Not really. Disney was not gifting the passes to the district, the district was choosing to spend part of their budget on employee benefits. The fact that Disney is ultimately paying for it is irrelevant, because it was the district's decision and the board could have chosen to spend that money on other things. And if anyone thinks "But Disney controls the board, so they forced them buy passes for the district employees."... if that were the case, and Disney had that much direct control over the board, why would they need to "bribe" the district with theme park passes?
You know what is a very explicitly-defined (by law) conflict of interest, though? Sitting on the State Ethics Commission while holding a government position.