Disney Ils# Program PDF

Licensee and Vendor
Standard Program
Requirements Booklet
January 2010
Page ii
Revised January 2010
TABLE OF CONTENTS
Introduction ............................................................................................... 1-1
Disneys Code of Conduct for Manufacturers ........................................................ 2-1
Licensee & Vendor Responsibilities.................................................................... 3-1
Sourcing Restrictions..................................................................................... 4-1
Facility Authorization .................................................................................... 5-1
On-Going Requirements ................................................................................. 6-1
Monitoring Facilities ..................................................................................... 7-1
Loss of Production Authorization ...................................................................... 8-1
Frequently Asked Questions ............................................................................ 9-1
Appendix ................................................................................................. 10-1
Facility and Merchandise Authorization (FAMA) Application ............................ 10-2
Country and Territory Groupings ............................................................ 10-4
Acceptable Social Compliance Monitors .................................................... 10-6
Code of Conduct Assessment Notification.................................................. 10-9
Corrective Action Plan Letter (CAP Letter) ............................................... 10-10
ICTI CARE Foundation Authorization Form ................................................ 10-11
Sample Social Compliance Audit Checklist ................................................ 10-12
Corrective Action Plan Acknowledgement Report (CAPAR) ............................ 10-16
Facility Termination Letter .................................................................. 10-18

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1 Introduction
Welcome to Disney. As a Disney licensee or vendor you are joining a network of
Disney business associates around the world. This guide is intended to help you
understand our International Labor Standards (ILS) program and requirements.

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Disneys International Labor Standards Program
The Walt Disney Company is committed to the promotion and maintenance of responsible
labor practices in Disneys licensing and direct sourcing operations throughout the world.
The International Labor Standards (ILS) program is part of Disneys Corporate Responsibility
effort and is designed to evaluate and establish criteria for the working conditions affecting
people who make Disney-branded products around the world. Disneys Code of Conduct for
Manufacturers (Code) provides guidelines and principles for the production of Disney-
branded goods (see the section Disneys Code of Conduct for Manufacturers).
As a licensee or vendor, you are responsible for upholding the Disney Code of Conduct
in the facilities you select to make Disney-branded products.
For more information about
Disneys International Labor Standards program,
visit www.DisneyLaborStandards.com and read
Disneys Corporate Responsibility report
at www.disney.com/crreport
About This Guide
This guide provides information on Disneys Code, licensee and vendor responsibilities and
facility approval requirements. It also provides samples of some documents you may send to
or receive from Disney.
The information contained in this guide is applicable to all contractual participants in
Disneys ILS program licensees (including our retailer licensees), vendors, factories and
subcontractors.
Licensees and vendors can use this guide to help establish a facility relationship for the first
time, keep facility records up to date, and as a reference for ongoing program requirements
and documents.
If you have any questions about the information contained in this guide, please contact your
designated Disney ILS representative.

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Terminology
Frequently used terms are defined here. In some cases, several words may be used
interchangeably throughout this document.
Audit: The following terms are used interchangeably to refer to the process by which an on-
site visit is made to a facility to assess compliance with Disneys or an equivalent Code of
Conduct: social compliance assessment, qualified social compliance audit, assessment or
audit.
Disney-branded products: The following terms are used to refer to merchandise and/or
packaged food items bearing brands, characters or other intellectual property owned, co-
owned or licensed by Disney: Disney-branded products, Disney merchandise, Disney-branded
merchandise, Disney goods.
Facility: The term facility is used to refer to the physical location where Disney-branded
products are made, assembled, packaged, labeled or otherwise processed, as well as factory
worker dormitories, cafeterias and other ancillary facilities, but not office buildings. For
the purposes of this document, the terms facility, factory and manufacturer are used
interchangeably. See the section Facility Authorization for additional information.
Licensee: We use the term "licensee" when we refer to a business that obtains the right (a
license) to produce and sell Disney-branded products. This definition includes retailer
licensees (direct-to-retail relationships).
Monitor: The following terms are used interchangeably to refer to the individuals or
organizations that conduct on-site facility audits: auditor, assessor, monitor, audit firm and
social compliance monitoring organization.
Vendor: We use the term "vendor" to refer to a supplier from which we obtain Disney-
branded products directly (for example, the supplier of products we purchase for resale at
our theme parks).

2 Disneys Code of Conduct
for Manufacturers
Established in 1996, the Disney Code of Conduct for Manufacturers sets forth
our requirements for manufacturers of Disney-branded products. The Code is
available in more than 50 languages at www.DisneyLaborStandards.com.
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Disneys Code of Conduct for Manufacturers
Disneys Code sets forth our requirements for manufacturers of Disney-branded merchandise
with respect to labor standards and working conditions in the following areas:
Child Labor
Involuntary Labor
Coercion and Harassment
Nondiscrimination
Association
Health and Safety
Compensation
Protection of the Environment
Other Laws
Subcontracting
Monitoring and Compliance
Publication
The principles embodied in our Code are consistent with core conventions of the
International Labour Organization (ILO), as well as various third party initiatives and
corporate codes of conduct pertaining to supply chain labor standards.
Disney-branded products are sourced and manufactured by organizations and people in many
countries, speaking many different languages. Those involved in licensing and sourcing, or
working in facilities, must be able to access and understand our Code so that they are aware
of their rights and responsibilities in making Disney-branded products. For this reason, our
Code is translated into more than 50 languages and distributed to tens of thousands of
licensees, vendors, facilities and individual workers. Available languages include:
Afraikaans
Albanian
Arabic
Bengali
Bulgarian
Chinese (Simplified)
Chinese (Traditional)
Croatian
Czech
Danish
Dutch
English
Finnish
Flemish
French
German
Greek
Haitian-Creole
Hebrew
Hindi
Hungarian
Indonesian
Italian
Japanese
Kannada
Khmer (Cambodian)
Korean
Latvian
Lithuanian
Malay
Maltese
Marathi
Norwegian
Polish
Portuguese
Romanian
Russian
Serbian
Sinhalese
Siswati
Slovak
Slovene
Spanish
Swahili
Swedish
Tagalog
Tamil
Thai
Turkish
Turkmen
Ukrainian
Urdu
Uzbek
Vietnamese
Zulu
Translations of the Disney Code are available at:
www.DisneyLaborStandards.com
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Code of Conduct for Manufacturers

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 manufacturers of Disney merchandise. At a
minimum, we require that all manufacturers of Disney merchandise meet the following standards:
Child Labor Manufacturers will not use child labor.
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.
Manufacturers 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 Labor Manufacturers will not use any forced or involuntary labor,
whether prison, bonded, indentured or otherwise.
Coercion and Harassment Manufacturers 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.
Nondiscrimination Manufacturers 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.
Association Manufacturers will respect the rights of employees to associate,
organize and bargain collectively in a lawful and peaceful
manner, without penalty or interference.
Health and Safety Manufacturers 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
ventilation. Manufacturers will also ensure that the same
standards of health and safety are applied in any housing that
they provide for employees.
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2-4
Compensation We expect manufacturers to recognize that wages are essential
to meeting employees basic needs. Manufacturers 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, manufacturers 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.
Manufacturers 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 manufacturers to meet the higher
standards.
Protection of the
Environment
Manufacturers will comply with all applicable environmental laws
and regulations.
Other Laws Manufacturers will comply with all applicable laws and
regulations, including those pertaining to the manufacture,
pricing, sale and distribution of merchandise. 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 standards.
Subcontracting Manufacturers will not use subcontractors for the manufacture of
Disney merchandise or components thereof without Disneys
express written consent, and only after the subcontractor has
entered into a written commitment with Disney to comply with
this Code of Conduct.
Monitoring and Compliance Manufacturers will authorize Disney and its designated agents
(including third parties) to engage in monitoring activities to
confirm 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 interviews with employees.
Manufacturers will maintain on site all documentation that may
be needed to demonstrate compliance with this Code of Conduct.
Publication Manufacturers 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.
* * * * *

