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No one understands this more than Michael Eisner and I do, and we know that one of the reasons for our ability to work effectively together is the fairness of the rules that govern our conduct. This Employee Policy Manual is the latest and most complete written expression of those rules. I ask you to review it for guidance on many issues and situations we may all face. With thanks for your service and enthusiasm, Robert A. Iger President and Chief Operating Officer The Walt Disney Company Page 1 General Company Policies January 2004 In the front section are those that apply to all employees of The Walt Disney Company and its subsidiary and affiliated companies (together, the Company ). In the second section are those that are specific to a particular business unit or location. A policy is a statement of general objective, intent, or guideline. If the application of a policy is unclear, employees should contact their Human Resources Department, Employee Relations Department, or Labor Relations Department (all referred to herein as the Human Resources Department ) for interpretation and assistance. These policies apply to all employees except to the extent they are subject to a collective bargaining agreement which sets forth different terms and conditions, in which case the collective bargaining agreement will apply. The Company complies with any federal, state or local law applicable to the policies in this manual. This manual is the property of the Company. Please keep it readily available. If in doubt about whether your copy contains the most up-to-date statement of policy, refer to The Disney Team Portal or contact your local human resources department. The Company reserves the right to amend, supplement, or rescind any policy or any provision reflected in this manual as the Company may deem appropriate in its sole and absolute discretion, whether or not in writing.
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All employees of the Company are employees at will unless subject to a specific signed written contract specifying employment for a particular term. Employment at will means an employee may be transferred, reassigned, or demoted, or his or her employment may be terminated, with or without cause, and with or without notice. Either the employee or the Company may terminate the employment relationship at will for any reason not prohibited by law or by a written Company policy in effect at the time of termination. Any practices that are or may appear to be at variance with this do not effect a waiver by the Company of the at-will employment status. No one has authority to modify or waive the at-will status in any way except the senior officer in charge of corporate operations of The Walt Disney Company, who may do so only in writing. January 2004 General Company Policies Page 2 This policy extends, but is not limited, to recruitment and employment, promotion, demotion, transfer, layoff, termination, rate of pay and other forms of compensation, education, and training. This policy also prohibits employees from harassing any other employee, guest, or other person in the course of the Company s business for any reason including, but not limited to, race, religion, color, sex, sexual orientation, national origin, age, marital status, covered veteran status, mental or physical disability, pregnancy, or any other basis prohibited by state or federal law. See also the Harassment policy. The Human Resources Department and all members of Management administer this policy. 1. All personnel decisions must be made without prejudice or discrimination in accordance with the principles of equal opportunity. 2. Retaliation against an employee who has made a good faith complaint about violation of this policy, or has cooperated with an investigation of such a complaint, is strictly prohibited. 3.
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Disciplinary action, not excluding termination, will be warranted if an employee fails to adhere to the provisions of this policy. 4. Employees who believe they have been harassed, discriminated, or retaliated against in violation of this policy should promptly report the facts of the incident and the name of the person involved to their Human Resources Department. Every report will be investigated. 5. Alternatively, employees may call the Company Guideline at (800) See also the Complaints policy, the Harassment policy, and the Standards of Business Conduct policy. Page 3 General Company Policies January 2004 The Human Resources Department and Management administer this policy. 1. Employees who are unable to report to work, or who expect to be late, must notify their supervisor as soon as possible before their scheduled starting time in order to allow alternate arrangements to be made. 2. If employees are unable to notify their immediate supervisor, they must notify another member of their department management as promptly as possible. 3. Absenteeism or tardiness may result in disciplinary action, not excluding termination. 4. Absence for three or more consecutive work days without notification to an employee s supervisor will result in termination of employment as of the end of the third day, absent extraordinary circumstances. 5. The Company may request documentation from the treating physician supporting an employee s absence from work. 6. Employees must maintain accurate time and attendance records. 7. False or materially incomplete entries on Company attendance or time records will subject the employee to termination of employment. January 2004 General Company Policies Page 4 The Human Resources Department administers this policy. 1. Regular employees are eligible for this benefit. 2. Conditions A. The deceased must be a spouse, qualified same-sex domestic partner, child, stepchild, grandchild, parent, parent-in-law, grandparent, or sibling of the employee.
