THE WALT DISNEY COMPANY POLICY FOR USE
OF COLLABORATION PLATFORMS
Emerging online collaboration platforms – such as blogs, wikis, online social networks, and other forms of online publishing and discussion – are changing the way cast members and employees of The Walt Disney Company and its affiliates (the ―Company‖) work with and engage each other, customers, guests, business counterparts, and vendors. These technologies create new opportunities to communicate and collaborate internally and externally, and the Company wants to use them to optimum good effect. As they also can create certain risks to the Company and those using them, the following policies have been adopted to help manage those risks.
1. Know and Follow the Employee Policy Manual and Standards of Business Conduct.
Your online activities are subject to the same Employee Policy Manual, Standards of Business Conduct, and local human resources policies that apply to the rest of your activities. These documents are likely to address many of your questions. If after checking them you are still unclear as to the propriety of a post, it is better to refrain and seek advice from your manager. While in general what you do on your own time is your choice, online activities that impair or reflect on your job performance, the performance of other cast members and employees, or the Company's business interests, regardless of when and where you engage in them, are subject to Company policies.
2. Do Not Disclose Confidential and Proprietary Information.
Never disclose the Company’s or anyone else’s confidential or proprietary information on a collaboration platform. This information includes properties, plans, and works not yet made public, whether in motion pictures, television programs, games, theme park attractions, or any other Company business, and can be in many forms (e.g., text, drawings, photos and videos). If you are unsure whether the information may be disclosed, err on the side of caution and assume it may not be. Collaboration technology and social networking blur many of the traditional boundaries between internal and external communications. Be careful about what you publish—particularly on external platforms.
A particularly important aspect of this policy is that you should not comment on confidential Company financial information such as business performance, business plans, or prospects. This includes commenting to anyone, including Wall Street analysts, media or any other third parties (including your friends), about an upcoming quarter or future periods, prospects for future success, and unannounced plans or information about new initiatives, mergers, acquisitions, ventures or alliances. It is Company policy that all requests from the press or other third parties about the Company’s performance and business activities 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. When the Company wishes to communicate publicly as a company—whether to the marketplace or to the general public—it has well-established means to do so. Only those officially designated by the Company have the authorization to speak on behalf of the Company
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3. You Are Responsible for What You Post -- Think Before You Send.
You are personally responsible for the content you publish on collaboration platforms, whether hosted internally or accessible to the public. Just because the dialogue on a collaboration platform may be more casual and less formal than email or other forms of written communication, do not let your guard down and write things you might later regret. You may be subject to liability if posts are found to be defamatory, harassing, invasive of privacy, or in violation of other applicable laws. A written record exists of what you post that may be made public and be available for a long time, so consider carefully the content of what your write. Is the subject matter one that is appropriate for the creation of this type of widely disseminated written record? If you are about to publish something that makes you even the slightest bit uncomfortable, think about why that is. If you remain unsure and the post is related to the Company’s business, feel free to discuss it with your manager. Ultimately, however, it is you who is responsible for what you publish in any form of online collaboration. The Company trusts—and expects—you to exercise personal responsibility whenever you participate in social media.
4. Be Mindful of Your Association with the Company.
Ensure that your posts, along with your profile and related content, are consistent with how you wish to present yourself to colleagues, guests, consumers, and business counterparts. Consider how what you say will impact how you are perceived in your professional capacity and remember that the lines between public and private, or personal and professional, are often blurred on collaboration platforms. By identifying yourself within a social network as a cast member or employee, which may happen simply through the use of your work email address as part of your account information or electronic identity, the reader will associate you with the Company and your colleagues. For that reason, if your post is not work-related, use your personal email address and not your work address. Just as you would not use Company stationery to send a letter to the editor of a newspaper expressing your personal opinions, you should not use your work email when you post personal opinions on collaboration platforms.
5. In Discussions Related to the Company Make Clear You Are Speaking for Yourself and Not for the Company.
If you identify or discuss the Company or Company-related matters on a site accessible outside of the Company, make it clear that you are speaking for yourself and not on behalf of the Company. When you discuss work done by the Company, you must use a disclaimer such as: "The views and opinions expressed on this post are mine and do not necessarily represent or reflect those of The Walt Disney Company."
