
Honesty: Our Commitment to the Company
and our Shareholders
Conflicts of Interest
Gifts, Entertainment and Hospitality
Gifts and Anti-corruption Compliance
Vendors, Suppliers and Customers
Protecting Company Assets
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Accurate Recordkeeping and Financial
Reporting and Complaints Regarding
Accounting and Auditing Matters
Speaking on Behalf of our Company
Play by the Rules: Our Commitment
to Lawful Business
Practices
Competition Laws
Trade Secrets, Trademarks, Patents and
Copyrights
Product Safety
Food and Drug Safety
Anti-corruption, Anti-bribery
Export, Import and Anti-boycott Laws
Doing Business with and Providing Information
to the Government
Inside Information and Securities Trading
Money Laundering
Respect: Our Commitment to the
Community
An International Presence
Labor Standards
The Environment
Charitable and Political Activities
GLOSSARY
RESOURCES
Employee Complaint Procedures for
Accounting and Auditing Matters
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We do what’s right
and take
responsibility for
our actions to
protect our guests,
our audiences, our
consumers and our
shareholders.
Integrity: Our Standards
Why We Have Standards of Business Conduct
Who is Required to Follow the Standards
Our Standards apply to all Cast Members
and employees (including temporary, part-
time and seasonal employees) as well as
others who are identified with our Company
as acting on its behalf.
What the Standards Mean for You
As a Cast Member or employee, you have a
responsibility to:
Act with integrity and honesty on the job.
Comply with all applicable laws and
regulations in performing your duties.
Be familiar with the Standards, follow them
at all times and seek help when you have
a question.
Share concerns about any conduct that
violates our Standards.
We are committed to compliance with our
Standards. Anyone who violates them is
subject to disciplinary action, up to and
including termination. Remember, one of the
best resources for solving an ethical dilemma
is your conscience. If an action you’re
contemplating feels dishonest, unethical or
illegal, it probably is.
If you are a supervisor, you have a greater
level of responsibility. We look to you to
model ethical behavior and promote a
workplace where Cast Members and
employees feel comfortable coming forward
with concerns and questions. Our Company
“ Yesterday, my
supervisor asked me
to do something that
violates our
Standards. I’m not
sure what to do ….”
You have a responsibility
to comply with our
Standards, even if your
supervisor asks you to
do otherwise. No one –
not even your supervisor
– has the authority to tell
you to do something
illegal or unethical. Talk
to someone else in
management or contact
your Human Resources
representative, The
Guideline or the Legal
department for help.
Standards of Business Conduct
Not sure? Ask yourself:
Is it legal?
Does it comply with our
Standards?
What would someone I
respect say about my
actions?
The connection we share with people around the
world through the content, entertainment and
experiences we offer is a privilege, one we must
never take for granted. We recognize that our
continued success depends upon a commitment
to conduct business with honesty, integrity and in
compliance with the law everywhere we operate.
Our Standards of Business Conduct (or “Standards”)
are a reflection of that commitment and provide you
with the information you need to do the right thing on
the job and preserve the reputation we have earned
as an ethical company.
Keep in mind, no document can address every
situation you may possibly face in your everyday
work. We rely on you to use these Standards as well
as your good judgment to guide your behavior and to
ask questions if you are ever unsure of the proper
course of action.
For more information regarding the Company’s
ethics and compliance policies, including
the Standards of Business Conduct, you may visit
www . disneyglobalcompliance . com
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with your supervisor, your Human Resources
representative or The Guideline.
Available anytime night or day, The Guideline
is operated by an independent, third-party
company located in the United States and
allows you to submit an online report or
share your concerns in your own language
with a professional interview specialist.
Reports are accepted anonymously where
permitted by law.
Regardless of whom you contact, you
may be assured that your concerns will
be addressed promptly and fairly. Our
Company does not tolerate any form of
retaliation (including separation, demotion,
suspension or loss of benefits) against
anyone who makes a good faith report
of potential misconduct or helps with an
investigation. We want you to be free to ask
questions and raise issues without fear of
retaliation, secure in the knowledge that you
did the right thing in coming forward.
Sometimes, it may seem easier to keep quiet
or look the other way when someone violates
our Standards, but doing nothing can, in
itself, result in serious consequences. When
you speak up about unethical and illegal
behavior, you’re saying that an honest and
ethical workplace matters to you.
is committed to open, free and effective
channels of communication, so promote an
“open door” policy, be a good listener and
work to earn the trust of your co-workers.
Make sure you are familiar not only with the
Standards but also with the specific laws and
policies that apply to you and your team. Our
Standards may complement other policies,
procedures and our employment
agreements. If you or anyone on your team
encounters an inconsistency or conflict, seek
the help of your supervisor or Human
Resources representative or The Guideline.
Asking Questions, Sharing Concerns: The
Guideline
One of our greatest assets is our reputation.
We’re known for operating with high ethical
standards everywhere we do business. Our
continued success depends, in part, on your
commitment to doing the right thing and
speaking up if you see or suspect someone
is violating our Standards.
You have the right and the responsibility to
protect our Company from conduct that can
threaten our day-to-day operations, our
reputation and our future growth. If you ever
have questions about our Standards or
Company policies or if you see or suspect
a violation, we rely on you to share them
The Guideline offers
a way for you to:
Share concerns about
questionable activities
Report known or
suspected acts of
financial misconduct or
other violations of our
Standards
Ask for guidance on any
business conduct-
related issue
I have an issue that
I’d like to discuss with
someone in Human
Resources, but my
supervisor told me that
all issues should be
discussed with her
first.
Is that right?”
It’s a good idea to
discuss issues and
concerns with your
supervisor first, but if, in
a particular situation, you
feel uncomfortable doing
so, you are free to
contact another member
of management, your
Human Resources
representative or
The Guideline.
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Trust: Our Commitment to
Guests and Customers
We are committed to
our guests and our
customers – they are
the reason we
are here.
