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THE WALT DISNEY COMPANY - Code Of Conduct

At The Walt Disney Company,

we are committed to:

- a standard of excellence in every aspect of our business and in every corner of the world;

- ethical and responsible conduct in all of our operations;

- respect for the rights of all individuals; and - respect for the environment We expect these same commitments to be shared by all suppliers of Disney products ("Suppliers").

At a minimum, we require that all Suppliers meet the following standards:

Child labour

Suppliers will not use child labour The term "child" refers to a person younger than 15 (or 14 where local law allows) or, if higher, the local legal minimum age for employment or the age for completing compulsory education. Suppliers employing young persons who do not fall within the definition of "children" will also comply with any laws and regulations applicable to such persons.

Involuntary labour

Suppliers will not use any forced or involuntary labour, whether prison, bonded, indentured or otherwise.

Coercion and harassment

Suppliers will treat each employee with dignity and respect, and will not use corporal punishment, threats of violence or other forms of physical, sexual, psychological or verbal harassment or abuse.

Non-discrimination

Suppliers will not discriminate in hiring and employment practices, including salary, benefits, advancement, discipline, termination or retirement, on the basis of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, political opinion or disability.

Health and Safety

Suppliers will provide employees with a safe and healthy workplace in compliance with all applicable laws and regulations, ensuring at a minimum reasonable access to potable water and sanitary facilities; fire safety; and adequate lighting and venti- lation. Suppliers will also ensure that the same standards of health and safety are applied in any housing that they provide for employees.

Compensation

We expect suppliers to recognise that wages are essential to meeting employees' basic needs. Suppliers will, at a minimum, comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime, maximum hours, piece rates and other elements of compensation, and provide legally mandated benefits. Except in extraordinary business circumstances, suppliers will not require employees to work more than the lesser of (a) 48 hours per week and 12 hours overtime or (b) the limits on regular and overtime hours allowed by local law or, where local law does not limit the hours of work, the regular work week plus 12 hours overtime. In addition, except in extraordinary business circumstances, employees will be entitled to at least one day off in every seven-day period.

Suppliers will compensate employees for overtime hours at such premium rate as is legally required or, if there is no legally prescribed premium rate, at a rate at least equal to the regular hourly compensation rate. Where local industry standards are higher than applicable legal requirements, we expect suppliers to meet the higher standards

Protection of the Environment

Suppliers will comply with all applicable environmental laws and regulations

Other laws

Suppliers will comply with all applicable laws and regulations, including those pertaining to the manufacture, supply, pricing, sale and distribution of Disney products. All references to "applicable laws and regulations" in this Code of Conduct include local and national codes, rules and regulations as well as applicable treaties and voluntary industry standars.

Subcontracting

Suppliers will not use subcontractors for the manufacture of Disney products or components thereof without Disney's express written consent, and only after the subcontractor has entered into a written commitment with Disuey to comply with this Code of Conduct. Monitoring and Compliance Suppliers will authorise Disney and its designated agents (including third parties) to engage in monitoring ctivities to onfirm compliance with this Code of Conduct, including unannounced on-site inspections of manufacturing facilities and employer-provided housing; reviews of books and records relating to employment matters; and private interview with employees. Suppliers will maintain on site documentation that may be needed to demonstrate compliance with tLis Code of Conduct.

Publication

Suppliers will take appropriate steps to ensure that the provisions of this Code of Conduct are communicated to employees, including the prominent posting of a copy of this Code of Conduct, in the local language and in a place readily accessible to employees, at all times.


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