STANDARDS OF BUSINESS CONDUCT - THE WALT DISNEY COMPANY

 
STANDARDS OF BUSINESS CONDUCT - THE WALT DISNEY COMPANY
The Walt Disney Company

Standards of Business Conduct

                                 “In the end, the quality and integrity of our people and product
© 2012 The Walt Disney Company
All rights reserved.             is paramount to us – it’s more important than anything we do.”
                                                                                  – Robert A. Iger
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STANDARDS OF BUSINESS CONDUCT - THE WALT DISNEY COMPANY
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                                             An Unparalleled                                                         Speak Up
                                             Commitment …

                                Dear Fellow Disney Team Member,                                                     You have the right and the responsibility to protect our
                                                                                                                   Company from conduct that can threaten our day-to-day
                                Throughout the years, we have earned the trust                                        operations, our reputation and our future growth.
                                of guests, audiences, consumers and shareholders
                                because of our commitment to high standards in                                                            The Guideline
                                everything we do, everywhere we operate. Integrity,                                     is a resource for employees and Cast Members to
                                honesty, trust, respect, playing by the rules, and                                 1) report questionable activities – including questionable
                                teamwork – these define not only the operating                                     accounting or auditing matters; 2) report complaints regarding
                                principles of our Company, but also the spirit of our                               the Company’s accounting, internal accounting controls
                                diverse global workforce and how we function.
                                                                                                                    or auditing matters; 3) ask for guidance on any business
                                Our Standards of Business Conduct provide the                                      conduct-related issue; or 4) make the Company aware of any
                                information, the resources and the tools necessary to                                suspected unethical or illegal conduct, or violation of our
                                conduct ourselves ethically and in compliance with the                             Standards of Business Conduct or of any other Company policies.
                                law. As a Cast Member or employee you are expected
                                to read and be familiar with the Standards and to use                                 Cast Members and employees in the United States
                                them to guide the way you act.                                                                and Canada, may report online:
                                                                                                                                www.disneyguideline.com
                                Always remember that in every interaction, you are
                                the face of our Company. Act responsibly in all of your                                           Or call anytime, day or night:
                                professional relationships, in a manner consistent with
                                the high standards we set for our business conduct,                                                    800-699-4870
                                and speak up whenever you have a question or
                                                                                                                             (Hearing Impaired: TTY 877-576-2569)
                                concern. As we continue to create Disney Magic, make
                                sure your actions reflect your pride in yourself, those                            Concerns are addressed promptly and fairly. Our Company
                                you work with and the 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
                                Robert A. Iger                                                                               refer to the information on this page.
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STANDARDS OF BUSINESS CONDUCT - THE WALT DISNEY COMPANY
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               Contents

                  1             Integrity: Our Standards

                                Why We Have Standards of Business Conduct                                            1
                                                                                                                             Accurate Recordkeeping and Financial
                                                                                                                               Reporting and Complaints Regarding
                                                                                                                               Accounting and Auditing Matters                     23
                                Who is Required to Follow the Standards                                              2       Speaking on Behalf of our Company                     24

                                                                                                                         5
                                What the Standards Mean for You                                                      2
                                Asking Questions, Sharing Concerns:                                                          Play by the Rules: Our Commitment
                                  The Guideline                                                                      3                           to Lawful Business
                                                                                                                                                 Practices

                  2             Trust: Our Commitment to Guests and
                                        Customers
                                                                                                                             Competition Laws
                                                                                                                             Trade Secrets, Trademarks, Patents and
                                                                                                                               Copyrights
                                                                                                                                                                                   27

                                                                                                                                                                                   28
                                Safety                                                                               5       Product Safety                                        29
                                Quality                                                                              5       Food and Drug Safety                                  29
                                Protecting Privacy                                                                   6       Anti-corruption, Anti-bribery                         30
                                                                                                                             Export, Import and Anti-boycott Laws                  32

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                                                                                                                             Doing Business with and Providing Information
                                Teamwork: O
                                           ur Commitment to Each Other                                                        to the Government                                   33
                                                                                                                             Inside Information and Securities Trading             34
                                                                                                                             Money Laundering                                      35

                                                                                                                         6
                                Fairness, Dignity and Respect                                                        9
                                A Diverse Workforce                                                                 10
                                                                                                                             Respect: Our Commitment to the

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                                                                                                                                       Community
                                Honesty: O
                                          ur Commitment to the Company
                                         and our Shareholders                                                                An International Presence                             37
                                                                                                                             Labor Standards                                       38
                                Conflicts of Interest                                                               11       The Environment                                       38
                                Gifts, Entertainment and Hospitality                                                14       Charitable and Political Activities                   39
                                Vendors, Suppliers and Customers                                                    19
                                Protecting Company Assets                                                           21       GLOSSARY                                              41

                                                                                                                             RESOURCES                                             43

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                                                                                                                                                                    “Yesterday, my
                                                                                                                    Who is Required to Follow the Standards           supervisor asked me
                                                                                                                                                                      to do something that
                                                                                                                                                                      violates our Standards.
                                                                                                                    Our Standards apply to all Cast Members           I’m not sure what
                                                                                                                    and employees (including temporary, part-         to do ….”
                                                                                                                    time and seasonal employees) as well as         You have a
                                                                                                                    others who are identified with our Company      responsibility to comply