" ... build quality into
every product and
service we deliver
and every interaction
we share."
Safety
Promoting the health, safety and welfare of our
guests and customers is a critical responsibility – one
that should never be ignored, minimized or sacrificed.
All of us share the responsibility of helping to make
guests safe and secure. Do your part to meet our
high standards, whether you are designing, building,
operating or maintaining our Company attractions,
products or facilities. Remember, the commitment you
make preserves not only the safety of our guests and
customers but also a safe workplace for your fellow
Cast Members
and employees.
Quality
We are recognized as providers of high-quality
content, entertainment and experiences of all kinds,
including films, television programs, news and
information, theme park attractions and resorts,
online experiences, consumer products and stores.
Each of us has a responsibility to build quality into
every product and service we deliver and
every interaction we share. That means being
courteous, knowledgeable and passionate
about providing a high-quality experience to
all of our guests and customers. It also
means creating products and services that
we are proud to identify as ours.
Protecting Privacy
In compliance with data privacy laws, we
work to keep personal data private. Personal
data includes any information that directly or
indirectly relates to a person; for example
office e-mail addresses, telephone numbers,
images, credit card information, etc. You are
expected to follow all Company policies as
they relate to handling and retention of the
information.
If you work with personal information as part
of your job, use it only for legitimate business
reasons and in compliance with all applicable
privacy notices or policies. There are strict
rules about collection of personal information
for marketing purposes – if you’re not sure
what is permissible, ask. Breaches of data
privacy can expose you and the Company to
legal penalties and harm the reputation we’ve
earned as an ethical company.
Standards of Business Conduct
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Be sensitive when sharing personal
information. Personal information
regarding guests or customers should never
be disclosed to anyone, except as permitted
by law and by the Company. Before sharing
personal information with anyone – inside or
outside of the Company – make sure the
recipient is authorized to receive the
information, that he or she knows the
information is confidential and understands
how the information is to be used or
disseminated and that it is legally permitted
to share that information. You should
contact the Legal department if you have
any questions.
Limit the amount of information shared
to only what is needed to accomplish the
business requirement. Be sure to obtain
a confidentiality or privacy agreement,
if required, before disclosing personal or
confidential information to individuals
outside of our Company.
Want to know more?
Information Security Policies
and Standards
The Walt Disney Company
Standards of Business Conduct
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Teamwork: Our Commitment
We work together to
protect the heritage
we have built as a
company with high
ethical standards.
to Each Other
Fairness, Dignity and Respect
Our Cast Members and employees are the
cornerstone of our magic. We are committed to a
work environment where everyone is afforded the
dignity and respect that they deserve. We don’t allow
any form of harassment or discrimination
on the basis of race, religion, color, sex, sexual
orientation, gender identification, national origin, age,
marital status, covered veteran status, disability,
pregnancy or any other basis prohibited by
applicable law. If you see or suspect any violation, or
feel you, yourself, are a victim of harassment or
discrimination, promptly report it.
For more information, please consult the Employee
Policy Manual or, if you work for Pixar, the Pixar
Employee Handbook.
We promote professional development. We are
also committed to offering opportunities for Cast
Members and employees to develop and advance
professionally, in a manner consistent with their
abilities. Any decisions related to hiring, evaluating
performance, promoting, disciplining or terminating
Cast Members and employees are made
fairly, with discretion and respect for privacy.
A Diverse Workforce
Each of us is a valued member of the team.
We embrace our multicultural workforce and
tap the unique talents and potential of every
Cast Member and employee to create
superior products and services. To foster
diversity, we:
Seek to attract and develop a workforce that
reflects the guests and customers, business
partners, shareholders, labor markets and
communities in which we do business.
Maintain a workplace that offers open
opportunities to all, recognizing individuals
for their experience, performance, training,
work history and potential.
I overheard a co-worker
use insulting language
when referring to
someone on our team.
What should I do?”
" Each of us is a valued
member of the team."
Standards of Business Conduct
The Walt Disney Company
Language that is
disrespectful of a
person’s race, religion,
color, sex or any other
protected class doesn’t
fit in a workplace that
values diversity. If you
feel comfortable doing
so, say something to
your co-worker to
express your concern. If
you don’t, speak to your
supervisor, your Human
Resources
representative or call
The Guideline.
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Honesty: Our Commitment to
Protecting our
reputation requires
a commitment
to truth and high
standards in
everything we do.
When my department
hosts special events,
my team puts me in
charge of catering
because my daughter-
in-law owns a local
restaurant that
provides great food at a
discount. Is that okay?”
Standards of Business Conduct
the Company and
our Shareholders
in which you or a member of your immediate
family has a financial interest, which is defined
as any paid relationship or arrangement
(for example as an agent, representative,
employee, promoter, consultant or “finder”) with
a business or any ownership interest (of stock,
partnership, interest, etc.) other than not in
excess of 5 percent of a publicly-traded entity
unless you obtain approval from the
Management Audit department.
What about situations where you are not
actually conducting business yourself with
a member of your immediate family or a
company owned by an immediate family
member, but you are in a position to influence
or affect our Company’s business relationship
with that person or company? If you or a
member of your immediate family has a
material financial interest in a company that is
or wants to do business with our Company, you
must disclose that information to the
Management Audit department as soon as you
become aware of it.
Don’t ask others to do something you
are prohibited from doing. If you are a
supervisor, you may not allow (or direct)
any employees you directly supervise to
conduct business with you or members
of your immediate family or companies in which
your immediate family has a financial interest,
unless approval is obtained from the
Management Audit department.
In situations where employees you indirectly
supervise are conducting or intending to
conduct business with a member of your
Conflicts of Interest
Our business is built on public trust and confidence
and an expectation by guests and customers that they
can depend on our products and services. To deliver
our very best, each of us has an obligation to make
objective decisions on behalf of the Company and
avoid situations where a conflict (or apparent conflict)
exists between the Company’s interests and our own,
personal interests.
