Legal (India)

Generative AI Policy

Generally, production companies are restricted from using or permitting the use of generative AI or general-purpose AI models/systems such as Bard, ChatGPT, Claude, Codex, Cohere, Dall.e, Dolly 2, LLaMA, Midjourney, Mistral, Stable Diffusion, Sora etc. ("GAI") in connection with AS audio-visual content (including development, production, promotion and exploitation thereof), unless (i) the GAI is a Permitted GAI, (ii) the production company’s legal counsel reviews and approves such use (as compliant with the requirements set forth in this policy, applicable law and regulation, applicable guild/collective bargaining requirements, other Amazon policies, and contractual requirements, if any) and (iii) such use falls within the Permitted ProdCo Uses below and is not a Prohibited ProdCo Use. For clarity, this restriction also applies in relation to any on-screen talent, writers, directors, producers, or others engaged by or on behalf of the production company or any of the foregoing in connection with the AS content.

Production companies should communicate these restrictions to and require all on-screen talent, writers, directors, producers, or others engaged by or on behalf of the production company or any of the foregoing to comply with these restrictions.

Permitted GAI Tools/Services

• The Nova family of GAI tools in Amazon Bedrock: https://aws.amazon.com/ai/generative-ai/nova/

Permitted ProdCo Uses (for which notification to Amazon Legal is not required), which are subject to the below Requirements:

• Creation or modification of digital alterations, digital replicas, or synthetic performers to appear in AS audio-visual content, provided such uses are approved by Amazon Creative and Amazon Production;
• Traditional / historical practices, such as VFX, CGI, or alterations/manipulations customarily carried out in post-production such as:
  • Cosmetics/wardrobe, noise reduction, timing/speed, continuity, pitch/tone, clarity
  • Addition of visual/sound effects or filters
  • Adjustments for standards and practices or ratings
  • Adjustment in dialogue/narration or similar purposes
  • Where dubbing is already permitted by applicable collective bargaining agreement and/or talent agreement
  • Adjustment of lip/facial movements/voice to a foreign language where already permitted by applicable collective bargaining agreement and/or talent agreement
  • Changes in dialogue/photography for distribution in a particular market; or
• Outputs will be used for strictly internal use only and will not form part of the development, production, or marketing of the AS audio-visual content

Prohibited ProdCo Uses:

• Usage of any GAI tool/service other than Permitted GAI Tools/Services;
• Usage of any GAI (including Permitted GAI Tools/Services) for any purpose other than a Permitted Prodco Use;
• Disclosure of AS confidential information, including as an input or prompt into GAI;
• Usage of GAI as part of creative development (e.g. creation of scripts, treatments, series bibles, and similar materials, or any portion thereof); or
• Where the usage of GAI would cause the AS audio-visual content to be non-compliant with AS’s Content Standards (e.g., offensive images or symbols such as swastikas, obscene/indecent content such as sex scenes involving minors).

Requirements:

Any use of GAI in connection with AS audio-visual content must be:

(1) subject to appropriate quality control by a human reviewer; and

(2) documented by the production company (including but not limited to the Permitted Use and any technologies used) and shared with AS, together with a statement of compliance with the terms of this policy from the production company’s legal counsel. The executed statement of compliance should be sent by the date the last cut is locked to the AS IP Legal Team at GAI-compliance-statements@amazon.com (using the four-letter show code and current project title in the e-mail subject line) with the AS legal contact for the project in cc, as well as saved in the relevant Legal Deliverables folder

View Generative AI Policy Statement of Compliance

Legal Content Review

Overview

This policy applies to the following placements included during production: (i) product placements (i.e., accepting or agreeing to receive payment or other valuable consideration (such as marketing support) in exchange for including or referring to a particular product, service or brand/trade mark within a film, series, or other audio-visual content) and (ii) unpaid placements (also known as “prop placements” or “trade outs”), including wardrobe, travel, accommodation, locations, and props, where the value of all prop placements by a single brand exceeds USD $10,000 or local currency equivalent (such significant-value unpaid placements together with product placements, collectively “Placements”). 

This policy also applies to sponsorships, which refers to a company or person contributing to the costs of a production or an event (other than through any Placement(s)) for the purpose of promoting that sponsor’s or another’s name, brand, image, activities, products, or services (collectively, “Sponsorships”).

I. Placements
Generally, production companies are welcome to buy or rent whatever services or property are required for use in connection with a program they are producing at fair market value. However, in certain circumstances, Placements may be proposed and considered in connection with Amazon and MGM Studios original productions and Prime Video Branded Originals in compliance with this policy.
If a production company intends to engage an agency or consultant to source Placements,
it must use one approved by the AS Production team. All Placements must be pre-approved by:

1. the AS Creative Executive

2. the AS Production Executive

3. Production company’s legal counsel, and

4. The AS Promotions and Partnerships team to ensure that there are no conflicts with any marketing integration deals they may be pursuing (a team member will be assigned to the title).

