JAKKS EMBARGO / SECURITY GUIDELINES

EMBARGO/SECURITY GUIDELINES

FOR HANDLING CONFIDENTIAL INFORMATION & RESTRICTED MATERIALS

 IMPORTANT OVERVIEW

Because we are entrusting to you Confidential Information and Restricted Materials (both, as defined below) from both our valued licensors as well as JAKKS Pacific, Inc and Disguise, Inc. (collectively, “JAKKS”), these Embargo/Security Guidelines (“Guidelines”) provide some practical guidance to assist you in securely handling the Confidential Information and Restricted Materials entrusted to you. These Guidelines are minimum standards for you to follow. Based on the nature of your company’s operations, you are encouraged to adopt additional practices and procedures to safeguard both the Confidential Information and Restricted Materials in your possession.

JAKKS holds a great deal of “Confidential Information” (as defined in the Mutual Confidentiality & Non-Disclosure Agreement (“MNDA”), some of which belongs to JAKKS itself, while much of it is entrusted to JAKKS by our valued licensors. We focus on continuously maintaining the secrecy and security of all this Confidential Information, as all information that each licensor provides to us is treated as Confidential Information that deserves protection.

Each licensor may also provide a list of “Restricted Materials” (as defined in the MNDA) containing embargoed imagery, storylines, characters, scores, and movie or promotional elements with specific embargo release dates: i) by character or element (if the dates vary by type or kind) and ii) by specific parties for whom the embargo will be lifted (e.g., factories, distributors, retailers, or consumers). In short, Restricted Materials are time-restricted or recipient- limited subsets of Confidential Information.  All Restricted Materials must be very closely guarded and not disseminated until the exact embargo release dates the licensors authorize for disclosure to specified parties and ultimately, to consumers.

JAKKS will provide you with specific embargo information for each property or brand as we receive such information from our licensors. Be aware that Restricted Materials within the same licensor brand could have different embargo release dates and/or different authorized recipients, and these embargo release dates sometimes change based on our licensors’ changing business plans. When in doubt, verify any embargo release dates with your JAKKS contact.

Despite everyone’s best efforts, leaks of Confidential Information or Restricted Materials can happen. If you  suspect or know a leak has occurred, please immediately email legal@jakks.net and alert your JAKKS contact immediately.

IT ALL BEGINS WITH TRAINING

Confidentiality & Trade Secret Protection Training

Every business possesses confidential information that they must safeguard.  Respect for confidential treatment of such valued assets begins with employee education. We encourage you to provide training to  your employees so that they understand the importance of confidentiality and trade secret protection – and especially of Restricted Materials – and how to safeguard these important assets. Tailor this training to your specific company’s operations.  

Licensor Training Programs for Handling their Confidential Information and Restricted Materials

Many licensors require people who handle any of their Confidential Information or Restricted Materials to be trained in specific processes or procedures for protecting their assets. As a downstream recipient of our licensors’ Confidential Information and/or Restrictive Materials, your employees who handle these assets in any way should complete all such required training.

For example, Disney mandates that before handling any of their Confidential Information or Restricted Materials, every recipient must complete Disney’s SHIELD training. If your company receives Disney Confidential Information and/or Restricted Materials, your employees must complete the SHIELD training. Your company can create a profile in the SHIELD training database by emailing CPGP.SIP@disney.com with a list of all team members (including first and last names, and email address) who will be handling Disney assets at your company. Each person to be trained will receive an individual email from Disney (the email will come from support@disneytrainingalerts.com) assigning personal login credentials and instructions for completing the training, which must be done within seven (7) days of receiving the email. Disney requires that this training be repeated annually.

WATERMARKING

Watermarking helps to ensure traceability of documents. When sharing materials containing Restricted Materials, all pages must be watermarked with the recipient company’s name, individual recipient’s email, and date shown to the recipient. These watermarked materials are highly confidential and must not be disclosed prior to the applicable embargo release dates without the licensor’s specific approval. JAKKS’ team will communicate the embargo release dates with you as they receive such information from licensors.

