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kohl's Download Corporate Governance Documentation	Report to Shareholders on Social Responsibility
 

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    kohl's Download Corporate Governance Documentation	Report to Shareholders on Social Responsibility kohl's Download Corporate Governance Documentation Report to Shareholders on Social Responsibility Document Transcript

    • Kohl’s Department Stores, Inc. Report To Shareholders On Social Responsibility 2007 1
    • Table of Contents 3 Letter from the President Social Responsibility 4 A. Product Manufacturing 4 Kohl’s Compliance Philosophy 4 Our Policy 5 Oversight of Our Policy 5 Compliance Program 6 Our Monitors 7 Factory Monitoring Process 8 Corrective Action and Remediation 8 Education and Training 9 Program Performance Statistics 9 B. Community Involvement 9 Charitable Programs 10 Volunteer Efforts 11 C. Environmental Responsibility 11 Energy Management Programs 12 Waste Stream Reduction Programs 13 Building Design: Kohl’s a “LEED”ing Green Retailer 14 Reduction of Climate Damaging Emissions 15 Encouraging Environmental Values 15 D. Health and Safety 15 Workplace Health and Safety 16 Product Integrity 16 Policy on Cosmetic Testing 17 Appendix Terms of Engagement 2
    • ___________________________________________________ Letter from the President: Kohl’s is committed to the highest standards of integrity and performance relating to social responsibility. Responsible corporate citizenship is a company core value, therefore social, economic and environmental considerations are integrated into our purchasing and risk management processes. Incorporating socially responsible principles into our daily business activities generates benefits not only in the present, but also for the future. We are involved in the communities in which we operate through charitable donations, volunteer efforts and environmental partnerships. Through Kohl’s Cares for Kids ®, we have raised more than $102 million for children’s health and educational initiatives since 2000. In 2007, more than 39,000 Kohl’s associates volunteered over 136,000 hours and donated $3.2 million to youth-serving, nonprofit organizations. Our 2007 environmental efforts included initiating delivery of rooftop solar energy to 113 Kohl’s locations in California, New Jersey, Wisconsin and Connecticut which was the largest rooftop solar rollout in U.S. history. The objective of all of these efforts is to promote positive change for the community, our customers, business partners, shareholders and associates. In support of our commitment to positive change, we maintain a dynamic social responsibility program. Program components include established terms of engagement for our suppliers, clear communication of company expectations and guidance in achieving compliance and monitoring efforts to track supplier performance. In addition, we encourage our suppliers to develop and enhance their own social responsibility functions. Together with our business partners, we strive to implement positive social, economic and environmental change. We are pleased to issue this Report to Shareholders on Social Responsibility which includes company initiatives and progress updates relating to social, economic and environmental responsibility. Our commitment to enhancing the communities we serve remains strong and social responsibility will continue to be an essential element of our growth and success. Sincerely, Kevin Mansell President 3
    • Social Responsibility A. Product Manufacturing Kohl’s is committed to high standards of behavior and performance on issues of social responsibility. Through our Terms of Engagement (“our Policy”), we hold all of our Vendor Partners to these same high standards. Our Policy is designed to protect the interests of workers engaged in the manufacture of merchandise procured for Kohl’s. Our Policy focuses on compliance with local labor laws, working conditions and spells out Kohl’s expectations to our Vendor Partners regarding wages, child labor, health and safety issues, forced labor, respecting the rights of workers to free association and more. Our Policy is posted on our Website at www.connection.kohls.com (“new vendors” tab). We do not own or operate the manufacturing facilities in which merchandise we sell is produced, nor do we control the production capacity of such facilities. We do not manufacture the merchandise we sell. We purchase goods from independent suppliers. We contract with numerous Vendor Partners who in turn contract with hundreds of manufacturing facilities in the United States and throughout the world to procure the merchandise we sell in our stores. It is critically important to us that each Vendor Partner’s manufacturing facility treats its workers fairly and in compliance with our Policy. We have several ways to ensure that the merchandise we sell is produced in compliance with our Policy: seeking Vendor Partners who share our commitment to the principles contained in our Policy, monitoring our Vendor Partner’s compliance efforts and exercising our ability to take corrective action, when necessary. This report summarizes Kohl’s progress in further developing and implementing our compliance program for our Vendor Partners. While the foundation of our efforts is our Policy; we believe compliance is a process which requires working closely with our Vendor Partners to identify and address challenges in a responsible manner, that considers the needs and expectations of the affected Vendor Partner, its suppliers, employees, and our shareholders. This means that we will continually challenge our Vendor Partners to protect the health, safety and human rights of workers. Kohl’s Compliance Philosophy We select Vendor Partners who we believe share our commitment as expressed in our Policy. If deficiencies in adherence to our Policy are discovered, we exercise our ability to take corrective action. Our compliance philosophy focuses on remediation and continuous improvement. We demand, as a condition of doing business, that our Vendor Partners and suppliers adhere to our Policy and eliminate unacceptable conditions in their facilities and that they respond appropriately and swiftly to correct conditions that fall short of our expectations. From time to time, we review our Policy to determine whether in light of new developments, Policy modifications would be appropriate. Our Board of Directors is kept apprised of the development of our compliance program. Our Policy Kohl’s adopted a formal human rights policy in October 1996 entitled “Terms of Engagement for Kohl’s Business Partners”, which emphasized our longstanding philosophy that no merchandise purchased by us will