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                                                                                                                                                                    with our Standards,
                                                                                                                    as acting on its behalf.                        even if your supervisor
                                 Integrity: Our Standards                                                                                                           asks you to do
                                                                                                                    What the Standards Mean for You                 otherwise. No one – not
                                                                                                                                                                    even your supervisor –
                                                                                                                                                                    has the authority to tell
         We do what’s            Why We Have Standards of Business Conduct                                          As a Cast Member or employee, you have a        you to do something
        right and take                                                                                              responsibility to:                              illegal or unethical.
 responsibility for our          The connection we share with people around the                                                                                     Talk to someone else in
actions to protect our           world through the content, entertainment and                                       • Act with integrity and honesty on the job.   management or contact
                                                                                                                    • Comply with all applicable laws and          your Human Resources
guests, our audiences,           experiences we offer is a privilege, one we must                                                                                   representative, The
   our consumers and             never take for granted. We recognize that our                                         regulations in performing your duties.       Guideline or the Legal
     our shareholders.           continued success depends upon a commitment                                        • Be familiar with the Standards, follow       department for help.
                                 to conduct business with honesty, integrity and in                                    them at all times and seek help when you
                                 compliance with the law everywhere we operate.                                        have a question.
                                                                                                                    • Share concerns about any conduct that
                                 Our Standards of Business Conduct (or “Standards”)                                    violates our Standards.
                                                                                                                                                                    Not sure? Ask yourself:
                                 are a reflection of that commitment and provide you                                                                                • Is it legal?
                                                                                                                    We are committed to compliance with our
                                 with the information you need to do the right thing                                                                                • Does it comply with our
                                                                                                                    Standards. Anyone who violates them is             Standards?
                                 on the job and preserve the reputation we have
                                                                                                                    subject to disciplinary action, up to and       • What would someone
                                 earned as an ethical company.                                                                                                         I respect say about my
                                                                                                                    including termination. Remember, one of the        actions?
                                                                                                                    best resources for solving an ethical dilemma
                                 Keep in mind, no document can address every
                                                                                                                    is your conscience. If an action you’re
                                 situation you may possibly face in your everyday
                                                                                                                    contemplating feels dishonest, unethical or
                                 work. We rely on you to use these Standards as well
                                                                                                                    illegal, it probably is.
                                 as your good judgment to guide your behavior and
                                 to ask questions if you are ever unsure of the proper
                                                                                                                    If you are a supervisor, you have a
                                 course of action.
                                                                                                                    greater level of responsibility. We look to
                                                                                                                    you to model ethical behavior and promote

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STANDARDS OF BUSINESS CONDUCT - THE WALT DISNEY COMPANY
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                                a workplace where Cast Members and                                        with your supervisor, your Human Resources        The Guideline offers a
                                employees feel comfortable coming forward                                 representative or The Guideline.                  way for you to:
                                with concerns and questions. Our Company                                                                                    • Share concerns about
                                                                                                                                                               questionable activities
                                is committed to open, free and effective                                  Available anytime night or day, The               • Report known or
                                channels of communication, so promote an                                  Guideline is operated by an independent,             suspected acts of
                                “open door” policy, be a good listener and                                third-party company located in the United            financial misconduct or
                                                                                                                                                               other violations of our
                                work to earn the trust of your co-workers.                                States and allows you to submit an online
                                                                                                                                                               Standards
                                                                                                          report or share your concerns in your own         • Ask for guidance on
                                Make sure you are familiar not only with                                  language with a professional interview               any business conduct-
                                the Standards but also with the specific                                  specialist. Reports are accepted anonymously       related issue
                                laws and policies that apply to you and your                              where permitted by law.
                                team. Our Standards may complement other
                                policies, procedures and our employment                                   Regardless of whom you contact, you
                                agreements. If you or anyone on your team                                 may be assured that your concerns will
                                encounters an inconsistency or conflict,                                  be addressed promptly and fairly. Our
                                seek the help of your supervisor or Human                                 Company does not tolerate any form of
                                Resources representative or The Guideline.                                retaliation (including separation, demotion,
                                                                                                          suspension or loss of benefits) against
                                Asking Questions, Sharing Concerns:                                       anyone who makes a good faith report
                                The Guideline                                                             of potential misconduct or helps with an
                                                                                                                                                            “I have an issue that
                                                                                                          investigation. We want you to be free to ask        I’d like to discuss with
                                One of our greatest assets is our reputation.                             questions and raise issues without fear of          someone in Human
                                We’re known for operating with high ethical                               retaliation, secure in the knowledge that you       Resources, but my
                                                                                                                                                              supervisor told me that
                                standards everywhere we do business. Our                                  did the right thing in coming forward.
                                                                                                                                                              all issues should be
                                continued success depends, in part, on your                                                                                   discussed with her first.
                                commitment to doing the right thing and                                   Sometimes, it may seem easier to keep               Is that right?”
                                speaking up if you see or suspect someone is                              quiet or look the other way when someone           It’s a good idea to
                                violating our Standards.                                                  violates our Standards, but doing nothing          discuss issues and
                                                                                                          can, in itself, result in serious consequences.    concerns with your
                                                                                                                                                             supervisor first, but if,
                                You have the right and the responsibility to                              When you speak up about unethical and              in a particular situation,
                                protect our Company from conduct that                                     illegal behavior, you’re saying that an honest     you feel uncomfortable
                                can threaten our day-to-day operations, our                               and ethical workplace matters to you.              doing so, you are free to
                                                                                                                                                             contact another member
                                reputation and our future growth. If you                                                                                     of management, your
                                ever have questions about our Standards or                                                                                   Human Resources
                                Company policies or if you see or suspect                                                                                    representative or
                                                                                                                                                             The Guideline.
                                a violation, we rely on you to share them

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STANDARDS OF BUSINESS CONDUCT - THE WALT DISNEY COMPANY
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                                                                                                                    every product and service we deliver and         "... build quality into
                                                                                                                    every interaction we share. That means being       every product and
                                                                                                                                                                       service we deliver and
                                                                                                                    courteous, knowledgeable and passionate            every interaction we
                                                                                                                    about providing a high-quality experience          share."
                                                                                                                    to all of our guests and customers. It also
                                                                                                                    means creating products and services that
                                                                                                                    we are proud to identify as ours.

                    2            Trust: O
                                         ur Commitment to
                                        Guests and Customers
                                                                                                                    Protecting Privacy

                                                                                                                    In compliance with data privacy laws, we
We are committed to              Safety                                                                             work to keep personal data private. Personal
  our guests and our                                                                                                data includes any information that directly
customers – they are             Promoting the health, safety and welfare of our                                    or indirectly relates to a person; for example
       the reason we             guests and customers is a critical responsibility –                                office e-mail addresses, telephone numbers,
             are here.           one that should never be ignored, minimized or                                     images, credit card information, etc. You are
                                 sacrificed. All of us share the responsibility of helping                          expected to follow all Company policies as
                                 to make guests safe and secure. Do your part to                                    they relate to handling and retention of the
                                 meet our high standards, whether you are designing,                                information.
                                 building, operating or maintaining our Company
                                 attractions, products or facilities. Remember, the                                 If you work with personal information as
                                 commitment you make preserves not only the                                         part of your job, use it only for legitimate
                                 safety of our guests and customers but also a                                      business reasons and in compliance with all
                                 safe workplace for your fellow Cast Members                                        applicable privacy notices or policies. There
                                 and employees.                                                                     are strict rules about collection of personal
                                                                                                                    information for marketing purposes – if
                                 Quality                                                                            you’re not sure what is permissible, ask.
                                                                                                                    Breaches of data privacy can expose you
                                 We are recognized as providers of high-quality                                     and the Company to legal penalties and
                                 content, entertainment and experiences of all kinds,                               harm the reputation we’ve earned as an
                                 including films, television programs, news and                                     ethical company.
                                 information, theme park attractions and resorts,
                                 online experiences, consumer products and stores.
                                 Each of us has a responsibility to build quality into

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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?