3 Licensee & Vendor
Responsibilities
Our licensees and vendors play a critical role in ensuring that Disney-branded
products are made under ethical and responsible working conditions. In this section,
you will learn about specific activities required to meet your Disney ILS obligations.
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3-2
Licensee and Vendor Responsibilities
All licensees and vendors are required to comply with Disneys ILS program requirements in
the following manner:
Source only from eligible countries and territories: Do not produce Disney-branded
products in countries restricted for trade by either the U.S. government or by Disney
(see the section Sourcing Location Restrictions).
Select compliant facilities: Select facilities that are capable of complying with the
Disney Code or comparable standards approved by Disney (see the section Disneys
Code of Conduct for Manufacturers).
Communicate Disneys expectations to facilities: Inform potential and current
facilities of Disneys Code, ILS program and monitoring and termination procedures so
that the facility fully understands Disneys expectations. Facilities should follow
expectations provided by Disney regarding the required submission of audits or
expected remediation.
Submit documents in a timely manner: Provide the following documents to Disney
ILS prior to committing any production of Disney-branded products in the facility (see
the section Facility Authorization for details):
o Facility and Merchandise Authorization (FAMA) Application
o Qualified Social Compliance Audit Report that meets Disneys Minimum
Compliance Standard, if required by ILS.
Obtain approval for facility use: Obtain explicit approval from Disney before starting
any Disney-branded production, as evidenced by receipt of a signed Facility and
Merchandise Authorization (FAMA) form from Disney.
Remediate: Work with facilities to encourage improved working conditions, where
needed, including submitting subsequent facility audit reports as required by Disney
to demonstrate improvement and in order to maintain approval to continue Disney
production.
Provide access to facilities: Allow Disney and its authorized social compliance
monitors full access to all facilities to evaluate compliance with ILS program policies
and standards, with or without advance notification to licensees, vendors or facilities.
Remove Disney-branded products if required: Terminate all production of branded
goods at any facility within 30 days following notification from Disney of the facilitys
ineligibility to produce Disney-branded merchandise.

4 Sourcing Restrictions
Licensees and vendors are prohibited from manufacturing in or purchasing from certain
countries or territories subject to Disney and/or U.S. government sanctions. In addition,
certain sourcing locations may be subject to additional requirements.
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Restricted Countries and Territories Policy
Licensees and Vendors may not apply, or permit the application of, any Disney proprietary
material to items produced in restricted countries or territories (e.g., a Disney logo may not
be embroidered on a plain backpack made in a country that has been restricted for
manufacturing by Disney). If any of the merchandise is produced, in whole or in part, in a
restricted country you will be held responsible, and in addition to any and all rights and
remedies available to Disney, you will be required to pay immediately for all costs
associated with the collection, return and destruction of such merchandise as Disney may
direct. If Disney directs you to destroy the merchandise, you must immediately do so in an
environmentally acceptable manner, and provide Disney with a sworn Certificate of
Destruction.
In addition, licensees and vendors must abide by restrictions outlined below.
U.S. Government Restrictions
Licensees and vendors may not source or sell products from or into countries, and may not
export any controlled products to certain countries, subject to U.S. government trade
restriction programs.
The Export Administration Regulations (EAR) are administered by the U.S. Department of
Commerce. For more information, see the following websites:
http://www.access.gpo.gov/bis/ear/ear_data.html
http://www.bis.doc.gov/complianceandenforcement/index.htm
The OFAC Country Sanctions Programs are administered by the U.S. Department of the
Treasury, Office of Foreign Assets Control (OFAC). OFAC information is available at:
http://www.treas.gov/offices/enforcement/ofac/
In addition, the U.S. prohibits doing business with certain sanctioned parties (e.g.
terrorists), wherever they may be located. For more information, see the following
websites:
http://www.treas.gov/offices/enforcement/ofac/sdn/ (administered by the
Treasury Department);
http://www.bis.doc.gov/ComplianceAndEnforcement/ListsToCheck.htm
(administered by the Commerce Department)
Disney applies these trade restrictions to all of its licensees and vendors, regardless of
whether the products are intended for a U.S. or non-U.S. market, and to all products and
components of products whether or not they bear Disney intellectual property.
It is the responsibility of all licensees and vendors to comply with all trade restriction
programs, regardless of where the vendor or licensee is physically located or legally
registered. Trade restrictions can apply to countries, products, industries or persons.
Trade Restrictions are subject to change. The above cited websites maintain the
most up-to-date information on current U.S. Government trade restriction programs.
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4-3
Disney Restrictions
Until further notice, licensees and vendors may not source products from the following
countries and territories due to Disneys heightened level of concern about human rights
issues or civil and political instability.
Afghanistan Libya
I raq Northern Mariana I slands (Saipan)
Laos Syria
This list is subject to change.
Other Sourcing Requirements
The following countries are subject to specific requirements.
Bangladesh
Licensees and vendors cannot place Disney-branded production in new facilities in
Bangladesh. If you are currently producing Disney-branded product in Bangladesh you must
continue to follow the pre-production and subsequent audit requirements. Please contact
your Disney ILS representative for additional details.
Cambodia
Disney supports the International Labour Organizations Better Factories Cambodia program,
which maintains a single assessment process and provides capacity-building opportunities for
apparel facilities in Cambodia. In support of this program and to reduce the duplication of
monitoring in Cambodian apparel facilities, we will accept only social compliance audits
conducted by the Better Factories Cambodia program. See www.betterfactories.org for
additional information and contact your Disney ILS representative for additional details.
Haiti and Jordan
Disney supports the International Labour Organizations Better Work Haiti and Better Work
Jordan programs, which maintain a single assessment process and provide capacity-building
opportunities for apparel facilities in Haiti and Jordan. In support of this program and to
reduce the duplication of monitoring in Haitian and Jordanian apparel facilities, we will
accept only social compliance audits conducted by the Better Work program. See
www.betterwork.org for additional information and contact your Disney ILS
representative for additional details.
As the Better Work program is extended to additional countries, we will consider similar
support for the program in those territories.

5 Facility Authorization
Disney licensees and vendors must disclose all facilities that will produce Disney-branded
products. Facility disclosure is communicated to Disney via the Facility and Merchandise
Authorization (FAMA) Application; and if required by Disney, a qualified social compliance
audit report that demonstrates conformity with Disney's Minimum Compliance Standard.
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Types of Facilities to be Disclosed
Facilities that must be declared to Disney:
Physical locations where Disney-branded products are produced, manufactured,
assembled, printed, embroidered or engraved/etched, including locations of any and
all subcontractors;
Locations of farms, orchards or facilities where Disney-branded agricultural products
are processed, labeled or packaged; and
Locations where Disney-branded paper products such as leaflets, instruction booklets,
and packaging materials are produced, processed or assembled.
At this time, facilities that do not need to be declared to Disney for the purposes of ILS
requirements include:
Trading companies, business agents, buying offices, showrooms and other places of
business operations where products are not being produced or assembled.
Facilities that produce blank products with no Disney-branded images on them.
However, blank products cannot be produced in restricted countries or sourced from
restricted parties, and Disney urges that licensees and vendors purchase blank
products only from facilities who have standards comparable to Disneys Code .
Raw materials, fabric mills or processors of generic commodity items, such as cotton,
metals and paper. However, raw materials should not be produced in restricted
countries or sourced from restricted parties, and Disney urges that licensees and
vendors purchase only raw materials produced and supplied under conditions
comparable to Disneys Code.
o Note: Until further notice, cotton from Uzbekistan may not be used in any
Disney-branded products.
Examples:
Denim shirt with Mickey embroidered patch and Mickey-shaped buttons
You must submit details on the facilities that produce the embroidered patch and Mickey-shaped
buttons, as well as the facilities that attach the embroidered patch and buttons onto the shirt.
You must also submit information on any factories that produce or assemble labels and/or
packaging with Disney proprietary materials.
You do not need to submit the facility where the blank denim shirts are purchased. However,
the blank denim shirts must not be produced in restricted countries.
Disney book
You must submit details on the facility that prints the book, as well as any facilities that provide
packaging for the book.
You do not need to submit information on the design house that produces the art or production
film, nor where the blank paper is produced. However, the art or production film should not be
produced in restricted countries.
Fresh produce
You must submit details of the packaging supplier; i.e., the facility that makes any boxes, labels
or other material with Disney proprietary materials.
5-2