Managers and executives take note: This standard disclaimer does not by itself exempt the Company’s managers and executives from a special responsibility when using collaboration platforms. By virtue of their position, they must consider whether comments they publish may be misunderstood as expressing the Company’s positions. A manager also should assume that his or her team will read what is written. A public collaboration platform is not the place to communicate the Company’s policies to its employees.
When communicating on a collaboration platform about the Company or issues affecting the Company in which you are involved, you should not post anonymously or use a pseudonym or false screen name. Readers value transparency and honesty. If you are writing about your work, use your real name, be clear who you are, and identify that you work for the Company. If you have a vested interest in something you are discussing, be the first to point it out. You may not use collaboration platforms for covert marketing or public relations.
6. Add Value.
Collaboration platforms that are hosted on Company-owned domains should be used in ways that add value to the Company's business by increasing efficiency. Provide worthwhile information and perspective. Try to avoid reinventing wheels and build on an existing knowledge base. Before publishing on a topic, inform yourself about it and find out whether anyone else has already covered the same ground. If you refer to someone else’s work, cite it appropriately, including providing links. If it helps you, your colleagues, our customers, or our business counterparts to do their jobs and solve problems; if it helps to improve knowledge or skills; if it contributes directly or indirectly to the improvement of the Company's products, processes and policies; or if it helps to promote the Company's values, then it is adding value. Personal commentaries on topics that do not relate to your job are not considered work-related.
7. Be Smart.
Though not directly business-related, some background information you choose to share about yourself, such as information about your family or personal interests, may be useful in helping establish a relationship between you and your readers, and it is entirely your choice whether to share this information. But also be smart about protecting yourself, your privacy and the privacy of others; be judicious in disclosing personal details. .
8. Do Not Pick Fights.
Avoid unnecessary or unproductive arguments. Do not court controversy for its own sake and do not try to settle scores or goad others into inflammatory debates. You should ask yourself whether use of a collaboration platform is the most appropriate way to resolve a particular point of dispute. If you make an error in what you placed onto a collaboration platform, be up front about your mistake and correct it quickly.
9. Respect Trademarks and Copyrighted Material.
You must honor all trademarks and copyrights held by others and may only use the Company’s trademarks and copyrighted materials when authorized to do so and in accordance with the Employee Policy Manual and Standards of Business Conduct. Your use of another’s trademark improperly could constitute trademark infringement and violate the law, and for that reason, you should not use the trademarks of others on collaboration platforms. Likewise, you must abide by the laws governing copyright and fair use with respect to copyrighted material. You should
never quote more than short excerpts of someone else's work. And it is good general practice to link to others' work rather than quoting it at length.
10. Respect your Co-Workers.
The Company wants all cast members and employees treated with fairness, dignity and respect. Remember that the Company is a global organization whose employees reflect a diverse set of customs, values and points of view. When expressing your views, do so respectfully. This includes not only the obvious (e.g., no ethnic slurs, harassing language, personal insults, obscenity or other conduct not appropriate in a workplace), but also proper consideration of topics that may be considered sensitive or inflammatory, such as politics or religion. If a collaboration platform is hosted on a Company-owned property or limited to Company employees, avoid these subjects and focus on ones that are business-related. It is fine for cast members to disagree, but do not use social media to air your differences in an inappropriate manner. Also, respect the privacy of your colleagues. For example, ask permission before posting on a collaboration platform any personal information about or picture of another employee, or a private conversation you had with another cast member.
11. Protect the Company’s Customers, Guests, Business Counterparts and Vendors.
Customers, guests, business counterparts, and vendors should not be cited or referenced without their approval. In external communications, never identify a customer, guest, business counterpart, or vendor by name without their permission and never discuss on collaboration platforms confidential details of any interaction with them. Collaboration platforms may permit customers, guests, business counterparts, and vendors to participate, so be sensitive to who might see your content.
Do not discuss specific details of projects or use non-identifying pseudonyms for a customer, guest, business counterpart or vendor that makes it easy for someone to identify the individual or entity. Be particularly careful not to violate any non-disclosure agreement. Remember, a collaboration platform is not the place to conduct confidential business with a business partner or anyone else.
12. Be a Responsible Member of the Community.
Participants using collaboration platforms are part of a community. Do not let someone’s misjudgment ruin the experience for everyone else. If you see a post that you believe is inappropriate, speak up. And, if someone is posting material that violates these or other Company policies (e.g., inappropriate or harassing content), you should report it to your supervisor, Human Resources, or the Guideline at (800) 699-4870.
