Political Activity and Contributions

Kohler Co. firmly believes in and supports the political process. As a company we regularly provide information and business opinions on a wide variety of subjects. Efforts are made, within ethical and legal parameters, to make Kohler Co.’s position known on issues affecting the Company, its associates, shareholders, the private sector and those communities in which Kohler Co. does business. Associates who represent the Company in political and governmental matters must comply fully with all laws that regulate corporate participation in public affairs.

In many jurisdictions, the Company is legally prohibited from contributing directly or indirectly to the support of political parties or candidates for elective office.

Expenditures on behalf of a candidate, such as travel on Company aircraft, the purchase of tickets or special dinners, and other fundraising events, may be considered indirect contributions and are therefore generally prohibited unless otherwise previously approved by the General Counsel.

This prohibition is not intended to discourage associates from making personal contributions to candidates or political organizations of their choice. However, no officer, supervisor or associate shall apply any pressure, direct or implied, on other associates to coerce or dictate the amount or recipient of personal political contributions and/or support.

In the heat of an election year, your supervisor approaches you and offers you tickets to a fundraising dinner for a local government official. He flippantly remarks that the evening would be “on the house” as he used the company card to purchase the tickets for associates within the group to “show the company’s support” for the local candidate. While you are indifferent to any political party, you still think it is odd and possibly unethical for the company to be indirectly supporting a campaign of any sort. How should you respond?

While Kohler Co. encourages associates to exercise their right to take part in the political process, no officer, supervisor or associate of the Company should be asking other associates to participate in any political activities, regardless of how direct or indirect the activities may be. Further, as a general rule, Company funds should not be used to support political parties or candidates for office. This scenario should be reported immediately to an HR representative to avoid possible breach of this policy.