You must submit details of where the fresh produce is being packed; i.e., the farm, processing
facility or other location.
You do not need to submit details of the grower if there is no Disney intellectual property being
used on site.
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Documents Needed for Facility Disclosure
In order to produce Disney-branded merchandise at a selected facility, each licensee and
vendor must first receive authorization to use the facility from the Disney ILS group. To
obtain such authorization, the licensee or vendor must submit the following documentation
to Disney ILS, prior to commencement of production.
1. Facility and Merchandise Authorization (FAMA) Application
Facility information is submitted by the licensee or vendor using the Facility and
Merchandise Authorization (FAMA) Application (see the Facility and Merchandise
Authorization Application in the Appendix for a sample). This document must be completed
and returned to the appropriate Disney ILS representative. The FAMA form identifies the
name and location of the physical facility where you intend to produce Disney-branded
goods. A FAMA form signed by Disney also serves as evidence of your authorization to use
Disney intellectual property in connection with your products and as a Customs release
document.
You must submit one FAMA Application for each facility. Disney requires licensees and
vendors to submit the names and addresses of physical locations of ALL licensee/vendor-
owned facilities, sub-contractors and third party manufacturers of Disney-branded products.
2. Qualified Social Compliance Audit that Meets Minimum Compliance Standard
1
In certain instances and prior to the start of production, a licensee or vendor may be asked
to submit a qualified audit for all facilities in which it intends to place Disney-branded
production. The audit must demonstrate compliance with Disneys Minimum Compliance
Standard. Please contact your local ILS representative for more information.
If you have been asked to submit an audit prior to the start of Disney production, you should
check with your facility as to whether a recent audit has been conducted and whether the
report is available.
Minimum Compliance Standard:
Absence of child labor
Absence of involuntary labor
Absence of coercion and harassment
Absence of discrimination
Absence of serious health and safety workplace conditions
Absence of interference with freedom of association
1
Not all licensees and vendors are required to submit audits, please contact your local ILS representative for
audit requirements.
5-4

Qualified Audit Criteria
A qualified audit must meet all of the following conditions:
Is an audit report documenting the social compliance conditions of a facility (this does
not include GMP - Good Manufacturing Practices, product safety or product quality
audits or non audit certificates);
Is no more than 12 months old from date of audit to time of submission to Disney;
Was performed by qualified social compliance monitors; i.e.,
o Social compliance monitors listed (see the Accepted Social Compliance
Monitors listed in the Appendix),
o other credible audit providers as determined by Disney,
o a known brand with an established social compliance program (e.g., Levi
Strauss, Gap, Marks & Spencer, Nike, Timberland) or
o the licensees or vendors internal auditors, provided that the licensee or
vendor is able to provide proof, upon request, that the auditors are trained and
qualified to conduct social compliance audits.
Covers elements of Disneys Code; i.e., child labor, involuntary labor, coercion and
harassment, nondiscrimination, association, health and safety, compensation,
protection of the environment, compliance with other laws, subcontracting,
monitoring and compliance, and publication;
Was conducted with full access to the facility, required documentation and employee
interviews;
Included confidential worker interviews, management interviews, review of
documents and visual inspection of facility premises, including any dormitories;
Was conducted without any interference in the audit process that may compromise
the integrity of the audit (e.g., coercion or harassment of auditors, bribe attempts);
Identifies the full address and phone number of the facility, including floor and
building designations, street address, district, city and country; and
Is in English and submitted electronically.
A qualified audit may come from two sources:
1. A social compliance audit that the licensee, vendor or facility shares with Disney, or
2. A Disney audit
Licensees and vendors should seek available audits through their facility contacts first,
instead of relying solely on the Disney ILS team to validate existing audits in Disney ILS audit
database.
Examples of other acceptable audit standards:
Business Social Compliance Initiative (BSCI)
Electronic Industry Citizenship Coalition (EICC)
Ethical Trading Initiative (ETI)
Fair Labor Association (FLA)
International Council of Toy Industries (ICTI) CARE Program (see the section
Monitoring Facilities for additional information on ICTI CARE)
5-5

SEDEX Members Ethical Trade Audit (SMETA)
Social Accountability 8000 (SA8000) (see the section Monitoring Facilities for
additional information on SA8000)
Worldwide Responsible Accredited Production (WRAP)
Other audit sources will be considered and accepted at Disneys sole discretion. Licensees
and vendors are encouraged to submit available audits for review.
Notes on Declaring Factories
Manufacturing is restricted in some countries and territories. Disney will not accept FAMA
Applications for facilities located in these countries and territories (see the Sourcing
Restrictions section for details).
Facility addresses in Hong Kong should be double-checked to avoid the submission of
office locations. Production is generally located in mainland China.
Provide complete and accurate facility address and phone/fax numbers. Include full
street name, building number, floor number, phone/fax numbers with area or country
code and full contact names.
Facilities in Asia, particularly in China, tend to have multiple official names or various
translations in English. In order to properly identify the facility, please list all of the
facilitys official names from registrations or legal permits, any name variations or
translations, and any also-known-as or doing business as names. If possible, also
provide the names in the local characters.
It may take from several days to weeks for Disney to review and process the documents
required to authorize a facility. Licensees and vendors are encouraged to submit the
documents in a timely manner so as not to delay the start of production. Authorization
will be evidenced by a FAMA signed by Disney and provided by Disney to the licensee or
vendor.
Failure to declare facilities is a material breach of Licensees or Vendors contract with
Disney and could result in termination of the contract.
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Facility Authorization Process
2
In order to authorize production of Disney-branded goods, licensees and vendors must submit
a FAMA Application. In addition, certain licensees and vendors are required to submit a
qualified audit for each facility. Once the FAMA Applications are received, Disney will
determine if it has an existing record of the facility and the status of each facility.
If the facility is not eligible for Disney production, the licensee or vendor must select a
different facility.
When a licensee or vendor is required to submit an audit and the facility has a qualified
social compliance audit report on file, Disney ILS will send to the licensee or vendor a
signed FAMA authorizing production.
When a licensee or vendor is required to submit an audit and the facility does not have a
qualified social compliance audit report on file with Disney, then the licensee or vendor
will be required to submit the audit to Disney. Once a qualified social compliance audit
report is received, reviewed and accepted by Disney, Disney ILS will send to the licensee
or vendor a signed FAMA authorizing production.
FACTORY STATUS REQUEST
Highly recommend that Licensee / Vendor request audit status
from the factory in advance of submitting documentation
LICENSEE / VENDOR SUBMITS:
1. FAMA Application
2. If requested, a social compliance
assessment report that meets the Minimum
Compliance Standard
ILS REVIEWS AND PROCESSES:
1. FAMA Application
2. Social compliance assessment report if
necessary
2
Not all licensees and vendors are required to submit audits, please contact your local ILS representative for
audit requirements.
Documentation meets Disney ILS requirements
FAMA released to Licensee / Vendor
Production of Disney goods may begin
Documentation does not meet Disney ILS
requirements
Licensee / Vendor will be advised on next steps
Production of Disney goods may not begin
Eligible Not Eligible
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5-8
Checklist for Facility Disclosure
Submit a FAMA Application form for each facility.
Submit a qualified audit (i.e., one that meets the Minimum Compliance Standard) when
requested by Disney or allow Disney to conduct an audit, if required.
Before commencing any Disney-related production, obtain formal authorization to
manufacture (a signed FAMA) from Disney ILS.
Disney does not certify facilities. Possession of a Disney
FAMA, social compliance assessment report, CAPAR, Corrective
Action Plan letter or other document from Disney does not
indicate that a facility is currently eligible for Disney production.
Always check directly with Disney to confirm the status of a
facility.
Disney ILS will not release a signed FAMA authorizing your
production, shipment and sale of branded goods without
submission and approval of a FAMA Application. In addition,
certain licensees and vendors may be asked to submit a qualified
social compliance audit as part of the application process.

