Conducting Business

Terms & Conditions

Each business transaction is governed by the following terms and conditions specific to the site to which goods or services are provided.


Kohler Co. is committed to lawful, ethical and fair practices in all operations, and we conduct business with suppliers who share that commitment. We expect our suppliers to obey minimum international fair labor practices that require them to treat workers fairly, provide a safe and healthy work environment and protect environmental quality as set forth in the Supplier Code of Conduct. Certification is required once every five years.


Longstanding traditions of high moral conduct and ethical standards are basic to our conduct of business.  Honesty and integrity are core values that we must observe with our supplier relationships and is demonstrated by our Supplier Code of Conduct. Dishonest, fraudulent or illegal activities such as theft, embezzlement, bribery, misappropriation of property or creation of false documentation are strictly prohibited. Further, irregularities or misrepresentations in business transactions must be avoided.

If you have questions, concerns or wish to report a suspected violation please contact our Ethics Helpline by e-mail ( or by phone:  

  • In the U.S.: 877-286-7893 or 920-457-4441 extension 77958
  • Outside the U.S., dial your country’s AT&T access code then dial 877-286-7893 (Find AT&T access codes at

More information is also available at


The manual conveys core minimum quality requirements and expectations for all suppliers of production materials, products and services to the family of businesses owned directly or indirectly by Kohler Co. Agreement is required every five years.


Kohler Co. and each associate have the mission of contributing to a higher level of gracious living for those who are touched by our products and service. Our suppliers are considered an integral part of our business and are therefore a critical link to the fulfillment of our mission. Consequently, it is imperative that all purchased materials satisfy current governmental and safety constraints restricted, toxic and hazardous materials. Hazardous materials (such as Class 7 Radioactive Materials) are articles or substances which are capable of posing an unreasonable risk to health, safety, property or the environment. This document is to inform Suppliers of the minimum requirements for adherence to our hazardous materials requirements regarding radiation.


This document is to inform Suppliers of the maximum requirements for adherence to Kohler Co.'s Reach/ RoHS requirements. All material, components, and assemblies are required to comply with European Union Directive, 2011/65/EU Restriction of Hazardous Substances (RoHS). Kohler Co. requires Suppliers to acknowledge and agree to this requirement as our assurance that the material, component or assembly to which this statement applies, is compliant with the RoHS directive.



The EPA published in the Federal Register a final rule to add Title VI to the Toxic Substances Control Act to reduce exposure to formaldehyde emissions from certain composite wood products and component parts or finished goods containing these products, including hardwood plywood, medium-density fiberboard and particleboard, that are sold, supplied, offered for sale or manufactured (including imported) in the United States.  TSCA Title VI is applicable, but not limited to, manufacturers, importers, distributors, retailers, panel producers, fabricators, third party certifiers, and accreditation bodies.

You can review the regulation by clicking on the hyperlink or by pasting into your web browser.




The California Air Resources Board (CARB) approved an Airborne Toxic Control Measure (ATCM) in April 2007 to reduce formaldehyde emissions from composite wood products including hardwood plywood (HWPW), medium density fiberboard (MDF), and particleboard (PB) (Title 17, Division 3, Chapter 1, Subchapter 7.5, California Code of Regulations §93120-93120.12). The ATCM applies to manufacturers, distributors, importers, fabricators, retailers, and third party certifiers of composite wood products, and finished goods that contain composite wood products, which are destined for the California market.


You can review the regulation by clicking on the hyperlink or by pasting in to your web browser.


In August 2012, as required by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act “the Dodd-Frank Act”, the Securities and Exchange Commission (SEC) imposed reporting requirements upon Public traded companies, with respect to "Conflict Minerals." Conflict Minerals include Tungsten, Tantalum, Tin, or Gold coming from the Democratic Republic of the Congo or/an adjoining country.

It is the intention of Kohler Co. to comply with this act with a compliance program across our supply base, with the ultimate aim to enable designation of all manufactured products of Kohler Co., and its subsidiaries, as “Conflict Free”. This includes an internal due diligence process aimed at identifying and reducing risks with respect to supplier sources of 3TG minerals from the DRC Zone.

In addition, we revised our Supplier Code of Conduct, and will continually look for other improvement opportunities.


