Dear fellow employee:
Over the last century, Hasbro has evolved into a global and innovative branded play company. While our business model continues to evolve, we have been unwavering in our commitment to do the right thing. Our success is measured not only by our results, but also by how we achieve those results. We take great pride in maintaining that tradition of ethics and compliance and count on you to demonstrate our pledge by doing business with integrity every day.
In today’s complex business and regulatory environment, our Code of Conduct outlines our core values and remains the foundation that guides us in our decisions. Employees are expected to read and understand our Code. However, if you are faced with a difficult situation, do not hesitate to contact one of the many resources identified in the document to ensure you are making the right decision.
As always, if you witness or become aware of improper behavior, report your concerns through an appropriate channel, which includes the Hasbro Helpline. We are committed to creating an environment that fosters open communication and supports employees in reporting potential violations. Retaliation of any kind is inconsistent with our values and will not be tolerated.
Keeping with our continued commitment of doing business with integrity, I am confident that you will meet these expectations and safeguard Hasbro’s future success. Together, we are Hasbro.
Chairman of the Board, President and Chief Executive Officer
As a branded play company, our customers include children and their caregivers. Knowing that the products and content we produce bring joy and fun to others is a source of great pride and satisfaction. But with this privilege comes responsibilities: as employees and directors of Hasbro we must maintain high ethical standards, meet social compliance expectations, and consistently deliver safe and trusted products, while returning value to our shareholders.
To meet these goals requires daily effort. To maintain our reputation and high standards, we must work hard to make good decisions; and we must never lose sight of the fact that the choices we make can have an impact on many others including the children, who are our ultimate consumers, their families and also our fellow employees, shareholders, and our community.
To help us make good choices, our Code of Conduct (“Code”) is designed to serve as a resource when we need additional information about policies and standards, or when we need help to address a difficult ethical situation.
Our Code covers many of the ethics and compliance topics that we are likely to face in our work, but no code can cover every possible situation. That is why it is important to remember that you have other resources in addition to our Code that can help you make good decisions.
Since we operate globally in many countries around the world, there may be times when laws and customs conflict. Whenever there is a conflict or a difference between a legal requirement and our Code, we will apply the strictest standard.
Who must follow our Code
Our Code applies to all employees of Hasbro, regardless of position. Our Board of Directors and certain business partners serve as an extension of Hasbro and their conduct can have an impact on our Company. They, too, are expected to follow our Code as well as any applicable contractual provisions when working on behalf of Hasbro.
If you are in a position to supervise our business partners, you are responsible for ensuring that they understand our ethics and compliance standards. We expect all our contractors and their employees to act in a way that is consistent with our Code. We will take the appropriate measures where we believe they have not met our high standards or their contractual obligations.
United States and Canada
Outside United States and Canada
OR WRITE TO
Asking questions or raising concerns
Each of us has a responsibility to help protect the reputation and integrity of Hasbro. If you see or suspect any illegal or unethical behavior — whether it relates to you, your manager, a business partner, or anyone else — or if you have a question or need help making an ethics or compliance decision, you have several options. You can contact any of the following at any time:
Hasbro is committed to investigating potential violations and will deal with each report fairly and reasonably. Remember: an issue can only be addressed if it is brought to someone’s attention.
Using the Hasbro Helpline
The Hasbro Helpline is a confidential way to get answers to your questions and concerns about ethics. You may contact the Hasbro Helpline 24 hours a day, 7 days a week; if your call goes into voicemail, you may leave a message. Employees may choose to remain anonymous when reporting concerns and we will protect that anonymity to the extent permitted by local law.
When an employee contacts the Helpline, the operator will listen to the concern or question, ask clarifying questions if necessary, and then write a summary report of the call. The summary will then be provided to Hasbro leadership for assessment and further action, if necessary.
Any report made to the Helpline will be kept confidential, to the extent possible, and will remain consistent with the law and good business practices.
We will not tolerate retaliation
Hasbro does not tolerate retaliation against anyone for raising or helping to address an ethics or compliance concern. We consider acts of retaliation to be acts of misconduct. Threats, intimidation and violence undermine everything we stand for as an ethical company and will not be tolerated.
If you think that you or someone you know has suffered retaliation, contact the Helpline or the Legal Department.
Making the right choice — guidelines for ethical decision-making
Making the right decision is not always easy. There may be times when you are under pressure or unsure of what to do. Always remember that co-workers and management are available to help but if you are not comfortable, you may contact the Legal Department, the Human Resource Department, or any of the resources listed in our Code.