be manufactured through use of labor conditions contrary to our Policy. Our Policy sets forth our requirements with respect to working conditions, wages and benefits, working hours, nondiscrimination, compliance with laws, and prohibitions against child and prison labor. Our Policy has been translated into 46 languages. It is distributed to all of our Vendor Partners and suppliers each year. It is available on Kohl’s Website, www.connection.kohls.com (“new vendors” tab). We also distribute our Policy to all of our buying agents and all potential Vendor Partners from whom we are considering procurement of overseas merchandise. We provide training to Vendor Partners on our Policy and our expectation of compliance. We require all Vendor Partners to certify that each facility used to produce merchandise for Kohl’s will operate in compliance with all applicable laws. To ensure that all Vendor Partners and all manufacturing facilities understand our Policy and specifically the consequences which will result from 4
    • noncompliance, Kohl’s requires Vendor Partners to notify and discuss our Policy with each manufacturing facility used for the production of merchandise sold by us. Vendor Partners are also required to post the Policy in each manufacturing facility that produces merchandise for Kohl’s in the language of the workers and of management in the facility. During factory visits, our monitors validate that our Policy is posted and, if needed, distribute copies of our Policy to ensure that factories are aware of our requirements. Our buying agents and all prospective and current Vendor Partners must fully comply with our Policy as a condition of doing business with Kohl’s. Compliance with our Policy isn’t just mandatory at the outset of production; it is an ongoing requirement for doing business with Kohl’s. Regardless of which factors led to the selection of a particular Vendor Partner, manufacturing facilities must comply with our Policy throughout the manufacturing process. Prospective manufacturing facilities which do not meet the requirements of our Policy after being given reasonable opportunity to do so are not permitted to manufacture merchandise for us. For those Vendor Partners producing merchandise for Kohl’s where deficiencies are identified, our expectation that Vendor Partners move into full compliance is clearly communicated to them. Our Policy was written to help Vendor Partners understand and apply these standards to their day-to- day operations and adopt them as “company policy”. Words like “shall” and “must” are included in our Policy instead of words like “should” or “may”, because we want our Vendor Partners to take our Policy seriously and to have no misunderstanding that keeping Kohl’s business depends on how their facilities are run. In addition, we require our suppliers of diamonds and jewelry to ensure that the merchandise they sell to us meets the requirements of the Clean Diamonds Trade Act and the Kimberly Process Certification and that this merchandise does not contain conflict diamonds. Oversight of Our Policy Implementation of our Policy is subject to the review and guidance of a group of senior executives who are responsible for our corporate and business operations and personnel directly responsible for the day-to-day efforts of our compliance program. Our compliance program includes an established set of rules, requirements and expectations as set forth in our Policy, communication of our rules, requirements and expectations, factory monitoring, corrective action and remediation, and education and training. The senior executives are responsible for the overall direction of our compliance program in addition to assessment of ongoing monitoring and remediation efforts of our Vendor Partners. These executives are also responsible for strengthening our policies and procedures as they believe is in the best interests of Kohl’s. The Audit Committee of our Board of Directors also reviews our efforts with respect to our Policy and compliance program on an annual basis. Kohl’s organizational structure supports the uniform and objective application of the compliance program to all Vendor Partners. Corporate Governance department personnel are responsible for day- to-day duties and administration of the compliance program and are independent of the Product Development and Merchandising departments who are responsible for development, sourcing, and merchandising. The Senior Vice President of Corporate Governance reports to the Audit Committee of the Board of Directors. As a result, day-to-day decisions regarding the social compliance status of potential factories, and those factories that are being used to produce merchandise for Kohl’s, are made by personnel not involved in actual purchase negotiation. It is important to note that social, economic and environmental considerations are also incorporated into our product development, purchasing and risk management processes. Compliance Program We expect our Vendor Partners to take all steps necessary to ensure compliance with our Policy in their manufacturing facilities that produce merchandise for us, whether the facility is operated by them or by one of their subcontractors. We require our Vendor Partners who produce private label and exclusive merchandise for us to identify all manufacturing facilities, domestic and foreign, that they plan to use to produce such merchandise and to provide us with written certification that each facility will operate in 5
    • compliance with our Policy. Subcontractors that a Vendor Partner desires to use in the manufacturing process must be approved by us. For private label and exclusive merchandise that is produced by Vendor Partners who are designated the “importer of record”, we require participation in a manufacturing facility compliance survey. Under this program, the facilities that the Vendor Partner intends to use must first conduct a self-survey of the Policy requirements and then submit to inspection by third party monitors. If a deficiency is discovered, the facility is given the same opportunity to correct deficiencies as are made available to those Vendor Partners from whom Kohl’s acquires the merchandise, when Kohl’s is designated the “importer of record”. We reserve the right to review all Vendor Partner facilities – including the use of unannounced, on site inspections of manufacturing facilities. During fiscal 2006 and 2007, Kohl’s further developed its risk based factory monitoring methodology. Factories that are deemed to have higher-than-average risk receive ‘unannounced’ visits. The following methodology is used to asses risk and to determine if monitoring visits are announced or unannounced. Risk assessment is based