It’s impossible to list all of the situations that could
present a potential conflict of interest, but there
are certain situations where conflicts often arise. It’s
important that you are familiar with these situations,
recognize a potential conflict when you see one and
take the appropriate action.
Doing business with family can present a conflict
of interest. Even if you work to remain objective
in your business dealings, the fact that you share
a personal relationship or financial interest with
someone or a company can create the appearance of
a conflict of interest. As a result, you may not conduct
business on behalf of our Company with a member of
your immediate family or with a company
No, even if the restaurant
offers a great meal at a
great price, selecting your
daughter-in-law’s
business without prior
approval from the
Management Audit
department may give the
appearance that we
chose her business
because of your family
connection.
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To make some extra
money, I’ve started my
own Internet business
on my home computer.
Is that okay?”
immediate family or company in which you
or your immediate family has a financial
interest, you must disclose the situation to
the Management Audit department as soon
as you become aware of it.
Be careful in working for or investing in
other companies. Working for or having a
material financial interest in a company that
competes with our Company can present a
conflict. A conflict can also arise if you work
for a company that has no association with
ours but your work interferes with the time,
talent and energy you bring to the work you
do for our Company.
Therefore, if you are considering investing in
such a company, starting your own business
or accepting a second job, talk to your
supervisor to make sure there is no conflict.
If you have questions about investments
and possible conflicts, contact the
Management Audit department.
Are you involved in decisions regarding
our Company and a financial institution?
If you play a role in establishing or
managing a relationship between our
Company and any financial institution, you
may not enter into any transaction with – or
receive any benefit or opportunity from – the
institution that isn’t generally available to
other customers or clients. This policy also
applies to members of your immediate
family or a business where you or your
family have a material financial interest.
Gifts, Entertainment and Hospitality
The exchange of gifts is often a common business
practice and one that can build goodwill among
companies with which we do business, but when
gift-giving becomes lavish or frequent, it can
suggest something improper. That’s why we have
policies in place to help you determine what’s
appropriate – and what’s not – in terms of giving or
receiving gifts.
Our policies are designed to:
Comply with the law and, when giving a gift,
comply with the company policies of the person
receiving the gift.
Make sure our success is based on the merits of
our products and services, not gifts we give or
receive.
Promote transparency – we don’t engage in any
activity that would compromise our professional
judgment or suggest favorable or preferential
treatment.
What is a “Gift”? A gift is anything of value. It
includes tangible items such as jewelry and art, but
also intangible items such as discounts, services,
loans, favors, special privileges, advantages, benefits
and
rights that are not available to the general public.
Agift” also includes meals, entertainment, hospitality,
v
acations, trips, use of vacation homes, tickets
to sporting or music events, golf outings, vendor
familiarization trips and use of recreational facilities.
Under no circumstances should you ever solicit a gift
from any person or company that is doing – or seeks
to do – business with us unless it is for charitable
purposes and no employee or Cast Member receives
any benefit. Note that meals, entertainment and
hospitality may also qualify as a gift.
The Walt Disney Company
Standards of Business Conduct
It’s always best to check
with your supervisor but,
in general, as long as the
business doesn’t
compete with the
Company’s business,
use Company assets or
interfere with your ability
to do your job, it is
acceptable.
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"… Disney’s success
is based on the
merits of our
products and
services, not gifts we
give or receive."
Giving gifts: What’s our policy? Offering
gifts to win or keep business is unethical
and, in many cases, illegal. Be sure you
understand the rules and ask questions
if you’re ever unsure about whether a
particular gift is okay. In general, you should
never give a gift that:
Is (or could reasonably be perceived to be)
an inducement to do business with our
Company
Would be considered excessive under the
circumstances
Would violate our Company policies or those
of the recipient
Would be contrary to the interests of our
Company
Is, in fact, different from what you reported
either to us or to others
In addition, if you are located in the United
Kingdom, work for a Disney entity that is
subject to U.K. law, or are otherwise subject
to U.K. law you must obtain approval
from your immediate manager before giving
any gift in connection with any
business relationship.
Accepting gifts: What’s our policy? From
time to time, you may be offered gifts from a
person or a company that does – or seeks to
do business – with us. Use the following
information to guide your decision-making
and ask for help if you are ever unsure of the
proper course of action. Note that this policy
applies whether you are personally offered a
gift or if a gift is offered for the benefit of
a specific group or department at the Company
(including as a prize to be distributed at a party or
event).
Gifts worth not more than US$75:
In general, you may accept a gift as long as the
total
value of all gifts received from such person or
company does not exceed US$75 in value in any
one calendar year. Keep in mind gifts of cash or
cash equivalents such as checks or gift cards that
can be converted to cash are never acceptable.
Gifts greater than US$75 but less than US
$500: Gifts within this range are subject to our
“ordinary course of business” test. Ask yourself:
- Would the gift be considered customary given
your job duties, job title and seniority? If the
gift was reported in the media, would others
think favorably of you? Of our Company?
- Would the gift complement or enhance a
business relationship? For offers of hospitality
or entertainment, is the person extending the
offer going with you?
If the answers to these questions are “yes,”
based on your good faith assessment, you may
accept the gift without notifying the Management
Audit department.
In addition to the other requirements of this
policy, if you are located in the United Kingdom,
work for a Disney entity that is subject to United
Kingdom law, or are otherwise subject to U.K.
law you must obtain approval from your
immediate manager before accepting any gift
whose fair market value exceeds US$75.
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Standards of Business Conduct
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One of my vendors
routinely provides
me with tickets to a
professional football
game – is that a
violation of our gift
policy?”
If the gift fails the “ordinary course of
business” test, you must either: (1) return
the gift letting the giver know that it is
against Company policy to accept it; (2)
give the gift to the Company so it may be
either donated to charity or otherwise
disposed of; or (3) keep it and write a
check to the Company for the amount by
which the fair market value of the gift
exceeds US$75, which will be used by the
Company for charitable purposes.