When faced with a difficult decision, it may help to ask yourself these questions:
If the answer to any of these questions is “No,” or if you are uncertain, stop and ask for guidance.
Violations of laws, our Code or other Company policies may result in disciplinary action up to and including termination of employment. Certain actions may also result in legal proceedings, or penalties against the Company and possibly you.
Waivers and exceptions
No part of our Code can be waived without prior written approval from the Chief Legal Officer or Board of Directors. Waivers will only be granted in exceptional circumstances and all appropriate reports and disclosures will be made. Our Code does not alter the terms and conditions of employment or create a contract of employment.
All of us work best when we feel safe. For this reason, we do not tolerate any form of abuse or harassment. This includes actions that are offensive, intimidating, or discriminatory as well as any form of sexual harassment. Our responsibilities to each other include the following:
For further information, consult your function or the Human Resources Department for additional guidance.
Inclusion, diversity, equal opportunity and respect for others
We value the unique contribution that each person brings to Hasbro. Collaboration and inclusivity are central to how we work and we believe the best solutions are those that draw on diverse ideas and perspectives. That is why we value each and every employee as an important contributor to our success and aim to create an inclusive environment where our employees are given the opportunity to achieve their full potential.
If you feel you are being discriminated against, contact your Human Resources representative, the Legal Department, or any of the resources listed in our Code.
Respect the privacy and the confidentiality of personal employee information. Only use personal information that it is needed for a legitimate and lawful business purpose or to comply with the law.
Safe and healthy work environment
Remember: Safety first. There is no job so important that we cannot take the time to complete it safely.
We all need to be aware of safety and health risks as we go about our jobs. Each of us has the responsibility to be a role model for safety, and work in a way that helps ensure the safety and health of our co-workers, business partners, and visitors to our facilities.
The safety of our products and appropriateness of our entertainment content are our top commitments to our consumers. Hasbro will always comply with applicable laws and standards. Each of us is expected to do our part to help the Company meet or exceed professional industry standards and consumer expectations.
Our advertising and marketing must always be true and never misleading or deceptive. We must abide by all laws and applicable industry standards, and further, since we recognize that our consumers are children and their caregivers, we must ensure that our promotion of Hasbro products is appropriate to a children’s and family entertainment company.
We must always deal fairly with consumers, business partners and competitors and never take unfair advantage of another through manipulation, concealment, abuse of privileged information, misrepresentation of facts, or any other unfair business practice.
Additional prohibitions exist, please contact the Legal Department if you have questions regarding a particular marketing practice.
We value our consumers’ trust and work hard to keep that trust by protecting the privacy of the children and families who use our online websites and games.
Our privacy policies for all our websites and mobile apps are driven by compliance with global laws. For any specific legal questions regarding online privacy, please seek advice from the Legal Department.
Our suppliers and business partners are essential to our ability to do business and meet our high standards and our consumers’ expectations. That is why we choose them carefully and use an objective selection process.
We work with others who share similar values and our commitments to quality, safety, security, ethics and compliance.
A conflict of interest may occur when our personal interests or activities affect our ability to make objective decisions for Hasbro. The best approach to handling possible conflicts is to disclose situations to your manager that might create a conflict, or even the appearance of a conflict; also you must complete the Conflict of Interest Disclosure form. Once disclosed, we then have the opportunity to better address the situation.
You are not allowed to engage in activities that create a conflict of interest or the appearance of a conflict of interest. The following are common types of conflicts of interest:
It is possible that a relative or close friend may be working at Hasbro, (whether as an employee, temporary employee, intern, or freelancer) or may be a supplier or business partner. Favoritism towards relatives or friends should never play any role in business decisions. In some cases, a conflict may be difficult to recognize, but the situation should always be disclosed to your manager as soon as possible. In no instance, should one family member directly manage or control the work of another.
Outside employment must be disclosed to and reviewed by your manager. If approved, you are responsible for making sure that your outside activity does not interfere with or detract from your work at Hasbro. Working for a competitor while employed by Hasbro is never permissible. Working for a supplier may raise additional conflicts that will need to be discussed with management. In all cases you should not be involved in side or personal business that competes or does business with Hasbro.
You should not have significant investments in one of our competitors, suppliers, customers or business partners. ‘Significant’ is difficult to define and may vary depending on the circumstance. Discuss the situation with the Legal Department.
If you learn about a business opportunity through your work at Hasbro, you cannot take advantage of the opportunity for your own, personal benefit nor should you forward the information for the benefit of your family or friends. An example of an impermissible opportunity would be providing confidential information to benefit a potential vendor, who is also a personal friend.
