The Walt Disney Company is committed to fostering safe, inclusive and respectful
workplaces—in our parks and resorts, in our Disney-owned stores, in our distribution
centers and offices, and in facilities around the world where Disney-branded products
are made. In support of this commitment, Disney’s Standards of Business Conduct for
employees include an expectation of respect for all employees. In addition, Disney
maintains a Code of Conduct for Manufacturers and operates an International Labor
Standards (ILS) Program designed to help address working conditions in facilities around
the world where Disney-branded products are made. These facilities are not owned or
operated by Disney and are instead mostly engaged by or associated with the independent
vendors and licensees with whom we do business. As a condition of doing business with
Disney, our licensees and vendors agree to observe the standards established by our ILS
Program. In 2010, Disney also adopted a Human Rights Policy Statement.
Prohibition of all forms of forced labor, including slavery and human trafficking, is a
core principle of our Human Rights Policy Statement and is prohibited by our Code of
Conduct for Manufacturers. Our Code includes specific provisions on Involuntary Labor
that prohibit the use of forced or involuntary labor—whether prison, bonded, indentured
or otherwise—in the production of Disney-branded products. Our Code also includes
provisions on Coercion and Harassment that prohibit the use of corporal punishment,
threats of violence or other forms of physical, sexual, psychological or verbal harassment
or abuse against employees. We have been reporting on the extent of compliance with
Involuntary Labor and other provisions of our Code each year since the publication of our
first Corporate Citizenship Report published in 2009.
We expect all of our independent licensees, vendors and manufacturers to uphold the
standards set forth in our Code and in our ILS Program and to implement any necessary
corrective actions to ensure compliance. Our independent licensees and vendors agree,
represent and/or warrant that they will comply with all applicable local and national laws
and regulations concerning the manufacture of Disney-branded product, which would
include compliance with laws regarding forced labor, human trafficking and slavery. Disney
also requires our independent licensees and vendors to disclose to us the facilities that
they intend to use to produce Disney-branded products, including subcontractors they
intend to use. In our annual Corporate Social Responsibility report, we include data on the
number of facilities that are authorized to produce Disney-branded products under our ILS
Program, and we maintain a dedicated facility database to store this information.
The company routinely verifies labor conditions in the facilities in the supply chain for Disney-branded products, including evaluating the risk of forced labor, human trafficking and slavery. We use the World Bank Governance Indicators (WGI) as the primary resource for identifying and comparing areas of risk, for determining sourcing policies and for focusing our monitoring resources and auditing activities. This data helps us generate our Permitted Sourcing Countries which determines the countries from which licensees and vendors may source their production of Disney-branded products.
Furthermore, we use the U.S. Department of State’s Trafficking in Persons Report and
the U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor
to prioritize our auditing activities around areas of potential risk, particularly with
respect to forced labor. On-site assessments are conducted by our global, dedicated
ILS staff, by specialized third parties engaged by Disney for this purpose and by or on
behalf of our independent licensees and vendors. In our fiscal year 2018, we conducted
and received over 10,000 social compliance audits, including unannounced audits. We
require our assessments to evaluate compliance by interviewing workers and facility
management, reviewing documents and inspecting the facilities, including dormitories
where present. For any known violations of the critical elements of our Code, called
the Minimum Compliance Standards, our independent licensees and vendors are
required to take appropriate corrective action and failure to do so can result in removal
of authorization to produce Disney-branded products. Information related to audit
results can be found in our annual Corporate Social Responsibility Report. A sample of a
Disney-directed audit agenda, checklist and Corrective Action Plan can be found in the
ILS Program Manual.
As part of our ILS Program, training resources are available for our ILS staff,
management and business partners outlining the requirements of our Code of Conduct
for Manufacturers, which includes prohibitions on the use of forced labor. These
resources include our ILS Program Manual as well as dedicated ILS staff located in key
international markets. Regular instructor-led trainings on the requirements of the ILS
Program are provided to internal staff and external business partners through these
offices. Additionally, our Consumer Products business makes available an e-learning
module for its employees covering the requirements of the ILS Program, including
prohibitions on the use of forced labor. Finally, our Standards of Business Conduct,
applicable to every employee of The Walt Disney Company and its affiliates, requires
adherence to ILS Program requirements. Beyond these training resources, we continue
to evaluate our training needs and work to develop additional resources as needed.
The Walt Disney Company is committed to working with our business partners and
external stakeholders to find solutions to address working conditions and worker
exploitation, including forced labor and human trafficking.