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United States securities and exchange commission logo
July 1, 2022
Deborah Thomas
Chief Financial Officer
Hasbro, Inc.
1027 Newport Avenue
Pawtucket, Rhode Island 02861
Re: Hasbro, Inc.
Form 10-K for
Fiscal Year Ended December 26, 2021
File No. 001-06682
Dear Ms. Thomas:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 26, 2021
General
1. We note that you
provided more expansive disclosure in your 2020 Corporate Social
Responsibility Data
Update ( CSR Report ) than you provided in your SEC filings.
Please advise us what
consideration you gave to providing the same type of climate-
related disclosure in
your SEC filings as you provided in your CSR Report.
Risk Factors, page 28
2. Disclose the material
effects of transition risks related to climate change that may affect
your business,
financial condition, and results of operations, such as policy and regulatory
changes that could
impose operational and compliance burdens, market trends that may
alter business
opportunities, credit risks, or technological changes.
3. Disclose any material
litigation risks related to climate change and explain the potential
impact to the company.
Deborah Thomas
FirstName
Hasbro, Inc.LastNameDeborah Thomas
Comapany
July 1, 2022NameHasbro, Inc.
July 1,2 2022 Page 2
Page
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations , page
44
4. We note your disclosure that you are subject to various United States
federal, state, local
and international requirements relating to the environment. Please
revise your disclosure
to discuss material pending or existing climate change-related
legislation, regulations, and
international accords and describe any material effect on your
business, financial
condition, and results of operations.
5. We note that you devote significant resources and expenditures to help
achieve your
sustainability goals. Tell us how you considered providing disclosure
regarding past and
future capital expenditures for climate-related projects related to
these goals. Include
quantitative information for the periods covered by your Form 10-K and
for future periods
as part of your response.
6. To the extent material, discuss the indirect consequences of
climate-related regulation or
business trends, such as the following:
decreased demand for goods that produce significant greenhouse gas
emission or are
related to carbon-based energy sources;
increased demand for goods that result in lower emissions than
competing products;
increased competition to develop innovative new products that
result in lower
emissions;
increased demand for generation and transmission of energy from
alternative energy
sources; and
any anticipated reputational risk resulting from operations or
products that product
material greenhouse gas emissions.
7. We note your disclosure that the risks of climate change include
severe weather events.
Please discuss the physical effects of climate change on your
operations and results, such
as weather-related impacts on the cost and availability of insurance
and weather-related
damages to your property or operations. As applicable, include
quantitative information
with your response for each of the periods covered by your Form 10-K
and explain
whether increased amounts are expected in future periods. Please also
discuss the
potential for indirect weather-related impacts that have affected or
may affect your major
customers or suppliers.
8. We note your disclosure on pages 25 and 70 about programs and costs
related to
compliance with environmental requirements. Tell us about and quantify
any compliance
costs related to climate change for each of the last three fiscal
years and explain whether
increased amounts are expected to be incurred in future periods.
9. We note disclosure in your Form 10-K and CSR Report regarding the use
of carbon
offsets. Please provide us with quantitative information regarding
your purchases or any
sales of carbon credits or offsets for each of the last three fiscal
years and amounts
budgeted for future periods. Provide your analysis as to the
materiality of the effects
those purchases or sales have had on your business, financial
condition, and results of
Deborah Thomas
Hasbro, Inc.
July 1, 2022
Page 3
operations.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact Erin Donahue at 202-551-6063 or Jennifer Angelini at
202-551-3047 with
any questions.
FirstName LastNameDeborah Thomas Sincerely,
Comapany NameHasbro, Inc.
Division of
Corporation Finance
July 1, 2022 Page 3 Office of
Manufacturing
FirstName LastName