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If an employee was especially close to or had responsibility for a relative other than these, bereavement leave may be granted by the head of Human Resources or a designated Human Resources representative. B. Bereavement leave may be taken for up to five work days for each applicable occasion. C. Payment is available only for scheduled work shifts which employees miss due to arrangement of, travel time to, and attendance at funeral services. D. Requests for bereavement leave must be made to and approved by the employee s immediate supervisor. The employee s relationship to the deceased and, upon request, the location and date of the funeral, must be provided in the request for bereavement leave. E. Requests for bereavement leave pay must be made no later than 30 days after the date of the leave. F. Employees must record any day they are absent from work due to bereavement leave. G. Bereavement leave benefits may not be accumulated, nor will employees be paid in lieu of any unused bereavement leave. H. Payment for bereavement leave will be made at the base wage or salary rate in effect at the time of the leave. Shift premium and lead pay will be included in the computation of bereavement leave when applicable. I. Employees on leaves of absence generally are not eligible for bereavement leave. J. Should the death of an employee s eligible family member occur while an employee is on vacation, vacation may be changed to include, or be replaced by, bereavement leave, at the request of the employee. Page 5 General Company Policies January 2004 The Human Resources Department administers this policy. 1. Definition A. The term bridging of service means adding a period of previous Company employment to the current period of employment with the Company for an adjusted hire date for determining an employee s total years of Company service for benefit eligibility other than the retirement plans. B.
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For retirement plan purposes, the retirement plan s bridging of service provisions apply. 2. Conditions Upon request, employees will be eligible for bridging of service as follows: A. Employees Who Voluntarily Terminate Their Employment Regular employees who voluntarily terminate their employment will be eligible for immediate bridging of service if they return to the Company as a regular employee within 30 calendar days after their employment with the Company has terminated. If they return to the Company beyond 30 calendar days, and if they have completed five or more continuous full years of prior service with the Company, they will be eligible for bridging of service if, after their return to the Company as a regular employee, they complete an additional five full years of continuous service. B. Employees Whose Employment Is Involuntarily Terminated 1) Regular employees who are laid off or whose employment is terminated for remaining on a medical leave of absence in excess of the time permitted by Company policy will receive immediate bridging of service if they are reemployed, as a regular employee, by the Company within 12 months of their termination date. If they are reemployed by the Company as a regular employee after 12 months, they will be eligible for bridging of service if they have completed five or more continuous full years of prior service with the Company and after their return complete an additional five full years of continuous service. 2) Regular employees whose employment is involuntarily terminated for any other reason will not be eligible for bridging of service. January 2004 General Company Policies Page 6 Page 7 General Company Policies January 2004 The Finance Department and Management administer this policy. 1. Specific Travel and Business Guidelines may be issued for each business unit. 2. Falsification of an expense report will subject the employee to termination of employment.
January 2004 General Company Policies Page 8 The Security Department, the Human Resources Department, and Management administer this policy. 1. Company property, including anything in waste containers, may not be removed from Company premises without written approval by the head of the department having responsibility for the property. 2. An employee who uses Company property but fails to see that it is kept in good repair or loses it may be disciplined. 3. When an employee leaves or is terminated from the Company, the Human Resources Department or management is to account for and obtain all property, including Company documents in the employee s possession. Employees must reimburse the Company for any property not returned. 4. Keys A. The unauthorized possession, use, or duplication of Company keys is prohibited. B. Employees must return Company keys upon demand by the Company or termination of employment. C. If an employee no longer has use for a key issued to him or her, the employee must return it to the Security Department or management. 5. Telephone Voice Mail All voice mail messages are the property of the Company. The Company may, in its sole discretion, access, record, or disclose any voice mail message left on a Company voice mail system, without further notice to the employee. 6. Company employee identification cards may not be duplicated in any way. 7. Violation of this policy may result in disciplinary action, not excluding termination. 8. See also the Computer Usage and Security policy and the Security policy. Page 9 General Company Policies January 2004 The Human Resources Department and Management administer this policy. 1. Complaints should be handled, if possible, within an employee s department. 2. An employee should discuss a work-related problem with his or her immediate supervisor as soon as possible. In the case of a complaint of discrimination or harassment, see also the Equal Employment Opportunity policy and the Harassment policy. 3.
