Code Of Conduct For Disney's 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, werequire 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 locallaw allows)or, if higher, the local legal minimum age for employment orthe age for completing compulsory education.

Manufacturers employing young persons who do not fall within thedefinition of"children"will also comply with any laws and regulationsapplicable to such persons.

Involuntary Labor

Manufacturers will not use any forced or involuntary labor，whetherprison, bonded, indentured or otherwise.

Coercion and Harassment

Manufacturers will treat each employee with dignity and respect, and willnot use corporal punishment, threats of violence or other forms ofphysical, sexual, psychological or verbal harassment or abuse.

Nondiscrimination

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

Association

Manufacturers will respect the rights of employees to associate, organizeand bargain collectively in a lawful and peaceful manner,without penaltyor interference.

Health and Safety

Manufacturers will provide employees with a safe and healthy workplacein compliance with all applicable laws and regulations, ensuring at aminimum reasonable access to potable water and sanitary facilities; firesafety; and adequate lighting and ventilation. Manufacturers will alsoensure that the same standards of health and safety are applied in anyhousing that they provide for employees.

Compensation

We expect manufacturers to recognize that wages are essential to meetingemployees' basic needs. Manufacturers will, at a minimum, comply withall applicable wage and hour laws and regulations,including thoserelating to minimum wages， overtime, maximum hours, piece rates andother elements of compensation, and provide legally mandated benefits.Except in extraordinary business circumstances，manufacturers will notrequire employees to work more than the lesser of (a) 48 hours per weekand 12 hours overtime or (b) the limits on regular and overtime hoursallowed 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 inextraordinary business circumstances，employees will be entitled to atleast one day off in every seven-day period.

Manufacturers will compensate employees for overtime hours at suchpremium rate as is legally required or, if there is no legally prescribedpremium rate, at a rate at least equal to the regular hourly compensationrate.

Where local industry standards are higher than applicable legalrequirements, we expect manufacturers to meet the higher standards.

Protection of the Environment

Manufacturers will comply with all applicable environmental laws andregulations.

Other Laws

Manufacturers will comply with all applicable laws and regulations,including those pertaining to the manufacture，pricing, sale anddistribution of merchandise. All references to“applicable laws andregulations"in this Code of Conduct include local and national codes,rules and regulations as well as applicable treaties and voluntary industrystandards.

Subcontracting

Manufacturers will not use subcontractors for the manufacture of Disneymerchandise or components thereof without Disney's express writtenconsent, and only after the subcontractor has entered into a writtencommitment with Disney to comply with this Code of Conduct.

Monitoring and Compliance

Manufacturers will authorize Disney and its designated agents (includingthird parties) to engage in monitoring activities to confirm compliancewith this Code of Conduct, including unannounced on-site inspections ofmanufacturing facilities and employer-provided housing; reviews ofbooks and records relating to employment matters; and private interviewswith employees. Manufacturers will maintain on site all documentationthat may be needed to demonstrate compliance with this Code ofConduct.

Publication

Manufacturers will take appropriate steps to ensure that the provisions ofthis Code of Conduct are communicated to employees,including theprominent posting of a copy of this Code of Conduct,in the locallanguage and in a place readily accessible to employees, at all times.