SEC Comment Letter 0000000000-23-007092 to Hanesbrands Inc. (CIK 0001359841)
Hanesbrands Inc. (CIK 0001359841)
Date: July 5, 2023 · CIK: 0001359841 · Accession: 0000000000-23-007092
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File numbers found in text: 001-32891
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United States securities and exchange commission logo
July 5, 2023
Stephen Bratspies
Chief Executive Officer
Hanesbrands Inc.
1000 East Hanes Mill Road
Winston-Salem, NC 27105
Re:Hanesbrands Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Form 10-Q for Fiscal Quarter Ended April 1, 2023
Item 2.02 Forms 8-K filed February 2, 2023 and May 3, 2023
File No. 001-32891
Dear Stephen Bratspies:
We have reviewed your filings and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 30
1.Please revise both your consolidated results of operations and operating results by
business segment discussions to quantify the incremental impact of each individual
business reason discussed on the overall change in the line item. Also, when you
discuss unfavorable product and channel mix, please disclose in greater detail what
products and channels were unfavorable and explain why. Refer to Item 303 of
Regulation S-K. This comment also applies to your Form 10-Q for the period ended April
1, 2023.
FirstName LastNameStephen Bratspies
Comapany NameHanesbrands Inc.
July 5, 2023 Page 2
FirstName LastName
Stephen Bratspies
Hanesbrands Inc.
July 5, 2023
Page 2
Item 2.02 Form 8-K filed February 2, 2023
Exhibit 99.1
2.Please discuss in greater detail each of the non-GAAP reconciling items included in
Tables 6-A and 6-B. Also, disclose how you computed the discrete tax benefits and the
tax effect on actions. In Table 6-C, please breakout the total restructuring and other
action-related charges line item and the other losses, charges and expenses line item into
smaller discrete adjustments and discuss in greater detail each of the non-GAAP
reconciling items. Refer to Item 10(e)(1)(i) of Regulation S-K and Question 102.11 of
the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. This
comment also applies to your Item 2.02 Form 8-K filed May 3, 2023.
3.Your non-GAAP adjustments, discussed on page 3, to remove non-cash reserves recorded
related to deferred taxes, appear to result in an individually-tailored income tax
recognition method. Please revise your non-GAAP presentations to omit these
adjustments or tell us why you believe they are appropriate. Refer to Questions 100.04
and 102.11 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.
4.Please remove Tables 6-A and 6-B, which present most of the line items and subtotals
found in your GAAP income statement, and present your non-GAAP reconciliations in a
different manner. Refer to Question 102.10(c) of the Non-GAAP Financial
Measures Compliance and Disclosure Interpretations. This comment also applies to your
Item 2.02 Form 8-K filed May 3, 2023.
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.
You may contact Blaise Rhodes at 202-551-3774 or Rufus Decker at 202-551-3769 if
you have questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services