                                     IT Use Policy, Collaboration Policy

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                                                                                                                   Cast Members and employees are made                “I overheard a co-worker
                                                                                                                   fairly, with discretion and respect for privacy.     use insulting language
                                                                                                                                                                        when referring to
                                                                                                                                                                        someone on our team.
                                                                                                                   A Diverse Workforce                                  What should I do?”
                                                                                                                                                                       Language that is
                                                                                                                   Each of us is a valued member of the team.          disrespectful of a
                                                                                                                   We embrace our multicultural workforce              person’s race, religion,

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                                                                                                                                                                       color, sex or any other
                                                                                                                   and tap the unique talents and potential of         protected class doesn’t
                                Teamwork: O
                                           ur Commitment                                                          every Cast Member and employee to create            fit in a workplace that
                                                                                                                                                                       values diversity. If you
                                                                                                                   superior products and services. To foster
                                          to Each Other                                                            diversity, we:
                                                                                                                                                                       feel comfortable doing
                                                                                                                                                                       so, say something to
We work together to             Fairness, Dignity and Respect                                                                                                          your co-worker to
                                                                                                                   • Seek to attract and develop a workforce
protect the heritage                                                                                                                                                   express your concern.
                                Our Cast Members and employees are the                                                that reflects the guests and customers,          If you don’t, speak to
  we have built as a
                                cornerstone of our magic. We are committed to a                                       business partners, shareholders, labor           your supervisor, your
 company with high
                                                                                                                      markets and communities in which we do           Human Resources
   ethical standards.           work environment where everyone is afforded the                                                                                        representative or call
                                dignity and respect that they deserve. We don’t                                       business.
                                                                                                                                                                       The Guideline.
                                allow any form of harassment or discrimination                                     • Maintain a workplace that offers open
                                on the basis of race, religion, color, sex, sexual                                    opportunities to all, recognizing individuals
                                orientation, gender identification, national origin,                                  for their experience, performance, training,
                                                                                                                                                                      "Each of us is a valued
                                age, marital status, covered veteran status,                                          work history and potential.                      member of the team."
                                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

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                                                                                                                    in which you or a member of your immediate          “When my department
                                                                                                                    family has a financial interest, which is defined     hosts special events, my
                                                                                                                                                                          team puts me in charge
                                                                                                                    as any paid relationship or arrangement               of catering because my
                                                                                                                    (for example as an agent, representative,             daughter-in-law owns
                                                                                                                    employee, promoter, consultant or “finder”)           a local restaurant that
                                                                                                                    with a business or any ownership interest (of         provides great food at a
                                                                                                                                                                          discount. Is that okay?”
                                                                                                                    stock, partnership, interest, etc.) other than

