The Walt Disney Company

The Walt Disney Company distributes a 25-page Code of Conduct document

to each of its employees. This document is well written and addresses areas
relevant to all employees. It contains the three main areas addressed as advantages
to an effective code of conduct.

The first page of the Disney code of conduct includes a brief letter from
Robert Iger, Chairman and CEO, stating the importance of the standards by which
the company abides. He also addresses the importance of employees representing
the company ethically. He instructs employees to speak up with concerns and
problems. Igers personal correspondence and urging of employees to take
responsibility for their conduct is a good way to begin.

The code continues by making reference to The Guideline, the companys
website for reporting questionable and suspected illegal or unethical activities, filing
complaints, and asking questions. There is also a 24-hour telephone hotline for
employees who wish to speak with someone.


The Disney code of conduct is well organized and the detailed table of
contents makes sorting through the information easier. The code is divided into
sections discussing commitments to customers, co-workers, company and
shareholders, the law and the community. Each page contains real employee
quotes or questions and company answers on the sides of the pages to correspond
with each topic of discussion.

It is continually made clear throughout the document that the code of
conduct takes precedence over instructions from management and that the law
takes precedence over the code of conduct. Employees are instructed to read and
learn the code as well as the laws so that they can be knowledgeable about issues
that may affect them in the workplace. In the case where something is unclear,
employees are instructed to contact various departments such as Human Resources
or the Legal Department to get answers to their questions.

To simplify the reading, key words and ideas are defined within sections. For
example, three pages are devoted to accepting gifts. Gifts are defined with examples
and the document includes a gift decision tree. Employees are also instructed to
contact the Management Audit Department for further questions or
concerns. Disney has gone above and beyond with the organization of this
document, including a glossary of terms at the end. Employees are also given a table
listing company resources and contact information if they should have questions on
various sections.

Overall, the Walt Disney Company code of conduct is a solid document. It is
well-organized, easy to read and visually appealing. However, the one thing this
code lacks is consequences for not abiding by the rules and standards it puts in
place. While it addresses privacy, conflicts of interest, safety, fairness, accurate
record keeping and labor standards, not once is there a mention of what would
happen if an employee should not follow the code. Each section that involves an
unethical or illegal action is ended with a request for the employee to contact the
appropriate manager or department for reporting a violation or to clarify any
information.

If you receive a request to comply with a foreign boycott (or a request to
supply boycott related information), consult with the Legal department to
determine the appropriate course of action.
If you ever receive such a request you should immediately advise the Legal
department and follow its instructions to ensure that the information or
documents we provide fully comply with our legal obligations.
Regardless of local practice or the practices of other companies, make sure
you avoid even the appearance of doing something improper. For more
information, see our anti-corruption policy.


Use good judgment if authorized to use Company-provided Internet access;
take care to never violate a law, harass other users, disclose confidential
information or interfere with network users, services or equipment.

There are no disciplinary steps or actions mentioned in the code. The Walt
Disney Company has created a document with a positive outlook that informs,
empowers and motivates employees. However, the code is not fully effective in that
it does not paint a complete picture of what it means to be a Disney employee, with
the good and the bad.

Risk Assessment

While not mandatory for running a business, companies take a risk by not
have a code of conduct in place. A lack of a code of conduct is risky and could cost a
company legally or financially and could possibly cause other companies to not take
them seriously.

Employees should know what is expected of them and within what
parameters they should function. When standards are not expressly stated in
writing, employees act at their own discretion. Management must hope that those
actions are aligned with what is in the best interest of the company. A formal code
of conduct can cause an employee to think twice before behaving in a questionable
manner. If guidelines and consequences are presented to individuals early in their
employment, they will take into consideration the ramifications should they
disregard company policies.

It is possible for a lack of a code of conduct to cause some legal
ramifications. In some states, the law requires a company to have a policy for
certain matters. In the state of Vermont, employees must be given a copy of the
company drug testing policy before making them submit to drug testing.

Studies have also shown that workplace violence is one of the top causes of
fatal occupational injuries. A 2005 study showed that less than 30% of companies
surveyed had a workplace violence policy in place. That same year, 792 or 14% of
the 5,734 workplace fatalities were caused by assault or violent acts. In 2011, 10%
of workplace fatalities were caused by homicide. Violent acts do not need to be
caused by co-workers. Domestic violence can follow an employee to work and
create serious legal problems for a company who does not have policies in place to
protect its workers. Neither the Jo-Ann or Disney codes of conduct mentioned
workplace violence.

The U.S. Department of Justice also gives leniency consideration to
companies with codes of conduct. Should a company ever be convicted of a crime,
its code of conduct can only help in the sentencing process. The departments
Sentencing Guide states that The two factors that mitigate the ultimate punishment
of an organization are: (i) the existence of an effective compliance and ethics
program; and (ii) self-reporting, cooperation, or acceptance of responsibility.

Failure to create policies for matters such as use of company equipment can
also cause problems. With the prevalence of so many forms of electronic
communication, companies face issues such as employees wasting company time
with personal matters or unintentionally revealing company secrets. Paying an
employee to surf the Internet or email friends during work hours is a waste of
money. An employee who uses a company computer for personal matters may
accidentally allow sensitive company material in the wrong hands. These things can
cause serious financial consequences to a company and if the problem is not
corrected in a timely manner, companies can go out of business.

A formal code of conduct shows that the company takes its values
seriously. In some ways, it can be seen as a marketing piece for the
company. Potential business associates may see the code of conduct as a symbol of
a company that is serious about its values, its commitment to employees, and its
adherence to the law. If a company does not take the time to introduce a written
code of conduct, other businesses may view that company negatively.

Companies need to be sure to enforce the code of conduct and keep it as a
living, breathing document. It should be continually modified and updated as
employment laws are updated. Employees should often be reminded of its existence
and trained in any areas that may require it. Failure to introduce an employee to the
companys culture and values can cost the company financially and later tarnish its
reputation.

A code of conduct establishes a companys core values and presents
expectations for each employee in regards to clients, customers and coworkers and
the company. In many cases, it is a way for a company to show its employees,
shareholders and business associates, its compliance to the laws concerning the
workplace. This document, while legally necessary for only publicly traded
companies, can be an essential tool for any business. This tool can endorse a
company to other companies and can increase trust among shareholders and
employees. Companies failing to utilize this tool, take unnecessary risks with its
business operations. It is imperative that companies take every opportunity to put
itself in a good light and having a code of conduct is a step in the right direction.