Gifts greater than US$500: If you are
offered a gift that you, in good faith,
believe meets the “ordinary course of
business” standard but exceeds US$500
in value, you have the option to refuse or
accept the gift. If you decide to accept it,
you must notify the Management Audit
department within 15 days of receipt.
They will review the gift and determine
whether it was, in fact, within the
“ordinary course of business.” If
Management Audit determines it was not,
you will be required to pay – or make a
charitable donation through the Company
equal to – the amount by which the fair
market value of the gift exceeds US$75.
Meals: Meals are not subject to a dollar-
value limit as long as they meet the
“ordinary course of business” test. Good
working relationships are important to our
business, but use good judgment and be
careful to avoid even the perception of
something improper.
You may accept it
as long as it’s not
cash or a cash
equivalent and the
combined value of
gifts from the giver
is less than US$75
in one calendar
year.
NO
YES
You may accept it as
long as it's not cash or a
cash equivalent.
If you are covered
by U.K. law, you must
obtain your immediate
manager's approval
before accepting the gift.
You may:
1. Return it.
2. Give it to Disney for
donation or other
use.
3. Keep it and pay
difference > US$75.
YES NO
Does it pass the
"ordinary course
of business" test?
Gift Decision Tree
Note that :
1) Gifts of cash or cash equivalents may never be accepted, and
2) Meals in the “ordinary course of business“ are not subject to a dollar
value limit.
This is a general framework for decision-making. Keep in mind, we
never accept any gift if it would compromise our professional
judgment or suggest favorable or preferential treatment. Contact the
Management Audit department regarding any questions or concerns
regarding Disney’s gift policy.
Can I Accept It?
Is the gift worth more
than US$75?
Is its value more
than US$500?
Either:
1. Refuse it
or
2. If covered by U.K. law, obtain
your manager's approval
and
3. Notify Management Audit within
15 days for "ordinary course of
business" determination.
YES
NO
The Walt Disney Company
Standards of Business Conduct
Use the “ordinary course
of business” test. Let’s
assume the gift is
customary given your
position at the Company.
Ask yourself: Does the
gift complement or
enhance my business
relationship? Certainly, if
the vendor just passes
the tickets on to you and
does not attend with you,
the event clearly does not
offer an opportunity to
build upon your working
relationship. In that case,
you should either: return
the gift to the vendor with
a polite letter that
references our policy or
accept the gift but write a
check to the Company for
the amount by which the
fair market value of the
tickets exceeds US$75
(generally, the fair market
value will be determined
by Management Audit
and the proceeds of the
check will be used by the
Company for charitable
purposes).
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I found a vendor’s
confidential five-year
plan in one of our
conference rooms.
What should I do?”
Gifts and Anti-corruption Compliance
In addition to the requirements for accepting or
receiving gifts stated in this document you must
also be mindful of the Company’s Anti-corruption
Policy which is available at
www.disneyglobalcompliance.com. Please note
that any gift – including meals, entertainment, and
hospitality – given to a “government official” (which
term is defined in the Anti-corruption Policy) that is
worth more than $20 USD, or a meal that cost
more than $100 USD per person, must be
approved in advance by the Legal department or
the Company’s Chief Compliance Officer. Your
business segment may have more stringent
requirements so check with your local legal
department for further guidance.
Vendors, Suppliers and Customers
Be fair and ethical in purchasing decisions. If you
purchase products or services for the Company,
put the Company’s interests first and seek to
obtain the maximum value for the money spent
consistent with Company policy. You must also
comply with the Company’s competitive bidding
policy.
Treat all vendors fairly, honestly and courteously.
Avoid unfair buying tactics and favoritism, and
never take unfair advantage of any vendor through
manipulation, concealment, misrepresentation of
material facts or any other unfair practice.
We are committed to having our suppliers reflect
the same diversity that we seek in our workforce.
Work to identify minority and women-owned
business enterprises, and evaluate them in
accordance with their qualifications.
Know your obligations as they relate
to customers and licensees. Treat others as
you wish to be treated. Understand the policies
and standards that are applicable
to our Company. Don’t misrepresent the
characteristics or capabilities of our products or
recommend products or services that don’t
meet a customer’s needs.
Be careful when collecting information
about competitors, customers and vendors.
You have a responsibility to comply with Company
policy in gathering competitive information in the
marketplace. Although the standard for what is
acceptable and what isn’t may vary from country
to country, the Company prohibits certain
practices that are always improper as follows:
Theft
Blackmail
Wiretapping
Bribery
Trespassing
Industrial espionage
Receipt of stolen property
Asking or inducing someone to disclose
information that is confidential regarding a
current or former employer. (Note that
collecting information for newsgathering
purposes is governed by other policies set
forth elsewhere.)
In addition, collecting information by
misrepresenting facts, employee identity or
Company affiliation is also prohibited without
the prior approval of the Company’s General
Counsel.
The Walt Disney Company
Standards of Business Conduct
Do not read the
information or share it
with others. Deliver the
plan promptly to the
Legal department for
follow-up.
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22
A co-worker asked me
to make her a copy of
some spreadsheet
software we use in our
department. That’s
okay since we work
for the same company,
right?”
I have a friend who is
starting a new
business and has
asked me for a list of
customers who might
be interested
in her services. Is that
okay?”
If you find you’re in possession of information
that may have been obtained unethically
or illegally, or if you’re ever in doubt about
whether a particular practice for the collection
of information is proper, contact the Legal
department or The Guideline.
Protecting Company Assets
Our assets – whether information, physical,
financial or technology assets – are essential
to operating our Company successfully. As a
Cast Member or employee, you have a
responsibility to use them only for legitimate
Company business and safeguard them
against theft, loss, waste or abuse. Never use
opportunities you discover through the use of
Company assets for your personal gain.
