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Kohler Energy and each associate have the mission of contributing to a higher level of gracious living for those who are touched by our products and services. Our suppliers are considered an integral part of our business and are therefore a critical link to the fulfilment of our mission. This conducting business page provides materials and requirements for how our suppliers are expected to conduct 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.

 

SUPPLIER CODE OF CONDUCT

Kohler Energy is committed to lawful, ethical and fair practices in all operations, and we conduct business with suppliers who share that commitment. This Supplier Code of Conduct applies to all entities doing business with Kohler Energy and communicates our expectations that our suppliers will practice the highest legal, moral and ethical standards when conducting our affairs to contribute to our mission of providing a higher level of gracious living to those touched by our products and services. Suppliers must certify to the Supplier Code of Conduct.

 

SUPPLIER ETHICS

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.

GLOBAL SUPPLIER QUALITY MANUAL

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 Energy.

SUSTAINABILITY AND PRODUCT TRANSPARENCY

Kohler Energy is actively working to make the world more sustainable through our innovative products and services. Through our work, we aim to improve the positive societal impacts of our products across their lifecycle, including supplier operations, manufacturing, use, and end of life. We are aggressively working to reduce our environmental impact around greenhouse gas emissions, water use, material valuation, and toxicity. As our suppliers are often a large part of the life cycle impact of our products, we expect suppliers to join us on the journey to reduce negative impacts in the pursuit of continuous improvement and operational excellence.

Kohler Energy is also committed to product transparency in order to share material health and environmental impacts with our customers. As many of our products have supplied components, suppliers are expected to provide requested information in order to help Kohler Energy to meet these goals.

RESTRICTED MATERIALS LIST

Kohler Energy is committed to the quality and safety of our products and the well-being of the consumers who use them. This commitment to safety includes the ingredients and materials used in our products.

Kohler Energy maintains a Restricted Materials List (RML) to ensure consistent, global practices both within our operations and with our supply base. Kohler Energy continuously monitors global regulatory agencies regarding restrictions of potential product ingredients to ensure content of the Restricted Materials List remains current. The RML document is intended to inform Kohler Energy Suppliers of the minimum requirements that must be adhered to in order to meet current regulatory requirements and public safety expectations.

CONFLICT MINERALS

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 Energy. 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 Energy, 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.

DATA PRIVACY

Kohler Energy is committed to complying with data privacy regulations by providing for protection, transfer, access, and storage of personally identifiable information (PII) and conducts business with suppliers that share that commitment. This includes, but is not limited to, General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

Personally Identifiable Information is any information that alone, or when combined with other data, can be used to identify someone as a person and includes, but is not limited to name, national ID or other ID number, location data, online data such as cookies, or physical, physiological, genetic, mental, economic, cultural or social characteristics.

Kohler Energy regularly reviews how we collect, view, handle, store, and use Personally Identifiable Information of anyone in contact with us, including customers, consumers, suppliers, distributors, and current and potential employees, to ensure privacy regulations compliance in all countries.

ON-SITE CONTRACTOR CLAUSES

Kohler Energy is committed to providing a safe working environment for its associates and any supplier employees or contractors operating at our facilities. Kohler Energy’s On-Site Contractor Clauses apply whenever a supplier is performing services or working on our facilities to ensure the supplier complies with all safety requirements.

ELECTRONIC PROCUREMENT

Kohler Energy is continually striving to improve upon its communication and business efficiency with suppliers by utilizing Electronic transaction processes. Kohler Energy 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.

IMPORT COMPLIANCE

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.

International Shipping Instructions

Any foreign supplier shipping product into the United States should follow these Import Shipping Instructions.

Commercial Invoice Requirements

Any foreign supplier shipping product into the United States must comply with these Commercial Invoice Requirements.

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

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 Energy. 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 Energy 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 Kohlerenergy.com/conducting-business.

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 Energy 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 Energy 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.

INTERNAL ACCOUNTABILITY

Kohler Energy 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 Energy 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.