6 On-Going Requirements
Once a facility has gained explicit approval from Disney to manufacture Disney-branded
product, licensees and vendors who were asked to submit a qualified social compliance audit
as part of the initial application process will be asked to provide subsequent facility audit
reports, at a time period specified by Disney. These subsequent audits take the form of a
qualified social compliance audit that identifies the facilitys level of compliance with local
labor laws, the Disney Code and the Minimum Compliance Standard. The failure for this
group of licensees and vendors to submit a required social compliance audit report, or
submission of a social compliance audit report revealing that a facility no longer meets the
Minimum Compliance Standard, will result in loss of authorization to produce Disney-branded
products in that facility as well as other possible consequences. Where Disney conducts
audits, licensees and vendors are expected to ensure that factories grant Disney access to
conduct the audit.
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On-Going Requirements of Licensees and Vendors
In addition to the requirements outlined in the section Licensee & Vendor Responsibilities,
licensees and vendors are required to perform the following activities on an on-going basis.
Notify: Inform Disney ILS of any changes in your facility base as soon as they occur,
including facilities you wish to add and facilities you no longer intend to use.
Audit: If required by Disney, submit periodic audits on the schedule prescribed by Disney
ILS or ensure Disney has access to conduct audits. You will receive a monthly report
identifying the next audit due date, which generally follows the monitoring schedule
below
3
. Certain programs, such as the ILO Better Work program, may have different
timeframes.
Remediate: Work with any and all facilities that produce Disney-branded products to
implement corrective action plans, as needed.
Exit: If Disney advises that a facility does not meet its requirements, communicate
expectations or requirements to the facility and ensure that all Disney-branded materials
are removed from the facility within 30 days or sooner if required by law.
Communicate: Communicate regularly with Disney ILS regarding questions, changes or
concerns.
Monitoring Timeframes
For licensees and vendors that are required to submit subsequent social compliance audit,
the monitoring timeframes vary from 6 to 24 months from the previous audit date,
depending on the type and severity of any violations cited in the previous audit and the
country/territory grouping as categorized by Disney ILS. See the chart below or contact your
Disney ILS representative for questions related to a specific next audit due date.
Country/Territory Grouping*
Audit
Violation
Category
Group 1 Group 2 Group 3
High 6 months 6 months 6 months
Medium 6 months 12 months 12 months
Low/Acceptable 12 months 24 months 24 months
3
Note that in some geographic regions only certain licensees and vendors will receive monthly status reports.
6-2

6-3
* See the Appendix 2 for countries and territories that fall into each group. Note: this list is
updated annually based upon changes in legal, political and economic conditions in each
country. Check with your Disney ILS representative for the most current information.
Examples of Violation Priorities:
The following are select examples of violations that fall into the High, Medium and Low
priority categories.
High Priority
Child labor
Verbal abuse
Discrimination in employment practices
Penalties for legal association
Falsified records preventing assessment of wages and working hours
Mandatory overtime
Restricting or limiting employee freedom of movement
Withholding passports or other identity documents
Medium Priority
Workers do not have one day off in a seven-day period
Workers paid below legal wage rate (regular or overtime)
Working hours exceed legal limit or the Disney Code of Conduct
Employees are denied or unable to exercise their rights to social benefits
Required deposits for tools or uniforms
Monetary fines
Employees lack labor contracts where required by law
Lack of written approval from Disney for any subcontractors
Low Priority
First aid kit not fully stocked
Labor contracts are established but employees are not provided copies
Company policies on wage deductions, deposits and/or fines exist on paper but no known
instances in practice

7 Monitoring Facilities
Disney conducts its own audits or requires current qualified social compliance audit
reports from certain licensees and vendors for facilities making Disney branded
products. Those licensees and vendors that are required to submit audits can either
obtain existing audit reports or work with a social compliance monitoring firm to
have an audit conducted.
7-1

Social Compliance Audit Options
4
If you are required to submit an audit to Disney ILS, a social compliance audit report may
already exist or you may need to arrange to have a new audit conducted.
1. Ask the facility if they have had a recent social compliance audit and if you can
supply this audit to Disney.
2. If not, check with Disney to determine if we have a qualified audit on file for the
facility you intend to use.
3. If not, contact one of the monitors noted in the Appendix section Accepted Social
Compliance Monitors to arrange for a new audit. Licensees and Vendors are
responsible for arranging the timeframe and payment structure for the audit. See the
remainder of this section for more information about working with social compliance
monitors.
While an audit conducted to Disney standards is preferred, we will also accept audits
conducted to other code of conduct and monitoring programs. See the Facility Authorization
section for examples of other acceptable audit types.
Other audit sources will be considered and accepted at Disneys sole discretion. Licensees
and vendors are encouraged to submit any available social compliance audits for review.
Disney-Directed Audits
Disney may elect to have its own social compliance audits performed at any facilities making
Disney-branded products. These audits may be conducted by Disney staff or one of the
listed Accepted Social Compliance Monitors on our behalf.
Disney audits may be scheduled in advance or unannounced. Licensees and vendors will
generally receive a Code of Conduct Assessment Notification (see the Appendix section Code
of Conduct Assessment Notification for a sample). When audits are scheduled in advance,
there will also be additional communication to set a specific date for the audit. For
unannounced audits, a Code of Conduct Assessment Notification will be sent without
indicating a specific date for the audit. We perform unannounced audits because our
experience shows that we may obtain a more accurate assessment of the working conditions
when audits are conducted in this manner. We will typically also conduct an unannounced
audit if there are discrepancies in the information we receive about facility conditions or if
allegations are raised by a third party.
In cases where Disney audits are conducted either by Disney staff or by one of our
Accepted Social Compliance Monitors we will issue a Corrective Action Plan Letter (CAP
Letter). Licensees and vendors are expected to review this letter with the facility and
implement a corrective action plan.
4
Only applicable to those licensees and vendors that are required by Disney to submit social compliance
audits.
7-2

Toy Facilities in China and ICTI CARE
Disney has a Memorandum of Understanding (MOU) with the International Council of Toy
Industries (ICTI) CARE Foundation, which operates the international toy industry's ethical
manufacturing process, aimed at ensuring safe and humane workplace environments for toy
facility workers worldwide. This MOU:
Recognizes the ICTI CARE Process as a program through which participating
facilities can satisfy Disneys requirements for labor standards and worker rights.
Makes available to Disney the ICTI CARE Process audit database specifically for
those facilities that have granted such access to Disney.
If your toy facility in China is participating in the ICTI CARE Process, please have the facility
authorize Disneys access to its audit reports. This may improve the speed with which
your facility is authorized by Disney. Contact ICTI CARE to obtain the appropriate
registration and authorizations forms; a sample ICTI CARE Foundation Authorization Form is
located in the Appendix.
If your toy facility in China is not currently participating in the ICTI CARE Process, we
strongly encourage them to apply and participate. The ICTI CARE Process sets a single social
compliance monitoring standard for toy facilities that Disney as well as many other toy
brands and retailers recognize. Participation in the ICTI CARE Process will reduce the
duplication of monitoring, save costs and may improve the speed with which a facility may
be authorized by Disney. See http://www.icti-care.org/applicationpackage.html for the
application package.
For more information about ICTI CARE, see http://www.icti-care.org/.
Disney will not accept facility certifications or seals of
compliance in lieu of the audits themselves.
Note that Disney may periodically conduct unannounced audits of facilities, regardless of
any audits submitted by licensees and vendors (whether or not it is required by Disney) or
support for any industry or multi-stakeholder program.
It is at Disneys sole discretion as to whether a third party audit will be
considered for evaluation purposes. Acceptance of a third party audit
does not confer approval of the facility.
Social Accountability International and SA8000
Disney is also a member of Social Accountability International (SAI), an international non-
profit human rights organization dedicated to the ethical treatment of workers around the
world. SAIs social standard - SA8000 may also be used to conduct qualified audits for
submission to Disney. SA8000 audits are performed by some of the organizations listed in
the Accepted Social Compliance Monitors section of the Appendix. For more information
about SAI, see http://www.sa-intl.org/.
7-3

Working With Social Compliance Monitoring Organizations
Whether you are required to submit social compliance audits to Disney or would like to hire
and work with social compliance monitoring organizations for the purpose of improving the
compliance level at the factory, some monitoring organizations can provide remediation
support as well as conduct facility audits based on the Disney Code of Conduct. However,
monitoring organizations are not responsible for dictating or interpreting Disney policy,
advising whether the facility is compliant with Disney standards, or providing guidance on
follow-up action.
Before hiring an external monitor, ensure that the facility management understands the
requirements of the Disney Code and the audit process, and that they will permit the
auditors access to the facility premises, employees and relevant documents. Some sample
questions that may be asked or reviewed during a social compliance audit are in the Sample
Social Compliance Audit Checklist in the Appendix.
Disney recommends the following steps.
1. Contact one of the Accepted Social Compliance Monitors.
2. Ensure that the monitor can conduct the social compliance audits according to your
timeframe. Audits may take several months to arrange depending on the location of
the facility and the monitoring organizations existing capacity.
3. Review results and communicate a corrective action plan with the facility
immediately. DO NOT send confidential information to the facility (e.g., facility
workers names) that could result in retribution or negative impact to workers or
violation of data privacy laws. Work with the facility to implement the corrective
action plan and ensure that any follow-up audits are scheduled with the monitor.
4. Send a copy of the audit results to Disney within five days of receipt. The monitor
will not send results directly to Disney unless specifically authorized by the licensee
or vendor. Note: the monitor may leave a Corrective Action Plan Acknowledgement
Report (CAPAR) with the facility. This is a preliminary assessment of the findings at
the facility (see the Appendix for a sample). You may request this from the facility
but understand it is not the final, formal assessment of conditions as information may
need to be validated or reviewed before final conclusions are made.
5. Communicate the remediation process and any follow-up results to Disney.