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                                                                                                                                                                         No, even if the
                                                                                                                    not in excess of 5 percent of a publicly-traded
                                                                                                                                                                         restaurant offers a
                                Honesty: Our Commitment to                                                         entity unless you obtain approval from the           great meal at a great
                                                                                                                    Management Audit department.                         price, selecting your
                                          the Company and                                                                                                                daughter-in-law’s
                                          our Shareholders                                                          What about situations where you are not              business without prior
                                                                                                                                                                         approval from the
      Protecting our            Conflicts of Interest                                                               actually conducting business yourself with           Management Audit
 reputation requires                                                                                                a member of your immediate family or a               department may give
                                Our business is built on public trust and confidence                                company owned by an immediate family                 the appearance that
      a commitment
                                                                                                                                                                         we chose her business
   to truth and high            and an expectation by guests and customers that                                     member, but you are in a position to influence
                                                                                                                                                                         because of your family
        standards in            they can depend on our products and services. To                                    or affect our Company’s business relationship        connection.
  everything we do.             deliver our very best, each of us has an obligation to                              with that person or company? If you or a
                                make objective decisions on behalf of the Company                                   member of your immediate family has a
                                and avoid situations where a conflict (or apparent                                  material financial interest in a company that
                                conflict) exists between the Company’s interests and                                is or wants to do business with our Company,
                                our own, personal interests.                                                        you must disclose that information to the
                                                                                                                    Management Audit department as soon as you
                                It’s impossible to list all of the situations that could                            become aware of it.
                                present a potential conflict of interest, but there
                                are certain situations where conflicts often arise. It’s                            Don’t ask others to do something you
                                important that you are familiar with these situations,                              are prohibited from doing. If you are a
                                recognize a potential conflict when you see one and                                 supervisor, you may not allow (or direct)
                                take the appropriate action.                                                        any employees you directly supervise to
                                                                                                                    conduct business with you or members
                                Doing business with family can present a conflict                                   of your immediate family or companies in
                                of interest. Even if you work to remain objective                                   which your immediate family has a financial
                                in your business dealings, the fact that you share                                  interest, unless approval is obtained from the
                                a personal relationship or financial interest with                                  Management Audit department.
                                someone or a company can create the appearance
                                of a conflict of interest. As a result, you may not                                 In situations where employees you indirectly
                                conduct business on behalf of our Company with a                                    supervise are conducting or intending to
                                member of your immediate family or with a company                                   conduct business with a member of your
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   “To make some extra          immediate family or company in which you                                  Gifts, Entertainment and Hospitality
     money, I’ve started my      or your immediate family has a financial
     own Internet business                                                                                 The exchange of gifts is often a common business
                                 interest, you must disclose the situation to
     on my home computer.                                                                                  practice and one that can build goodwill among
                                 the Management Audit department as soon
     Is that okay?”                                                                                        companies with which we do business, but when
                                 as you become aware of it.
     It’s always best to check                                                                             gift-giving becomes lavish or frequent, it can
     with your supervisor                                                                                  suggest something improper. That’s why we have
                                 Be careful in working for or investing in
     but, in general, as long                                                                              policies in place to help you determine what’s
     as the business doesn’t
                                 other companies. Working for or having a
                                                                                                           appropriate – and what’s not – in terms of giving or
     compete with the            material financial interest in a company that
                                                                                                           receiving gifts.
     Company’s business,         competes with our Company can present a
     use Company assets or       conflict. A conflict can also arise if you work
                                                                                                           Our policies are designed to:
     interfere with your         for a company that has no association with
     ability to do your job,     ours but your work interferes with the time,                              • Comply with the law and, when giving a gift,
     it is acceptable.           talent and energy you bring to the work                                      comply with the company policies of the person
                                 you do for our Company.                                                      receiving the gift.
                                                                                                           • Make sure our success is based on the merits of
                                 Therefore, if you are considering investing                                  our products and services, not gifts we give or
                                 in such a company, starting your own                                         receive.
                                 business or accepting a second job, talk                                  • Promote transparency – we don’t engage in any
                                 to your supervisor to make sure there is                                     activity that would compromise our professional
                                 no conflict. If you have questions about                                     judgment or suggest favorable or preferential
                                 investments and possible conflicts, contact                                  treatment.
                                 the Management Audit department.
                                                                                                           What is a “Gift”? A gift is anything of value. It
                                 Are you involved in decisions                                             includes tangible items such as jewelry and art, but
                                 regarding our Company and a                                               also intangible items such as discounts, services, loans,
                                 financial institution? If you play a role                                 favors, special privileges, advantages, benefits and
                                 in establishing or managing a relationship                                rights that are not available to the general public. A
                                 between our Company and any financial                                     “gift” also includes meals, entertainment, hospitality,
                                 institution, you may not enter into any                                   vacations. trips, use of vacation homes, tickets
                                 transaction with – or receive any benefit or                              to sporting or music events, golf outings, vendor
                                 opportunity from – the institution that isn’t                             familiarization trips and use of recreational facilities.
                                 generally available to other customers or                                 Under no circumstances should you ever solicit a gift
                                 clients. This policy also applies to members                              from any person or company that is doing – or seeks
                                 of your immediate family or a business                                    to do – business with us unless it is for charitable
                                 where you or your family have a material                                  purposes and no employee or Cast Member receives
                                 financial interest.                                                       any benefit. Note that meals, entertainment and
                                                                                                           hospitality may also qualify as a gift.
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   "… Disney’s success is       Giving gifts: What’s our policy? Offering                                  a specific group or department at the Company
   based on the merits          gifts to win or keep business is unethical                                 (including as a prize to be distributed at a party
   of our products and
   services, not gifts we
                                and, in many cases, illegal. Be sure you                                   or event).
   give or receive."            understand the rules and ask questions
                                if you’re ever unsure about whether a                                      • Gifts worth not more than US$75:
                                particular gift is okay. In general, you should                               In general, you may accept a gift as long as the
                                never give a gift that:                                                       total value of all gifts received from such person or
                                                                                                              company does not exceed US$75 in value in any
                                • Is (or could reasonably be perceived to be)                                one calendar year. Keep in mind gifts of cash or
                                   an inducement to do business with our                                      cash equivalents such as checks or gift cards that
                                   Company                                                                    can be converted to cash are never acceptable.
                                • Would be considered excessive under the
                                   circumstances                                                           • Gifts greater than US$75 but less than
                                • Would violate our Company policies or                                      US$500: Gifts within this range are subject to
                                   those of the recipient                                                     our “ordinary course of business” test. Ask
                                • Would be contrary to the interests of our                                  yourself:
                                   Company
                                                                                                             - Would the gift be considered customary given
                                • Is, in fact, different from what you reported
                                                                                                                your job duties, job title and seniority? If the
                                   either to us or to others
                                                                                                                gift was reported in the media, would others
                                                                                                                think favorably of you? Of our Company?
                                In addition, if you are located in the United
                                                                                                             - Would the gift complement or enhance a
                                Kingdom, work for a Disney entity that is
                                                                                                                business relationship? For offers of hospitality
                                subject to U.K. law, or are otherwise subject
                                                                                                                or entertainment, is the person extending the
                                to U.K. law you must obtain approval
                                                                                                                offer going with you?
                                from your immediate manager before
                                giving any gift in connection with any                                     If the answers to these questions are “yes,”
                                business relationship.                                                     based on your good faith assessment, you
                                                                                                           may accept the gift without notifying the
                                Accepting gifts: What’s our policy? From                                   Management Audit department.
                                time to time, you may be offered gifts from
                                a person or a company that does – or seeks                                 In addition to the other requirements of this
                                to do business – with us. Use the following                                policy, if you are located in the United Kingdom,
                                information to guide your decision-making                                  work for a Disney entity that is subject to
                                and ask for help if you are ever unsure of the                             United Kingdom law, or are otherwise subject
                                proper course of action. Note that this policy                             to U.K. law you must obtain approval from your
                                applies whether you are personally offered                                 immediate manager before accepting any gift
                                a gift or if a gift is offered for the benefit of                          whose fair market value exceeds US$75.

