Social Supply Chain Management At Kohl’s, our private brands and the business partners we choose must live up to the standards defined in our social compliance process, so we have and maintain responsible sourcing. They must share our convictions, abide by our policies and operate according to our universally applied standards regarding ethics and fairness. Social Supply Chain 57 2021 ESG REPORT Terms of Engagement We are committed to respecting human rights across our activities and operations. We hold ourselves to high ethical standards to create a positive social impact and we expect the same from our business partners. We require our merchandising vendors and facilities to adhere to our Terms of Engagement. The Terms of Engagement, which are posted at Corporate.Kohls.com , reflect our high standards and seek to protect the human rights and safety of the workers who manufacture products procured for sale in our stores and online. Our Terms of Engagement align with internationally recognized human rights principles developed by the United Nations, Core Conventions of the International Labour Organization (ILO) and other respected international organizations to promote and maintain fair business practices and put ethics and safety at the forefront of our business decisions. Our vendor and facility partners are strictly held to our Terms of Engagement, which outlines our requirements and expectations of social compliance regarding wages and benefits, working hours, prohibited use of child or forced labor (which includes, without limitation, prison, slave or bonded labor or human trafficking), discrimination, disciplinary practices, women’s rights, legally protected rights of workers to free association, health and safety issues, environmental requirements and more. Sourcing products responsibly requires the collaboration of internal and external business partners. Our Product Development and Merchant departments identify product categories for proprietary brands, develop individual product styles and negotiate the purchase transaction with suppliers. The Factory Compliance team works with agents, vendor partners and facilities to assess working conditions to help ensure the fair and ethical treatment of workers and a safe and healthy work environment. Zero-Tolerance Policy Our compliance philosophy focuses on continuous improvement; however, we enforce a zero-tolerance policy for certain violations of our Terms of Engagement, which can result in immediate termination of our business relationship with the vendor and/or facility. In certain circumstances, merchandise produced under the following conditions will not be accepted: Our zero-tolerance policy for certain violations of our Terms of Engagement is communicated to vendor and facility partners during meetings and through business correspondence to ensure awareness and understanding of these critical issues in an effort to eliminate human rights risks in our supply chain and ensure our goods are responsibly sourced. • Forced labor, child labor, prison labor, bonded labor, slavery or human trafficking • Physical or sexual abuse • Nonpayment of wages • Unsafe working conditions • Unauthorized subcontracting • Unethical business practices: Attempted bribery of social compliance, Customs Trade Partnership Against Terrorism (CTPAT), environmental or quality assurance auditors • Trans-shipment or altering/tampering with country-of-origin markings
Kohl's 2021 ESG Report Page 56 Page 58