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7-5
Disneys ILS Ethics Policy
All employees of The Walt Disney Company and its affiliated companies (collectively,
Disney) are required to comply with certain ethical and legal standards set forth in
Disneys Standards of Business Conduct. Disneys ILS Group follows these standards in its
daily operations worldwide.
In addition, Disneys ILS Group requires that social compliance monitors and other
representatives acting on Disneys behalf (collectively, Disney representatives) adhere to
the same standards. Among other things, these standards strictly prohibit the solicitation,
offer or acceptance of anything of value from any person or company that may impair or be
presumed to impair the exercise by any Disney representative of independent judgment and
unbiased assessment.
Furthermore, no individual or company may offer anything of value - including, but not
limited to, any cash, gratuity, benefit, discount, special privilege, loan, lodging or other
favor, or any meals and travel other than as reasonably necessary and incidental to a Disney
representatives work - intended, or which may reasonably appear intended, to influence
any Disney representative. Any individual or company doing so is subject to having its
contract to manufacture Disney products terminated immediately.
If you have any concerns or questions regarding the behavior of any Disney representative or
to report a violation of the ethics policy, please immediately contact the Disney Hotline in
your region at the number listed below:
Argentina 0800-666-1676 Italy 800-78-7634
Australia
A2 1-800-20-8921
AU 1-800-14-0796
Japan 00531-11-5136
Brazil 0800-891-4137 Korea
00798-1-1-005-8393
00308-11-0492 (DACOM)
00368-11-0099 (ONSE)
Canada 1-800-699-4870 Mexico 001-800-620-1428
Chile 1230-020-2093 Russia
Must dial from a landline
363-2400 (AT&T access number);
After tone, dial 888-475-43-56
China (North) 10-800-711-0583 Spain 900-97-1014
China (South) 10-800-110-0561 United Kingdom 0808-234-6062
France 0800-90-6152 United States 1-800-699-4870
India
Call collect to
704-973-0301
The hotline may be called any time, day or night, as it is available 24 hours a day, 365 days
a year. Disney strictly prohibits any form of retaliation against anyone who reports any
suspected wrongful conduct to Disney. Reports are also accepted anonymously. Disney will
use reasonable efforts to maintain the confidentiality of any report, although it must retain
the right to make disclosures that it deems required by law or otherwise necessary for the
protection of the Disney ILS program or other Disney rights and interests.

8 Loss of Production
Authorization
Disney is committed to working cooperatively with licensees, vendors and facilities to
strengthen their labor practices. However, on occasion, we remove authorization for
production of Disney-branded products at certain facilities. There are specific
reasons that a facilitys authorization to produce Disney-branded products might be
terminated, and also ways to prevent loss of production authorization at your facility.
8-1

Loss of Production Authorization
Loss of production authorization means that a facility has not complied with our Code or
other Disney ILS program expectations in a specified timeframe. Reasons may include (but
are not limited to) the following:
A qualified social compliance audit conducted by Disney, or submitted by licensees and
vendors within the required timeframe fails to demonstrate that the facility meets the
Minimum Compliance Standard.
Two consecutive qualified audits conducted by Disney, or submitted by licensees and
vendors within the required timeframe, demonstrate that the facility meets the Minimum
Compliance Standard but has High priority violations.
Three non-consecutive qualified audits submitted by licensees and vendors within the
required timeframe in a 24-month period demonstrate that the facility meets the
Minimum Compliance Standard but has High priority violations.
Any attempt was made to offer anything of value intended to influence an auditor or
other Disney representative.
Two audit attempts are made in which the auditor was denied full or partial access to
the facility, its employees for private interviews and/or its records.
Note: If a licensee or vendor is required to submit audits to Disney, it could also lose its
authorization to use a specific facility if it fails to submit subsequent audit reports on the
prescribed schedule.
Process of Authorization Removal
If a facilitys production authorization has been removed, the licensee or vendor:
will be sent a Facility Termination Letter (see Appendix for a sample);
must cease Disneyrelated production and remove any and all Disney-branded products
whether complete or in process within 30 days or as may be required by law.
The Facility Termination Letter is sent to all vendors or licensees that at one time or
another have worked with the facility and serves as notification of the facilitys status.
Ways to Minimize Facility Loss of Authorization
1. Adhere to your On-Going Requirements. These responsibilities include, but are not
limited to, notifying Disney when facilities are added or discontinued for production
and notifying Disney when steps have been undertaken with facilities to achieve and
sustain compliance with Disneys Code.
2. Inform the facility that if a facility manager or owner is not available at the time of
the audit, an authorized facility representative must be available to assist and
provide access to the facility, its employees and its payroll records.
8-2

8-3
3. Conduct a pre-production audit of any new facility, if required by Disney. Licensees
may use Disneys list of Accepted Social Compliance Monitors to screen facilities prior
to proposing them for production of Disney-branded goods.
Facility Reinstatement Process
If a facilitys authorization to produce Disney-branded products has been terminated, there
may be an opportunity to have it reinstated. The facility reinstatement process varies
depending on the severity of non-compliances revealed during the last audit.
A waiting period of 12 months is required before a facility can be considered for
reinstatement.
A business case for reinstatement must be submitted by the licensee or vendor, and
approved by the Vice President of the applicable Disney business unit and by the Disney
ILS group.
The reinstatement request must be accompanied by a qualified audit confirming that the
facility in question meets the Minimum Compliance Standard and has no High priority
violations.
If you have a facility you would like to have reinstated for production, please contact your
Disney ILS representative for further details.

9 Frequently Asked
Questions
9-1

9-2
Frequently Asked Questions
1. What are the ILS requirements to produce Disney goods?
Submit a Facility and Merchandise Authorization (FAMA) Application for each
facility location (all sections of the FAMA must be complete).
If asked by Disney, submit a full social compliance audit that meets the Minimum
Compliance Standard for each facility location or allow Disney to conduct an audit,
if required.
Receive a signed FAMA from Disney ILS.
2. What are the ILS requirements to continue producing Disney goods?
Update FAMA forms as needed and monitor progress if asked by Disney.
If asked by Disney, submit subsequent audit reports as required to continue
producing Disney goods.
3. Can a terminated facility be reinstated?
A facility may be eligible for reinstatement after 12 months. The licensee or
vendor must submit a reinstatement request with business case justification along
with a qualified audit report that meets the Minimum Compliance Standard and
does not have any High priority violations.
4. What if a licensee or vendor fails to declare a facility?
The potential consequences could be as significant as termination of contract.
5. What are the consequences for a facility failing to meet ILS requirements?
A facility that does not meet the Minimum Compliance Standard will be ineligible
to produce Disney goods.
6. If I am asked by Disney to submit an audit, what would constitute an "audit" and
where can it be obtained?
An audit is a full social compliance assessment of the facility that outlines the
labor standards conditions in the facility. If required by Disney to submit an audit,
the licensee or vendor may request a copy of any recent audit (not more than
twelve months old) from the facility or contract with a third party monitoring firm
to conduct an audit of the facility (see Accepted Social Compliance Monitors in
the Appendix).
7. Who do I contact in my region to answer ILS questions?
Please contact your local Disney ILS representative for additional information
about Disney ILS program requirements. If you do not know who your Disney ILS
representative is, your primary Disney business contact will be able to direct you.
8. Has the Disney Code of Conduct changed?
The Disney Code of Conduct has not changed. Disney is committed to the
promotion and maintenance of responsible labor practices in its licensing and
direct sourcing operations throughout the world.