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   “One of my vendors           If the gift fails the “ordinary course of                                  Gift Decision Tree
     routinely provides          business” test, you must either: (1) return
     me with tickets to a
                                 the gift letting the giver know that it is
                                                                                                                                              Can I Accept It?
     professional football
     game – is that a            against Company policy to accept it; (2) give
     violation of our gift       the gift to the Company so it may be either                                                                  Is the gift worth more
                                                                                                                                                   than US$75?
    policy?”                    donated to charity or otherwise disposed
     Use the “ordinary           of; or (3) keep it and write a check to the                                           NO
     course of business”
                                 Company for the amount by which the fair
     test. Let’s assume
     the gift is customary       market value of the gift exceeds US$75,                                       You may accept it
     given your position         which will be used by the Company for                                         as long as it’s not
     at the Company. Ask                                                                                         cash or a cash
                                 charitable purposes.                                                          equivalent and the
     yourself: Does the                                                                                                                                               YES
                                                                                                               combined value of
     gift complement or          • Gifts greater than US$500: If you are                                        gifts from the
     enhance my business            offered a gift that you, in good faith,                                     giver is less than                            Does it pass the
     relationship? Certainly,                                                                                     US$75 in one                               "ordinary course of
                                    believe meets the “ordinary course of                                                                                      business" test?
     if the vendor just passes                                                                                   calendar year.
     the tickets on to you          business” standard but exceeds US$500                                                                 YES                                                NO
     and does not attend            in value, you have the option to refuse or
     with you, the event            accept the gift. If you decide to accept it,                                                   Is its value more
     clearly does not offer                                                                                                         than US$500?
                                    you must notify the Management Audit
     an opportunity to build
     upon your working              department within 15 days of receipt. They
     relationship. In that          will review the gift and determine whether                                                    NO             YES
     case, you should either:       it was, in fact, within the “ordinary course
     return the gift to the                                                                                        You may accept it as        Either:                                You may:
                                    of business.” If Management Audit                                            long as it's not cash or a    1. Refuse it                         1. Return it.
     vendor with a polite
                                    determines it was not, you will be required                                      cash equivalent.               or                                2. Give it to Disney for
     letter that references
                                                                                                                                               2. If covered by U. K. law, obtain        donation or other use.
     our policy or accept the       to pay – or make a charitable donation                                         If you are covered               your manager's approval           3. Keep it and pay
     gift but write a check         through the Company equal to – the                                            by UK law you must                and                                   difference > US$75.
     to the Company for                                                                                          obtain your immediate         3. Notify Management Audit within
                                    amount by which the fair market value                                         manager's approval
     the amount by which                                                                                                                            15 days for "ordinary course of
     the fair market value          of the gift exceeds US$75.                                                  before accepting the gift.          business" determination.
     of the tickets exceeds
     US$75 (generally, the       • Meals: Meals are not subject to a dollar-
     fair market value will                                                                                 Note that :
                                    value limit as long as they meet the
     be determined by                                                                                       1) Gifts of cash or cash equivalents may never be accepted, and
     Management Audit               “ordinary course of business” test. Good
                                                                                                            2) Meals in the “ordinary course of business“ are not subject to a
     and the proceeds of            working relationships are important to our
     the check will be used                                                                                     dollar value limit.
                                    business, but use good judgment and be
     by the Company for                                                                                     This is a general framework for decision-making. Keep in mind, we
                                    careful to avoid even the perception of
     charitable purposes).
                                    something improper.                                                     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.
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                                Gifts and Anti-corruption Compliance                                       Know your obligations as they relate              “I found a vendor’s
                                                                                                           to customers and licensees. Treat others            confidential five-year
                                                                                                                                                               plan in one of our
                                In addition to the requirements for accepting                              as you wish to be treated. Understand the           conference rooms.
                                or receiving gifts stated in this document you                             policies and standards that are applicable          What should I do?”
                                must also be mindful of the Company’s Anti-                                to our Company. Don’t misrepresent the             Do not read the
                                corruption Policy which is available on the                                characteristics or capabilities of our products    information or share it
                                Hub. Please note that any gift – including                                 or recommend products or services that don’t       with others. Deliver the
                                                                                                                                                              plan promptly to the
                                meals, entertainment, and hospitality – given                              meet a customer’s needs.
                                                                                                                                                              Legal department for
                                to a “government official” (which term                                                                                        follow-up.
                                is defined in the Anti-corruption Policy)                                  Be careful when collecting information
                                that is worth more than $20 USD, or a                                      about competitors, customers and
                                meal that cost more than $100 USD per                                      vendors. You have a responsibility to comply
                                person, must be approved in advance by the                                 with Company policy in gathering competitive
                                Legal department or the Company’s Chief                                    information in the marketplace. Although the
                                Compliance Officer.                                                        standard for what is acceptable and what isn’t
                                                                                                           may vary from country to country, the Company
                                Vendors, Suppliers and Customers                                           prohibits certain practices that are always
                                                                                                           improper as follows:
                                Be fair and ethical in purchasing decisions.
                                If you purchase products or services for the                               • Theft
                                Company, put the Company’s interests first                                 • Blackmail
                                and seek to obtain the maximum value for                                   • Wiretapping
                                the money spent consistent with Company                                    • Bribery
                                policy. You must also comply with the                                      • Trespassing
                                Company’s competitive bidding policy.                                      • Industrial espionage
                                                                                                           • Receipt of stolen property
                                Treat all vendors fairly, honestly and                                     • Asking or inducing someone to disclose
                                courteously. Avoid unfair buying tactics and                                  information that is confidential regarding
                                favoritism, and never take unfair advantage                                   a current or former employer. (Note that
                                of any vendor through manipulation,                                           collecting information for newsgathering
                                concealment, misrepresentation of material                                    purposes is governed by other policies set
                                facts or any other unfair practice.                                           forth elsewhere.)