Confidential information is protected non-
public information you may be exposed
to as part of your job and can relate to
our Company, guests, customers, vendors
or other Cast Members and employees.
It represents one of our Company’s most
valuable assets and should never be used for
your personal benefit or disclosed to others
inside or outside of the Company who don’t
have the right to it – and the need for it – to
carry out their assigned work. Note, however,
that the obligation not to disclose confidential
information does not apply to a disclosure
made 1) in confidence to an attorney or
directly or indirectly to a federal, state, or
local official, as long as the disclosure is
made solely for the purpose of reporting or
investigating a suspected violation of law or
2) in a complaint or other
document filed in a
lawsuit or other proceedingas long as the filing
is made under seal.
Examples of confidential information include:
“Inside” information about our Company that
could reasonably influence someone in
making decisions to buy or sell stock in a
company (ours or someone else’s). For more
information, see the Inside Information and
Securities Trading section
Cast Member and employee personnel
information
Non-public sales and earnings figures
Financial projections or strategic plans
Information about contemplated acquisitions,
mergers, stock splits or sales of associated
companies or real estate transactions
Strategic business or marketing plans
New creative projects contemplated by the
Company
Except as otherwise stated in this section,
never disclose any confidential information to
any party except as specifically authorized by
management and be careful not to discuss
confidential information in public areas. Be
sensitive to conversations you have via cell
phone or on elevators and take care in dialing
fax numbers or sending e-mails if transmitting
confidential information electronically.
Our technical and creative works are
renowned the world over. You have a
responsibility to protect our trade secrets and
proprietary information even after you leave
the Company.
The Walt Disney Company
Standards of Business Conduct
No, our customer lists
are private and should
never be shared with
anyone outside our
Company (or with
anyone inside our
Company who does not
need the information to
do his or her job).
No, copying the software
could violate our license
agreement as well as
copyright laws. Unless
you have appropriate
permission to do so,
never copy any software
– even for business use.
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24
I think my supervisor
lists expenses on his
expense report that
he didn’t incur. Should
I say something to
someone?”
A local reporter
approached me at
work and asked me to
comment on a rumor
circulating about our
Company. It was a
great opportunity to set
the record straight, but
I didn’t think I should
say anything.”
Safeguard our physical and electronic
assets, too. Our Company assets also
include the physical space where you work,
the equipment and supplies you use and the
computer resources you access. Hardware,
software, e-mail, voicemail, intranet and
Internet access, computer files and programs
including any information you create, send,
receive, download or store on Company
assets – are Company property, and we
reserve the right to monitor their use, where
permitted by law to do so.
Never install unauthorized software, hardware
or storage devices on your Company-issued
computer and don’t access our network
through unauthorized applications or devices.
Use good judgment if authorized to use
Company-provided Internet access; take care
to never violate a law, harass other users,
disclose confidential information or interfere
with network users, services or equipment.
Accurate Recordkeeping and Financial
Reporting and Complaints Regarding
Accounting and Auditing Matters
Accurate and complete recordkeeping is
essential to the successful operation of our
Company, as well as to our ability to meet our
legal and regulatory obligations. You have a
responsibility to be accurate, complete and
honest in what you report and record to meet
regulatory requirements, as well as in all
Company documents, including accounting
records, time cards, expense reports,
invoices, payroll records, safety records,
business records, performance evaluations,
etc.
If you see or suspect financial misconduct,
notify your supervisor immediately and
contact the Management Audit department
or The Guideline. For more information,
refer to the Employee Complaint Procedures
for Accounting and Auditing Matters.
You are also responsible to provide accurate
information in connection with our financial
reporting obligations.
Comply with Company policy when it
comes to retaining, storing and
disposing of Company records. Our
records management and retention policy
ensures that we maintain the records we
need to meet our legal, tax and regulatory
requirements and securely dispose of
records that are no longer needed. Take
care never to dispose of information that
may be relevant to current or threatened
litigation or subject to a legal hold until you
are authorized in writing to do so by the
Legal department.
Speaking on Behalf of our Company
Our Company conducts business in many
parts of the world and the public expects the
information we provide to be accurate. It’s
critical that information provided to the
public is complete, consistent and accurate
and also that confidential information is
protected. Unless you are an authorized
The Walt Disney Company
Standards of Business Conduct
Yes. Lying on an
expense report is not
only a violation of our
Standards, but is plainly
wrong. Report your
concern to your Human
Resources
representative, the
Management Audit
department or contact
The Guideline.
Your instincts were
right. Unless you
are an authorized
representative, you
should not speak on
behalf of the Company.
Direct the reporter
to the Corporate
Communications
department.
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26
Company spokesperson, don’t speak on behalf
of the Company. Instead, refer the individual to
one of the following:
For media inquiries, contact the Corporate
Communications department.
For questions regarding financial
performance, contact Investor Relations.
For legal issues, contact the Legal
department.
Be responsible in your use of social media.
Use online tools in a way that is consistent with
our Company policies. Certainly when
speaking about the Company you should be
professional, truthful and accurate. Regardless
of whether you access the Internet via our
systems or yours, be sure to respect your
obligation to protect confidential information
and the confidential information of companies
with which we do business. If you comment
online regarding any aspect of Company
business, identify yourself as an employee and
make it clear that the views posted are your
own and not those of our Company.
Want to know more?
Employee Policy Manual,
see “Use of Social Media”
The Walt Disney Company
Standards of Business Conduct
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5
Play by the Rules: Our
Commitment
to Lawful
Business
Practices
We are committed to
comply with the law
everywhere in
the world that
we operate.
2727
Standards of Business Conduct
Competition Laws
We expect Cast Members and employees to compete
aggressively, but fairly, and to sell our products and
services on the basis of quality and merit. Antitrust and
competition laws are designed to promote a free and open
marketplace. You have a responsibility to comply with
these laws wherever you do business and avoid conduct
that might suggest a violation. Failing to do so can subject
both you and the Company to imprisonment, substantial
criminal fines and civil financial liability.
