Rhode Island
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1-6682
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05-0155090
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(State or other jurisdiction of incorporation or organization)
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(Commission File Number)
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(IRS Employer Identification No.)
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1027 Newport Avenue, Pawtucket, Rhode Island
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02861
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(Address of principal executive offices)
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(Zip code)
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Established a policy statement in 2013 with respect to sourcing of minerals from the Democratic Republic of Congo ("DRC") and its adjoining countries and published this statement online at the following internet address {http://csr.hasbro.com/has12-conflict-minerals-policy.php}. This policy was updated and enhanced in 2014 to reinforce our commitment to the ultimate goal that any conflict minerals included in our products are sourced from smelters identified as conflict free or are otherwise subject to supplier diligence sufficient to determine that such minerals are not being used to fund armed conflict in the DRC and its adjoining countries.
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Established an internal governance structure in 2013 that included a cross functional conflict minerals steering committee and working group comprised of representatives from Global Operations, Quality Assurance, Corporate Social Responsibility, Information Technology, Legal, Finance and Investor Relations.
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Implemented a supply chain diligence system through the use of a conflict minerals reporting survey.
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Continued to engage with at-risk suppliers of owned and operated manufacturing facilities (direct suppliers) and third party vendors (contract manufacturers) that Hasbro believed were most likely to supply products containing 3TG, by sending a notification letter to such suppliers and vendors at the start of the RCOI stating that Hasbro is subject to Section 1502 of the Dodd-Frank Act, and that their cooperation in responding to the survey is expected.
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Conducted supply chain surveys based on the EICC/GeSI conflict minerals questionnaire with 48 direct suppliers and contract manufacturers identified during our applicability assessment and RCOI. Unlike in 2013, when each direct supplier and contract manufacturer received one survey, in 2014 we employed separate surveys for each of the Company's four product categories: Boys, Girls, Preschool and Games, for contract manufacturers, such that an individual at-risk contract manufacturer could receive up to four individual surveys if they were providing products in each of the Company's four product categories.
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Provided surveyed direct suppliers and contract manufacturers with links to conflict minerals web-based training presentations that included an overview of the conflict minerals rules under the Dodd-Frank Act, as well as trainings on how to complete the survey.
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Developed a grievance mechanism in 2013, which was continued in 2014, to enable the reporting of grievances via the Hasbro Conflict Minerals email.
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Established a plan in 2013, which was continued in 2014, to retain conflict minerals program documentation for at least 5 years.
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Suppliers surveyed were asked to identify smelters and refiners that process conflict minerals contained in our products, including country of origin, based on the EICC/GeSI conflict minerals questionnaire.
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Every survey received was logged in our technology platform and reviewed manually by Hasbro personnel.
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Non-responsive suppliers and survey responses that we believed to be incomplete or inconsistent were identified for additional follow-up.
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Reasons for follow-up with suppliers included, but were not limited to, that the suppliers did not provide a complete smelter list or did not receive complete conflicts mineral sourcing information from all of their relevant suppliers.
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Smelters identified by suppliers surveyed by Hasbro were compared against the list maintained by the Conflict Free Smelter Program.
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The results of the survey review and associated risks were reported to members of the steering committee.
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Suppliers that did not respond to Hasbro's initial survey request were sent escalation letters requesting that they provide the information requested.
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Suppliers who provided incomplete or inconsistent responses were sent a follow-up corrective action letter asking them to update their survey response.
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Hasbro contacted suppliers who identified smelters that were not designated as conflict free to determine if they had any additional information regarding country of origin of the conflict minerals and to remind them of the responsible sourcing policy.
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Boys: Boys products include action figures, vehicles, playsets and role play items. Boys' franchise brands include the NERF line of sports and action products and TRANSFORMERS action figures and accessories. Our boys' category also included SUPER SOAKER water blasters, G.I. JOE action figures and accessories and entertainment-based licensed products based on popular movie, television and comic book characters.
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Girls: In our Girls business we offer small dolls and fashion dolls, creative play products, and active role play products. Girls' franchise brands comprise LITTLEST PET SHOP, MY LITTLE PONY and NERF REBELLE. Other major girls' brands included FURREAL FRIENDS, BABY ALIVE, EASY BAKE and FURBY.
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Pre-school: Franchise brand offerings in the preschool category included PLAY-DOH and TRANSFORMERS RESCUE BOTS products. Other major preschool brands included PLAYSKOOL.
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Games: Our games category included an assortment of brands delivered on various gaming platforms, including action battling, board, off-the-board, digital, trading card and role-playing games. Franchise brands in Games comprise MAGIC: THE GATHERING and MONOPOLY, and other major game brands included in our Games business are BATTLESHIP, BOP-IT, CANDYLAND, CLUE, CONNECT 4, CRANIUM, DUEL MASTERS, ELEFUN & FRIENDS, GAME OF LIFE, JENGA, OPERATION, RISK, SORRY!, TRIVIAL PURSUIT, TWISTER, and YAHTZEE.
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Continue to use contract terms and conditions for new contracts requiring direct suppliers and contract manufacturers to respond to inquiries regarding conflict minerals in a timely manner.