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Employees who want further review of their complaint should submit the complaint in writing to the head of their department. For still further review, they should submit a written complaint to their head of Human Resources. 4. Alternatively, employees may contact their Human Resources Department or may call the Company Guideline at (800) See also the Standards of Business Conduct policy. 5. Retaliation against an employee who has made a good faith complaint, or has cooperated with an investigation of such a complaint, is strictly prohibited. January 2004 General Company Policies Page 10 The Human Resources Department and the Ticket Services Department administer this policy. 1. For specific information about pass usage, refer to the written pass usage guidelines or contact the Ticketing Services Department. 2. The Company reserves the right to restrict the use of the passes in its sole discretion. 3. Passes are valid only during regular Park operating hours when admission tickets are accepted at the Main Entrance. They are not valid on dates designated by the Company and during private parties or events requiring special admission tickets. 4. Passholders must show their employee identification card or other valid photo identification at the time the pass is used. 5. Passes may be used only one time per day, but entitle the passholder to visit more than one Park on the same day. They must be returned upon termination of employment or upon demand by the Company. 10. Passholders are required to pay a fee to the Company for replacement of lost passes unless they present a police report documenting that the pass was stolen. Page 11 General Company Policies January 2004 The Information Technology Department and Management administer this policy. 1. Ownership of Assets and Licenses of Software A. All computer programs or data purchased or licensed by or developed for the Company are the property of the Company or its licensors.
In no event shall any computer program, data, documentation, listing, source code, or object code be sold, licensed, released or loaned to individuals or entities outside the Company, without prior express permission of the Chief Information Officer and an appropriate written agreement prepared by the Legal Department. B. All electronic mail messages are the property of the Company. C. All purchases, leases or licenses by the Company of computer hardware or software must be made pursuant to written agreements approved by the Legal Department. 2. Appropriate Use A. Company owned, leased, licensed or operated computer systems, including hardware, software and data, are to be used for Company business. If a Company computer user is uncertain about whether any particular use is appropriate, he or she should seek a determination from his or her supervisor or the appropriate security administrator. B. Software or other copyrighted material licensed from a third party may be used only in accordance with the license agreement. If anyone using software or licensed material is uncertain about permitted uses, he or she should seek a determination from the Legal Department. C. The Company s computer systems may not be used for unlawful activities, including copying, distributing or storing copyrighted materials in violation of copyright laws or license agreements. D. The Company s computer systems may not be used for solicitation for religious, political, charitable, social or personal purposes. January 2004 General Company Policies Page 12 Employees must: Follow all Security Policies and Standards issued by the Information Technology Department. Not subvert or disable password, virus detection, or other security protections. Not disclose or share passwords or other security features. Not attempt unauthorized access to any Company computer system, device, site or asset.
Not attempt to access any Company computer system, device, network, site or other asset from any unauthorized device, location, or software. Report incidents of any attempted information security breach or security lapse to management. Participate in periodic security awareness training. Page 13 General Company Policies January 2004 Non-employees must be identified as such in the directory of the electronic mail system. B. Management which authorizes a non-employee s use of computer systems must notify the security administrator promptly when the non-employee terminates his or her business relationship with the Company, so that access to use of the computer systems may be terminated. C. Employees designated as responsible for contract administration with a vendor, contractor or consultant who has access to, or is providing, Company computer hardware, software or data, are responsible for informing such vendor, contractor or consultant of this policy and for requiring compliance with this policy. 5. Unsolicited Submission of Ideas It is the long-standing policy of the Company not to accept the submission of ideas without prior authorized invitation. The word ideas in this context includes all creative suggestions, artwork, design, theme park attractions concepts, game proposals, scripts, treatments, manuscripts, and songs, in whatever form, from whatever source, and however communicated. As soon as an employee realizes that a message he or she has received constitutes the submission of an idea, the employee should stop reading the message and follow the guidelines as set forth in the Unsolicited Submission of Creative Ideas policy. January 2004 General Company Policies Page 14 If employees learn of any violation of this policy, they must notify their department head. Page 15 General Company Policies January 2004 The Corporate Communications Department and Management administer this policy. 1.
