TRAVEL/HOSPITALITY


Associates are allowed to pay for reasonable expenses directly related to the promotion, demonstration or testing of product or services. When paying for travel/hospitality expenses for current or pending customers, the payment of such expenses shall not be used as an inducement or award for the placement of a customer order or conclusion of business in some other way, such as the award of a contract.

In general, Kohler Co. corporate travel guidelines that apply to each associate's own travel expenses should be used as a guideline and benchmark for travel/hospitality expenses related to current and pending customers.

Refer to the full policy online for comprehensive guidelines and examples of reasonable and unreasonable travel expenses.

The following would be considered reasonable travel/hospitality expenses:

· Economy class airfare for customer representative only (no spouse, other family members). Business class travel may be provided upon management approval

· Business standard accommodations (Kohler Co.-approved hotel for the duration of the business trip would be considered reasonable)

· Local transportation between the hotel, airport, office and other venues where Kohler Co. business is being conducted

· Meals (breakfast, lunch and/or dinner) that are reasonably consistent with Kohler Co. corporate travel guidelines

· Occasional tickets to an athletic or cultural event

· Modest related entertainment (e.g., drinks after a business dinner at hotel bar)

The following would not be considered reasonable hospitality expenses:

· Side trips to theme parks or entertainment venues

· Trips to other forms of "inappropriate" entertainment venues

· Consumption of uncontrolled, extravagantly priced and/or excessive amounts of liquor/wine

· Extra days at a hotel for vacationing or sightseeing, which are paid for by Kohler Co.

· Travel expenses for souses or children

The applicable time period related to the travel/hospitality expenses should be limited to the legitimate business purpose and accompanied by Kohler Co. representatives.

These lists are not intended to be exclusive. Common sense should still prevail.

As a general rule, Kohler Co. does not pay for the travel and hospitality expenses for suppliers and vendors. On the rare occasion that it may be deemed appropriate, prior management approval should be obtained, and the above guidelines should be followed.

 

The Scenario

While out to lunch with a coworker, he regales you with stories from a recent business trip he took to a trade show in Las Vegas. He mentions that while in Vegas, he connected with one of your top customers to “seal a deal.” He says that he took the customer and his wife out to a show and then out for high-priced cocktails and expensed it all as a “business meeting.” While pleased that he strengthened the relationship with the customer, you are wary of the methods he used, as it doesn’t seem entirely on the “up and up.”

 

Our Stance

While your coworkers intentions were good in wanting to strengthen the bond with a business partner, his actions were ill-advised. As a general rule, Kohler Co. does not pay for the travel and hospitality expenses for suppliers and vendors, and the payment of such expenses shall not be used as an inducement or award for the placement of a customer order or conclusion of business. To maintain the longstanding ethical standard of the Company and the well-being of the long-term business model, any practices that conflict with this policy should be reported immediately.

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