Our assessment process often results in findings of noncompliance with one or more of the standards set forth in our Code of Conduct. We use this information to help us prioritize issues and resource deployment, and then conduct a prompt investigation of the situation. The most common violations found during assessments are related to health and safety, excessive working hours, inability to verify compliance (in part due to record discrepancies) and overtime wages.

We take several steps to identify areas that need to be addressed.

 1   At the end of a factory assessment, monitors explain preliminary findings to the factory management.

 2   Assessment reports are then reviewed by our ILS team who further evaluate the factory's compliance against the Code and local labor law and then create corrective action plan letters or other reports to communicate expectations for remediation to the licensees and vendors responsible for choosing those factories.

 3   Depending on the type and level of nonconformance, factories are given a certain period of time to demonstrate improvements in factory working conditions, which are then typically verified through follow-up assessments.

 *  Our Code of Conduct for Manufacturers contains 12 provisions that we expect manufacturers to meet. However, noncompliance with some of these provisions creates greater immediate risk to factory workers. Accordingly, we prioritize certain violations that require immediate correction. Examples of our zero tolerance" issues include child labor, involuntary labor and physical abuse. Other issues require prompt attention, but we will allow factories time to correct them, including wage and hour violations.

 4   Licensees and vendors are expected to communicate the findings to the factories and support their remediation efforts.

 5  Ultimately, the factory is responsible for taking corrective action.

Though we strive for sustained improvement in factory compliance, continued noncompliance with the Disney Code and local labor law may result in a factory being declared ineligible for Disney production. In our fiscal year 2008 we withdrew production authorization from approximately 500 factories due to severe or continued noncompliance.

In addition to non-compliances identified through the assessment process, we also receive information from and act upon claims brought to us by other sources NGOs, unions and other companies. We use this information to help us prioritize issues and resource deployment, and then conduct a prompt investigation of the situation. We then work with the factory, the licensee or vendor who sourced the product, and sometimes other parties to develop a remediation plan to help bring the factory's operation into compliance.