Governance and Ethics
Ethics
An ethical approach to doing business is embedded into our culture, values and day-to-day work environment. Our formal ethics program began in 1991, when we introduced a comprehensive Code of Conduct with mandatory training for employees.
In 1994, our Chief Legal Officer (CLO) also assumed the position of Chief Ethics Officer. Responsible for the management of all ethics issues, the CLO regularly briefs the company leadership on internal compliance and trends related to our global business.
We provide extensive training to management and employees on legal and ethical matters relevant to the day-to-day work environment across our global offices. These include, for example, fair treatment in the workplace, ethical business practices, competition laws, and potential conflict of interest. We train management and employees on the Foreign Corrupt Practices Act, antitrust laws, anti-bribery laws and IP protection, tailoring our approach to account for cultural differences in our facilities around the world.
Our chief executive officer (CEO) is a highly engaged and visible advocate of compliance, providing regular updates to our global workforce. In 2010, he highlighted the importance of an ethical culture in a video emailed to all employees, and linked to their ethics training. He also writes a regular “Compliance Corner” column in the company newsletter.
"In support of our commitment to fostering an ethical culture, we check the ethics hotline and mailboxes daily, and we respond to all ethics inquiries from employees."
Helpline
Understanding that ethics issues can be sensitive, Hasbro operates a global ethics helpline and two confidential mailboxes (administered by the head of the Audit Committee and Chief Legal Officer). Employees can use these to report ethics concerns anonymously and without fear of retaliation. The CLO’s office checks the ethics hotline and mailboxes daily and responds to all ethics inquiries.
Managers are required to report any ethical issues that arise, and investigations and disciplinary action follow if necessary. Noncompliance with our Code of Conduct may result in disciplinary measures, with termination of employment the ultimate sanction.
Code of Conduct
Hasbro first adopted a Code of Conduct in 1991 and our ethics and compliance program was updated in 2006.
The Code, available here, applies to all employees worldwide as well as our Board of Directors. Its purpose is to:
- Ensure we do business ethically and legally
- Provide employees with appropriate understanding of our policies and the ability to raise concerns
- Enable ethical issues to be reported and acted upon without retaliation.
All employees and officers receive training on the Code of Conduct when they first join Hasbro and take periodic refresher courses. As of December 31, 2010, 100 percent of eligible employees had completed the classroom training, which was based on real life situations experienced under our Code.
Public Policy
The toy industry is subject to regulation at national and local levels worldwide. Changes in the laws governing our industry can have an impact on our business.
Hasbro welcomes and takes active part in public policy debates surrounding our industry, particularly those centered on product safety, environmental restrictions for operations and manufacturing, and marketing to children. We realize the importance and shared benefit of dedicating time and effort in engaging with governments. In 2008, after a series of toy recalls triggered a global regulatory review of the industry, we established a formal Government Affairs practice. Although Hasbro products were unaffected, we recognized the need to advocate and educate on issues important to our company and stakeholder groups.
Hasbro executives also serve on the boards of the major toy associations around the world, recognizing the importance of an industry voice working with stakeholders on public policy issues. In the United States, our Chief Executive Officer (CEO) is a member of the Business Roundtable, a Washington D.C.-based association of CEOs who believe business should play an active and effective role in the formation of public policy.
In 2010, Hasbro engaged in the debate surrounding recent and upcoming changes in global toy safety laws and regulations. Learn more about these changes in the Product Safety section of this report.
Hasbro does not have an in-house lobbyist. We use outside firms to advocate on our behalf and we collaborate on industry association efforts globally. The regulatory issues most critical to our business are product quality and safety, environmental restrictions, chemicals use and chemical disclosure, and marketing to children.
We do not have a political action committee (PAC), nor do we make corporate political donations. Our executives are free to make personal political donations and to donate to the Toy Industry Association Political Action Committee (PAC).