Kohler Co.’s Commitment
With over 145 years of business, Kohler Co. has upheld the highest standards of integrity and the Company remains committed to complying with anticorruption laws where we operate. Kohler Co. prohibits any form of bribery, anywhere in the world, in both the private sector and with governments. Violations of antibribery laws can result in serious sanctions for both the Company and individuals involved.
As associates, we are prohibited from directly or indirectly:
Associates, contractors, and third parties acting on behalf of the Company are expected to know how to identify and avoid corruption. In addition, we follow all internal guidelines regarding:
What is “anything of value?”
Cash, hospitality (travel, meals, entertainment), kickbacks, donations or sponsorships, excess commissions, internships or jobs, rebates, gifts, or other items of value.
Taylor is 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, which normally takes two to three days. The local government ofﬁcial responsible for the license has been slow to approve the application. The ofﬁcial informs Taylor that the application was not properly completed but is willing to overlook it if the Company contributes 20 new toilets to a local orphanage.
Even though the orphanage may be a legitimate charity in need of toilets, the government ofﬁcial’s actions should be considered a request for a bribe, and Taylor should not agree.
Instead, Taylor should request that the ofﬁcial identify the alleged defects on the application so they can be corrected. In most situations, Taylor should also raise the matter with the ofﬁcial’s manager, thereby creating the opportunity to let it be known that Kohler Co. does not engage in such inappropriate behavior.