upon the following factors: - social conditions in the geographic location of the factory - factory management attitude towards social compliance - vendor historical performance across all factories used to produce goods for Kohl’s - past monitoring visit results, if the factory was previously visited - any reported potential issues The risk ratings for each of the above factors are reviewed to establish an overall risk rating for each factory. We recognize that publication of a statement of principles is insufficient to achieve compliance with those principles and that aggressive enforcement of our Policy is required. To achieve this goal, we actively monitor factories in which our merchandise is produced. We support this effort with a Policy Compliance team appointed to ensure consistency and quality in our monitoring efforts. To date, we have performed in excess of 13,000 monitoring visits to over 3,000 manufacturing facilities in 75 countries around the world. Each audit involves close inspection of a factory to ensure compliance with all aspects of the Policy. To support our monitoring efforts, we have also developed an extensive database that permits us to actively summarize and manage the information we receive through our monitoring efforts. It enables us to identify emerging issues and particular regional problems so that we are able to focus our efforts in areas with the greatest risks. Monitoring of factories is performed by professional, independent third party monitors and is ongoing. Factories are monitored by third party monitors as a condition of a business relationship with Kohl’s. Once deemed compliant with our Policy, factories are monitored by third party monitors periodically, based on established risk level. Our Monitors We have retained the services of two professional, independent third party monitors to monitor Vendor Partner compliance with our Policy. These monitors were selected on the basis of their reputations as experienced, independent, and world-renowned compliance and monitoring firms and to avoid even the appearance of a conflict of interest. Our monitors have auditing professionals located in the territories in which the manufacturing facilities are located, able to speak the language of the workers working in the facilities monitored, and who each have extensive experience with monitoring for compliance for social responsibility on behalf of numerous companies. We work closely with these monitors to develop a monitoring program that enables us to consistently assess compliance with our Policy and to track our compliance efforts. Out of this effort, we developed a lengthy, detailed and comprehensive set of materials, which were designed to enable monitors to evaluate production facilities used to manufacture Kohl’s private and exclusive brand merchandise. Our principal buying agent’s personnel also visit manufacturing facilities at the inception of each engagement and at least two times during the manufacturing. To ensure compliance with our Policy, Kohl’s requires this principal buying agent, who is trained to recognize violations of our Policy, to notify 6
    • us of such matters when they are observed. For certain high-volume merchandise purchased by us, our principal buying agent’s personnel is onsite at the manufacturing facility each day for the duration of the manufacturing process. Our principal buying agent also confirms that corrective action of previously identified Policy violations has been undertaken. Our internal product sourcing staff also watches for, and reports, issues of noncompliance with appropriate parties if violations of our Policy are observed during factory visits made by them for follow up and, when appropriate, corrective action. Factory Monitoring Process Our professional third party monitors monitor the manufacturing facilities in which Vendor Partners produce merchandise for us. The purpose of each inspection is to determine whether each factory is compliant with our Policy. The monitors spend one or two days in each manufacturing facility, interviewing factory management and workers. During such visits, the monitors perform a facilities walk-through where manufacturing facility conditions are observed, detailed testing of factory payroll is conducted and other business records are reviewed. A manufacturing facility floor plan is also reviewed to ensure that the entire facility is inspected. Our full-compliance audit program includes fifteen different modules: • Laws and Regulations • Wages and Benefits • Working Hours • Child Labor • Forced Labor • Discrimination • Free Association • Disciplinary Practices • Women Rights • Health and Safety • Health and Safety - Dormitories • Environmental Requirements • Communication and Record Keeping • Subcontracting • Monitoring and Compliance Third party monitors conduct an opening meeting with manufacturing facility management during which the monitor reviews our policy with management and the monitoring procedures are described in the language understood by the manufacturing facility management. Our emphasis on remediation to correct any deficiencies found is also stressed. Workers are selected to be interviewed at random and all worker interviews are conducted in a private place and in the local language of the workers. The content of these worker interviews is kept strictly confidential. During the course of each monitoring visit, the monitoring representative documents all violations or deficiencies related to our Policy and promptly reports findings to us. Upon completion of each monitoring visit, the monitor summarizes and discusses each violation with the facility’s management and the management team, once so notified, is asked to remedy all identified violations or deficiencies. Our internal Policy compliance team carefully reviews the monitor’s report and promptly sends a letter summarizing the monitoring results in detail to the manufacturing facility and our Vendor Partner, notifying each of them in writing of any Policy violations and deficiencies that have been identified by our third party monitor. Serious noncompliance issues require immediate submission of a corrective action plan. In all communications, our Policy compliance team provides recommendations of corrective action needed to bring the manufacturing facility into compliance with our Policy. To further ensure that manufacturing facilities comply with our Policy, we require our principal buying agent, who is trained to recognize deficiencies in Vendor Partner compliance, to notify us of such matters when they are observed. Such personnel visit manufacturing facilities at the inception of the relationship with Kohl’s and several times during the manufacturing process. For certain high-volume 7