All Placements must comply with the below requirements (including documentation requirements, category restrictions, portrayal and credit restrictions), any applicable talent restrictions (including any pre-existing contractual commitments to competing brands), and AS’s Clearance Guidelines set forth in this Production Manual. Any pre-existing talent endorsement deals with a product or service that will appear on screen should be notified to the lead AS Creative Executive and AS Content Standards.

Legal - Legal Content Review - Clearances
Production company’s legal counsel must review and approve each Placement and its agreement to ensure compliance with the requirements set forth in this policy and applicable law. Production company must record all Placements by populating a Product Placement Tracker form.

Documentation Requirements
If the arrangement is a Placement, it must be documented by entry into an agreement that complies with the minimum standards provided by AS Legal below. A template form and an addendum that can be added to third party paperwork is provided below. If the Placement is for an MGM motion picture, it must be reviewed and pre-approved by MGM Legal. For original content other than a MGM motion picture, if the Placement agreement has a value of $200,000 or more, the agreement must also be reviewed and pre-approved by AS Legal. When submitting for AS Legal review, please note if the template form or addendum is used, if so whether any elements of the template or addendum have been modified and if so identify which one(s), and confirm that the following minimum standards are reflected. Documentation of low-value prop placements that are not Placements is left to the production company’s discretion, but to the extent an agreement is entered into, it should also comply with the minimum standards set forth below.

1. No Creative Control – ultimate creative control of the content and Placement must be at the sole discretion of AS, and the Placement may not interfere with the editorial independence of the content or AS;

2. Right to Not Include Product – the agreement must clearly state that AS has the right to not go forward with the Placement, which may be for creative reasons or because the content will not be exhibited, in which event it may be agreed to return the consideration and/or product, and in the event the product cannot be returned, a cash-value should be assigned for repayment;

3. No Endorsement/Promotional References – the agreement may not include any obligation to endorse or promote a product, service, or trademark / brand (e.g., include advertising claims, encourage the purchase or rental of goods or services, provide price or availability information, or refer to the attributes or benefits of the product, service, or brand);

4. No Exclusivity or Blurring - the agreement may not commit to any exclusivity in relation to the category of product/service, or the blurring of competitor logos;

5. Waiver of Injunctive Relief – the agreement must include a waiver by the brand of injunctive relief (or restrictive covenant to the extent waiver is not enforceable under applicable law) against AS and the production company (i.e. in the case of a breach the brand may sue for damages only, no other type of relief);

6. Brand’s Waiver of Damages – the agreement must include a waiver by the brand of indirect, consequential, and punitive damages;

7. AS Commitments – any commitment to provide marketing support to the brand owner or create marketing assets specific to the placement must be requested and approved by AS Marketing, and no other commitments binding on AS should be agreed; and

8. Credits – the agreement may not conflict with the credit restrictions below.

Category Restrictions
AS does not permit Placements of any kind in documentary, current affairs, news, political, consumer affairs, religious or children’s content and does not permit Placements of the following products/services in any type of content:

• Firearms or other weapons, ammunition, related parts or accessories including replica guns
• Fireworks
• Cigarette or tobacco products, including nicotine pouches
• E-cigarettes or refill containers
• Other products of companies whose principal activity is manufacturing or selling cigarette, tobacco, e-cigarette or refill container products
• Cigarette lighters, cigarette papers, pipes intended for smoking
• Cannabis products or related products such as products that contain hemp
• Drug paraphernalia, drug tests, or products designed to beat drug tests
• Alcohol brands, drinks or edible products that may be used as an intoxicating agent
  (e.g. alcoholic ice cream)
• Non-alcoholic versions of alcoholic drinks (such as alcohol-free wine, beer, or spirits)
• Breath-testing devices or any other devices intended to mask the effects of alcohol or
  other intoxicating or mind-altering substances
• Medicines/medicinal products
• Medical devices
• Health services or medical treatments or facilities, including medical research solicitations
• Gender, paternity, infidelity tests, sexual assault test kits, STD test kits
• Sexual or explicit content products, including condoms and other forms of contraception, products claiming to enhance sex, and sexual wellness products
• Adult/sexual services or clubs
• Premium pay-per-call services
• Infant formulae or follow-on formulae
• UV tanning services or equipment
• Gambling or lottery products or services, including online gambling products/services
• Products related to elections or the political process, including any political party related and political issue-related products or services
• Financial or professional services (e.g., legal or accountancy services)
• Loyalty/affinity/rewards products or services
• Short-term, high-interest loans
• Psychics or related products/services
• Red band trailers or video content rated NC17 or Adult Only (or local equivalent)
• Religious or spiritual products or services
• Products, services, or technology that infringes, encourages, or enables the
  infringement of the intellectual property or personal rights of others
• Products, services, or technology, that promotes any illegal or dangerous activity, including hacking or evading law enforcement
• Any other product that cannot be advertised on television under law (e.g., illegal drugs, escort agencies, pornography, mail order brides) (all of the foregoing, collectively, the "Prohibited Products/Services”)

