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United States securities and exchange commission logo
September 23, 2021
Steven Voskuil
Chief Financial Officer
The Hershey Company
19 East Chocolate Avenue
Hershey, PA 17033
Re: The Hershey Company
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 17,
2021
File No. 001-00183
Dear Mr. Voskuil:
We have reviewed your filing 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.
1. We note that you
generally refer to future climate-change related investments and
priorities in your
proxy statement. If material, please describe and quantify material
planned expenditures in
your annual report.
2. To the extent material,
discuss the indirect consequences of climate-related regulation or
business trends, such
as the following:
decreased demand
for goods that produce significant greenhouse gas emissions or are
related to
carbon-based energy sources;
increased demand
for goods that result in lower emissions than competing products;
and
increased
competition to develop innovative new operational or production processes
that result in
lower emissions.
3. If material, discuss
the significant physical effects of climate change on your operations
and results. This
disclosure may include the following:
quantification of
material weather-related damages to your property or operations;
Steven Voskuil
The Hershey Company
September 23, 2021
Page 2
and
any weather-related impacts on the cost or availability of
insurance.
4. Quantify any material increase in compliance costs related to climate
change.
5. If material, provide disclosure about your purchase or sale of carbon
credits or offsets and
any material effects on your business, financial condition, and
results of operations.
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 Wei Lu, Staff Accountant at (202) 551-3725 or Ethan
Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding the
comments.
FirstName LastNameSteven Voskuil Sincerely,
Comapany NameThe Hershey Company
Division of
Corporation Finance
September 23, 2021 Page 2 Office of
Manufacturing
FirstName LastName