10 Appendix
The following documents are examples of materials you may need to submit to Disney
International Labor Standards or otherwise use to meet Disneys ILS program
requirements. These documents are only samples and should not be submitted in this
format.
Appendix 1: Facility and Merchandise Authorization Application*
Appendix 2: Country and Territory Groupings
Appendix 3: Acceptable Social Compliance Monitors
Appendix 4: Code of Conduct Assessment Notification
Appendix 5: Corrective Action Plan Letter
Appendix 6: ICTI CARE Foundation Authorization Form
Appendix 7: Sample Social Compliance Audit Checklist
Appendix 8: Corrective Action Plan Acknowledgement Report
Appendix 9: Facility Termination Letter
* Documents that licensees and vendors submit to Disney ILS
10-1

Appendix 1
Facility and Merchandise Authorization (FAMA) Application
FACILITY AND MERCHANDISE AUTHORIZATION APPLICATION
Attached is the Facility and Merchandise Authorization (FAMA) application that must be
completed for each Facility.
Please make as many copies of the attached FAMA Application as necessary so that you can
complete a FAMA Application for each Facility
Once the FAMA Application is completed for each Facility, please send to the appropriate ILS
Regional Analyst.
The Walt Disney Company
Address:
Contact Name
Phone:
Fax:
E-mail:
Disney will verify the information and determine whether each Facility will be allowed to
produce Licensed Products.
For those Facilities that are allowed to produce Licensed Products, you must provide a copy
of the Code of Conduct for Manufacturers (and any relevant translation) for the Facilitys
acceptance and covenant to comply.
You may begin production of Licensed Products as authorized under your applicable
agreement with Disney, once you receive the signed FAMA from Disney.
You also may present the signed FAMA to Customs officials to facilitate the importation of
goods if the Facility is outside the territory where the Licensed Products are to be sold.
Emergency Customs letters will no longer be issued.
Definition of Facility: any of Licensees own or third-party manufacturers, vendors, factories,
suppliers, and other facilities (as well as any sub-manufacturers, factories, suppliers and other
facilities) that design, produce, process, finish, assemble, or package Licensed Products, components of
Licensed Products, PA materials, labels, hang-tags, or any other item related to the Licensed Products,
or that assemble a final product including one or more Licensed Products.
Do NOT list facilities that only produce generic items such as cardboard boxes, plastic wrap, or plain
buttons UNLESS these components contain any Disney proprietary material. Unless they are involved in
the actual production or manufacture of Licensed Products, do NOT list agents, business offices or
showrooms as a Facility. The Shipper and/or Importer of Record is strictly the party who transports the
goods; if the name is different from that of the Licensee/Vendor or Facility, please so indicate on the
FAMA Application.
Incomplete or illegible forms will be returned to you for resubmission. Please make copies of these forms and
use the copies to submit your information. Maintain the original in your files for future use.
10-2

10-3
FACILITY AND MERCHANDISE AUTHORIZATION APPLICATION
(Please Type or Print Legibly in Ink)
LICENSEE/VENDOR NAME: ________________________________________
STREET ADDRESS:
___________________________________
_____________________________________________
____
_________________________________________________
_________________________________________________
10.1.1 TELEPHONE NUMBER:
___________________________
___
FAX NUMBER: ______________________________________
CONTACT NAME, TITLE AND, IF AVAILABLE, E-MAIL ADDRESS:
_________________________________________
____________________________________________________
1. Facility Name (Place Where Merchandise is Produced):
______________________________________________________________
_____
1a. Facility Address:
______________________________________________________________
_____
______________________________________________________________
_____
______________________________________________________________
_____
______________________________________________________________
_____
______________________________________________________________
_____
1b. Telephone Number: ______________________________________________
1c. Fax Number:
____________________________________________________
1d. Contact Name and Title:
______________________________________________________________
_____
1e. List All Other Names by Which the Facility
is Known:
_______________________________________________________
_
_______________________________________________________
_
1f. Is this Manufacturing Facility Owned by the Licensee or Vendor?
______________Yes ______________No
1g. List All Authorized Merchandise Produced in this Facility (as
listed on the License Agreement) : Attach a separate sheet if
necessary
2. Disney Property, Brand or Logo (List All Produced in this Facility): 4. Shipper Importer of Record (check one). Provide Name and
Address: Only List if the Transporter of the Merchandise is other than Facility
or Licensee/Vendor.
3. Territory Where Merchandise May Be Sold:

Appendix 2
10.2 Country and Territory Groupings
These countries and groupings are subject to change.
Group 1 Countries/Territories
Albania
Algeria
Angola
Argentina
Armenia
Azerbaijan
Bahrain
Bangladesh
Belarus
Benin
Bhutan
Bolivia
Bosnia-Herzegovina
Brazil
Burkina Faso
Burundi
Cambodia
Cameroon
Central African Republic
Chad
China
Colombia
Comoros
Congo (Brazzaville;
Republic of Congo)
Congo (Kinshasa;
Democratic Republic
of Congo)
Cote d'Ivorie
Djibouti
Dominican Republic
Ecuador
Egypt
El Salvador
Equatorial Guinea
Eritrea
Ethiopia
Fiji
Gabon
Gambia, The
Georgia
Ghana
Guatemala
Guinea
Guinea-Bissau
Guyana
Haiti
Honduras
India
Indonesia
Jamaica
Jordan
Kazakhstan
Kenya
Kosovo
Kuwait
Kyrgyzstan
Lebanon
Lesotho
Liberia
Macedonia
Madagascar
Malawi
Maldives
Mali
Mauritania
Mexico
Moldova
Mongolia
Montenegro
Morocco
Mozambique
Namibia
Nepal
New Caledonia
Nicaragua
Niger
Nigeria
Oman
Pakistan
Palestinian Territories
Panama
Papua New Guinea
Paraguay
Philippines
Qatar
Russia
Rwanda
Sao Tome & Principe
Saudi Arabia
Senegal
Serbia
Sierra Leone
Solomon Islands
Somalia
South Africa
Sri Lanka
Swaziland
Taiwan
Tajikistan
Tanzania
Thailand
Timor-Leste
Togo
Tonga
Trinidad & Tobago
Tunisia
Turkey
Turkmenistan
Uganda
United Arab
Emirates
Uzbekistan
Vanuatu
Venezuela
Vietnam
West Bank Gaza
Yemen
Zambia
Zimbabwe
10-4

10-5
American Samoa
Antigua & Barbuda
Belize
Botswana
Brunei
Bulgaria
Cape Verde
Chile
Cook Islands
Costa Rica
Croatia
Czech Republic
Dominica
Estonia
French Guiana
Greece
Guam
Hong Kong
Hungary
Israel
Kiribati
Latvia
Lithuania
Macau
Martinique
Mauritius
Malaysia
Marshall Islands
Nauru
Netherlands Antilles
Palau
Peru
Poland
Puerto Rico
Reunion
Romania
Samoa
Seychelles
Singapore
Slovakia
South Korea
St. Vincent & Grenadines
Suriname
Ukraine
USA
Uruguay
Virgin Islands US
Andorra
Anguilla
Aruba
Australia
Austria
Bahamas
Barbados
Belgium
Bermuda
Canada
Cayman Islands
Cyprus
Denmark
Finland
France
Germany
Grenada
Iceland
Ireland
Italy
Japan
Liechtenstein
Luxembourg
Malta
Micronesia
Monaco
Netherlands
New Zealand
Niue
Norway
Portugal
San Marino
Slovenia
Spain
St. Kitts & Nevis
St. Lucia
Sweden
Switzerland
Tuvalu
United Kingdom
Vatican City
Virgin Islands UK

Appendix 3
10.3 Acceptable Social Compliance Monitors
The following organizations have been approved to conduct audits on behalf of Disney and
with respect to the requirements outlined in the Disney Code of Conduct. Licensees and
vendors may contract with these organizations to conduct audits on their behalf to fulfill
Disneys ILS monitoring requirements.
This list of Acceptable Social Compliance Monitors is subject to change.
BUREAU VERI TAS CONSUMER PRODUCTS SERVICES (BVCPS)
NORTH AMERICA AND EUROPE
Contact Person: Jason Hill
Telephone: 503 764 9190
E-mail: jason.hill@us.bureauveritas.com
Contact Person: Maria Basilio
Telephone: 909 628 4368
E-mail: maria.basilio@us.bureauveritas.com
ASIA
Contact Person: Zoye Chen
Telephone: 8621 2416 6957
Fax: 8621 6489 3423
E-mail: zoye.chen@cn.bureauveritas.com
I NSI TE COMPLIANCE SERVICES
USA / INTERNATIONAL
Contact Person: Tanvi Patel
Telephone: 415 226 1772
Fax: 415 986 7599
E-mail: tanvi.patel@mts-insite.com
I NTERTEK TESTI NG SERVI CES
NORTH AMERICA
Contact Person: Toni Bellacosa (US)
Telephone: 212 803 5315
Fax: 212 453 5010
E-mail: toni.bellacosa@intertek.com
10-6