    • merchandise purchased by us, our principal buying agent is onsite at the manufacturing facility each day for the duration of the manufacturing process. Our principal buying agent also confirms that corrective action of previously observed Policy violations by our third party monitors has been undertaken, as necessary. Our internal sourcing staff is also trained to raise issues of noncompliance which are observed during manufacturing facility visits with appropriate individuals at Kohl’s. Corrective Action and Remediation Helping our Vendor Partners change to comply with our Policy helps everyone and we believe our approach is balanced, fair, and effective. If noncompliance with Kohl’s Terms of Engagement is brought to our attention, either through our monitoring efforts or otherwise, we take appropriate action, which, depending on the severity of the deviation, ranges from working with our Vendor Partner to ensure that adequate steps are taken to address the deficiencies discovered and to prevent reoccurrence, to canceling affected orders, terminating our relationship with our Vendor Partner, working with the authorities or other actions as warranted. We require our Vendor Partner to adopt a corrective action plan whenever possible. We prefer to work with Vendor Partners who address deficiencies that are reported to us. Timely remediation must be undertaken as necessary. Follow-up evaluations are completed to verify subsequent adherence to our Policy. If a deficiency is discovered and a decision is made to continue the business relationship, follow-up inspections to verify compliance are undertaken. Our principal buying agent provides direction and training to our Vendor Partners for implementation of needed corrections identified through our monitoring process and follows up as necessary. Our response to Vendor Partner noncompliance is dependent on the severity of the noncompliance, but we make every effort to try to bring noncompliant facilities into compliance rather than terminate them. Education and Training We regularly communicate with our Vendor Partners on compliance issues. We encourage educational programs and collaborative efforts by our Vendor Partners to enhance compliance with our Policy. In 2007, we conducted three group training sessions and numerous individual training sessions for Vendor Partners to promote understanding and compliance with our requirements. These training sessions brought together Vendor partners supplying Kohl’s with softlines, hardlines, home textiles and footwear. In this way, we clearly communicated our expectations and, in turn, our Vendor Partners had the opportunity to explain their practical challenges to us. We expect our Vendor Partners to cooperate in such efforts and to take the steps necessary to ensure their contractors and manufacturing facilities are also fully informed. The following topics were reviewed during these training sessions: • Expectations for suppliers • Definition of each element of our Policy • Best practices • Review of site verification methods • Reporting of findings and assessments • Remediation methods • Actions for compliance improvement In addition, we strongly encourage our Vendor Partners to develop and/or enhance their own internal social responsibility functions to raise awareness, improve and sustain performance. Kohl’s emphasizes the importance of vendors maintaining open lines of communication with both factory management and Kohl’s regarding issues of social responsibility. Kohl’s also partners with its agents and Vendor Partners to identify opportunities to enhance processes that promote sustained socially responsible performance. We also conduct regular internal training sessions on the requirements of our Policy. In 2007, training on Kohl’s policies and procedures related to our Policy was provided to associates responsible for the development of private and exclusive brand product and our merchants who are responsible for procurement of the merchandise we sell. Ongoing training sessions occur on a quarterly basis to 8
    • reinforce previous training and to orient new associates with regard to our Policy. In addition, Kohl’s executives are required to attend annual, internally presented business ethics meetings and sign a form acknowledging their attendance, understanding and compliance with Kohl’s business ethics standards. This training reinforces business ethics best practices and supports the company’s on-going commitment to high standards of behavior on issues of social responsibility. Program Performance Statistics Social Compliance Program Monitoring Statistics Item Description 2007 2006 Manufacturing Facility Visits 3,008 3,017 Percentage of Visits Performed Unannounced 30% 3% Number of Facilities Visited 1,615 1,520 Percentage of Facilities in Compliance with our Policy at Year End 62% 57% Percentage of Facilities that Failed to Meet Our Standards and were Made Not Authorized Due to Noncompliance 13% 11% Percentage of Facilities Vendor Partners Withdrew from Consideration since More Appropriate Facilities were Available 9% 13% Percentage of Facilities Still in Monitoring Process at Year End 16% 19% Kohl’s is a member of Business for Social Responsibility (BSR) and a participant in the Ethical Sourcing Working Group sponsored by BSR to allow members to share ideas and experiences regarding their social responsibility compliance efforts and to identify “best practices” relating to such issues. In addition, members of our Policy Compliance team have attended national conferences on corporate social responsibility. We believe our policy, and our efforts to achieve compliance with it, is a sound approach to promoting responsible working conditions in those factories that produce our private and exclusive brand merchandise. We have made progress during the course of the past year in further developing and implementing our compliance program for Vendor Partners. B. Community Involvement Kohl’s is involved in the communities in which we operate through charitable financial contributions and volunteer efforts. The objective of these efforts is to promote positive change for the community we serve, our customers, business partners, shareholders and associates. Charitable Programs Kohl’s Cares for Kids Kohl’s Cares for Kids is not just a program, it’s a promise of hope for a brighter, healthier future for children in communities that we serve. As a family-oriented company, Kohl’s dedicates its charity efforts to improving health and educational opportunities for children in our store communities. Every day across the country, from injury prevention to immunization programs, Kohl’s is putting time, effort and funding toward keeping children healthy. Throughout the year, Kohl’s sells special Kohl’s Cares for Kids merchandise with 100% of the net profits from the sale of this merchandise benefiting children’s health and educational initiatives 9
