Ethics at Kohler Co. Doing the Right Thing, Following the Law

This Code reflects the Company’s core values and standards, guiding how the Company does business across all regions and cultures. The Company recognizes that local laws, customs, and business practices may vary, but the commitment to integrity, respect, and compliance remains constant. In every market where the Company operates, you and your business partners must follow the Code—even when local norms differ—while also respecting applicable laws and cultural sensitivities. When conflicts arise between local practices and the Code, seek guidance to ensure decisions align with the Company’s global standards. If you encounter a conflict or potential conflict between this Code and the various laws and practices in a particular country or region, contact our Chief Legal Officer for assistance in resolving the conflict. Upholding the Code consistently across borders strengthens the Company’s reputation, fosters trust, and ensures the Company conducts business responsibly. Anywhere the Company operates, other organizations may engage in unethical or questionable practices, but the Company holds us to a higher standard. The Company’s values should guide every decision made, and you must remain steadfast in the commitment to fair competition, compliance with laws and regulations, and respect for the Company’s stakeholders. Doing business the right way is not just a policy—it’s how the Company operates.

Think about it.

The Company operates globally, and as a result, the laws of many different countries apply to its business. Some laws extend beyond country-specific borders. For example, certain laws in the U.S. concerning bribery and trade sanctions apply not just to the Company’s operations in the U.S. but also around the world.