Hasbro, Inc. (“Hasbro,” the “Company,” “we,” “us,” or “our”) (NASDAQ: HAS) is committed to combatting modern slavery and human trafficking across our global operations, as described in this Statement and supporting documentation. We take a continuous improvement approach to ensure our preventative and remedial efforts continue to be relevant, timely and effective. Additionally, Hasbro complies with the requirements of the California Transparency in Supply Chain (2010), UK Modern Slavery Act (2015), and the Australian Modern Slavery Act (2018). This Statement outlines our policies and actions taken to assess and address potential risks associated with modern slavery and forced labor in our supply chain, as of the end of Fiscal Year 2021.
1. Organizational Structure and Supply Chain:
Hasbro is a global play and entertainment company committed to making the world a better place for all children, fans, and families. Founded in 1923, Hasbro employs more than 6,800 employees, operates in 35 countries and contributes to sales in over 120 countries. We deliver immersive brand experiences for global audiences through consumer products, including toys and games, entertainment, and gaming. Our portfolio of approximately 1,500 brands includes MAGIC: THE GATHERING, NERF, MY LITTLE PONY, TRANSFORMERS, PLAY-DOH, MONOPOLY, BABY ALIVE, DUNGEONS & DRAGONS, POWER RANGERS, PEPPA PIG and PJ MASKS, as well as premier partner brands.
At Hasbro, we believe strong Environmental, Social and Governance (ESG) performance drives long-term value creation for all our stakeholders. As part of our ESG efforts we are committed to Corporate Social Responsibility and to building a safer, more sustainable, and inclusive company for all. For the past decade, we have been consistently recognized for our corporate citizenship, including being named one of the 100 Best Corporate Citizens by 3BL Media, one of the World’s Most Ethical Companies by Ethisphere Institute, and the Civic 50 Most Community-Minded Companies in the U.S.
Our global supply chain includes approximately 75 finished goods third-party manufacturing facilities in 13 countries including China, India, Vietnam, Mexico and the United States. We also rely on subcontractors, molders and raw material suppliers. For more information on our supply chain, please view our Third-Party Factory List 2021, which is publicly available and updated annually.
We continuously monitor and address labor and human rights issues, both within our direct workforce and our supply chain. We evaluate our supply chain for modern slavery risks, conduct ongoing in-depth supplier assessments for new and existing factories and implement thorough due diligence measures to address new global risks, such as institutional forced labor supported by governments or other actors. These reviews cover all aspects of the supply chain including health and safety, forced labor, child labor and other legal requirements and industry expectations.
2. Our Policies on Slavery and Human Trafficking:
We are keenly aware of the risks of modern slavery and forced labor in the global supply chain and have well-defined policies and due diligence processes to identify and remediate any instances of non-compliance, as well as a dedicated global Ethical Sourcing team. In keeping with our commitment to act with integrity, our policies help to ensure that there is no slavery or human trafficking in any part of our business or supply chains and set clear expectations for our suppliers.
Our relevant policies include:
Hasbro’s commitment to addressing the risks of forced labor in our supply chain is grounded in our Human Rights Policy. The Policy details our commitment to upholding our values and respecting human rights in our operations and business relationships, including the supply chain. We require our third-party vendors and licensees to provide fair and safe working conditions for all workers and treat their employees with dignity and respect.
Hasbro’s Global Business Ethics Principles (HGBEP) and the Responsible Business Alliance (RBA) Code of Conduct, guide our human rights and ethical sourcing practices within our global supply chain. The HGBEP standard has been approved by Hasbro senior management and the Board of Directors, is updated regularly and is communicated to the company’s suppliers prior to starting any sourcing relationship as well as continually through our audit and remediation process. The Hasbro Global Business Ethics Principles are mandatory for all facilities involved in the manufacturing of our products and stipulates very clearly:
“Forced Labor - The use of forced, bonded, prison, indentured or compulsory labor in the production or manufacture of Hasbro products is prohibited. This includes modern forms of slavery, human trafficking, compulsory overtime or withholding personal papers, work permits, personal identification, or compensation. It is prohibited for factories to allow or require workers to pay employer or labor agent recruitment or other fees to obtain their employment. Workers shall not be subject to unreasonable restrictions of movement.”
The Hasbro Global Business Ethics Principles incorporates the Responsible Business Alliance (RBA) Code of Conduct by reference; and in the event of a conflict, the stricter standard applies. The RBA Code provides that, “[f]orced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons is not permitted.” In addition to the leading RBA Forced Labor standards, the RBA Code specifies that factories adhere to “Supplier Responsibility”, which includes “a process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.”
As part of the RBA, Hasbro also is committed to the Responsible Labor Initiative (RLI) Commitment on Forced Labor re-iterating the requirement of ensuring voluntary work, treatment of workers free from discrimination and harsh or inhumane treatment, no worker fee policy and reimbursement to workers who have already paid fees, no holding of workers’ passports, etc.
The Hasbro Ethical Sourcing Guide for Licensees stipulates the requirements for licensee partners to effectively manage their supply chain compliance, including to prevent Forced Labor, submit third-party audits for Hasbro Ethical Sourcing approval and responsibly remediate any identified issues. Factories located in low-risk countries are required to submit a self-assessment questionnaire in order to identify foreign and/or contract labor, which would lead to further due diligence. In addition, licensees are required to complete a Forced Labor Due Diligence report ensuring that they are addressing all potential forced labor risk. The Hasbro Ethical Sourcing Guide for Licensees is referenced in all licensee agreements.