    • nationwide. Kohl’s Cares for Kids is Kohl’s way of supporting its customers, communities and improving the lives of children. Through Kohl’s Cares for Kids ®, we have raised more than $102 million for children’s health and educational initiatives since 2000. Kohl’s Cares for Kids Hospital Program Kohl’s supports children’s health initiatives through partnerships with designated hospitals in each community it serves. Kohl’s partners with hospitals in the communities we serve to support community outreach initiatives that improve children’s health. Kohl’s Kids Who Care Scholarship Program The Kohl’s Kids Who Care recognition program is a signature program under the Kohl’s Cares for Kids umbrella which provides Kohl’s an annual opportunity to recognize and reward young volunteers who transform their communities for the better. This grassroots program demonstrates Kohl’s commitment to the community and kids at the local level. Through the Kohl’s Kids Who Care Scholarship program, parents, educators and community members nominate children ages 6 through 18 who volunteer in their community to be recognized by Kohl’s for their efforts. Kohl’s Cares for Kids Fundraising Card Program Kohl’s has created a simple, effective way to help raise much needed funds for schools and youth- focused nonprofit organizations, while eliminating many of the challenges characteristically associated with fundraising. The Kohl’s Cares for Kids Fundraising Card Program provides discounted fundraising gift cards to youth-serving, non-profit organizations. These groups then sell the purchased cards at face value and keep the remaining profits. US Youth Soccer For the past six years, Kohl’s has served as the Official Department Store sponsor of US Youth Soccer and is pleased to announce a three year partnership extension with US Youth Soccer through 2010. In addition, Kohl’s will maintain title sponsorship of the only national recreational property executed by US Youth Soccer called the American Cup – a premier recreational youth soccer tournament hosted through US Youth Soccer State Soccer Associations throughout the country. It is Kohl’s American Cup philosophy that all players should receive equal opportunities and benefits within their level of play. All players have the right to participate in competitions where they can develop and exhibit their skills while enjoying themselves. The Kohl’s American Cup provides recreational players this opportunity and places emphasis on participation, as opposed to competition. Volunteer Efforts Kohl’s A-Team The Kohl’s A-Team is an associate volunteer program under the Kohl’s Cares for Kids umbrella that supports youth. Its mission is to enhance the lives of youth in the communities we serve to enrich the lives of our associates by leveraging our collective talents through volunteer efforts. In 2007, more than 39,000 Kohl’s associates volunteered over 136,000 hours and Kohl’s donated $3.2 million on behalf of those volunteer efforts to youth-serving, nonprofit organizations. 10
    • C. Environmental Responsibility Kohl’s Environmental Mission: To be a leading environmentally responsible retailer through focused resource stewardship by our associates, vendors and business partners. Kohl’s Resource Stewardship Strategies: • Maximize Energy Efficiency • Minimize Waste • Improve New Building Design • Reduce Climate Damaging Emissions • Encourage Environmental Values Energy Management Programs Central Energy Management System Implementation: 2005 98% of Stores Through careful monitoring, this system controls most interior and exterior lighting as well as heating and cooling systems at our stores. As a result of this program, Kohl’s has one of the lowest energy usages per square foot in the retail industry. High Efficiency Lighting Implementation: 2003 This has resulted in 12.3% lower energy use for all new locations constructed after rollout in 2003. Occupancy Based Sensor Lighting Most locations in our stores, distribution centers and corporate offices have occupancy based sensor lighting in bathrooms, stockrooms, fitting rooms and office areas to further conserve energy. Environmental Protection Agency (EPA ) Green Power Partnership Membership Since: 2006 Kohl’s partnered with the EPA in purchasing 201,396,000 kWh in renewable energy credits for use in 2007. This purchase of biomass energy from Clear Sky, and other municipal providers ‘greens’ 20% of Kohl’s total energy consumption. These commitments placed Kohl’s at # 2 on the EPA Top Ten Retail Green Power Purchasers and rank # 8 overall in 2007. On October 22, 2007 Kohl’s was recognized by the EPA with a Green Power Leadership Award for its commitment to renewable energy. Demand Response Controls Implementation: 2007 Kohl’s partnered with RTP Controls to install “automated demand response” controls in 33 stores in California. Using these controls, Kohl’s has voluntarily agreed to reduce power usage in its stores during the peak times Monday through Friday in the months May to October. The utility alerts RTP when the demand will likely exceed the supply and RTP sends a message to the control unit at our stores that automatically shuts down the store’s cornice and spotlights to support energy reduction at these times. The store customers and associates are alerted by a message that is broadcast at regular intervals on the store public address system. Solar Power Installations Kohl’s entered into a “power purchase agreement” with SunEdison for a twenty year term in 2007. This allows installation of solar power on Kohl’s rooftops without any capitol outlay to Kohl’s. This use of a silent, clean power is cost saving and great for the environment. As of January 2008, Kohl’s has 21 solar power systems activated in California and another 21 systems in various stages of construction. As the largest single host of solar electricity production in North America, the Kohl’s implementation will generate 25 megawatts of electricity in California alone when completed. This is 11