Antitrust laws (sometimes called “competition
laws” or “unfair trade laws”) prohibit agreements
that unreasonably restrict competition. Don’t enter
into any agreement or understanding, whether formal
or informal, with a competitor, customer or supplier to:
Set prices or price-related terms, also known as
“fixing” prices
Refuse to deal with a customer or supplier
Divide territories or customers
The Walt Disney Company
2828
Also, in certain circumstances, using market
power to coerce buyers to buy unwanted
products by tying them to other “must have”
products, may be prohibited.
Keep in mind, antitrust laws are complex and
differ from country to country. Entering into
exclusive dealing or licensing agreements,
engaging in pricing practices that suggest a
monopoly, charging different prices to different
customers for the same product – those and
many similar practices may raise issues under
antitrust laws. If you ever have a question about
how antitrust and competition laws apply to a
particular business situation, you should seek
help from the Legal department or contact
The Guideline.
Trade Secrets, Trademarks, Patents and
Copyrights
You must honor the trade secrets, trademarks,
patents and copyrights of others. This includes
trade secrets of previous employers. While our
Company is entitled to your skills and creative
energy while you work here, we do not want to
learn of secrets you developed or learned about
through previous employers.
Copyright infringement issues can be
complex. A person who infringes a copyright
willfully and for commercial advantage may be
subject to civil liability as well as criminal
prosecution. There are some circumstances,
however, where it is proper to reproduce
portions of copyrighted work for purposes of
criticism, comment, news reporting, teaching
and research; this is called “fair use” and
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30
doesn’t violate copyright law. However,
making fair use determinations is difficult and
must be done on a case-by-case basis. Don’t
take chances: any questions about what is
permissible – and what isn’t – should be
directed to the Legal department to ensure
compliance with the law.
Product Safety
The safety of products bearing Disney
brands, characters and other intellectual
property is of crucial concern to the
Company. We require that licensees and
manufacturers comply with all applicable
legal and regulatory safety requirements and
conduct safety tests by independent, certified
third-party testing laboratories or equivalent
procedures.
If you become aware of a product safety
concern regarding any Disney-branded
product immediately contact the Disney
Product Integrity group at 818-560-3474.
Food and Drug Safety
We are recognized around the world, among
other things, as a provider of high-quality
food products and merchandise. We rely on
you to preserve the reputation we’ve earned.
Comply with all applicable food and drug
laws and cooperate fully with all federal and
state inspectors who come to our facilities.
Make sure you:
Store, prepare and serve food, drugs and
other products in a sanitary and healthful
condition.
Never represent that a product has been
inspected or labeled as fit for use if it
hasn’t been.
Don’t sell anything that is improperly or
incompletely labeled.
If a product needs inspection, don’t allow it
to be purchased or sold in any of our
facilities without inspection.
Anti-corruption, Anti-bribery
We never, under any circumstances, offer
bribes or influence decisions through
improper means. As a global company, we
have a duty to comply with the laws in the
countries in which we do business as well as
the U.S. Foreign Corrupt Practices Act
(FCPA) and (if it applies to you) the U.K.
Bribery Act. As a Cast Member or employee,
you need to understand and comply with the
FCPA and the U.K. Bribery Act as well as
any other anti-corruption laws that apply
where you operate. Violations can result in
lawsuits, substantial fines – even
imprisonment for individuals.
The rules for giving gifts to government
officials are very strict. Never offer, promise
or give (either directly or indirectly) anything
of value to induce or influence a government
official (including officials of international
organizations, political parties
The Walt Disney Company
Standards of Business Conduct
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32
Anything of value”
could be:
Free or discounted
goods or services
The promise of a job
A charitable or political
contribution
Gift certificates or gift
cards
Use of materials,
facilities or equipment
A loan
Tickets to a theme park
or resort accommodations
and employees of state-owned or state-
controlled enterprises) to gain an improper
advantage or to do something improper.
Violations can subject you and our Company
to severe penalties and damage our public
reputation.
Regardless of local practice or the practices
of other companies, make sure you avoid
even the appearance of doing something
improper.
For more information, see our anti-corruption
policy.
Giving any gift requires accurate
recordkeeping. Any gift permitted under our
policy and given by you in connection with
your job must be transparent and recorded
accurately in our corporate books and
records. When completing an expense report
regarding the gift, you are required to
accurately state the purpose of the expense
and the person to whom you gave it. You
must also identify whether it was given to a
government official – in which case you
should have obtained the approval of the
Legal department in advance.
Before engaging in any transaction which
you think is questionable, you must consult
with the Legal department. If the transaction
is approved, make sure it is accurately
reported in our Company’s books
and records.
We could be responsible for bribes made
on our behalf by third parties. Our Company
may be liable if a bribe is paid on our behalf,
even if we did not authorize it to be paid, so it
is critical that we are careful in the selection of
agents, i.e., those people or companies who
act on our behalf. Exercise due diligence to
make sure our agents are reputable and that
they agree to conduct business in compliance
with anti-bribery laws and regulations.
A full statement of the Company’s Anti-
corruption Policy can be found at
www.disneyglobalcompliance.com. That
Policy is called “The Walt Disney Company
and Affiliates Global Anti-corruption Policy.” It
sets forth in detail the policies and procedures
to be followed regarding anti-corruption and
anti-bribery compliance. If you have any
questions about the Policy please contact
the Legal department or the Guideline.
Export, Import and Anti-boycott Laws
We comply with all applicable laws, regulations
and restrictions in the import or export of
products, services, information or technology,
wherever we operate in the world. If you
are involved in the movement of goods or
technology across international borders, make
sure you know and comply with:
Any U.S. restrictions on doing business with
certain foreign countries
All applicable export control requirements
The trade laws and regulations associated
with the countries in which you do business
The Walt Disney Company
Standards of Business Conduct
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34
I just heard about a
large contract Disney
entered into with
one of our suppliers.