The following categories require prior review and approval from AS Legal:

• Tourism / location-based placements (e.g., hotel) where the location’s brand and/or distinctive architecture will be visible in the content

Content Portrayal Restrictions
1. Not Promotional - Content should not include (with respect to the Placement) any of the following: encouragements to purchase (whether direct or indirect), advertising claims, price or availability information, references (either explicit or implicit) to the positive attributes or benefits of the placed product, service or brand; slogans associated with the placed product, service or brand, and/or endorsements (either explicit or implicit); and
2. No Undue Prominence – In the content, Placements should not be unduly prominent. In general, undue prominence occurs when the degree of prominence given to a Placement is not creatively justified or explained by the editorial context of the program. Production companies should consult with their legal counsel to understand undue prominence but some examples might be an unnecessarily large number of references or extended close ups that are not justified by the storyline.

Credit Restrictions
1. An end credit for the brand must be included but must not be promotional or unduly prominent, and no other credits (such as opening credits) may be agreed. The end credit must not contain any advertising messages, calls to action, a list of placed products/services, information about the brand/products/services, or brand slogans /graphics / logos, but may contain the brand name. The end credit for the brand must not be unduly prominent in respect of its size, placement within the end credits, or duration.
2. Examples of approved product placement end credit wording include:

• “This program contains product placement.”
• “Product placement provided by [brand name].”
• “Promotional consideration provided by [brand name].”

3. Examples of approved prop placement end credit wording include:

• “With friendly support from [brand name].”
•  “Special thanks to [brand name].”

II. Sponsorships
All Sponsorships must be pre-approved by (1) the lead AS Creative Executive, (2) the AS Production Executive, (3) production company’s legal counsel, and (4) the AS Promotions and Partnerships team to ensure that there are no conflicts with any marketing integration deals they may be pursuing (a team member will be assigned to the title).

All Sponsorships must comply with the below requirements (including documentation requirements, category restrictions, portrayal restrictions, and credit restrictions) and any applicable talent restrictions (including any pre-existing contractual commitments to competing brands). Any pre-existing talent endorsement deals that may conflict with a proposed sponsorship should be called to the attention of the lead AS Creative Executive.

AS Legal and AS Content Standards
Production company’s legal counsel must review and approve each Sponsorship and its agreement to ensure compliance with the requirements set forth in this policy and applicable law. Any verbal or visual reference within the content to the sponsor or its products/services /brands (other than in the sponsorship announcement / credit) as a result of a commercial arrangement, shall be considered product placement (irrespective of the value) and must comply with the product placement section of this policy in addition to this sponsorship section.
Production company must record all Sponsorships by populating a Sponsorship Tracker form (an Airtable link will be provided by the relevant AS Clearance Manager).

Documentation Requirements
Each Sponsorship must be documented with an agreement that complies with the minimum standards provided by AS Legal below. A template form and an addendum that can be added to third party paperwork is provided below. If the Sponsorship agreement has a value of $200,000 or more, the agreement must also be reviewed and pre-approved by AS Legal.
(1) No Creative Control – the sponsor shall not be entitled to influence the editorial content of the sponsored program;
(2) No Endorsement/Promotional References – the agreement may not include any obligation to endorse or promote a product, service, or trademark / brand (e.g., include advertising claims, encourage the purchase or rental of goods or services, provide price or availability information, or refer to the attributes or benefits of the product, service, or brand);
(3) No Blurring – the agreement may not commit to any blurring of competitor logos;
(4) Waiver of Injunctive Relief – the agreement must include a waiver by the sponsor of injunctive relief (or restrictive covenant to the extent waiver is not enforceable under applicable law) against AS and the production company (i.e. in the case of a breach the brand may sue for damages only, no other type of relief);
(5) Brand’s Waiver of Damages – the agreement must include a waiver by the sponsor of indirect, consequential, and punitive damages;
(6) AS Commitments – any commitment to provide marketing support to the sponsor or create marketing assets specific to the Sponsorship must be requested and approved by AS Marketing, and no other commitments binding on AS should be agreed;
(7) License - the agreement must include the right to use the sponsor’s name and trade mark as envisaged in connection with the content; and
(8) Credits – the agreement may not conflict with the credit restrictions below.