    • greater than that of the five largest photovoltaic systems in the US combined, and equivalent to the electricity used by 3,087 California homes. It will offset more than 28 million pounds of carbon dioxide in the first year, similar to taking approximately 2,500 cars off the road. The systems will provide about 40% of each store’s power. An average system on the California stores will have 2,340 solar panels that will nearly cover the roof of the typical 88,000 square foot building. Kohl’s largest system is on the San Bernardino, California Distribution Center and has 6,208 panels and will generate 1 megawatt of power. Green Power Purchases Kohl’s has partnered with the EPA Green Power Partnership to support the use and development of renewable energy. Kohl’s demonstrates its support of green power by purchasing renewable energy credits. Kohl’s made two substantial purchases in the past year. Kohl’s commitment is to have 20% of its energy use come from renewable energy sources. To accomplish this goal, a purchase of 201,396,000 kWh of renewable energy credits was made in 2007. Kohl’s ranked # 2 on the Retail Top Ten list and # 6 on the Fortune 500 List for purchase of green power in 2007. Waste Stream Reduction Programs Paper Purchasing Programs Kohl’s considers a variety of factors when choosing mill partners who provide paper for the printing of our weekly advertisements. They include pricing, sustainable and certified forestry, environmentally friendly processes and the use of recycled content. Kohl’s also looks at each mill’s internal operations for production and distribution efficiencies. Selection of mill partners who share our environmental commitment will help us to improve the environmental aspects of this program and the paper we purchase. Through mill partnerships, Kohl’s supports and encourages the following certifications: • Program for the Endorsement of Forest Certification (PEFC) • Forest Stewardship Council (FSC) • Sustainable Forestry Initiative (SFI) • Canada Standards Association (CSA) • Master Logger Certification Program (MLC) • American Tree Farm Systems (ATFS) Kohl’s challenges all suppliers to provide only certified sources of wood and fiber. Kohl’s does not knowingly purchase forest products that are illegally harvested or protected from harvesting by law. Kohl’s requires each mill partner to operate under a third-party certified chain of custody (COC). We work with all mills to improve paper purchasing certifications. Kohl’s also prefers mills who meet all 12
    • government regulations for clean air and water, and who manufacture paper without the use of chlorine or chlorine compounds. Kohl’s paper purchasing team purchased from 100% certified sources in 2007. They will continue to conduct annual sustainability meetings with all suppliers who provide forest products. Recycling Programs Kohl’s has a longstanding commitment to recycling as part of our business practice. Recycling Results - 2007 Cardboard and Paper 92,200 tons Hangers 5,721 tons Merchandise 1,550 tons Plastic 1,005 tons Misc* 2,522 tons *Bottles, Cans, Gift Cards, Fluorescent Light bulbs Plastic Recycling: Kohl’s implemented a new plastic recycling program in 2007 that is supporting 70% of our stores. Our stores strip all plastic that is shipped with our merchandise and return it through our distribution network for recycling. This plastic is recycled into plastic pellets that will be used for molding new products. Use of Products with Recycled Content When cost effective, it is Kohl’s goal to use products with recycled content. The following is a list of items Kohl’s purchases for its business operations. Item % of Recycled Content Gift Boxes 100% Restroom Papers 100% Merchandise Bags 10-30% E-Commerce Shipping Cartons 30% Advertising Paper 20.5% Office Supplies 12% Waste Prevention Kohl’s waste stream management program does not stop with just recycling and using recycled products. Looking for ways to reduce what arrives at, or is used at Kohl’s is also an important aspect of this strategy. One example is the decision to cut the number of advertisements sent to the stores on a weekly basis. It was reported that distribution was too high and therefore wasteful. After researching the issue, the advertising team reduced its printing order by 5.5 million copies in 2007. This suggestion alone saved 313 tons of paper, expense and trees. Building Design: Kohl’s a “LEED”ing Green Retailer LEED for Retail Portfolio Program Prototype Kohl’s Store Planning team is partnering with the United States Green Building Council (USGBC) to modify all new store prototype plans to meet the USGBC “Leadership in Energy and Environmental Design” (LEED) criteria. There will be a variety of improvements using the Retail Portfolio Program in Kohl’s prototype store design particularly in energy and water efficiency, construction innovation and operational improvements. By participating in this program, Kohl’s will have its prototype certified by LEED, streamlining the future certification process. This means that all new stores that Kohl’s constructs starting in Fall 2008 will constructed as LEED certified locations. Photo Studio The new Kohl’s Photo Studio located in Milwaukee, Wisconsin which opened early in 2008, has been designed using LEED criteria. Kohl’s will be applying for certification of this photo studio in 2008 with 13
    • an expectation of achieving a “Gold” rating from the USGBC. This location will be Kohl’s first certified LEED building. Sustainable Attributes: • Use of Rapidly Renewable Materials - The building features bamboo and cork flooring in some areas. • Use of Certified Wood - A large portion of the lumber used came from certified forests. • Construction Waste Management - Construction waste was separated for recycling rather than going to landfills. • Storm Water Design - Ponds located on the property will help control water flow during storms and will be used to water the landscaping. • Water Efficient Landscaping - Native plantings will be watered using a new WeatherTrak control system that monitors local weather conditions. • Light Pollution Reduction - The building has no exterior ‘up’ lights and the sign at this location uses LED technology. • On Site Renewable Energy and Green Power - This location will have an on-site solar power installation which begins construction in April, 2008 as well as using 35% renewable energy through renewable energy credits. • Green Housekeeping and Recycling - Use of green cleaning methods and chemicals along with a robust recycling program will help to keep the building an environmentally friendly operation. Existing Stores Prior to 2007, Kohl’s tested a number of construction methods that are friendly to our environment. They include: • Daylight Harvesting • Low Emitting Adhesives, Paint and Sealants • Bioswales: Bioswales are landscape elements designed to remove silt and pollution from surface runoff water. They consist of drainage with gently sloping sides and filled with vegetation, compost and/or riprap. • Stormceptors: A stormceptor is a prefabricated, underground unit that separates oil, grease, and sediment from storm water runoff. • LED Signage and Lighting • Irrigation Control Systems • Landscape Plantings