U.S. Securities and Exchange Commission and Walt Disney Company

In organizations where there seems to be an increasing focus on unethical behavior within public companies from senior managers, it is vital that organizations establish policies and processes to ensure that it is complying with the rules and regulations put in place by the Securities and Exchange Commission. Walt Disney Company is able to meet its reporting requirements for the Security and Exchange Commission by using the following resources.

The availability of technology, internal disclosure controls, internal controls over financial reporting, and independent accounting auditors who verify that these controls are in place and working as intended. The SEC requires that Disney posts all Interactive Data Files. These files are required to be submitted and posted pursuant to Rule 405 of Regulation S-T during the preceding 12 months. Viewing the Investor Relations tab of The Walt Disney Company corporate website shows that historical SEC filings are listed by category for a variety of required reports, including forms 10-K, 10-Q, 8-K, 11-K, S-8, 425, S-4, and proxy statements.

Disney uses internal disclosure controls by their policy that all SEC filings be signed by a senior member of the management. These people are President, CFO, Managing VP and Internal Counsel helps ensure that the filings are correct, comply with reporting requirements, and are communicated to the other stakeholders in the management of Disney. These are Board of Directors and other Senior Members of the management team. In an era where CEOs and CFOs are continually being called before US Congress to testify on the financial situation within their firms, this policy adds a layer of accountability to senior management.

Internal Controls over Financial Reporting. Company management explicitly acknowledges their accountability for being able to create accurate, reliable, sufficiently detailed, and timely external financial reports Independent Accounting Auditors. Disney makes use of PricewaterhouseCoopers as an independent auditing firm to provide a third party analysis of their internal controls over financial reporting. In addition, PricewaterhouseCoopers’ own report to the Board of Directors and Shareholders of The Walt Disney Company is included in the Annual Report and discusses the process by which Disney’s internal controls over financial reporting are tested and audited to provide a reasonable level of assurance that the controls are working and that external financial reports are being reported based on generally accepted accounting principles as required by U. S. Law. By following all of the procedures that Disney has put into place they can be positive that they are following the SEC rules and regulations.