Category Restrictions
AS does not permit Sponsorships of news or current affairs content and does not permit the following types of sponsors:

• Any sponsor not able to advertise on television under law (e.g., weapons manufacturers, escort agencies, breath-testing devices or product intended to mask the effects of alcohol, betting systems, products that are intended to facilitate winning games of chance, or pyramid promotional schemes)
• Any sponsorship for the purpose or with the direct effect of promoting any products or services that are Prohibited Products/Services, or companies whose principal activity is manufacturing or selling any Prohibited Products/Services.

Portrayal Restrictions
1. Not Promotional – Sponsorship credits / announcements should not include any encouragements to purchase or rent (whether direct or indirect) the products or services of the sponsor.

Credit Restrictions
1. Sponsorship must be clearly identified by means of a sponsorship credit which must include the identity of the sponsor by reference to its name or trade mark; and an association between the sponsor and the sponsored content. Examples of approved sponsorship credits include:

• “Official Partner of [Sponsor]”
• “In Association with [Sponsor]”
• “[Sponsor] proudly sponsors [Program]”

2. Credits must appear at the beginning and/or end of the program (and may appear elsewhere in the program) and the symbol/logo of the sponsor must also be shown (except in children's programs or religious programs which must not contain sponsor logos); provided that the graphic is static (i.e., not animated) and the credits contain no advertising message, call to action, or other information about the sponsor or its products / services / brands.

3. Any reference to the sponsor must be less prominent than the content itself (e.g., the font size for the sponsor credit should not be as large as the font size used for the title of the program).

4. Sponsorship credits / announcement must be distinct from the editorial content and any advertising/commercials (for example, by using an overlay, banner or split screen).The sponsorship credit / announcement should focus on the brand's sponsorship of the content, rather than general advertising for the brand's products/services (for example, the sponsorship credit should not include descriptions or claims about the products/services of the sponsor).

5. Any sponsorship credit / announcement should not be unduly prominent (e.g., a brief, neutral visual or verbal statement identifying the sponsorship arrangement accompanied only by a static graphic of the name and logo or distinctive symbol of the sponsor, that is not excessively large, frequent, or long in duration, except (with respect to the logo/distinctive symbol) in children's programs or religious programs which must not contain sponsor logos).

6. If a sponsor is prohibited from product placement in the sponsored program, then sponsorship credits / announcements may not be shown during the program (but may be shown at the end). For example, a children's program may not contain product placement, but is eligible for sponsorship; however, no mid-program sponsor credits /announcements could be surfaced in the middle of such children's program (only at the end).

7. Any sponsorship credit within a trailer must be brief and secondary to the primary purpose of the trailer of alerting viewers of a forthcoming program.

Based on or Inspired by Real People or Events

Prod Co is responsible for ensuring that all program content and materials will not infringe on the personal rights of any individual, living or deceased. These rights may include rights of publicity, privacy, honor, and repute, however identified under applicable law. At a minimum, any potential claims should be evaluated under the law of the jurisdiction in which the individual resides or resided, where they were deceased, the law of the country in which the content is produced, and the law of the country where the content is primarily intended to be marketed.

For projects that are based on or inspired by real people (including all unscripted projects) or characters based on real people, Prod Co is responsible for obtaining annotations of all scripts using the Annotation Guide. Please also refer to the country-specific Addenda within this Production Manual for any other country-specific requirements or additional vetting procedures. For unscripted programs, scripts must be created based on (and tracking) the edited cuts, and those scripts must be annotated. This applies to projects that not only depict real people or events, but also to projects that are inspired by real people or events, whether in whole or in a composite form.
Prod Co’s counsel is responsible for briefing Amazon Legal on any potential risks and proposed creative parameters for risk mitigation.

Clearances

Prod Co is responsible for ensuring that all program content and materials are cleared for use in all media worldwide, in perpetuity, on a full buyout basis, except as pre-approved in writing by Amazon Legal. Please carefully review Amazon Legal’s Clearance Guidelines. Clearance Guidelines set forth Amazon Legal policies pertaining to clearance issues, including, by way of example, clearance processes, copyright and trademark review standards for various intellectual property categories, competitive product prohibitions, location agreements, music clearance considerations, and personal information.

IP Management

Website & E-mail Addresses
Mentions or depictions of active or otherwise working non-Amazon website, e-mail addresses, or social media handles are not permitted, including in credits. Fictional site addresses may be referenced with prior approval provided that any such site name is registered or reserved for a period of not less than two years by and in the name of the production company as the account holder. No such registered names may be sold or subleased during the term of AS’s exclusive distribution term, nor may such registered names be utilized by the account holder or others under its control as an active or otherwise working website during the term of AS’s exclusive distribution term.

