SEC Comment Letter for HAWKINS (HWKN) — Feb 27, 2026
HAWKINS INC
Date: Feb. 27, 2026 · CIK: 0000046250 · Accession: 0000000000-26-002051
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File numbers found in text: 000-07647
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February 27, 2026
Jeffrey Oldenkamp
Executive Vice President and Chief Financial Officer
Hawkins, Inc.
2381 Rosegate
Roseville, MN 55113
Re: Hawkins, Inc.
Form 10-K for Fiscal Year Ended March 30, 2025
Form 8-K Furnished January 28, 2026
File No. 000-07647
Dear Jeffrey Oldenkamp:
We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).
Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Form 10-K for Fiscal Year Ended March 30, 2025
Notes to Consolidated Financial Statements, page 32
1. It appears selling, general and administrative expenses is material to
your results of
operations. Please consider describing what this line item consists of.
Note 14 - Leases, page 45
2. Please disclose the cash paid for amounts included in the measurement of
lease liabilities
pursuant to ASC 842-20-50-4.g.1.
Note 15 - Segment Information, page 45
3. You disclose here there are no intersegment sales. On page 1 under
Business you
disclose the Industrial Group ("Industrial") repackages water treatment
chemicals for
the Water Treatment Group ("Water Treatment"), there are significant
synergies between
Water Treatment and Industrial regarding chemicals sold by Water
Treatment derived
from large volume of chemicals purchased by Industrial, and Water
Treatment and
Industrial share certain resources. In view of this, please describe for
us and disclose as
February 27, 2026
Page 2
appropriate the relationship between these two groups such that no
intersegment sales
occur. Also, describe for us and disclose as appropriate how the costs
of resources shared
between these groups and chemicals purchased by Industrial on behalf of
Water
Treatment are assigned to the appropriate segment.
Form 8-K Furnished January 28, 2026
Exhibit 99.1, page 1
4. Under the caption "Third Quarter Fiscal Year 2026 Highlights," for the
non-GAAP
measure Adjusted EBITDA, please present the most directly comparable
GAAP measure
of net income with equal or greater prominence. Refer to Question
102.10(a) of the
Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Robert Shapiro at 202-551-3273 or Doug Jones at
202-551-3309 with any
questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
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