A friend of mine
owns stock in the
supplier’s company and
mentioned recently that
he planned to sell it.
I know I can’t tell him
about the news of the
award, but is it okay to
encourage him to hold
on to his stock?“
We also have a responsibility to comply with
U.S. anti-boycott laws. If you receive a
request to comply with a foreign boycott (or
a request to supply boycott-related
information), consult with the Legal
department to determine the appropriate
course of action.
Doing Business with and Providing
Information to the Government
Doing business with the government is
highly regulated and typically follows stricter
rules than those in the commercial
marketplace. If you work with government
officials or a government-owned (or partially-
owned) company, you have a special duty to
know and comply with applicable laws and
regulations, adhere to the highest standards
of integrity and avoid even the appearance
of impropriety.
We are committed to full compliance with
the law, wherever we operate. If you are
responsible for acting on our Company’s
behalf in providing financial information,
complying with the tax laws or meeting
cash-related reporting requirements or any
other legal or regulatory requirements,
always be accurate and timely. Moreover,
never destroy, discard, tamper with, conceal
or make any false entries on documents you
provide to government agencies or officials.
The same is true for responding to any
request in connection with a government
investigation or proceeding. If you
ever receive such a request you should
immediately advise the Legal department
and follow its instructions to ensure that the
information or documents we provide fully
comply with our legal obligations.
Inside Information and Securities Trading
As a Cast Member or employee, your job
may expose you to material, nonpublic
(or “inside”) information about our Company
or companies with which we do business.
Material inside information
is information about a company that is
not available to the public but, if it were,
might influence someone’s investment
decision about that company. Examples
of material inside information include:
information about mergers or acquisitions,
financial performance, changes in executive
management, significant transactions or new
projects contemplated.
You may not trade in Company stock or other
securities based on material inside
information you have about our Company,
and you may not trade in the stock of
companies we work with if your job exposes
you to inside information about those
companies. Passing along a “tip” is also a
form of insider trading and strictly prohibited.
Keep in mind, even the appearance of an
improper transaction must be avoided.
The Walt Disney Company
Standards of Business Conduct
No, you cannot help
someone make a profit
or avoid a loss on
the basis of material
non-public inside
information you know
about by virtue of your
job. Suggesting to your
friend that he hold onto
his stock, even if you
don’t offer a reason,
would be a violation of
our policy and may also
be a violation of U.S.
insider trading laws.
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36
What if you participate in the employee
Stock Purchase Plan? You are encouraged
to participate in this program and invest in
our collective future. Do not, however,
change your instructions in the plan if you
are in possession of inside information.
Money Laundering
Money laundering is the process by which
funds generated through criminal activity
(such as terrorism, drug dealing, fraud, etc.)
are processed through commercial
transactions in order to conceal the
source of the proceeds, avoid reporting
requirements or evade taxes. As a
Company, we do not want to be used by
those engaged in criminal activity. Be on the
alert for possible instances of money
laundering and immediately notify your
supervisor, the Legal department or The
Guideline regarding any suspicious activity.
The Walt Disney Company
Standards of Business Conduct
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3737
Standards of Business Conduct
6
Respect: Our Commitment to
the Community
As a member of the
global community, we
have a responsibility
to be a good
corporate citizen.
An International Presence
We are dedicated to delivering quality products and
services and cooperating with community leaders
and members throughout the world to benefit local
communities. While we are bound by U.S. laws and
regulations and Company policy, we recognize that,
as we grow, we are introducing not only a new
Company, but often a new corporate culture and,
perhaps, different business practices in countries all
across the globe. We count on every Cast Member
and employee to follow the letter and the spirit of
those U.S. laws that may apply (for example, the
Foreign Corrupt Practices Act) and maintain an
awareness of – and sensitivity to and commitment to
observe – differing legal requirements from country to
country.
If a local law conflicts with our Standards, comply
with the local law. If a local custom conflicts with our
Standards, comply with the Standards. If you’re not
sure, ask for help.
Labor Standards
We comply with employment laws in all
markets where we operate. In addition, the
Company’s International Labor Standards
prohibits the following in connection with
the manufacturing of Disney-branded
products: 1) child labor; 2) involuntary labor;
3) coercion or harassment; 4) unfair
discrimination; 5) serious health or
workplace violations; 6) interference with
workers' freedom of association; and 7) the
improper use of home workers. These
requirements apply to the Company’s own
sourcing activities as well as to licensees,
vendors, buying agents and production
facilities involved in the manufacture of
Disney-branded products.
The Environment
We are committed to the protection of the
environment and the conservation
of natural resources. We fully comply with
environmental laws and regulations,
including those relating to disposal of
wastes. In addition to complying with all
such applicable laws ourselves, we also
expect companies and contractors with
which we partner to do the same.
I have seen some co-
workers dumping trash
in an area that’s not
authorized for that
purpose, but I don’t
want to get involved –
or get them in trouble.”
" … maintain an
awareness of – and
a sensitivity to and
a commitment to
observe – differing
legal requirements
from country to
country."
The Walt Disney Company
As a Cast Member or
employee you have
a responsibility to
take action when you
become aware of
potential violations
of our Standards; this
includes reporting
environmental hazards
or any other unsafe
working conditions.
Speak to your
supervisor or contact
The Guideline.
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Charitable and Political Activities
We want to foster good relations within the
communities where we operate. You are
encouraged to participate in local activities
that address the needs of the communities in
which you live and work and to participate as
a private citizen in government and the
political process, using your own money and
your own time.
Make sure your involvement in charitable
or political activities is not prohibited by other
Company policies or suggestive of anything
improper, and do not use without specific
authorization (such as is authorized by the
Company’s Matching Gifts program) any
Company funds or resources to help or
promote any charitable cause or political
candidate or party.