IP Management Introduction
All titles for any Amazon-branded films or series, including Amazon Originals and Amazon Exclusives, Amazon Freevee Originals, or Kids+ Originals, must be submitted to the Studios IP Legal team (IP Legal) for clearance. For all IP related questions please email studiosiplegal@amazon.com.

Copyright Notice

Films/Series (Wholly-Owned):

© [YEAR OF PUBLICATION] Amazon Content Services LLC or its Affiliates

Films/Series (Co-Productions):

© [YEAR OF PUBLICATION] Amazon Content Services LLC or its Affiliates and [Partner Studio Copyright Entity]

Ex: 2019 Amazon Content Services LLC or its Affiliates and Sony Pictures Television Inc.
Note: It is acceptable to reverse Amazon and Partner Studio.

Film Scripts:

© [YEAR CREATED] Amazon Content Services LLC or its Affiliates. All Rights Reserved.
This material is the exclusive property of AMAZON CONTENT SERVICES LLC OR ITS
AFFILIATES and is intended solely for the use of its personnel. No portion of this script may be performed, or reproduced by any means, or quoted, or published in any medium without prior written consent of AMAZON CONTENT SERVICES LLC. and applicable Affiliate

Additional Information:

• It is Amazon's policy not to include copyright lines in marketing or advertising for any wholly-owned or co-produced Amazon Originals.
• Note: Licensors of Branded Originals have approval rights over marketing materials, and may insist on a copyright line.
• Amazon Content Services LLC or its Affiliates is the correct Amazon entity for all copyright notices.
• The following language has no legal effect, and does not need to be included in a
  notice:
• ALL RIGHTS RESERVED. NOT TO BE DUPLICATED WITHOUT PERMISSION. This material is property of Amazon Content Services LLC or its affiliates, and is intended solely for use by its personnel. The sale, copying, reproduction or exploitation of this material in any form is prohibited. Distribution or disclosure of this material the unauthorized persons is prohibited.

Employment & HR

Paperwork

• No work may be performed by cast or crew until all necessary contractual documentation has been completed and signed between Prod Co. and Amazon Studios (“AS”).
• Each Prod Co must have its own Code of Conduct that is distributed to all personnel with the start paperwork packet.
• The Code of Conduct must, at a minimum, include policies prohibiting discrimination, harassment, and retaliation consistent with all applicable laws. These policies must define prohibited conduct; provide an effective method for employees to raise good faith concerns under the policies; and prescribe a mechanism for prompt and thorough investigation.
• All personnel must submit an acknowledgement that they have received, reviewed and agree to comply with the Code of Conduct.
• All cast and crew must enter into an employment or independent contractor agreement with Prod Co.
• Prod Co must collect all tax, data privacy notices, background check consent forms, right to work documents, attestations, and any other onboarding documentation required by applicable law.
• All Records, digital or hard copy, must be securely stored according to all applicable privacy laws.
• In certain jurisdictions, a data privacy notice must be provided and/or consent may be required prior to storing some or all of their Records.
• Access to Records must be limited to those with a specific business need to know (e.g., payroll processing or health & safety).
• As required by applicable law, an individual must be given access to their Records upon request.
• The Prod Co is the data controller and is responsible for ensuring compliance with privacy and data protection laws. The Prod Co must have a compliant Privacy Policy.

Equal Employment Opportunity Policy
Amazon Studios (“AS”) firmly believes in equal employment opportunity for all and the importance of each employee as an individual. There will be no discrimination against any employee or applicant for employment on the basis of race, religion, creed, color, national origin, citizenship, marital status, sex, age, sexual orientation, gender identity, protected veteran status, political ideology, ancestry, the presence of any physical, sensory, or mental disabilities, or other legally protected status. The Prod Co must recruit, hire, train, and promote persons in all job titles, and ensure that all other personnel actions are administered without regard to race, religion, creed, color, national origin, citizenship, marital status, sex, age, sexual orientation, gender identity, protected veteran status, political ideology, ancestry, the presence of any physical, sensory, or mental disabilities, or other legally protected status. The Prod Co must ensure that all employment decisions are based only on valid job requirements. Prod Co is required to have established procedures that are legally compliant to ensure that all personnel actions such as recruiting, hiring, compensation, benefits, training, transfers, promotions, layoffs, discipline, social and recreational programs, and all workplaces associated with AS are administered in compliance with applicable law.

Minors
If Prod Co utilizes the services of any cast member or other personnel who is a minor (i.e., an individual under the age of 18 or under the age of majority in the applicable jurisdiction), Prod Co must ensure compliance with all applicable laws or other requirements for working with minors. This includes, at a minimum, compliance with child labor laws, obtaining proper permits, obtaining written consent to work from parents/legal guardians, obtaining background checks (where permissible) for personnel working directly with minors, and notifying the appropriate government organization.

