Kohler Co.’s Commitment

Kohler Co. is committed to delighting our customers with high-quality, innovative products and services at competitive prices. Kohler Co. supports fair and vigorous competition that allows customers to benefit from choice in a free market economy. With that in mind, Kohler Co. prohibits agreements or arrangements with competitors that fix prices, coordinate bids, allocate customers or sales territories, or otherwise eliminate or restrict competition for its goods or services. 

Our Role

As associates, we comply with all applicable competition laws and regulations. To support our commitment, we:

• Never propose or enter into agreements or understandings about any aspect of competition between Kohler Co. and a competitor; 
• Never receive, provide, or exchange competitive information with competitors, such as customers, prices, bids, distribution methods, profits, market share, strategy, territories, products, or sales terms;  
• Avoid contacts with competitors that may create the appearance of improper agreements or understandings; and 
• Ensure that we engage Kohler Co. Legal when we have questions regarding contacts with competitors, handling of competitive information, agreements or bidding, or joining with competitors to lawfully present industry positions to federal, state, or local governments. 

Important: Violation of antitrust laws may result in severe criminal and civil legal penalties for our Company and for individuals involved.

The Scenario

Arlo approaches a supervisor with concerns about Q4 sales. The supervisor pulls Arlo aside “in confidence” about an “arrangement” made with a competitor to adjust its pricing and position to help meet the Company’s quarterly sales goals. Arlo fears this may violate ethical and legal practices and put the Company at risk.

Our Stance

Kohler Co. abides by antitrust and competition laws to preserve and protect fair and open competition. As associates, we are required to fully comply with all antitrust and competition laws pertaining to contracts or joint activities with other companies. Creating such an “arrangement” with a competitor is strictly prohibited. Arlo should report this to a manager or supervisor, Human Resources, Legal, Compliance and Ethics, or the Ethics Helpline.