Conflicts may occur when our personal interests or activities affect our ability to make objective decisions for Hasbro. You must disclose potential conflicts, which may include:
If not handled carefully, the exchange of gifts and entertainment can be illegal or damage Hasbro’s reputation, especially if it appears to or actually does influence a business decision.
Each of us is responsible for protecting Hasbro’s assets. Company assets include our facilities, property and equipment, computers and information systems, time, confidential and proprietary information, intellectual property, corporate opportunities and funds. Please refer to the Technology Use Policy for further information.
Our consumers place their trust in us; and therefore, we must protect their confidential information. We are committed to guarding against unintentional public exposure of personal consumer information.
Hasbro’s brands and licensed brands constitute some of our most valuable assets. Whether it is a movie or TV script, clip or still image, a product concept, design or sample, a new character, story idea or play pattern, a new expression of one of our brands, a marketing campaign, or any other brand expression that has not been released to the public, we must protect and maintain the confidentiality and security of this information.
We consider willful violations of Hasbro’s Intellectual Property Polices to be acts of misconduct. Please consult the Intellectual Property Protection and Social Media Guidelines for further information and consult with your manager to determine if your department has any specific intellectual property protection policies or procedures in place that you must follow in the performance of your job.
All of us contribute to the process of recording financial and non-financial information. Business partners, government and regulatory officials and the public rely on our accurate and thorough disclosures and business records. Such information is also essential within Hasbro so that we can make good decisions.
When collecting business intelligence we must never engage in fraud, misrepresentation or deception to obtain information. When we hire former employees of competitors, we need to properly determine if there are any valid legal obligations of those employees and not use, or encourage them to disclose, the confidential information of their former employers or solicit employees from their former employers, if there are such restrictions.
When we share information with the public, it is important that we do so carefully and that we are consistent and speak with one, clear voice.
Social media is an important, dynamic way for us to communicate and create content. If used appropriately, social media can be an efficient means of sharing information, marketing, and communicating with our consumers and business partners. However, if used improperly, social media may expose the Company to additional risk.
You may become aware of information about Hasbro or about other companies that is not publicly available. Using this ‘inside information’ for personal gain, sharing it with others, or spreading false rumors, is illegal and against our values.
Hasbro is committed to free and open competition. We gain our competitive advantages through superior performance rather than through unethical or illegal business practices. Most countries have laws against practices that interfere with competition. The following activities are considered “red flags” and should always be avoided and reported to the Legal Department:
Competition laws are complex and compliance requirements can vary based on the country and circumstance. If you have any questions, discuss the matter with the Legal Department before taking action.
Corporate social responsibility (CSR) at Hasbro is powered by a simple belief: every day is a chance to be better. To use what we love most about play—joy, creativity, problem solving—to make a positive and enduring difference for people and our planet.
CSR is not just something we do. It’s how we see the world, how we push ourselves to think differently and act with greater purpose- from making safe products and ethical business choices to improving our sustainability performance and helping people and communities thrive. To move forward—and make every day better than the last.
And that means not only striving to act responsibly and operate with integrity, but also actively building and maintaining trust with each other and our business partners. To do so, each of us must do our part to ensure that Hasbro and our business partners meet high standards of ethics, including respect for human rights and the environment.
As an individual, you have the right to voluntarily participate in the political process including making personal political contributions; however, you need to make it clear that your personal views and actions are not those of Hasbro.
Be sure to contact the Government Affairs Department for approval before engaging in any lobbying or discussions with government officials on behalf of Hasbro.
Bribery and corruption in all of its forms are completely contrary to our values and business standards. Not only do we comply with anti-bribery laws and regulations, but also stand firm and support efforts to eliminate bribery and corruption worldwide. We strive to make sure that our business partners share our commitment.
Never give or accept bribes, kickbacks or any other kind of improper payment.
There can be severe consequences if we or a business partner violate anti-bribery laws. Even the perception by others that we may have crossed the line can be damaging. For this reason, always be aware of how our actions might be viewed by others and err on the side of caution.
Countries and jurisdictions need to control the import and export of products that travel across their borders. For this reason, we must honor all trade, import and export laws in the countries where we operate. If there is a conflict, or if you are not sure what laws apply, consult with the Legal Department.
Below, please find the policies referenced in our Code. You should be aware that there may be additional policies for your function and/or geographic region that may be applicable. Please consult your function and/or regional policy for additional guidance.