The Hasbro Conflict Minerals Policy includes our requirement that all third-party vendors who produce Hasbro products which contain conflict minerals (tin, tantalum, tungsten and gold) complete an annual survey and only use Responsible Mineral Initiative (RMI), or London Bullion Market Association (LBMA) certified smelters.
The Hasbro Responsible Recruitment and Contract Labor Policy , developed and introduced to the supply chain in 2021, includes our requirements for the responsible recruitment, fair treatment and accountability of direct, contract and student workers in our supply chain involved in the production of Hasbro products, packaging, components and raw materials. The policy builds on our existing standards to further specify how our global supply chain partners should proactively ensure compliance, including labor agent selection, training and monitoring, as well as a requirement to notify Hasbro if they develop new relationships with labor agents or educational institutions and/or plan to contract foreign migrant labor.
3. Risk Assessment and Due Diligence:
The risk of modern slavery and human trafficking within our own organization is substantially mitigated as a result of our strict policies and procedures which integrate human rights and ethical sourcing into factory selection and ongoing business operations. The greatest risk of modern slavery and human trafficking is in our supply chain as we do not manufacture in owned facilities. However, we also evaluate human rights risk outside of the supply chain. Our 2021 comprehensive human rights assessment of Logistics, Digital Gaming and Entertainment and Film business areas, conducted by Verité, resulted in plans this year to expand our monitoring efforts, including audits of our warehouses in high- risk countries for forced labor, and strengthen human rights contract language with logistics providers.
In order to identify and mitigate risk, we undertake regular due diligence and reviews which include:
We work with industry organizations, stakeholder groups, and other brands to evaluate and address human rights and labor risks including modern slavery, human trafficking and forced labor. Our RBA and RLI membership allow us to take advantage of tools to identify and address risk as well as share best practices with other members.
4. Audits, Ongoing Verification and Evaluation:
Our Global Business Ethics Principles apply to all vendors and licensees manufacturing Hasbro and licensed products. Before beginning a relationship with Hasbro, vendors must sign onto our HGBEP requirements as a condition of their legal contract with Hasbro.
To ensure that our factories uphold our HGBEP requirements, Hasbro requires unannounced audits with third-party auditors, as well as subsequent follow-up and verification visits. We assess all finished goods and subcontractor factories as well as conduct additional annual risk-based oversight audits at least 10% of high-risk factories annually. Hasbro also retains the unilateral right to terminate its relationship with a vendor, supplier or licensee facility in violation of the Global Business Ethics Principles.
In addition, we conducted a supply chain Tier 2 mapping and assessment, including raw material suppliers and labor agents, to gain a deeper understanding of these suppliers and associated labor and human rights risks in 2021. As a follow-up to the assessment, we will conduct audits on a representative sample of these suppliers in order to identify and address violations as well as reassess risk for sub-tiers of the global supply chain.
Our approach to managing supply chain risk is to establish and maintain long-term partners that share our values. We believe that ongoing engagement best positions us to understand issues on the ground, build strong relationships with factories, enhance transparency and collaborate to proactively address issues. We evaluate the effectiveness of our work through:
5. Training and Awareness:
We ensure that factories are made aware and properly trained on the HGBEP by regularly engaging and educating our vendors, auditors and internal teams on supply chain issues, including those related to modern slavery, human trafficking and forced labor. We do this by:
In addition, we actively engage with industry organizations (RBA, RLI), regional meetings (U.S. government panel on CAATSA, Mekong Club), expert consultants (e.g. Verité and Elevate), and other brands to stay abreast of the latest developments, issues and regulations and collaborate where possible. The Vice President of Global Sustainability and Human Rights also has been an active participate on the RBA VAP Advisory Council.
6. COVID-19 Pandemic Actions
Throughout the pandemic, we have sought to live our values and our purpose in real time, working tirelessly to support our people, adapt and reimagine our businesses and supply chains, and engage our communities and governments to help make a difference for all. With regard to our supply chain, we supported major suppliers in safe re-openings, provided training to factories on Covid Safety, ensured that factories followed local laws of paying Covid-lockdown and sick-leave wages properly, and produced a Covid-safety best practices webinar for other suppliers locally and globally to benefit. We also converted several of our partner manufacturers to PPE operations—producing 50,000 face shields/week for donation to frontline healthcare workers in the U.S. and Europe. For more information, please see pages 15 – 17 in the 2019-2020 Corporate Social Responsibility Update report.
7. Governance and Internal Accountability
Responsibility for the implementation of this policy rests with our ESG and Purpose team led by the Chief Purpose Officer, who reports directly to the CEO, and managed by the Vice President of Global Sustainability and Human Rights. Oversight for these policies resides with the Nominating, Governance and Social Responsibility Committee of the Hasbro Board of Directors (“Governance Committee”), as well as with Hasbro’s executive Environmental, Social and Governance Committee. In addition, the ESG and Purpose team regularly reviews and updates this policy in close collaboration with the functional teams. The Governance Committee approved this statement on July 27, 2022.
Eradicating human trafficking requires strong action and collaboration from governments, business, international organizations, and civil society. Hasbro is committed to regularly reviewing and continuously improving our approach to human rights, including human trafficking and modern slavery, and strengthening our approach as needed, to align with emerging laws, regulations and Hasbro core values.
Chris Cocks
Chief Executive Officer (CEO)
Hasbro, Inc.
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