• Receipt and maintenance of applicable documentation (including labor permits, minor’s agreement, signed Parental Consent Form, and any other legally required documents such as academic standing, age, and/or physical fitness certificates)
• Having a teacher on set for minors who are of school age when school is in session
• Plans to have one guardian be present at all times within sight/sound distance while a minor is working or otherwise being utilized and at least one responsible person designated by Prod Co to supervise and safeguard the minors throughout their engagement while making sure the minor is never alone with a crew member (including the designated responsible person)
• Background checks for cast and crew that will be working with or in close proximity to any minors, if permitted and in compliance with applicable law
• Plans for having an established dressing room/rest area/bathroom that is separate from adults.
• No minor (i.e., anyone under the age of 18, regardless of the age of majority where the program is filmed) may be present on the set during any scene involving the indecent or obscene representation of a child or nudity (either of the child or another person), any sexual act / content (in real or simulation), gratuitous violence, or scenes involving firearms, or other mature content. Further, no child/adolescent shall be made to participate in making of any content which is not suitable / advisable / certified to be viewed by them. Please ensure all necessary and legally prescribed safety protocols are put in place.
• Additional safety protocols, parental/guardian releases, and/or other considerations if a minor is participating in activities that could be considered hazardous or sexual in nature, and only if legally permitted; and
• The portrayal of the minor is in accordance with the AS Content Standards. The requirement(s) are subject to applicable law, which prevails at all times.

Anti-Harassment Policy
Amazon Studios is committed to providing a safe and respectful work environment for everyone that is free from all forms of harassment, whether based on sex, or any other characteristic covered by Amazon's Equal Employment Opportunity Policy. AS expects that Prod Cos will comply with all applicable law and will promptly investigate all reports. Anyone who violates this policy will face discipline, up to and including termination of employment. This policy applies to all conduct that negatively impacts the work environment or reasonably interferes with an employee's ability to perform their job duties. Conduct prohibited by this policy is unacceptable in the workplace and any work-related setting outside of the workplace, including but not limited to:

• Business trips, meetings, dinners, and conferences;
• Training sessions;
• Social events, including non-business-related social events; and,
• Communications transmitted in hard copy or via social media sites, text messaging, messaging systems and other electronic forms, including those circulated outside the workplace.

This policy applies to all production personnel, including temporary workers, contractors, vendors, consultants, clients, customers, or sellers, when they interact with our employees. This policy is intended to be consistent with local and country laws prohibiting discriminatory harassment.

Employees who violate this policy are subject to discipline up to and including the possibility of immediate dismissal.

Harassment
Harassment is defined as unwelcome verbal or physical conduct that offends, humiliates or intimidates an individual because of any characteristics protected by law including but not limited to race, color, religion, national origin, sexual orientation, gender, gender stereotypes, marital status, disability, age, pregnancy, medical condition, and veteran's status.
Prod Cos must have their own anti-harassment policies in place. Such harassment may include conduct that creates an intimidating, hostile, or offensive work environment, or unreasonably interferes with an employee's work performance. Examples of harassment include:

• Making obscene gestures;
• Making racial or ethnic slurs, or drawing or displaying racial or ethnic graffiti;
• Leering or staring at someone;
• Making sexist remarks or stereotypical comments bases upon gender; and,
• Making jokes about a person's race, national origin, disability, or any other protected
  characteristic.
• Sexual harassment
• Sexual harassment is unwelcome and offensive conduct of a sexual nature, or on the basis of sex and gender, which offends, humiliates, or intimidates any person. Anyone can be the target of sexual harassment, regardless of the gender of the harasser and regardless of the position or level of the target or the harasser. What matters is that the conduct is unwanted and unwelcome by the person to whom the conduct is directed or a person who otherwise experiences the conduct. Sexual harassment may involve requests for sex or other unwelcome verbal or physical conduct of a sexual nature or based on sex, whether or not the harasser is sexually or romantically interested in the individual who experiences the conduct. Examples of sexual harassment include, but are not limited to:
  • Requests or demands of sexual favors, including unwelcome sexual flirtations, romantic attention, repeatedly asking a person out on a date that they declined, or propositions in exchange for preferential treatment;
  • Insulting or obscene sexual or sex-based comments, sexual jokes, or use of sexually explicit language, including comments about an individual's body or appearance;
  • Unwanted physical contact or gestures (i.e., touching, grabbing, or rubbing up against a person);
  • Circulating sexual pictures or videos; and,
  • Harassment based on an individual's sexual orientation or gender identity (i.e., teasing a man who is feminine, a woman who is masculine, or LGBTQ status).

