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Walt Disney Company
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Mickey Mouse



I. Ethical Standards

C. Responsibility to the Company and Shareholders (continued)

Use of Corporate Information, Opportunities, and Assets
Cast Members and employees may not use confidential Company information for their personal benefit or the benefit of others. Such information includes, but is not limited to: inside information used to trade in stock of the Company or of other companies; information about significant real estate transactions; confidential personnel information; and other confidential information such as sales and earnings figures, acquisitions or mergers, strategic business plans, major contracts, stock splits, commencement of significant litigation, the sale of an associated company, or new projects or motion pictures contemplated by the Company. Moreover, opportunities that are discovered through the use of corporate property, information, or through one's position at the Company may not be used for personal gain. If in doubt as to whether information is confidential or may be shared with others inside or outside the Company, please consult your manager, business unit head, or the Corporate Legal Department for clarification prior to sharing such information.

Company assets are property of the Company. Everyone must protect the assets of the Company and ensure that they are used appropriately and efficiently. Theft, carelessness and waste reduce the Company's profitability. Company assets should only be used for legitimate Company business.

Intellectual Property and Proprietary Information
Cast Members and employees may have important information that is confidential (e.g. business plans and forecasts, costs, unannounced projects, etc.). Outside parties could easily benefit from such information and may attempt by various means to obtain it. Every Cast Member and employee is obliged to maintain the confidentiality of information entrusted to them by the Company. Accordingly, except as specifically authorized by management, no one shall disclose any Company proprietary information to any outside party. Unintentional disclosure of proprietary information may be just as damaging as intentional disclosure. Therefore, each individual should exercise care not to discuss confidential issues in public areas or in casual conversation. Examples of how confidential information may be unintentionally disclosed include, but are not limited to: conversations on cellular telephones; inadvertent transmission to incorrect fax numbers; or transmission of information via the Internet, where submissions may not be secure and may potentially be viewed by others. Furthermore, the Company expects Cast Members and employees to maintain the secrecy of the Company's trade secrets and proprietary information, even if they leave the Company.

When appropriate, the Company protects its proprietary information and secures legal protection through trademarks, patents and copyrights. In the same way, the Company expects its Cast Members and employees to honor the copyrights, trademarks, patents and proprietary information of others. Examples of information which may be protected include, but are not limited to, the following: written materials, audio and video products, and computer software.

We believe our best ideas develop from the internal interaction of our Cast Members and employees. Such ideas may include, but are not limited to: creative suggestions, artwork, designs, theme park attraction concepts, game proposals, scripts, treatments, manuscripts, and songs, in whatever form. Therefore, Cast Members and employees should politely reject the submission of unsolicited ideas, as defined in Company policy, from external sources except as may be in accordance with Company policy. Further, to avoid any potential misunderstanding regarding the source of Cast Member or employee original ideas, any recipient of an unsolicited idea from outside the Company must stop reading or listening to the information being submitted, immediately forward the material to the Corporate Legal Department, and not review or retain such information, or make notes or forward such ideas to other Cast Members or employees. Adherence to this policy helps to protect the Company against unwarranted claims that an idea reviewed by the Company, or left unreviewed in Company files, is the true source of a creative proposal or property developed by the Company. Furthermore, to avoid any claim that the Company used a third party's confidential information, Cast Members and employees must contact the Corporate Legal Department for proper guidance before participating in any meeting or conversation with anyone not affiliated with the Company during which confidential information of such person or entity may be disclosed

Accurate Reporting
Each individual shall report and record all information, and complete Company documents, accurately and honestly. These include, for example, time cards, reimbursable business expense requests, invoices, payroll records, safety records, business records and performance evaluations.

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