CORRECTIVE ACTION PLANS
After receiving and analyzing an ILS Audit Report received from you or as the result of an ILS Audit conducted by Disney, Disney may issue a Corrective Action Plan (“CAP”). The CAP will provide a summary of the violations of the Disney Code of Conduct. You are expected to review the CAP with the Facility and implement steps to promptly remedy any MCS violations identified prior to the time a follow up ILS Audit is required. (See Appendix 14: Sample Corrective Action Plan for more information and the Remediation of Noncompliance section for details.) You should also use either the CAP or the ILS Audit Report to address all Code violations identified and to make continuous improvements in working conditions at the Facility.
WORKING WITH SOCIAL COMPLIANCE MONITORING
ORGANIZATIONS AND SOCIAL COMPLIANCE CONSULTANTS
Social Compliance Monitoring Organizations may conduct ILS Audits using a program accepted by Disney and, in some cases, may also be available to support the remediation of compliance violations. (See Appendix 5: Social Compliance Monitoring Organizations for a representative sample of organizations that conduct ILS Audits.) Disney is not bound by any interpretation of Disney policy, any opinion as to whether a Facility is compliant with Disney standards, or any guidance on follow-up action provided by a Social Compliance Monitoring Organization or a social compliance consultant. Before engaging a Social Compliance Monitoring Organization or a social compliance consultant, ensure that the Facility management understands the Code and that your representatives must be permitted full access to the Facility premises, relevant documents, and workers for private and confidential interviews. (See Appendix 12: Sample ILS Audit Agenda and Appendix 13: Sample ILS Audit Records Checklist for more information.)
When working with a Social Compliance Monitoring Organization, you may wish to:
? Request that a qualified ILS Audit be conducted by the Social Compliance Monitoring Organization.
? Ensure that the organization you choose can conduct the ILS Audit according to your schedule, as audits may take time to arrange based on Facility location and monitor capacity.
? Review ILS Audit results with the Social Compliance Monitoring Organization and communicate a remediation plan to the Facility.
? Send a copy of the ILS Audit Report to Disney. The Social Compliance Monitoring Organization will not send the ILS Audit Report to Disney unless specifically authorized by you to do so.