                                We are committed to having our suppliers reflect                           In addition, collecting information by
                                the same diversity that we seek in our workforce.                          misrepresenting facts, employee identity or
                                Work to identify minority and women-owned                                  Company affiliation is also prohibited without
                                business enterprises, and evaluate them in                                 the prior approval of the Company’s General
                                accordance with their qualifications.                                      Counsel.
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                                If you find you’re in possession of                                           For more information, see the Inside           “A co-worker asked me
                                information that may have been obtained                                       Information and Securities Trading section       to make her a copy
                                                                                                                                                               of some spreadsheet
                                unethically or illegally, or if you’re ever in                             • Cast Member and employee personnel               software we use in
                                doubt about whether a particular practice                                     information                                      our department. That’s
                                for the collection of information is proper,                               • Non-public sales and earnings figures             okay since we work
                                contact the Legal department or The                                        • Financial projections or strategic plans          for the same company,
                                                                                                                                                               right?”
                                Guideline.                                                                 • Information about contemplated
                                                                                                                                                             No, copying the
                                                                                                              acquisitions, mergers, stock splits or sales
                                                                                                                                                             software could violate
                                Protecting Company Assets                                                     of associated companies or real estate         our license agreement
                                                                                                              transactions                                   as well as copyright
                                Our assets – whether information, physical,                                • Strategic business or marketing plans           laws. Unless you have
   “I have a friend who is                                                                                                                                  appropriate permission
                                financial or technology assets – are essential                             • New creative projects contemplated by
     starting a new business                                                                                                                                 to do so, never copy
                                to operating our Company successfully. As                                     the Company                                    any software – even for
     and has asked me for a
     list of customers who      a Cast Member or employee, you have a                                                                                        business use.
     might be interested        responsibility to use them only for legitimate                             Never disclose any confidential information
     in her services. Is that   Company business and safeguard them                                        to any party except as specifically authorized
     okay?”                     against theft, loss, waste or abuse. Never use                             by management and be careful not to
     No, our customer lists     opportunities you discover through the use                                 discuss confidential information in public
     are private and should
                                of Company assets for your personal gain.                                  areas. Be sensitive to conversations you have
     never be shared with
     anyone outside our                                                                                    via cell phone or on elevators and take care
     Company (or with           Confidential information is protected non-                                 in dialing fax numbers or sending e-mails
     anyone inside our          public information you may be exposed                                      if transmitting confidential information
     Company who does not
                                to as part of your job and can relate to                                   electronically.
     need the information to
     do his or her job).        our Company, guests, customers, vendors
                                or other Cast Members and employees.                                       Our technical and creative works are
                                It represents one of our Company’s most                                    renowned the world over. You have a
                                valuable assets and should never be used for                               responsibility to protect our trade secrets
                                your personal benefit or disclosed to others                               and proprietary information even after you
                                inside or outside of the Company who don’t                                 leave the Company.
                                have the right to it – and the need for it – to
                                carry out their assigned work.                                             Safeguard our physical and electronic
                                                                                                           assets, too. Our Company assets also
                                Examples of confidential information include:                              include the physical space where you work,
                                                                                                           the equipment and supplies you use and the
                                • “Inside” information about our Company                                  computer resources you access. Hardware,
                                   that could reasonably influence someone                                 software, e-mail, voicemail, intranet and
                                   in making decisions to buy or sell stock                                Internet access, computer files and programs
                                   in a company (ours or someone else’s).                                  – including any information you create,
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    “I think my supervisor     send, receive, download or store on Company                                  You are also responsible to provide accurate     “A local reporter
      lists expenses on his     assets – are Company property, and we reserve                                information in connection with our financial       approached me at
      expense report that                                                                                                                                       work and asked me to
      he didn’t incur. Should
                                the right to monitor their use, where permitted                              reporting obligations.                             comment on a rumor
      I say something to        by law to do so.                                                                                                                circulating about our
      someone?”                                                                                              Comply with Company policy when                    Company. It was a
     Yes. Lying on an           Never install unauthorized software, hardware                                it comes to retaining, storing and                 great opportunity to set
     expense report is not                                                                                                                                      the record straight, but
                                or storage devices on your Company-issued                                    disposing of Company records. Our                  I didn’t think I should
     only a violation of
                                computer and don’t access our network                                        records management and retention policy            say anything.”
     our Standards, but is
     plainly wrong. Report      through unauthorized applications or devices.                                ensures that we maintain the records we           Your instincts were
     your concern to your       Use good judgment if authorized to use                                       need to meet our legal, tax and regulatory        right. Unless you
     Human Resources            Company-provided Internet access; take care to                               requirements and securely dispose of records      are an authorized
     representative, the                                                                                                                                       representative, you
                                never violate a law, harass other users, disclose                            that are no longer needed. Take care never
     Management Audit                                                                                                                                          should not speak on
     department or contact      confidential information or interfere with                                   to dispose of information that may be             behalf of the Company.
     The Guideline.             network users, services or equipment.                                        relevant to current or threatened litigation      Direct the reporter
                                                                                                             or subject to a legal hold until you are          to the Corporate
                                                                                                                                                               Communications
                                Accurate Recordkeeping and Financial                                         authorized in writing to do so by the Legal
                                                                                                                                                               department.
                                Reporting and Complaints Regarding                                           department.
                                Accounting and Auditing Matters
                                                                                                             Speaking on Behalf of our Company
                                Accurate and complete recordkeeping is
                                essential to the successful operation of our                                 Our Company conducts business in many
                                Company, as well as to our ability to meet                                   parts of the world and the public expects
                                our legal and regulatory obligations. You                                    the information we provide to be accurate.
                                have a responsibility to be accurate, complete                               It’s critical that information provided to the
                                and honest in what you report and record to                                  public is complete, consistent and accurate
                                meet regulatory requirements, as well as in all                              and also that confidential information is
                                Company documents, including accounting                                      protected. Unless you are an authorized
                                records, time cards, expense reports, invoices,                              Company spokesperson, don’t speak on
                                payroll records, safety records, business records,                           behalf of the Company. Instead, refer the
                                performance evaluations, etc.                                                individual to one of the following:

                                If you see or suspect financial misconduct,                                  • For media inquiries, contact the Corporate
                                notify your supervisor immediately and                                          Communications department.
                                contact the Management Audit department                                      • For questions regarding financial
                                or The Guideline. For more information, refer                                   performance, contact Investor Relations.
                                to the Employee Complaint Procedures for                                     • For legal issues, contact the Legal
                                Accounting and Auditing Matters.                                                department.

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                                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?

                                     Policy for Use of Collaboration
                                     Platforms

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                                                                                                                    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,

