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Conflict of Interest

Kohler Energy’s Commitment

Kohler Energy’s business decisions are based on what is best for the Company as a whole and our customers. Kohler Energy expects us as associates to continue building our reputation as a fair, honest business and business partner by maintaining our objectivity in all business dealings.

A conflict of interest occurs when personal interests or interests of family and friends have the potential to hinder our ability to make an objective decision in the best interest of Kohler Energy Examples:

Financial investments outside the Company;

Employment, consulting, or other positions outside Kohler Co;

Political activities;

Close personal relationships in a direct or indirect reporting line or with others working for a supplier, partner, competitor, or customer of Kohler Energy; and

Other situations that may create a conflict between an associate and the Company.

Our Role

As associates, we do not use our position at Kohler Energy to obtain favors or benefits for ourselves or others, and we should avoid any situations that may cause the perception of divided loyalty. In addition, we are responsible for disclosing any actual, perceived, or potential conflict of interest—both at hire and throughout our Kohler Energy employment. The Company will work with us to remove any risk to Kohler Energy.

The Scenario

Marlow was contacted by an external company via social media. The company offered to pay $200 USD per hour to “consult” for them by answering questions about products, manufacturing, and sales trends in the home and decor space. Marlow is considering the offer because it is decent money and in an area of Marlow’s expertise. What should Marlow do?

Our Stance

This situation is a conflict of interest because it parallels Marlow’s role at Kohler Energy. In addition, it is possible this company is a competitor of Kohler Energy or works for one.

In this situation, Marlow should decline the offer.