Methods of communication
Conduct may result in a violation of Prod Co policies whether in person, on the phone, or over electronic communications, including but not limited to: hand-written notes or cards; internal messaging sites like Chime or Skype; email, voicemail, or text message; dating and social media sites like Instagram, Facebook, Snapchat, Twitter, WeChat, or WhatsApp; and anonymous and/or print or electronic bulletin board communications like Blind. This includes communications circulated outside the workplace that may interfere with an employee's ability to perform their duties.

Work-related exposure to adult-themed materials
In many areas of our business, we create, market, and distribute a wide variety of products and programming. Some of these are adult-themed or sexually explicit. They may include images and speech related to race, religion, sexual orientation, gender identity or expression, marital or family status, national origin, disability, or age. Your personnel may be exposed to products that some may consider offensive and in such cases, we expect the Prod Co to sensitize their personnel on how to appropriately handle such situations in accordance with applicable laws. Mere exposure to products and programming does not violate this policy. However, the use of any product or programming by an employee to harass another employee would violate this policy. If your personnel have concerns about their exposure to this material or their work environment, they can contact:

• UPM
• Their manager;
• ProdCo Human Resources; or
• The Anonymous Production Hotline

Investigation of complaints
Reports of harassment or inappropriate conduct must be promptly investigated. To the extent required by law, the privacy of all involved parties should be protected.. Prompt, appropriate, and proportionate corrective action must be taken to stop the offending behavior, as deemed appropriate under the circumstances. Cooperation with investigators should be ensured.

Retaliation
Retaliation (or victimization) is a negative action taken in response to someone reporting harassment, participating in an investigation, or engaging as an active bystander. Retaliation of any kind must not be tolerated by the Prod Co against any personnel who makes a report or participates in an investigation or proceeding related to harassment. If any personnel believe that they have been retaliated against for making a report of harassment, or participating in an investigation or proceeding related to harassment, they should report their concerns immediately to the UPM, their manager, Human Resources, or the Anonymous Production Hotline.
Negative action does not include regular performance management, unless new action is taken because of the filing of a report of harassment, participating in an investigation, or engaging as an active bystander. The negative action does not need to be job-related or occur at work to be considered retaliatory. A report of retaliation will be investigated and, if substantiated, appropriate disciplinary action will be taken.

Accommodations
Prod Co is responsible for providing reasonable accommodations to qualified contractors/ personnel/ employees in compliance with applicable law. This may include accommodations due to a disability, pregnancy, religious beliefs or practices, and any other circumstance or condition that employers or service providers are required to accommodate under applicable local law. Personnel should be informed of how to request an accommodation and may be required to submit additional documentation. That documentation must be stored in accordance with all applicable privacy laws.

Leave from Work
Prod Co is responsible for ensuring any legally required paid or unpaid leave is provided to personnel in compliance with all applicable laws.

Visas & Right to Work
All personnel must have the right to work in the territory where their services are provided, and it is Prod Co’s responsibility to confirm all personnel have such right to work. Prod Co must be responsible for any required visa or work permit with respect to its personnel.

Anonymous Production Hotline
Amazon MGM Studios (AS) provides an Anonymous Production Hotline for production personnel to report ethics, health, safety & security concerns by calling in or submitting a report online. This resource is required to be made available to cast, crew & contractors supporting all phases of production (i.e., prep, production, post, music; VFX). The AS Production Executive will setup the production's account during prep. The Prod Co will be notified by Navex, vendor that manages the Hotline, when the account is setup.
Hotline numbers are located on the Hotline posters, QR codes & process flow charts can be found.
The Hotline number & reporting portal must be listed on all call sheets, production schedules; contact sheets for the duration of production-related work. The Hotline poster must be posted alongside any local regulatory postings and included in start paperwork. Additionally, an announcement should be made at the first safety meeting notifying cast and crew that the Hotline exists. The designated contacts for each Prod Co will be notified by the AS Production Attorney or the Prod Co’s production attorney whenever an ethics or safety report on one of their productions is received through the Anonymous Production Hotline.
The Prod Co is responsible for reviewing each report and determining the appropriate response. This may include conducting a formal investigation. AS will assist in this determination and the investigation process as it deems necessary. Please see the NAVEX Ethicspoint Hotline Complaint Process for further details on the Anonymous Production Hotline process, as well as the Production Process Ethicspoint Setup for guidance on how to get a production entered into the Safety & Ethics Hotline system reporting portal here.

