The Guide to Corporate Conduct can be found in its entirety at http://phx.corporate-ir.net/phoenix.zhtml?c=68329&p=irol-govConduct, but highlights of the Guide are as follows:
Advertising, Marketing and Promotion
It is Hasbro's policy to be truthful, fair, and honest in the advertising, marketing, and promotion of its products. Advertising and promotion of Hasbro products complies with all applicable laws and regulations, and such activities are expected to be conducted in a way which is appropriate for a children's and family entertainment company.
Antitrust and Competition Law
Hasbro employees must abide by the antitrust and competition laws in each country in which we do business. Applicable laws vary from jurisdiction to jurisdiction, but the following types of behavior are almost universally prohibited: agreements with competitors to fix prices or to boycott specified suppliers or customers, agreements with competitors to allocate products, markets or territories, and certain types of behavior which constitute an attempt to monopolize.
Bribes and Kickbacks
Even though customs and ethical standards may vary from country to country, payment or acceptance of bribes or kickbacks is never permissible under the Hasbro Guide to Corporate Conduct. As a U.S.-based company, Hasbro expects all employees to abide by the United States Foreign Corrupt Practices Act, which restricts payments to officials of foreign governments, political parties and candidates for public office.
Fair Dealing
Hasbro expects all its personnel to deal honestly and fairly with the Company's customers, suppliers, competitors, and fellow employees. It is unacceptable to take advantage of third parties through manipulation, fraud, concealment, abuse of confidential or privileged information, misrepresentation of material facts, or any other unfair dealing or practice.
Financial Integrity / Public Disclosure
Hasbro maintains its books and records in a manner that provides for a reliable and auditable record of its financial transactions, in conformity with generally accepted accounting principles, both in the United States and all other applicable jurisdictions. Employees are advised that they have a range of options in reporting concerns regarding potentially questionable accounting or auditing practices, including the opportunity to report such concerns directly and confidentially to the Chair of the Audit Committee of the Company's Board of Directors. Hasbro¡¯s securities filings are prepared and filed in a timely manner, with the objective of providing accurate, complete and understandable disclosure. The Company devotes substantial internal and external resources to assure the accuracy of its financial statements and the entries and transactions underlying those statements. It also places significant focus and attention on assuring that all disclosure requirements are met in every jurisdiction where those requirements apply.
Insider Trading
It is Hasbro's expectation that all employees and job applicants will be afforded equal opportunity for employment and advancement at every level of employment without regard to race, color, religion, pregnancy, ancestry, age, gender, national origin, sexual orientation, mental or physical disability, marital status, or status as a disabled veteran or Vietnam-era veteran, and to conform to all applicable employment-related laws and regulation.
Relations with Employees
It is Hasbro's expectation that all employees and job applicants are will be afforded equal opportunity for employment and advancement at every level of employment without regard to race, color, religion, pregnancy, ancestry, age, gender, national origin, sexual orientation, mental or physical disability, marital status, or status as a disabled veteran or Vietnam-era veteran, and to conform to all applicable employment-related laws and regulation.
Workplace Environmental, Health and Safety
Hasbro is committed to the safety and health of its employees worldwide and to complying with all applicable health, safety and environmental laws and regulations wherever it does business. The Company has an Environmental, Health, & Safety Committee made up of a representative group of its senior managers to oversee compliance with its policies and to identify opportunities for continued improvement in these areas. All employees are obliged to report any violation of health, safety, or environmental laws, and are encouraged to identify ways to conduct business which help to minimize these issues in Hasbro's facilities throughout the world.
Implementation
All Hasbro employees and the Hasbro Board of Directors are provided with a copy of the Guide to Corporate Conduct and are expected to thoroughly review it and to sign an acknowledgement confirming the receipt and review of the Guide. The Guide is updated from time to time to address new legal obligations or areas of ethical compliance that the Company wishes to highlight. Employees are expected to participate in periodic training with respect to the Guide and the Company¡¯s expectations as to their conduct in areas that can affect Hasbro¡¯s corporate reputation and compliance with applicable laws.
Hasbro has appointed its General Counsel as its corporate ethics officer with responsibility for monitoring performance under the Guide to Corporate Conduct and for resolving issues arising under the Guide. Employees are advised that they are specifically responsible for reporting potential violations of the Guide or other ethical concerns to the General Counsel, but that they may also report such violations to whomever else in management they feel comfortable with as a potential resource. A well-publicized ¡°helpline¡± is provided and maintained to facilitate such reporting. Also, included in the reporting options available to employees is the opportunity to report issues on a confidential, anonymous basis. Employees are advised that there will be no retaliation for reporting possible violations of the Guide.