related to planting zones • Green Rooftops All stores have been constructed with “Energy Star” rated roofs that help with heating and cooling efficiencies. Over 115 existing locations have been “recycled” since 2000 saving structural steel and concrete. Reduction of Climate Damaging Emissions Transportation Programs In 2007, Kohl’s executed 18,794 backhaul trips to our Distribution Centers from our vendors on the return trips to the stores, eliminating 3,608,448 empty trailer miles. These once empty trailers now carry merchandise from our vendors ultimately reducing the overall number of inbound transportation trips. In addition, Kohl’s uses rail transportation for 31% of all inbound transportation. Rail uses less fuel and creates fewer emissions than truck service. Our transportation carriers are doing their part with regard to fuel efficiency. In 2006, our top seven carriers had the highest rating of 1.25 in the EPA Smartway program that stresses fuel efficiency and carbon reduction strategies. In total, 84% of all miles traveled in 2006 were through EPA Smartway rated carriers. Kohl’s joined the EPA Smartway Shipper program in 2007 and has established goals as part of this program. 14
    • Climate Leaders: Kohl’s joined the EPA Climate Leaders in 2007 and is committed to measuring its carbon footprint by looking at energy use, transportation miles, and business travel. As a retail company, Kohl’s only has indirect impacts on emissions as a result of our operations. By enlisting the help of the EPA, Kohl’s will be developing a corporate-wide inventory of its greenhouse gas emissions. Once completed, work will begin on setting goals to reduce Kohl’s impact on the global environment. Encouraging Environmental Values Associate Engagement and Communication In 2007, Kohl’s created the “Green Scene” as a way to organize business practices that are good for both Kohl’s and the environment. Through creation of our own environmental brand with the mission of “Transforming our Future”, encouragement of environmental values began. The Green Scene program publishes updates on a monthly basis on Kohl’s internal website as well as in a quarterly magazine distributed to our associates. Vendor Engagement Kohl’s introduced its environmental mission in 2007 at its annual Vendor and Carrier Summit Conferences. Vendors have been challenged to help reduce packaging in determining the right number of units per carton as well as developing their own environmental sustainability programs. Carriers have been encouraged to participate in the EPA Smartway carrier program. The Store Planning team is engaging its vendors through the LEED portfolio program for retail and all general contractors will be required to build to our LEED criteria as well as recycling construction waste. D. Health and Safety Kohl’s Commitment: We are committed to protecting our associates and customers through dedicated workplace safety initiatives. Workplace Health and Safety Kohl’s concern for the welfare of our associates and customers is demonstrated through our risk management programs. Since 2002, we have reduced our associate injury rate per store and distribution center. While encouraged by these reductions, we continue to expand our safety initiatives in all of our facilities. In 2007, a new safety communication platform named C.A.R.L. was rolled out to every associate in the company. C.A.R.L.’s four fundamental principles include: Cleanliness, Awareness, Responsibility and Leading by Example. Associate support of these key principles has continued the trend of reduced customer and associate incident rates. Safety programs are highlighted in daily huddles, monthly training materials, associate contests and an Annual Safety week to clearly and consistently reinforce C.A.R.L. principles to maintain a safe environment. Retail Stores Associate understanding of Kohl’s safety commitment is just the beginning. In addition, our Risk Management department partners with other corporate departments and store associates to improve the in-store shopping experience for our customers by identifying and mitigating potential safety concerns. From fixtures to facilities, Kohl’s balances its uncompromising safety philosophy with 15
    • business initiatives. Key safety initiatives are rolled out and monitored to ensure that our associates are safety conscious on an ‘every day’ basis. Distribution Centers We maintain comprehensive safety programs in our distribution centers which provide a safe working environment to our associates and reduce workplace injuries. Such programs involve safety training and awareness initiatives which provide a safe and productive work environment. Product Integrity At Kohl’s, delivering a quality product is our business. In order to ensure that we are living-up to our deliverables, product integrity considerations are built into the product development process. During every phase of the product development process, we are continually checking to ensure that what is developed is a safe product and that it meets the applicable Federal and state mandates. Product compliance and safety are the driving force of the Product Integrity department at Kohl’s. The department works with manufacturers, vendors and agents to ensure that all private and exclusive brand products are subjected to rigorous testing prior to shipment. Testing is conducted at independent third party laboratories approved by Kohl’s. Depending on the end product, testing can range from checking for mechanical hazards, choking hazards or chemical hazards to flammability of fabrics. Only when the product that is being tested has passed Kohl’s quality standards, can it be shipped to our stores. Our Product Integrity department is continually working with government agencies and trade associations to keep itself abreast of any changes in consumer product regulations. During the past year, this department has been very closely monitoring product compliance and safety developments at the federal, state and local levels. The department is responsible to ensure that such changes are incorporated into our product development culture. Additionally, Kohl’s has taken proactive steps in voluntarily adopting product safety programs, keeping in mind the best interests of our customers. The goal of our Product Integrity department is to ensure that the Product Development team adopts and embraces changes made to Kohl’s Corporate Testing Program. The Product Integrity department understands the importance of training, awareness and communication and is responsible for training our internal staff, agents and vendors on topics ranging from Product Safety and Children’s Sleepwear to Footwear Testing. The end goal is to deliver a safe, quality product. Policy on Cosmetic Testing The primary cosmetic manufacturers used by Kohl’s do not perform any testing on animals. April, 2008 16