Kohler Co. must approve any product or process changes having the potential to affect the fit, form or function of the products purchased from you. Approval for the requested change must be gained from Kohler Co. prior to making any changes through the change request form.


Kohler Co. is continually striving to improve upon its communication and business efficiency with suppliers by utilizing Electronic transaction processes. Kohler Co. has deployed Electronic Data Interchange (EDI) to replace many of our paper or fax based communication methods. In addition, we have enabled a Supplier Web Portal that provides suppliers access to current long-term planning requirements, product inventory levels, open purchase orders, blocked invoice reports and payment status inquiries on-demand.


Kohler Co. utilizes a barcode program for all of its suppliers. This barcode program enhances the ability of our Receiving Departments to process product from our valued suppliers. Due to the enormous amount of product being received into Kohler Co., we have developed guidelines regarding the Barcode Label / Pallet Manifest layout and placement. All barcode labels for US bound products should comply with ANSI MH10.8M or AIAG standards and are to be in Code 39.


  • Customs Trade Partnership Against Terrorism (CTPAT)
    Suppliers importing into the United States must submit a completed questionnaire annually to maintain our CTPAT membership.
  • International Wood Packing Rules
    Any supplier shipping product into the United States that includes wood packing is required to comply with this regulation.
    Wood Packing Material Import Final Rules (PDF)
  • International Shipping Instructions
    Any foreign supplier shipping product into the United States should follow these Import Shipping Instructions.
    Kohler Import Shipping Instructions (PDF)
  • Commercial Invoice Requirements
    Any foreign supplier shipping product into the United States must comply with these Commercial Invoice Requirements.
    Commercial Invoice requirements for US Imports (PDF)


On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the state of California. The act seeks the elimination of slavery and human trafficking from product supply chains and requires that companies disclose their efforts to ensure that their supply chains are free from slavery and human trafficking.  As a responsible corporate citizen, Kohler Co. strives to ensure that human rights are upheld for our employees and all workers in our supply chain. We strive to ensure that slavery and human trafficking are absent from our supply chain through the following:

  • We require suppliers who want to enter our supply base to certify that they do not use child or slave labor, or engage in human trafficking.  When a supplier wants to join our supply base, it is required to complete a profile form which specifically requires that it does not use child or slave labor, or engage in human trafficking.  If a supplier is unwilling to certify that it does not use child or slave labor, or that it does not engage in human trafficking, we do not permit such supplier into our supply base. While we do not currently undertake assessments to verify such certifications, each supplier profile form, including the certification that they do not use child or slave labor, or engage in human trafficking, is reviewed by Kohler Procurement employees.
  • We have a Supplier Code of Conduct.  Such Supplier Code of Conduct establishes guidelines for the standard of ethical behavior we expect from our suppliers, which states that a supplier may not use child, slave or forced labor.  As each new supplier enters our supply base, it is required to certify in writing that it is in compliance with this Supplier Code of Conduct.  We also have the capabilities to re-validate existing suppliers at periodic points through our supplier certification system. The Supplier Code of Conduct is available at
  • We have an established supplier audit program that incorporates supplier certification items into this process for targeted suppliers. These supplier audits are conducted internally by our Kohler supply chain team members.  These supplier audits may be unannounced.  Non-compliance with our company standards can result in corrective action or termination.
  • All Kohler Procurement employees receive training on the Supplier Code of Conduct.  Such training covers our policy of requiring each supplier to certify that it cannot use child, slave or forced labor but it does not currently include how to mitigate associated risks from our suppliers. Employees and contractors failing to meet our company standards regarding slavery and human trafficking are subject to corrective action or termination.
  • Any Kohler employee, supplier or concerned individual can anonymously report a potential ethical violation, including human trafficking by a Kohler supplier using the website

All allegations will be thoroughly investigated by an internal team that includes Supply Management representatives. Allegations that are found to be credible will be dealt with as appropriate, which may include elimination from our supply-base.


Kohler Co. educates employees responsible for sourcing products on how to identify and respond to social and environmental responsibility issues, such as forced labor or child labor. All associates and contractors of Kohler Co. are also required to comply with our Business Ethics, which includes provisions aimed to ensure that these business partner or supplier operations are complying with all applicable laws.


Existing Suppliers


Prospective Suppliers