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Employees may have access to important information about the Company or other corporations with which the Company is doing business that is confidential and not general knowledge. Employees may not, without permission from an authorized member of management, disclose data or information of a proprietary or confidential nature concerning the Company to anyone not employed by the Company, or to another employee who has no need for or right to know such data or information. 2. Employees may have access to confidential information concerning the Company s customers, employees and other individuals associated with the Company. Employees should not, without proper permission from an authorized member of management, give or release confidential data or information concerning any customer, employee or other individual associated with the Company to anyone not employed by the Company, or to another employee who has no need for or right to know such data or information. 3. Any disclosure of proprietary vendor information to anyone who does not have a need to know is prohibited. 4. Any access to any proprietary or confidential Company data by anyone without a need to know is prohibited. 5. Employees may not answer questions from, or speak on behalf of the Company to, the press or third parties except when specifically authorized to do so. Any such requests from the press or other third parties should be directed to the Corporate Communications Department, or to the communications department for the business unit most closely connected with the subject matter of the request. 6. Violation of this policy may result in disciplinary action, not excluding termination. January 2004 General Company Policies Page 16 The Corporate Management Audit Department, the Business Standards Policy and Programs Department, and Management administer this policy. 1.
Conflicts of Interest Every employee must avoid conflicts of interest or the appearance of conflicts of interest in the performance of his or her job. Employees may not, without the approval of the Company, conduct business on behalf of the Company with a member of their immediate family, or with any business organization in which they, or (to their knowledge) any member of their immediate family, has a direct or indirect financial interest. A Supervisor with actual knowledge, may not, without the approval of the Company, allow Supervised employees to conduct business on behalf of the Company with a member of the Supervisor s immediate family, or with any business organization in which the Supervisor, or (to the Supervisor s knowledge) any member of the Supervisor s immediate family, has a financial interest. Employees not actually doing business themselves but who are in a position to influence or affect the Company s business relationships with other business organizations may not, without the approval of the Company, seek to influence the Company s decision to enter into, continue, or terminate a business relationship with any business organization in which they, or any member of their immediate family, have a direct or indirect material financial interest. Employees in a position to influence or affect the Company s business relationships with any business organization that does business or seeks to do business with the Company must disclose to Corporate Management Audit Department any direct or indirect material financial interest that they, or any member of their immediate family, have or acquire with such business organization.
Similarly, employees who have knowledge that an employee they indirectly supervise is doing business, or intending to do business, with a member of that indirect supervisor s immediate family, or with any business organization in which they, or (to their knowledge) any member of their immediate family, have a direct or indirect financial interest, must disclose the relevant information to the Corporate Management Audit Department. Page 17 General Company Policies January 2004 22 Conflicts of Interest (continued) An employee shall not engage in any type of self-employment or employment by another to an extent that such employment interferes in any way with the performance of the employee s services to the Company. No employee shall compete with the Company, render services to, or have a material financial interest in, a competitor of the Company. For purposes of this policy, the following definitions apply: Immediate family members mean a spouse, parents, children, siblings and mothers and fathers-in-law, sons and daughters-in-law, brothers and sisters-inlaw, as well as persons (other than household employees) who permanently reside in a person s home. For purposes of this policy only, Supervisor is an employee who directly supervises any other person. A Supervised employee is an employee who is supervised directly by a Supervisor. 2. Violation of this policy may result in disciplinary action, not excluding termination. January 2004 General Company Policies Page 18 23 Corporate Identity It is the policy of the Company that Company marks, logos, stationery, and corporate names be used consistently and precisely. All stationery materials must be printed by a Company-approved print house. 7. The following is not permitted: A. Electronic versions of Company stationery may not be used. Company stationery includes, but is not limited to, Company letterhead, memorandum paper, personalized note stationery. All documents must be printed on preprinted stationery. B.