Note that the Company’s Senior Vice
President of Government Relations must
approve any corporate contribution to any
political candidate, any committee supporting
any such candidate, any political party, any
organization advocating on behalf of or in
opposition to any such candidate or party
organization, or any organization advocating
on behalf of or in opposition to any proposition
that is or is expected to be submitted to voters
of a jurisdiction.
The Walt Disney Company
Standards of Business Conduct
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“Inside” information – Any information about a company, its customers, suppliers
or other companies that an employee knows – by virtue of being an employee of the
company – that is not known by the public. Such information is material if it would
likely be considered important in deciding to buy, sell or hold stock in a company.
“Material inside information” can include information about new products and
services, pricing, budgets, earnings announcements, proposed mergers and
acquisitions, anticipated layoffs, etc.
Insider trading – Using material, non-public (i.e., “inside”) information – or tipping
someone else to use it – to buy or sell stock in a company.
Intellectual property – Intangible property that has commercial value and is the
result of creative effort including copyrighted property (such as literary or artistic
works), patents, trademarks, business methods or industrial processes.
Legal hold – When a company is – or may be – involved in a legal proceeding, the
law requires that it save information relevant to the case; a legal hold is a notice that
advises you not to destroy certain records. It generally includes special recordkeeping
instructions and requests for specific documents and audits.
Material financial interest – Any paid relationship or arrangement (for example, as
agent, representative, employee, promoter, consultant or “finder“) with a business
organization or any ownership interest (of stock, partnership interests, etc.) in excess
of 5 percent in a publicly traded entity or, in the case of a non-public entity, having a
fair market value in excess of US$25,000.
“Ordinary course of business” test – A series of questions you can ask yourself
to inform decision-making about accepting a gift: (1) Would the gift be considered
customary given your job duties, job title and seniority? (2) If the gift was reported
in the media, would others think favorably of you? Of our Company? (3) Will the
gift complement or enhance a business relationship? (4) For offers of hospitality or
entertainment, is the person extending the offer going with you?
Proprietary information – Information that a company owns that represents the work
it does. It includes software programs, trade secrets, engineering drawings,
copyrights, ideas, techniques, inventions, product specifications, research, marketing
data – all of the information that makes our Company unique. All proprietary
information is considered confidential information.
U.K. Bribery Act – A law that makes it illegal for anyone (public, quasi-public or
private) working for a company in the U.K., or a company that does business or is
registered in the U.K., to give or receive a financial or other advantage to induce or
reward someone for doing – or to do – an improper act in exchange for a business
advantage.
Glossary
“Anything of value” – Money or other “things” (e.g., services, transportation,
hospitality, donations, contributions, etc.) that have value.
Company assets – Anything owned by the Company, including physical property
(such as buildings, equipment and furniture), technology (such as computer hardware,
software and information systems), financial assets (such as cash, bank accounts and
credit standing) and information assets (such as customer lists, financial information
and intellectual property).
Confidential information – Information a company has or acquires that is kept
private and not made available to the public. It includes personal information about its
employees, any information that isn’t readily available from a public source or specific
information that is shared between parties in confidence.
Conflict of interest – A conflict of interest exists when an employee or a member of
his/her family is involved in an activity that affects (or appears to affect) his/her
objectivity as an employee of the company. Personal relationships, outside
employment opportunities and investments an employee makes can all pose potential
conflicts of interest.
Due diligence – Taking the necessary actions required to know who a person or a
company is doing business with; knowing why, when and to whom they are releasing
funds, and being in a position to feel confident that business relationships are
transparent and ethical.
Financial interest Any paid relationship or arrangement (for example, as agent,
representative, employee, promoter, consultant or “finder“) with a business or any
ownership interest (of stock, partnership interest, etc.).
Foreign Corrupt Practices Act (FCPA) A law that prohibits the bribery of non-
United States government officials (including employees), and which requires certain
accounting and recordkeeping practices for companies.
“Good faith” – Honestly believing in what you’re doing. For example, making a report
to The Guideline “in good faith” means that you honestly believe that there’s a
violation of our Standards or Company policies and that you’re not deliberately
making a false report.
Immediate family – A spouse, parent, child, sibling and mother- or father-in-law, son-
or daughter-in-law, brother- or sister-in-law, as well as people (other than household
employees) who permanently reside in a person’s home.
The Walt Disney Company
Standards of Business Conduct
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The Walt Disney Company
44
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43
Standards of Business Conduct
Resources to Help You
If you have a question, wish to discuss a personal situation or need to
report a possible violation of our Standards, talk with your supervisor, your
Human Resources representative or any of the resources listed below.
For additional information regarding employee complaints of accounting
matters, refer to the Employee Complaint Procedures for Accounting and
Auditing Matters.
Resource:
Contact Regarding: To Access:
Human Resources
department
Any question or to discuss a personal
situation or Human Resources matter
8228-5632
or 818-560-5632
The Legal
deparment
Any possible legal issue, question or
concern
8228-1301
or 818-560-1301
The Guideline
1) Questionable activities – including
questionable accounting or auditing
matters;
2) Complaints regarding the
Company’s accounting, internal
accounting
controls or auditing matters;
3) Guidance on any business conduct-
related issue; or
4) To make the Company aware of any
suspected unethical or illegal
conduct or violation at the Company.
Cast Members and
employees in the United
States and Canada, may
report online:
disneyguideline.com
Or call anytime, day or night:
800-699-4870
Management
Audit
department
1) Questionable activities – including
questionable accounting or auditing
matters;
2) Complaints regarding the
Company’s accounting, internal
accounting controls or auditing
matters;
3) Waivers of the Standards or
questions related to the Company’s
conflicts of interest and gift policies.
8494-4000, Ext. 1
or
818-553-4000, Ext. 1
Investor Relations
Outside inquiries regarding the
Company’s financial performance.
818-560-4536
Corporate
Communications
Media inquiries
818-560-3117
Global ethics &
compliance
web site
More information regarding the
Company’s ethics and
compliance policies.
disneyglobalcompliance.com
As of May 2017
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