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Continue engaging non-responsive and non-compliant suppliers from 2014 into the 2015 reporting period, with the objective of achieving a 100% response rate from all direct suppliers and contract manufacturers and obtaining complete smelter lists and the ability to link specific direct suppliers and contract manufacturers to particular smelters and to particular product categories.
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New in 2015 our Executive Vice President, Chief Global Operations and Business Development Officer is reaching out to direct suppliers and contract manufacturers who have not provided complete survey data.
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Continue to work with direct suppliers and contract manufacturers to identify to the extent possible the source of conflict minerals used in Hasbro's products.
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Build capabilities with active and new contract manufacturers by helping them understand the importance of this initiative to Hasbro and to encourage their participation in 2015 through supplier trainings.
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Encourage direct suppliers and contract manufacturers to source from smelters that have received the conflict free designation or that are otherwise subject to adequate due diligence to ensure such minerals are not being used to fund conflict.
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Continue working with our direct suppliers and contract manufacturers to better understand how individual sources of conflict minerals may apply to our individual product categories.
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CFSP Compliant Smelters
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Metal Name
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Smelter Name
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Smelter Country Name
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Gold
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Allgemeine Gold-und Silberscheideanstalt A.G.
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GERMANY
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Gold
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Argor-Heraeus SA
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SWITZERLAND
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Gold
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Heraeus Ltd. Hong Kong
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HONG KONG
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Gold
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Heraeus Precious Metals GmbH & Co. KG
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GERMANY
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Gold
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JX Nippon Mining & Metals Co., Ltd.
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JAPAN
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Gold
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Matsuda Sangyo Co., Ltd.
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JAPAN
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Gold
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Metalor Technologies SA
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SWITZERLAND
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Gold
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PAMP SA
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SWITZERLAND
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Gold
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Rand Refinery (Pty) Ltd
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SOUTH AFRICA
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Gold
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The Refinery of Shandong Gold Mining Co. Ltd
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CHINA
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Gold
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Shandong Zhaojin Gold & Silver Refinery Co. Ltd
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CHINA
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Gold
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Tanaka Kikinzoku Kogyo K.K.
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JAPAN
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Gold
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Valcambi SA
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SWITZERLAND
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Gold
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Western Australian Mint trading as The Perth Mint
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AUSTRALIA
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Gold
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Zhongyuan Gold Smelter of Zhongjin Gold Corporation
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CHINA
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Tantalum
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F&X Electro-Materials Ltd.
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CHINA
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Tantalum
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Ulba
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KAZAKHSTAN
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Tin
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Alpha
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UNITED STATES
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Tin
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Mitsubishi Materials Corporation
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JAPAN
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Tin
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Malaysia Smelting Corporation (MSC)
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MALAYSIA
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Tin
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PT Bangka Putra Karya
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INDONESIA
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Tin
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PT Tambang Timah
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INDONESIA
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Tin
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PT Timah (Persero),Tbk
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INDONESIA
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Tin
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PT 2indo Inter Nusa
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INDONESIA
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Tin
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PT Tinindo Inter Nusa
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INDONESIA
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Tin
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Thaisarco
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THAILAND
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Tin
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Yunnan Tin Company, Ltd.
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CHINA
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Tungsten
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Ganzhou Huaxing Tungsten Products Co., Ltd.
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CHINA
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Tungsten
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Ganzhou Seadragon W & Mo Co., Ltd.
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CHINA
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Tungsten
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Ganzhou Grand Sea W & Mo Group Co Ltd
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CHINA
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Tungsten
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Global Tungsten & Powders Corp.
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UNITED STATES
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Tungsten
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Hunan Chunchang Nonferrous Metals Co., Ltd.
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CHINA
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Tungsten
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Xiamen Tungsten (H.C.) Co., Ltd.
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CHINA
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Tungsten
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Xiamen Tungsten Co., Ltd.
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CHINA
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Smelters Actively Pursuing CFSP Designation
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Metal Name
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Smelter Name
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Smelter Country Name
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Tin
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China Tin Group Co., Ltd.
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CHINA
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Tin
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Liuzhou China 2
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CHINA
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Tin
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Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.
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CHINA
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Tungsten
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Fujian Jinxin Tungsten Co., Ltd.
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CHINA
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Tungsten
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Ganzhou Non-ferrous Metals Smelting Co., Ltd.
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CHINA
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Tungsten
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Zhangyuan Tungsten Co.,Ltd.
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CHINA
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All Other Smelters
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Metal Name
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Smelter Name
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Smelter Country Name
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Gold
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WuJiang HengYuan Metal Products Co.,Ltd.
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CHINA
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Tin
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EM Vinto
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BOLIVIA
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Tin
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Gejiu Kai Meng Industry and Trade LLC
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CHINA
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Tin
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Gejiu Non-Ferrous Metal Processing Co. Ltd.
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CHINA
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Tin
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Gejiu Zi-Li
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CHINA
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Tin
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PT Koba Tin
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INDONESIA
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Tin
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Shen Zhen HuaJun Metal Products Co.,Ltd
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CHINA
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Tin
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Yunxin Youse Dianjie Co.,Ltd
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CHINA
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Tungsten
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Kennametal Huntsville
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UNITED STATES
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