SEC Comment Letter 0000000000-23-011560 to HERSHEY CO (HSY) (CIK 0000047111) (HSY)
HERSHEY CO (HSY) (CIK 0000047111)
Date: Oct. 23, 2023 · CIK: 0000047111 · Accession: 0000000000-23-011560
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo October 23, 2023 Steven Voskuil Chief Financial Officer The Hershey Company 19 East Chocolate Avenue Hershey , PA 17033 Re:The Hershey Company Form 10-K for the year ended December 31, 2022 Filed February 17, 2023 File No. 1-00183 Dear Steven Voskuil: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 the period ended December 31, 2022 Trends Affecting Our Business, page 22 1.We note your disclosure that among other things, "negative macroeconomic conditions, including inflation on inputs to consumer products" is a current trend impacting your business. In future filings, please expand your disclosures to identify the principal factors contributing to the inflationary pressures the company has experienced and clarify the resulting impact to the company, if material. Please also identify specific actions planned or taken, if any, to mitigate inflationary pressures Management's Discussion and Analysis of Financial Condition and Results of Operations Consolidated Results of Operations, page 24 2.We note your discussion of your results of operations, starting on page 24, that qualitatively describes multiple factors that impacted these line items in each respective reporting period. For example, your discussion of the year over year drivers of cost of sales increase "was driven by higher sales volume, higher supply chain inflation costs,
FirstName LastNameSteven Voskuil Comapany NameThe Hershey Company October 23, 2023 Page 2 FirstName LastName Steven Voskuil The Hershey Company October 23, 2023 Page 2 including higher logistics and labor costs and an incremental $40.8 million of unfavorable mark-to-market activity on our commodity derivative instruments intended to economically hedge future years’ commodity purchases. Additionally, the increase was partially offset by favorable price realization and supply chain productivity." In future filings, please revise to further describe material changes to a line item in both quantitative and qualitative terms for each disclosed component, including the impact of offsetting factors. Refer to Item 303(b) of Regulation S-K. 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 Charles Eastman at 202-551-3794 or Claire Erlanger at 202-551-3301 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
October 23, 2023
Steven Voskuil
Chief Financial Officer
The Hershey Company
19 East Chocolate Avenue
Hershey , PA 17033
Re:The Hershey Company
Form 10-K for the year ended December 31, 2022
Filed February 17, 2023
File No. 1-00183
Dear Steven Voskuil:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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 the period ended December 31, 2022
Trends Affecting Our Business, page 22
1.We note your disclosure that among other things, "negative macroeconomic conditions,
including inflation on inputs to consumer products" is a current trend impacting your
business. In future filings, please expand your disclosures to identify the principal factors
contributing to the inflationary pressures the company has experienced and clarify the
resulting impact to the company, if material. Please also identify specific actions planned
or taken, if any, to mitigate inflationary pressures
Management's Discussion and Analysis of Financial Condition and Results of Operations
Consolidated Results of Operations, page 24
2.We note your discussion of your results of operations, starting on page 24, that
qualitatively describes multiple factors that impacted these line items in each respective
reporting period. For example, your discussion of the year over year drivers of cost of
sales increase "was driven by higher sales volume, higher supply chain inflation costs,
FirstName LastNameSteven Voskuil
Comapany NameThe Hershey Company
October 23, 2023 Page 2
FirstName LastName
Steven Voskuil
The Hershey Company
October 23, 2023
Page 2
including higher logistics and labor costs and an incremental $40.8 million of unfavorable
mark-to-market activity on our commodity derivative instruments intended to
economically hedge future years’ commodity purchases. Additionally, the increase was
partially offset by favorable price realization and supply chain productivity." In future
filings, please revise to further describe material changes to a line item in both quantitative
and qualitative terms for each disclosed component, including the impact
of offsetting factors. Refer to Item 303(b) of Regulation S-K.
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 Charles Eastman at 202-551-3794 or Claire Erlanger at 202-551-3301 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing