Confidential Information

In the course of employment with Kohler Co., an associate may work with information and materials which are proprietary, confidential or which may contain trade secrets. Protection of this information is vital to the Company’s future success.

As associates, we have an obligation not to disclose confidential and proprietary information. This obligation continues even after associates leave the Company. Similarly, associates may not disclose or use confidential information procured during the course of previous employment at other companies in connection with their employment at Kohler Co. The Company requires that all information be handled in accordance with its sensitivity whether it is labeled confidential or not. Some of the information that should always be considered confidential and must be handled as such includes, but is not limited to: any financial information, merger and acquisition activity, ACTs, sales figures, production information, environmental records, strategic plans, new product designs and plans, trade secrets, organization charts, technical information, IT systems configurations, networks, physical security controls, user IDs and passwords, investigation information, security information, legal documents, HR-related information, and information protected by third-party laws and regulations such as an individual’s or customer’s private data and credit card information.

If, at any time, confidential or sensitive information is lost, stolen or released to an unauthorized third party, a report must immediately be made to the Technology Services Center, the Labor Relations department, the Corporate Security department or the Corporate IT Security department, as appropriate.

Imagine an engineering team worked for a year on breakthrough technology, with the business division investing a significant amount of money in research and development costs. During that time, someone from the product team lost his laptop at an industry trade show. Two months before the new product launch, a competitor introduced the breakthrough technology.

Exposing proprietary information can ruin a brand’s reputation, give the competition an unwarranted competitive edge and potentially demoralize the associates of the Company. Which is why protecting proprietary information must be a top priority. If this type of information happens to be lost or unintentionally exposed, it must be reported immediately.