                   5
                                                                                                                    engaging in pricing practices that suggest a
                                                                                                                    monopoly, charging different prices to different
                                Play by the Rules: Our                                                             customers for the same product – those and
                                                    Commitment                                                      many similar practices may raise issues under
                                                    to Lawful                                                       antitrust laws. If you ever have a question
                                                    Business                                                        about how antitrust and competition laws
                                                    Practices                                                       apply to a particular business situation, you
We are committed to                                                                                                 should seek help from the Legal department or
                                Competition Laws
comply with the law                                                                                                 contact The Guideline.
      everywhere in
                                We expect Cast Members and employees to compete
      the world that                                                                                                Trade Secrets, Trademarks, Patents and
                                aggressively, but fairly, and to sell our products and
         we operate.                                                                                                Copyrights
                                services on the basis of quality and merit. Antitrust and
                                competition laws are designed to promote a free and
                                                                                                                    You must honor the trade secrets, trademarks,
                                open marketplace. You have a responsibility to comply
                                                                                                                    patents and copyrights of others. This includes
                                with these laws wherever you do business and avoid
                                                                                                                    trade secrets of previous employers. While our
                                conduct that might suggest a violation. Failing to do so
                                                                                                                    Company is entitled to your skills and creative
                                can subject both you and the Company to imprisonment,
                                                                                                                    energy while you work here, we do not want to
                                substantial criminal fines and civil financial liability.
                                                                                                                    learn of secrets you developed or learned about
                                                                                                                    through previous employers.
                                Antitrust laws (sometimes called “competition
                                laws” or “unfair trade laws”) prohibit
                                                                                                                    Copyright infringement issues can be
                                agreements that unreasonably restrict
                                                                                                                    complex. A person who infringes a copyright
                                competition. Don’t enter into any agreement or
                                                                                                                    willfully and for commercial advantage may
                                understanding, whether formal or informal, with a
                                                                                                                    be subject to civil liability as well as criminal
                                competitor, customer or supplier to:
                                                                                                                    prosecution. There are some circumstances,
                                • Set prices or price-related terms, also known as                                 however, where it is proper to reproduce
                                   “fixing” prices                                                                  portions of copyrighted work for purposes of
                                • Refuse to deal with a customer or supplier                                        criticism, comment, news reporting, teaching
                                • Divide territories or customers                                                   and research; this is called “fair use” and
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                                doesn’t violate copyright law. However,                                   • Store, prepare and serve food, drugs and
                                making fair use determinations is difficult                                  other products in a sanitary and healthful
                                and must be done on a case-by-case basis.                                    condition.
                                Don’t take chances: any questions about                                   • Never represent that a product has been
                                what is permissible – and what isn’t – should                                inspected or labeled as fit for use if it
                                be directed to the Legal department to                                       hasn’t been.
                                ensure compliance with the law.                                           • Don’t sell anything that is improperly or
                                                                                                             incompletely labeled.
                                Product Safety                                                            • If a product needs inspection, don’t allow
                                                                                                             it to be purchased or sold in any of our
                                The safety of products bearing Disney                                        facilities without inspection.
                                brands, characters and other intellectual
                                property is of crucial concern to the                                     Anti-corruption, Anti-bribery
                                Company. We require that licensees and
                                manufacturers comply with all applicable                                  We never, under any circumstances, offer
                                legal and regulatory safety requirements                                  bribes or influence decisions through
                                and conduct safety tests by independent,                                  improper means. As a global company, we
                                certified third-party testing laboratories or                             have a duty to comply with the laws in the
                                equivalent procedures.                                                    countries in which we do business as well as
                                                                                                          the U.S. Foreign Corrupt Practices Act (FCPA)
                                If you become aware of a product safety                                   and (if it applies to you) the U.K. Bribery Act.
                                concern regarding any Disney-branded                                      As a Cast Member or employee, you need
                                product immediately contact the Disney                                    to understand and comply with the FCPA
                                Product Integrity group at 818-560-3474.                                  and the U.K. Bribery Act as well as any other
                                                                                                          anti-corruption laws that apply where you
                                Food and Drug Safety                                                      operate. Violations can result in lawsuits,
                                                                                                          substantial fines – even imprisonment for
                                We are recognized around the world,                                       individuals.
                                among other things, as a provider of high-
                                quality food products and merchandise. We                                 The rules for giving gifts to government
                                rely on you to preserve the reputation we’ve                              officials are very strict. Never offer,
                                earned. Comply with all applicable food                                   promise or give (either directly or indirectly)
                                and drug laws and cooperate fully with all                                anything of value to induce or influence a
                                federal and state inspectors who come to                                  government official (including officials of
                                our facilities. Make sure you:                                            international organizations, political parties

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                                  and employees of state-owned or state-                                    We could be responsible for bribes made
                                  controlled enterprises) to gain an improper                               on our behalf by third parties. Our Company
                                  advantage or to do something improper.                                    may be liable if a bribe is paid on our behalf,
                                  Violations can subject you and our Company                                even if we did not authorize it to be paid, so it
                                  to severe penalties and damage our public                                 is critical that we are careful in the selection of
                                  reputation.                                                               agents, i.e., those people or companies who act
                                                                                                            on our behalf. Exercise due diligence to make
                                  Regardless of local practice or the practices                             sure our agents are reputable and that they
                                  of other companies, make sure you avoid                                   agree to conduct business in compliance with
                                  even the appearance of doing something                                    anti-bribery laws and regulations.
                                  improper.
                                                                                                            A full statement of the Company’s Anti-
                                  For more information, see our anti-                                       corruption Policy can be found on the Hub.
   “Anything of value”           corruption policy.                                                        That Policy is called “The Walt Disney Company
     could be:
   • Free or discounted                                                                                    and Affiliates Global Anti-corruption Policy.” It
      goods or services           Giving any gift requires accurate                                         sets forth in detail the policies and procedures
   • The promise of a job         recordkeeping. Any gift permitted under                                   to be followed regarding anti-corruption and
   • A charitable or political
                                  our policy and given by you in connection                                 anti-bribery compliance. If you have any
      contribution
   • Gift certificates or gift   with your job must be transparent and                                     questions about the Policy please contact the
      cards                       recorded accurately in our corporate books                                Legal department or the Guideline.
   • Use of materials,
                                  and records. When completing an expense
      facilities or equipment
   • A loan                       report regarding the gift, you are required to                            Export, Import and Anti-boycott Laws
   • Tickets to a theme park     accurately state the purpose of the expense
      or resort accommodations    and the person to whom you gave it. You                                   We comply with all applicable laws, regulations
                                  must also identify whether it was given to                                and restrictions in the import or export of
                                  a government official – in which case you                                 products, services, information or technology,
                                  should have obtained the approval of the                                  wherever we operate in the world. If you
                                  Legal department in advance.                                              are involved in the movement of goods or
                                                                                                            technology across international borders, make
                                  Before engaging in any transaction which                                  sure you know and comply with:
                                  you think is questionable, you must consult
                                  with the Legal department. If the transaction                             • Any U.S. restrictions on doing business with
                                  is approved, make sure it is accurately                                      certain foreign countries
                                  reported in our Company’s books                                           • All applicable export control requirements
                                  and records.                                                              • The trade laws and regulations associated
                                                                                                               with the countries in which you do business

