Anticorruption

Kohler Energy’s Commitment

Kohler Energy has upheld the highest standards of integrity, and the Company remains committed to complying with anticorruption laws where we operate. Kohler Energy prohibits any form of bribery, anywhere in the world, in both the private sector and with governments. Violations of antibribery laws can result in serious sanctions for both the Company and individuals involved.

Our Role

As associates, we are prohibited from directly or indirectly:

Promising, offering, making, or authorizing a payment or giving anything of value intended to influence an act or decision, obtain or retain business, or secure an improper business advantage; and

Making payments to expedite the performance of a routine administrative or government action, except with prior Compliance or Legal approval or when an associate's safety or security is at stake.

Associates, contractors, and third parties acting on behalf of the Company are expected to know how to identify and avoid corruption. In addition, we follow all internal guidelines regarding:

Screening and selection of third parties representing Kohler Energy;

Gifts, hospitality, and other business courtesies;

Travel and meals;

What is “anything of value?”

Cash, hospitality (travel, meals, entertainment), kickbacks, donations or sponsorships, excess commissions, internships or jobs, rebates, gifts, or other items of value.

The Scenario

Taylor is the manager of a new manufacturing facility. Local regulations require completion of an application form and payment of a licensing fee prior to starting production, which normally takes two to three days. The local government official responsible for the license has been slow to approve the application. The official informs Taylor that the application was not properly completed but is willing to overlook it if the Company contributes 20 new toilets to a local orphanage.

Our Stance

Even though the orphanage may be a legitimate charity in need of toilets, the government official’s actions should be considered a request for a bribe, and Taylor should not agree.

Instead, Taylor should request that the official identify the alleged defects on the application so they can be corrected. In most situations, Taylor should also raise the matter with the official’s manager, thereby creating the opportunity to let it be known that Kohler Energy does not engage in such inappropriate behavior.