Addressing Noncompliances Social Supply Chain 60 2021 ESG REPORT We track the collaborative efforts of our business partners and work to ensure corrective actions occur without delay. CAPs are designed to drive improved compliance performance and provide visibility throughout the audit process. Since the implementation of the automated CAP process in spring 2018, the CAP completion rate has more than exceeded 95%. To help elevate compliance and support our vendor and facility partners, the Factory Compliance team classifies and tracks all noncompliance violations to guide future training content. Abiding Practices Doing business with us means abiding by all of the laws that govern our industry. We require our merchandise partners to adhere to laws and treaties, both domestic and international, and our Terms of Engagement that align with internationally recognized human rights principles developed by the United Nations, Core Conventions of the International Labour Organization (ILO) core labor standards and other respected international organizations. We enforce compliance with independent, professional third parties and diligently monitor our supply chain. To manage industry trends and consumer demands, we continue to implement policies and programs into our supply chain to help ensure that our human rights commitments are met. In the past several years, we have taken steps to consolidate our vendor and facility base so that we partner more closely with like-minded vendors and facilities regarding the commitment to human rights and fair and safe working conditions. Vendor and facility compliance with our Terms of Engagement is a threshold determination of whether or not the production of our proprietary goods may be placed at a facility. We review production capacities and working conditions prior to placing production in order to support our commitment to human rights. To align with rising social challenges, we update our Terms of Engagement to all vendor partners and facilities as needed. Upon conclusion of a facility inspection, an online Corrective Action Plan (CAP) is created for the facility management, vendor partner, agent (if applicable) and Kohl’s to update as deficiencies are remediated. All business partners can submit questions, make comments and upload pictures to support their remediation of the violation. Top 10 Non-compliances by Category in 2021 19 % Emergency Preparedness 17 % Employee Protection & Machine Safety 10 % Hours of Work 9 % Chemical & Hazardous Substances 9 % First Aid / Medical 8 % General Work Environment 6 % Wages & Benefits 4 % Management System 3 % Environment 3 % Building Safety 12 % Others 3 % 3 % 4 % 6 % 8 % 9 % 9 % 10 % 17 % 19 % 12 %
Kohl's 2021 ESG Report Page 59 Page 61