It is Company policy for every associate, including associates of all subsidiaries, to comply with the Anti-Bribery Laws in every jurisdiction in which we operate. The basic provision of these laws makes it unlawful to pay, offer to pay or receive any money, gift or item of value that in any way can be associated with either the associate, Company or subsidiary obtaining an improper advantage or obtaining/retaining business. The prohibition is not limited to making an offer or payment to government officials and politicians. The policy prohibits associates from entering into arrangements in which individuals are improperly rewarded, whether by kickbacks, bribes, excess commissions, rebates, gifts or other questionable payment. Kohler Co. follows the literal terms of the Anti-Bribery Laws as well as acknowledging the spirit behind those laws.


You are the manager of a new manufacturing facility. Local regulations require completion of an application form and payment of a licensing fee prior to starting production. You are confident the application was properly completed, and the corporate check is for the correct amount. The application process normally takes 2 to 3 days. Every day production is delayed, the business unit loses $20,000 USD. The local government official responsible for issuing the license has been slow to approve the application. After more than a week, you call the official and ask why. The official informs you he feels the application was not properly completed, but he would be willing to overlook that if you contributed 20 new toilets to the nearby orphanage that is run by his brother.


Even though the orphanage may be a legitimate charity in need of the toilets, the government official’s actions should be considered a request for a bribe, and you should NOT agree. Instead, you should request that the official identify the alleged defects on the application. If none exist, insist the license be issued. In most situations, you should also raise this matter with the official’s manager, thereby creating the opportunity to let it be known Kohler Co. does not engage in such inappropriate behavior.