NAVEX Ethicspoint Hotline Complaint Process here.
Production Process Ethicspoint Setup
For additional questions about the hotline process, please reach out to <insert production alias> . A hotline number cannot be used until it is registered by the AS Production Executive. here Studios-Hotlines@amazon.com

Training / Compliance

Health, safety, and other trainings are required by Prod Co and/or its personnel as per applicable law. The Prod Co must ensure delivery of anti-harassment training, and any other legally mandated forms of training to every cast, crew, and executive team member at the beginning of principal photography. While in-person training is preferred, virtual training is acceptable. Production workers are required to complete training within five (5) days of their first day of work on the production. AS may provide anti-harassment training content and/or a list of approved vendors, if requested by Prod Co. Prod Co must select a vendor to deliver training, as well as submit a list of attendees and attestation of training completion to AS. Production workers who provide proof of comparable anti-harassment training in the previous 12 months may be exempted from training. Individuals with supervisory responsibilities should undergo additional training as required by law.

Interns
The Prod Co must comply with all applicable laws and regulations related to engaging interns, including minimum pay, overtime, and benefits.

Complaints / Disputes / Grievances / Terminations / Layoffs
Prod Co must follow all processes and procedures required under applicable law relating to personnel complaints, disputes, grievances, terminations and/or layoffs, including any information/consultation requirements. All personnel disputes, grievances and terminations or layoffs must promptly be escalated to AS Production and AS Legal. Any complaints regarding alleged discrimination, harassment, retaliation, policy violations, or other employment legal matters must be immediately escalated to Amazon Studios Legal and any other individuals required by local law.

Legal Deliverables

All Production Companies (“Prod Cos”) are expected to deliver certain legal documents (“Legal Deliverables”) into a designated delivery location for review by the Amazon Studios (“AS”) Legal Team. The designated delivery location will be provided to the Prod Co by AS Production. This section addresses only the legal deliverables requirements. The Prod Co must organize the documents as outlined below. Please do not use any symbols (#, *, %, $) or punctuation when naming the documents as the AS system will not recognize them. All documents must be fully executed. All documents must be uploaded to the corresponding Box folder, even if they have been distributed to Amazon Legal prior to receiving access to the Wrapped Deliverables folder.

Working Hours & Payroll Practices

• Prod Co must comply with all applicable laws regarding permitted hours of work, meal periods and rest breaks, and any other required breaks.
• Prod Co is responsible for proper classification of employees and ensuring compliance with all wage and hour and working time laws.
• Prod Co is also responsible for withholding and remitting tax and social insurance contributions for employees and must provide necessary wage information to all employees according to law.
• Prod Co is also responsible for any required time keeping records and policies for employees.
• Prod Co is responsible for handling all business expense reimbursements for employees

Legal Deliverable Checklist

Please include all of the following listed below, as applicable to your production.

1. Master Clearance Log
2. Signed Material Use License Agreements

• Footage and Still Licenses
• Art/Props/Set/Wardrobe Releases
• All misc. Licenses/Releases
• Likeness Releases

3. Signed Above the Line Agreements

• Creator
• Executive Producers and/or Co-Executive Producers
• Producers
• Writers
• Directors
• On-Screen Talent and Voice Over Talent
• Casting Directors
• Above the Line Restrictions Memos (as directed by AMZ Legal)

4. Signed Appearance, Guest, Day Player Releases, and Agreements
5. Signed Below the Line Crew Agreements

• Department Heads
• Editors
• Graphic Designers
• All Other Crew

6. Dubbing Restrictions Memo
7. Editing-Restrictions & Obligations Memo
8. Docs Related to the Employment of Minors (if applicable)

• Court approvals
• Coogan account if applicable, etc.

9. Signed Service Agreements

• Subcontractor Agreements for Production Services
• VFX Agreements
• Vendor Agreements
• Creative Services
• Animation Services
• Voice Record Services, etc.

10. Signed Location Agreements and Permits
11. Signed Rental or Purchase Agreements and Releases
12. Certification of Compliance with Pence Act (Initial Season Only)
13. Sworn Affidavit of costs paid and confirmation of no liens
14. Copy of Final Contest Rules (if applicable – Unscripted TV Only)
15. Music

• Music Supervisor Agreements
• Composer / Lyricist Agreements
• Label/Publishing Waiver

16. Union/Guild (If Applicable)

• SAG-AFTRA / ACTRA or other applicable acting guild
• Agreement or Adherence Letter
• New Show Info Sheet
• Final Cast List
• DGA
• Agreement
• Project Info Form
• Copies of all DGA Deal Memos
• Waivers (if any)
• IATSE 839 (If applicable)
• Agreement or Adherence Letter
• Project Info Form
• Waivers (if any)
• Unique/One Off Union Agreements

17. Paid Ad Statement
18. Billing Blocks (Features Only)
19. Product Placement Statements (if applicable)
20. Certificate of Origin (as directed by AMZ legal)
21. CNC Certificate (FR Theatrical Release Only)
22. Miscellaneous