GENERAL GUIDELINES ON HANDLING

CONFIDENTIAL INFORMATION AND RESTRICTED MATERIALS

  • Verify that EVERY person to whom you send any Confidential Information or Restricted Materials has signed a Confidentiality & Non-Disclosure Agreement with your company that provides parallel protections as the MNDA your company signed with JAKKS.
  • Never share any Restricted Materials without the prior consent of JAKKS or its licensor.
  • Never post Confidential Information on creative boards, walls, conference rooms, or offices visible to those who do not have a genuine business need to know.
  • Never share any Confidential Information with anyone outside the project team (including family or friends!) unless they have a genuine business need to know.
  • Never take (or allow others to take) pictures or videos of any Restricted Materials (including products or packaging) unless specifically authorized and required by your job function.
  • Never share any work-related Confidential Information with family members or friends, and never post same on social media or blogs, until after applicable embargo release dates have passed (and even then, only if the material shared is appropriate for sharing).
  • If Restricted Materials are on your phone/computer, set the device to automatically lock if left unattended.
  • Print outs:
    • Never leave items with Restricted Materials at a printer; pick up all printouts immediately.
    • After both internal & external meetings, always collect printouts containing any Restricted Materials.
    • Keep printouts on your desk face down when away from your desk.
    • Lock printouts in your desk overnight or if you’ll be away from your desk for an extended period.
    • Put shredders or shred bins near every printer, and shred printouts with Confidential Information immediately when no longer needed.
  • Product Samples:
    • If you are a retailer, you must supply JAKKS with names and contact info for all employees handling embargoed imagery or products.
    • Pre-release product samples may only be shipped directly to one of the retailer employees identified above who signs an official receipt of shipment.
    • Pre-release product samples must be destroyed by the retailer and certified upon request.
  • Electronics:
    • Secure devices (laptops, phones, and tablets) by turning devices to “Lock Screen” or “Sleep” mode when not in use to prevent others from viewing Confidential Information or Restricted Materials.
    • Store devices in a safe place when away from your office or desk and follow procedures in your work location, such as locking your office door when leaving for the night.
    • Always lock your workstation whenever walking away from your computer.
    • Never transfer Restricted Materials from one location to another using portable storage without the USB device (or drive) being encrypted and password protected.
  • Restricted Materials:
    • Communicate in writing the applicable embargo release dates to all personnel within your company who have a need to know.
    • Withhold all embargoed graphics or other elements for embargoed recipients until the embargo release date occurs.
    • Never include Restricted Materials imagery or descriptions on retailer price lists.
    • Sketches and photography of Restricted Materials may ONLY be shown to authorized recipients via a watermarked presentation that has been approved in advance by the licensor.
    • Clean, unwatermarked images of Restricted Materials should ONLY be shared with authorized recipients after the licensor’s written approval.
    • Limit sharing via Zoom or Teams meetings (or similar) to an absolute minimum; if you must do so, always watermark each presentation page and never linger on any slide with Restricted Materials.
    • For presentations with Restricted Materials where a leave-behind handout is required, the licensor must review in advance and provide direction on what may need to be removed from the handout.

ELECTRONIC TRANSFER OF

CONFIDENTIAL INFORMATION AND RESTRICTED MATERIALS

  • Restricted Materials should:
    • Be distributed internally only to those with a genuine business need to know.
    • Be password protected and watermarked (see instructions above) prior to any electronic transfer.
    • Never be transferred by email.
    • Never be saved or transferred using public online storage (e.g., Google Drive, DropBox).
  • Remind all recipients of the secrecy and security required for protecting the assets.
  • Keep track of the identity of all third-party recipients of Restricted Materials and provide the list to JAKKS or licensors when requested.

SETTING UP WEBSITE LISTINGS FOR RESTRICTED MATERIALS

If you are setting up an online listing for products containing embargoed Restricted Materials:

  • For Amazon, suppress listings so they are un-searchable on Amazon.com before the embargo release date.
  • For all retailers (including Amazon):
    • If listings are required to have placeholder information:
      • If image is required: Add a placeholder image. Never use embargoed images.
      • If title is required: Use generic item titles (e.g., ‘Character #1’, ‘Character #2’).
      • If bullet points are required: Put no identifying information in the bullet points.
  • Update site images and descriptions ONLY ON the embargo release date, not earlier.

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