ASIA
Contact Person: K.Y. Cheung (China)
Telephone: 86 755 2602 0868
Fax: 86 755 2602 0899
E-mail: kamyuen.cheung@intertek.com
EUROPE
Contact Person: Nurten Gunaydin (Turkey)
Telephone: 90 212 473 1340
Fax: 90 212 693 4987
E-mail: nurten.gunaydin@intertek.com
LATIN AMERICA
Contact Person: Viviana Rodriguez (Colombia)
Telephone: 57 1 610 8458 Ext 104
Fax: 57 1 610 8458 Ext 114
E-mail: viviana.rodriguez@intertek.com
LEVEL WORKS LTD.
GLOBAL CONTACT & LATIN AMERICA
Contact Person: Jose Corado (USA)
Telephone: 1.415.440.4141
Fax: 1.415.440.4777
E-mail: jcorado@level-works.com
INDIA, BANGLADESH, SRI LANKA, PAKISTAN
Contact Person: B. Ganesh (India)
Telephone: 91 44 23723511 / 91 44 24812498
Fax: 91 44 23728383
E-mail: ganeshb@level-works.com
CHINA, HONG KONG, MACAU
Contact Person: Raymond Huang (China)
Telephone: 86 755 8214 4529
Fax: 86 755 8214 4530
E-mail: rhuang@level-works.com
EUROPE, MIDDLE EAST, AFRICA
Contact Person: Bahadir Yuce (Turkey)
Telephone: 90 532 445 8298
Fax: 90 212 341 1111
E-mail: byuce@level-works.com
10-7

10-8
SOCIAL COMPLIANCE SERVICES ASIA
(China, Taiwan, Hong Kong and Macau audits only)
ASIA / INTERNATIONAL
Contact Person: Samuel Wong
Telephone: 852 2376 0328
Fax: 852 2376 2263
E-mail: samuel.wong@scsagroup.com
SOCI T GNERAL DE SURVEI LLANCE (SGS)
ALL REGIONS
Contact Person: Margarita Chiriboga
Telephone: 973 461 7928
Fax: 973 575 1193
E-mail: margarita.chiriboga@sgs.com
SPECIALIZED TECHNOLOGY RESOURCES (STR) (formerly CSCC)
Responsible Sourcing Division
USA / INTERNATIONAL
Contact Person: Jan Salvaryn
Telephone: 310 215 0554 ex.528
Fax: 310 417 9083
E-mail: Jan.Salvaryn@STRRS.com
VERI TE*
USA / INTERNATIONAL
Contact Person: Robin Jaffin
Telephone: 413 253 9227
Fax: 413 256 8960
E-mail: rjaffin@verite.org
* Note: Provides in-depth assessments, consultation, and training services.

Appendix 4:
10.4 Code of Conduct Assessment Notification
* For Disney-directed audits only
International Labor Standards Group
Code of Conduct Assessment Notification
500 South Buena Vista Street
Burbank, California 91521-8400 USA
From:
Licensee/Vendor ILS #:
Licensee/Vendor:
To:
Email:
Tel:
CORPILS-FANReply@disney.com
Fax Number: Country:
Notice of assessment of manufacturing facility producing Disney articles
Disney Worldwide Services, Inc. has selected the following facility for a Code of Conduct compliance assessment by our
authorized monitoring organization, in approximately 90 days.
Facility to be assessed:
Location:
ILS Number:
Our records indicate that this is a facility currently engaged in the manufacture of Disney-branded products pursuant to your
license agreement with Disney.
As you are aware, your license agreement with Disney requires that our auditors be provided entrance into the facility at the
time of assessment. A denial of access to the facility would result in a breach of your license agreement and could result in the
termination of the facilitys authorization to manufacture Disney-branded products.
Please notify your facility immediately of this pending assessment
Please contact us promptly, and in any event within 15 days, at CORPILS-FANReply@disney.com and reference the ILS
number if:
_1. The manufacturing facility information is incorrect. If this is the case, please provide the correct facility information.
_2. The manufacturing facility has relocated. If this is the case, please provide the new address and contact details.
_3. You are no longer using the manufacturing facility. In this case, please provide the name, address, phone, contact
of the manufacturing facility you are using.
Thank you.
Disney Worldwide Services, Inc., an indirect subsidiary of The Walt Disney Company, provides services in support of the International Labor Standards program
of The Walt Disney Company family of companies
Disney Worldwide Services, Inc., an indirect subsidiary of The Walt Disney Company, provides services in support of the International Labor Standards program
of The Walt Disney Company family of companies
10-9

Appendix 5
10.5 Corrective Action Plan Letter (CAP Letter)
* For Disney-directed audits only
Date
XYZ Licensee/Vendor
[address]
Dear __________:
In accordance with the License Agreement and/or Memorandum of Understanding ABC Facility,
(K123-4567-8), located in City, State/Province, Country was audited for the second time on Date. This Corrective
Action Plan (CAP) letter summarizes the violations of the Disney Code of Conduct and identifies the corrective
actions necessary to ensure compliance.
1. Monitoring and Compliance
The Disney Code of Conduct requires manufacturers to maintain all documentation on site that may
be necessary to demonstrate compliance with the Disney Code of Conduct. Auditors are required to review
at least 12 months of records to confirm compliance with the Disney Code of Conduct. We have noted that
compliance with overtime wage requirements could not be verified because overtime payroll records were
not available to review during the audit. Please ensure that the necessary record-keeping improvements
are made and ensure that complete payroll records are available for review during the follow-up audit.
2. Health and Safety
The Disney Code of Conduct requires manufacturers to provide employees with a safe and healthy
workplace in compliance with all applicable laws and regulations. We have noted the following violations of
the Country Law and the Disney Code of Conduct that require immediate attention:
a. Emergency evacuation drills are not conducted regularly;
b. Three fire extinguishers are empty; and
c. Emergency evacuation routes are not marked clearly.
Please ensure that the necessary improvements are made in order to provide a safe and healthy
workplace for all employees.
The above issues were discussed with factory management. As the licensee/vendor, it is your responsibility to
ensure that each of these violations is rectified. Please address these violations with factory management. Given
the nature of the audit findings we will perform a follow-up audit within 180 days.
Should further clarification be required or if you are no longer using this factory, please contact .
Thank you for your time and attention to this matter.
Sincerely,

10-10

Appendix 6
10.6 ICTI CARE Foundation Authorization Form

ICTI CARE Foundation Asia Limited
WWW.ICTI-CARE.ORG
Authorization Form
Date|#.
To]: ICTI CARE Foundation Asia Limited
Dear Sir/MadamT,
1. We hereby confirm that we consent to grant Disney access to our audit reports and other
proper information at the ICTI CARE Process database system.
]][]]F),
|)417#W)T7O[|7)T$#|(,
2. We fully understand that we shall have to inform (written) ICTI CARE Process in the event
of any changes in Disneys access to the Factorys database.
]]mE]]+/%ICTI CARE Process(UQTu)||T$|)#(u#,
For and on behalf of [English Factory Name ]
[Seal Number Q@@]
(Signature & Factory Chop)

Director #
Name+:
10-11

Appendix 7
10.7 Sample Social Compliance Audit Checklist
In preparation for the site visit, facility management should assemble and make available to
monitors the following documents.
APPLICABLE LAWS AND REGULATIONS:
Child labor
Restrictions on workers below the age of unrestricted employment
Minimum wage
Maximum daily / weekly hours
Overtime
Annual leave and required holidays
Other benefits and allowances
Health and safety
Environment
FACI LI TY POLICI ES:
Employee handbook / terms and conditions of employment
Wage and hour policies
Collective bargaining agreement(s)
Government licenses and waivers, certificates of operation, inspection reports re:
sanitation, fire safety, worker safety, structural safety, environmental
compliance, etc.
Machinery inspection / service logs
Policies / procedures on use of personal protective equipment
Accident / injury log
Emergency medical procedures
Evacuation plan
Timecard or other work hour support
Payroll records in this facility or other for the last 12 months (i.e. piece rate
records, pay stubs, etc.)
Support for overtime calculations
WORKER DOCUMENTATION:
Personnel file (including job application, employment contracts, discipline letters,
etc.)
Personal identification cards, birth certificate, or other age identification records
10-12

