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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Benchmarking Alert: Disney’s roller coaster anti-corruption policy

The Walt Disney Company has had an immeasurable impact on countless people all over the world in the last century. It made a name by turning ink on paper into something new — lifelike, likable, and inspiring characters. Its global anti-corruption policy is somewhat different. How does it compare?

1. FCPA is the focus, but global laws are in the extended universe.

The Company is committed to observing the laws of every country in which it does business, including those prohibiting corruption. Disney Employees and Third Parties doing business in any country must comply with the laws in that country in every respect. Where the local laws are more stringent/restrictive than the FCPA, the local laws will take precedence.

2. Use caution when hiring a prince or princess.

An offer of employment or a paid or unpaid internship may also constitute an advantage under the FCPA, UK Bribery Act or local anti- corruption law. Accordingly, any offer of employment by the Company to a person the Company knows or believes to be a relative of a Government Official or of a person or entity doing business with the Company– or if any such offer results directly or indirectly from the recommendation of a Government Official or such person or entity – must be carefully evaluated to ensure that it is based on relevant job-related criteria, is not intended as a benefit to the Government Official, and complies with the Hiring Policy.

3. These are not the facilitation payments you’re looking for.

Facilitation payments are prohibited under this policy except in case of duress.

This is similar to Unilever, Carlsberg, Apple, Novartis, Microsoft, Volkswagen, Airbus, GM, 3M, and Pfizer that all ban facilitating payments. Coca-Cola, Tesla, and ExxonMobil might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. Avoid being frozen in carbonite.

Because physical health and safety is of paramount importance, this policy is not intended to require anyone to put their health and safety at risk. Accordingly, in a situation where a payment is demanded, and failure to comply would reasonably create a risk to your health and safety, or that of a family member or colleague, the payment may be made.

This is similar to Unilever, Carlsberg, GM, Microsoft, Pfizer, and ExxonMobil the only other mentions of extortion we’ve seen.

5. Don’t use agents as a shield.

Because the Company may be held responsible under the FCPA and other laws for the wrongful acts of intermediaries (including Third Parties) even if the Company did not authorize such actions, retention of intermediaries presents a significant risk to the Company. Accordingly, this policy prohibits offering or paying anything of value to any person, knowing that all or part of the thing of value will be offered, given or promised to anyone, including a Government Official for an improper purpose.

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Click here to view the full 19-page Walt Disney Company anti-corruption policy

View more anti-corruption policy benchmarks here.

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