Departments may not use stationery materials printed with their departmental name. C. Departments may not use a logo different from that of the legal name, or approved trade name, of their Company. D. Employees may not use business cards without their name and title. Page 19 General Company Policies January 2004 24 Corporate Identity (continued) E. Non-employees of the Company may not use Company stationery materials. Employees of other companies or entities, including temporary leased workers, may not use stationery materials with Company logos, marks, or corporate names, even if they have offices on Company property. F. Company logos, marks, or names may not be used in conjunction with logos, marks or names of non-company entities or businesses. G. Fax cover sheets may not be used with the likeness of a Disney character, a Company logo, or a Company name. Fax cover sheets may only identify the sender s name, telephone and fax number. H. Corporate logos, corporate names and tag lines may not be altered in any manner. I. See also the Use of Company Names, Characters or Symbols policy. J. Violation of this policy may result in disciplinary action, not excluding termination. January 2004 General Company Policies Page 20 25 Discipline It is the policy of the Company to take action as the Company, in its sole discretion, deems necessary in response to conduct and performance which fall below the Company s high standards. The Human Resources Department and Management administer this policy. 1. All employees of the Company are employees at will unless subject to a specific signed written contract specifying employment for a particular term. Employment at will means an employee may be reassigned, transferred, or demoted, or his or her employment terminated, with or without cause, and with or without notice.
Either the employee or the Company may terminate the employment relationship at will for any reason not prohibited by law or by a written Company policy in effect at the time of termination. Any practices that are or may appear to be at variance with this do not effect a waiver by the Company of the at-will employment status. No one has authority to modify or waive the at-will status in any way except the senior officer in charge of corporate operations of The Walt Disney Company, who may do so only in writing. 2. The Company may discipline employees when and in the manner it, in its sole discretion, deems appropriate. January 2004 General Company Policies Page 22 27 Educational Reimbursement It is the policy of the Company to provide financial reimbursement for eligible employees who enroll in and successfully complete qualified job-related courses. The Disney University and the Human Resources Department administer this policy. For specific information about eligibility for Educational Reimbursement, employees should obtain a copy of the Educational Reimbursement Application, which is available from The Disney University or their local Human Resources Department. Page 23 General Company Policies January 2004 28 Employment of Relatives It is the policy of the Company that relatives and qualified same-sex domestic partners of current employees may work for the Company only if the Company, in its sole discretion, determines that employment of the relative or qualified same-sex domestic partner does not create problems of supervision, confidentiality, morale, or conflict of interest. The Human Resources Department and Management administer this policy. 1. The Company discourages employees from working in close physical proximity to or under the supervision or leadership of any relative or qualified same-sex domestic partner. 2.
If two employees are related, married, or are qualified same-sex domestic partners and the Company, in its sole discretion, determines that the employees work in such proximity to each other that the relationship might create problems of supervision, confidentiality, morale, or conflict of interest, or an appearance of impropriety, one of the employees will be permitted to stay in his or her current position while the other will be transferred or terminated unless reasonable accommodations can be made to alleviate the potential problem. If the Company determines that both employees cannot remain in their positions, within 30 calendar days of the Company s determination, the employees involved must decide which of them will remain in his or her current position. If the employees refuse to decide, the employee with the shorter length of service will be asked to make a change in his or her position. January 2004 General Company Policies Page 24 29 Employment References and Requests for Employee Information It is the policy of the Company that employees may not give employment or other references for current or former employees on behalf of the Company. The Human Resources Department administers this policy. 1. The Company provides only the following information in response to inquiries about employees: Current employees: Verification of employment, job title and hire date. Former employees: Verification of employment, job title at termination, and hire and termination dates. 2. Additional information, such as salary and job chronology, may be provided in response to written requests only when authorized in writing by the employee. 3. Employees who choose to give references in a purely personal capacity may not use Company stationery and may not imply that they are representing the Company in doing so.