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                                We also have a responsibility to comply                                   investigation or proceeding. If you                “I just heard about a
                                with U.S. anti-boycott laws. If you receive                               ever receive such a request you should               large contract Disney
                                                                                                                                                               entered into with
                                a request to comply with a foreign boycott                                immediately advise the Legal department              one of our suppliers.
                                (or a request to supply boycott-related                                   and follow its instructions to ensure that the       A friend of mine
                                information), consult with the Legal                                      information or documents we provide fully            owns stock in the
                                                                                                                                                               supplier’s company and
                                department to determine the appropriate                                   comply with our legal obligations.                   mentioned recently that
                                course of action.                                                                                                              he planned to sell it.
                                                                                                          Inside Information and Securities                    I know I can’t tell him
                                Doing Business with and Providing                                         Trading                                              about the news of the
                                                                                                                                                               award, but is it okay to
                                Information to the Government                                                                                                  encourage him to hold
                                                                                                          As a Cast Member or employee, your job               on to his stock?“
                                Doing business with the government is                                     may expose you to material, nonpublic              No, you cannot help
                                highly regulated and typically follows                                    (or “inside”) information about our                  someone make a profit
                                stricter rules than those in the commercial                               Company or companies with which we                   or avoid a loss on
                                                                                                                                                               the basis of material
                                marketplace. If you work with government                                  do business. Material inside information
                                                                                                                                                               non-public inside
                                officials or a government-owned (or                                       is information about a company that is               information you know
                                partially-owned) company, you have a                                      not available to the public but, if it were,         about by virtue of your
                                special duty to know and comply with                                      might influence someone’s investment                 job. Suggesting to your
                                                                                                                                                               friend that he hold onto
                                applicable laws and regulations, adhere to                                decision about that company. Examples                his stock, even if you
                                the highest standards of integrity and avoid                              of material inside information include:              don’t offer a reason,
                                even the appearance of impropriety.                                       information about mergers or acquisitions,           would be a violation of
                                                                                                                                                               our policy and may also
                                                                                                          financial performance, changes in executive          be a violation of U.S.
                                We are committed to full compliance with                                  management, significant transactions or              insider trading laws.
                                the law, wherever we operate. If you are                                  new projects contemplated.
                                responsible for acting on our Company’s
                                behalf in providing financial information,                                You may not trade in Company stock or
                                complying with the tax laws or meeting                                    other securities based on material inside
                                cash-related reporting requirements or any                                information you have about our Company,
                                other legal or regulatory requirements,                                   and you may not trade in the stock of
                                always be accurate and timely. Moreover,                                  companies we work with if your job exposes
                                never destroy, discard, tamper with, conceal                              you to inside information about those
                                or make any false entries on documents you                                companies. Passing along a “tip” is also a
                                provide to government agencies or officials.                              form of insider trading and strictly prohibited.
                                                                                                          Keep in mind, even the appearance of an
                                The same is true for responding to any                                    improper transaction must be avoided.
                                request in connection with a government

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                                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.

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StandardsofofBusiness
  Standards     BusinessConduct
                         Conduct             Contents ¦ Glossary ¦ Resources ¦ Last Page Viewed Q ¦ | Back ¦ Next }                                                               The Walt Disney Company

                                                                                                                      Labor Standards                                "… maintain an
                                                                                                                                                                       awareness of – and
                                                                                                                                                                       a sensitivity to and
                                                                                                                      We comply with employment laws in all            a commitment to
                                                                                                                      markets where we operate. In addition, the       observe – differing
                                                                                                                      Company’s International Labor Standards          legal requirements from
                                                                                                                                                                       country to country."
                                                                                                                      prohibits the following in connection with
                                                                                                                      the manufacturing of Disney-branded

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                                                                                                                      products: 1) child labor; 2) involuntary
                                   Respect: O
                                             ur Commitment to                                                        labor; 3) coercion or harassment; 4)
                                            the Community                                                             unfair discrimination; 5) serious health or
                                                                                                                      workplace violations; 6) interference with
   As a member of the              An International Presence                                                          workers' freedom of association; and 7)
global community, we                                                                                                  the improper use of home workers. These
  have a responsibility            We are dedicated to delivering quality products and                                requirements apply to the Company’s own
          to be a good             services and cooperating with community leaders                                    sourcing activities as well as to licensees,
     corporate citizen.            and members throughout the world to benefit local                                  vendors, buying agents and production
                                   communities. While we are bound by U.S. laws and                                   facilities involved in the manufacture of
                                   regulations and Company policy, we recognize that,                                 Disney-branded products.
                                   as we grow, we are introducing not only a new
                                                                                                                                                                     “I have seen some co-
                                   Company, but often a new corporate culture and,                                    The Environment                                  workers dumping trash
                                   perhaps, different business practices in countries all                                                                              in an area that’s not
                                   across the globe. We count on every Cast Member                                    We are committed to the protection of            authorized for that
                                                                                                                                                                       purpose, but I don’t
                                   and employee to follow the letter and the spirit of                                the environment and the conservation             want to get involved –
                                   those U.S. laws that may apply (for example, the                                   of natural resources. We fully comply            or get them in trouble.”
                                   Foreign Corrupt Practices Act) and maintain an                                     with environmental laws and regulations,        As a Cast Member or
                                   awareness of – and sensitivity to and commitment to                                including those relating to disposal of           employee you have
                                                                                                                                                                        a responsibility to
                                   observe – differing legal requirements from country                                wastes. In addition to complying with all
                                                                                                                                                                        take action when you
                                   to country.                                                                        such applicable laws ourselves, we also           become aware of
                                                                                                                      expect companies and contractors with             potential violations
                                   If a local law conflicts with our Standards, comply                                which we partner to do the same.                  of our Standards; this
                                                                                                                                                                        includes reporting
                                   with the local law. If a local custom conflicts with
                                                                                                                                                                        environmental hazards
                                   our Standards, comply with the Standards. If you’re                                                                                  or any other unsafe
                                   not sure, ask for help.                                                                                                              working conditions.
                                                                                                                                                                        Speak to your
                                                                                                                                                                        supervisor or contact
                                                                                                                                                                        The Guideline.

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Standards of Business Conduct      Contents ¦ Glossary ¦ Resources ¦ Last Page Viewed Q ¦ | Back ¦ Next }   The Walt Disney Company

                                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.

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