APPENDIX 4
EXAMPLES OF MINIMUM COMPLIANCE STANDARD (MCS) VIOLATIONS
Examples of Minimum Compliance Standard (“MCS”) violations include, but are not limited to:
CHILD LABOR
Any confirmed current employment of underage workers or any inappropriate remediation of child labor
violations under applicable laws including, but not limited to the following examples:
• One or more employees are younger than the legal working age.
• Compliance with the minimum age requirement is unable to be verified because of the lack of the required
proof-of-age documents.
• Facility management did not ensure the safe return of previously hired underage worker(s) to his/her parents
or legal guardians.
INVOLUNTARY LABOR
Any confirmed current employment of forced, bonded, indentured, or prison labor; mandatory or involuntary
overtime, or imposition of penalties or fines for refusing overtime; withholding of personal property
(e.g., passport, identification papers) or wages; or unreasonably limiting freedom of movement during and/or
after work hours including, but not limited to the following examples:
• Employees are fined for refusing to work overtime.
• Access to the restroom is permitted only during break time.
• Documents, monetary deposits, or other collateral are retained as a condition of employment. Workers are
subjected to the withholding of wages, identification cards, passports, or other travel documents, or other
personal belongings.
COERCION AND HARASSMENT
Any policy permitting, or the actual use of, corporal punishment; threats of termination of employment;
imposing penalties or retaliation as disciplinary action; or intrusive or intimidating security practices including,
but not limited to the following examples:
• Employees selected for interviews by auditors were intimidated by management.
• Employees who disagreed with job arrangements were restricted from working overtime.
• Some employees were verbally and/or physically abused by a supervisor.
NONDISCRIMINATION
Discriminatory hiring and employment practices (e.g., salary, benefits, advancement, discipline, termination,
or retirement) on the basis of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender,
political opinion, disability, pregnancy, or union membership including, but not limited to the following examples:
• Job applicants are subject to HIV testing as part of the hiring process.
• Migrant employees receive lower wages for the same job held by local employees.
• The Facility recruits only females between the ages of 18 and 25.
ASSOCIATION VIOLATIONS
Policies or practices that prevent employees from exercising their legal right to associate, organize, and bargain
in a lawful and peaceful manner in accordance with applicable laws (or retaliation for the exercise of any
such right) including, but not limited to the following examples:
• Employees were punished for participating in union activities.
• Employees were dismissed for participating lawfully in a labor strike.
HEALTH AND SAFETY
Conditions in the Facility, including dormitories, that could cause immediate severe injury or death to employees
or the public including, but not limited to the following examples:
• Emergency exits are locked or obstructed.
• The number of required emergency exits is insufficient.
• Emergency evacuation drills are not conducted regularly.
SUBCONTRACTING
Any use of another Facility or other source for Disney-branded production without authorization from Disney.