DORMITORIES:
Government Licenses, Certificates of Operation, Inspection Reports re: sanitation,
fire safety, structural safety, etc.
Dormitory rules and regulations
CONTRACTS WITH DISNEY:
Memorandum of Understanding (if applicable)
SAMPLE QUESTIONS:
1. What is the age of the youngest worker in this facility?
2. Are there any work experience programs for school age children?
3. Are there restrictions for workers under 18?
4. What procedures does this facility have in place to verify the age of the employees?
5. Are all employees voluntarily working in this facility?
6. What procedures does this facility have in place to ensure/monitor that all employees
are working voluntarily?
7. Are any of workers properties detained by the employer during the course of
employment?
8. Are there any workers in this facility that are prisoners, have been assigned by the
military, or any other branch of government?
9. Are employees free to leave when their work shift ends?
10.Are guards posted only for normal security reasons? If so, what are their basic duties?
11.How are employees recruited (i.e. newspaper ad, agent, contract)?
12.How are employees disciplined for misconduct or poor performance?
13.Does this facility restrict employment by age, race, ethnic group, religion, gender, sexual
orientation, political affiliation, and/or national origin?
14.What is the lowest wage paid by this contractor for trained (e.g. production) employees?
For untrained employees?
15.How are employees paid? (cash/check/auto pay/other)
16.How is the pay rate calculated? (per hour/piece rate/per day/other)
17.Is all work attendance documented?
18.How often are employees paid? (weekly/monthly/other)
19.Are there any deductions from employees wages?
20.What charges are deducted from your employees pay?
21.How is this documented?
22.Does any employee owe the Company money?
23.What allowances and benefits are provided to employees in this facility? (Housing, meals,
transportation, and other allowances; health care; child care; sick leave; bereavement
leave; emergency leave; pregnancy and menstrual leave; vacation; religious and holiday
leave; and contributions for social security, life, health, workers compensation and
other insurance coverage.)
24.Are benefits and/or allowances included in calculating the minimum wage?
25.Are there any incentive plans offered (e.g. bonus)?
26.Are workers paid for training (if applicable)?
27.Are workers paid for overtime?
28.What is the maximum number of consecutive days worked?
10-13

29.What are the operational hours of this facility?
30.How many work shifts are run in this facility?
31.How many hours per work shift?
32.How are overtime wages calculated (e.g. weekdays, 1.5x; holidays 2x, etc.)?
33.What is the average number of overtime hours worked per worker each week?
34.What is the maximum number of work hours per day at regular pay?
35.What is the maximum number of hours employees are asked to work in a given week?
36.Do employees have time each day for a meal?
37.Do employees have time each day for breaks? If yes, how many and what is the duration
of each break?
38.Do employees take work home?
39.How are wages for this work determined?
40.Are first aid supplies available in this facility?
41.Are there any medically trained personnel on site?
42.Are safety education/training programs offered (i.e. first aid, etc.)?
43.Do you have fire extinguishers and/or sprinkler systems in this facility?
44.Are fire escapes available for buildings more than one story high?
45.Is personal protective equipment available at no cost to the employee?
46.Do employees have unrestricted access to drinkable water?
47.How many functional toilets does this facility have? (male/female)
48.Does this facility have ventilation and lighting system?
49.Is there a supervisor on the floor for each work shift?
50.How many supervisors per work shift?
51.Does this facility allow its employees to associate?
52.Does this facility provide residential facilities for workers? If yes: vendor/licensee
controlled facilities/rental units/other
53.What efforts does this facility make in regards to the environment (i.e. waste
management, air purification, and hazardous material disposal)?
54.Does this facility outsource any of its production?
55.Does this facility source to individuals, families or collective work groups?
56.What articles/components are produced by these workers?
57.How are these workers paid?
The following questions pertain to dormitories.
58.Number of buildings? Number of employees that reside in this dormitory?
59.Average number of employees in a sleeping room?
60.Approximate space (in square meters) per employee in sleeping room?
61.Are sleeping quarters segregated by sex?
62.Are employees provided their own individual mats or sleeping space?
63.Are the room doors in the dorms locked from the inside or outside?
64.Are directions for evacuation in the case of fire or other emergencies posted in all
sleeping quarters in the native language?
65.Does this facility have fire extinguishers in all sleeping quarters?
66.Are fire drills conducted?
67.Are fire escapes available for buildings more than one-story high?
68.Are combustible materials stored in the dormitories or buildings connected to the
dormitories?
69.Number of toilets and shower facilities for employees (male/female)
10-14

10-15
70.Is hot water available at the showering facility?
71.Are kitchen or laundry facilities provided?
72.Are the employees charged for the following? (sleeping quarters/ meals/
transportation/ other) How much?
73.Is dormitory access controlled?
74.Are there any curfews on employees?
75.Are employees free to come and go as they please?

Appendix 8
10.8 Corrective Action Plan Acknowledgement Report (CAPAR)
Corrective Action Plan Acknowledgement Report
The Corrective Action Plan Acknowledgement Report (CAPAR) will be used to summarize the preliminary facility audit
findings and a draft corrective action plan that both the auditor and the facility representative believe is reasonable to
ensure conformity with the Disney Code of Conduct for Manufacturers (Disney Code of Conduct) and applicable local
laws.
The form should be used in the following manner:
Document preliminary facility audit findings on the form below prior to the closing meeting;
Then use the form as an agenda during the closing meeting;
During the closing meeting, explain the preliminary facility audit findings with the facility representative;
Document the corrective action plan;
Both auditor and facility representative should sign and date the form.
Please leave one copy of the CAPAR with the facility representative and retain one copy with the audit program or
working papers.
Facility
D.B.A / A.K.A
ILS #
Audit Type
Date
Facility Address Country
Facility Telephone Number Fax Number
Auditor Name Firm
Start time of audit End time of audit
Facility Representative Title
CL - Child Labor IL - Involuntary Labor CH - Coercion and Harassment
DI - Discrimination AS - Association MW - Minimum Wage
OW - Overtime wage OH - Overtime Hours SB - Social Benefits
OC - Other Compensation MC - Monitoring & Compliance HS - Health & Safety
DO - Dormitories PE - Protection of the Environment Sub - Subcontracting
OL - Other Laws PU - Publication
Int. _____ Int. _____ Page 1 of 2
Auditor Facility Rep
10-16

10-17
A closing meeting has been performed. The above preliminary facility audit findings were discussed and a draft corrective
action plan was explained to the facility representative. Please note that while all preliminary facility audit findings are
subject to a final review process, and it is possible further updates to these preliminary facility audit findings may be
necessary, the facility is responsible for and expected to take immediate corrective actions of the preliminary facility audit
findings.
The facility should contact the customer who contracted with the facility for Disney-branded production for the final version
of the Corrective Action Plan letter to ensure that all issues are promptly identified and addressed. Continued finding of
nonconformity with the Disney Code of Conduct and applicable local laws may lead to termination of the facility for all
Disney production.
The signatures below reflect that the auditor has explained the preliminary facility audit findings to the facility
representative.
Signature
Auditor
Date Signature
Facility Representative
Date
Print name
Auditor
Date Print name
Facility Representative
Date
Note: Disney may authorize production for a specific period of time and may assess compliance to its Code, but does not
currently maintain a list of approved suppliers. Possession of a Disney Manufacturers Agreement (MA), Factory and
Merchandise Authorization (FAMA), audit, CAPAR, Corrective Action Plan letter, or other document does not indicate that
a facility is an approved Disney supplier.
Page 2 of 2

Appendix 9
10.9 Facility Termination Letter
Date
XYZ Licensee/Vendor
[address]
Dear Licensee/Vendor,
In accordance with the provisions of your licensing agreement to develop, manufacture and distribute Disney-
branded products, we have recently conducted a Manufacturers Code of Conduct compliance assessment of the
following manufacturing facility:
ABC Facility (Disney ILS#)
Facility street address, city, country
The assessment was conducted on [Date].
During the course of the assessment, our auditors documented certain violations of the Code of Conduct. At the
completion of the audit, we discussed the violations with the facility's management, if appropriate. Unfortunately,
management has failed to rectify the violations or to present a satisfactory plan for doing so in the future.
Therefore, we are terminating your authorization to continue the manufacture of Disney-branded products
at this facility, with immediate effect. We therefore require that you cease using this manufacturing facility to
produce Disney-branded products and destroy or ship any remaining inventory within the next 30 days, or as may
be required by law. If you have already notified us that you are no longer using this facility, this letter will serve as
your notice that the facility can no longer be used to produce Disney-branded products.
Sincerely,
10-18

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