    • APPENDIX TERMS OF ENGAGEMENT FOR KOHL'S BUSINESS PARTNERS These Terms of Engagement apply to all of Kohl’s Business Partners. Kohl’s strongly encourages Business Partners to exceed these Terms of Engagement and promote best practices and compliance by Business Partners with the Terms of Engagement in all factories in which they manufacture merchandise. For questions or for information pertaining to Kohl’s Terms of Engagement, e-mail: kohlslaw@kohls.com. While Kohl’s recognizes that there are different legal and cultural environments in which Business Partners operate throughout the world, these Terms of Engagement set forth the basic minimum requirements Business Partners must meet in order to do business with Kohl’s. The Terms of Engagement also provide the foundation for Kohl’s ongoing evaluation of compliance by Business Partners with the Terms of Engagement. Business Partners are defined as vendors, manufacturers, contractors, subcontractors and other suppliers, sources and agents who provide Kohl's with goods or services ordered pursuant to any purchase order, contract or agreement issued directly by Kohl's or ordered on Kohl’s behalf. LAWS & REGULATIONS All Kohl’s Business Partners must operate in full compliance with all applicable local and national laws, rules and regulations pertaining to all aspects of factory operations in the jurisdiction of which they conduct business. EMPLOYMENT PRACTICES Kohl's will only do business with Business Partners whose workers are treated fairly and who in all cases are present voluntarily, not put at risk of physical harm, fairly compensated, and allowed the right of free association and not exploited in any way. Business Partners shall ensure procedures are in place by which workers, alleging violations of these Terms of Engagement, may do so without fear of negative repercussions. In addition, Kohl’s Business Partners must adhere to the following: • Wages and Benefits: Kohl's Business Partners must pay workers wages and legally mandated benefits that comply with the higher of (a) any applicable law, or (b) to match the prevailing local manufacturing or industry practices. In addition to their compensation for regular hours of work, workers shall be compensated for overtime hours at such premium rates as are legally required, or in those countries where such laws do not exist, at least equal to their regular hourly wage rate. Kohl’s recognizes that wages are essential to meet workers’ basic needs. Kohl’s will seek and favor Business Partners who are committed to the betterment of wages and benefits within their facilities. • Working Hours: Kohl's expects its Business Partners to operate based on prevailing local work hours. Except in extraordinary circumstances, Business Partners shall limit the number of hours that workers may work on a regularly scheduled basis to the legal limit on regular and overtime hours established by local laws and regulations in the jurisdiction in which they manufacture. Subject to the requirements of local law, a regularly scheduled workweek of no more than sixty (60) hours and one day off in every seven (7) day period are encouraged. Partners will comply with applicable laws that entitle workers to 17
    • vacation time, leave periods and holidays. Business Partners must regularly provide reasonable rest periods and one day off within a seven-day period. Any time worked over the norm for the area should be compensated as prescribed by the local labor laws. Working hours must be recorded by an automated timekeeping system. Whenever a worker is present in a facility, the worker’s time must be recorded and the worker properly compensated. This applies to both regular and overtime working hours and any time used for work preparations or repairs. • Child Labor: Use of child labor is strictly prohibited. Business Partners must observe all legal requirements for the work of authorized minors, particularly those relating to hours of work, wages, minimum education and working conditions. Kohl’s supports the development of legitimate, workplace apprenticeship programs and Business Partners will be expected to comply with all laws and regulations applicable to such apprenticeship programs. “Child” is defined as a person who is younger than 15 (or 14 where the law of that country permits) or younger than the age for completing compulsory education in the country where such age is higher than 15. Kohl’s will not utilize Business Partners who use or permit the use of child labor in any of their facilities. • Prison Labor/ Forced Labor: Business Partners will not use or permit the use of bonded labor, indentured labor, prison labor or Forced Labor in the manufacture or finishing of products ordered by Kohl’s. Nor will Kohl’s knowingly purchase materials from a Business Partner utilizing bonded labor, indentured labor, prison labor or Forced Labor. “Forced Labor” is defined as any work or service which is extracted from any person under the threat of penalty for its non- performance and for which the worker does not offer himself voluntarily. An employer involuntarily keeping workers identification documents is prohibited. • Discrimination: While Kohl's recognizes and respects cultural differences, employment (hiring, wages, benefits, advancement, termination, and retirement) shall be based on the worker’s ability and not on personal characteristics. Kohl’s believes that workers should be employed on the basis of their ability to do the job, rather than on the basis of gender, age, disability, sexual orientation, racial characteristics, cultural or religious beliefs or similar factors. Kohl’s will not utilize Business Partners who discriminate against workers on the basis of gender, age, disability, sexual orientation, racial characteristics, cultural or religious beliefs or similar factors. • Free Association: Workers must be free to join organizations of their own choice. Business Partners shall recognize and respect the rights of workers to freedom of association and collective bargaining. Workers shall not be subject to intimidation or harassment in the peaceful exercise of their legal right to join or to refrain from joining an Organization. • Disciplinary Practices: All Business Partners must treat all workers with respect and dignity. Kohl’s will not utilize Business Partners who use, or permit the use of corporal punishment, physical, sexual, psychological or verbal harassment or other forms of mental or physical coercion, abuse or intimidation. Business Partners shall not use, or permit the use of fines as a disciplinary practice. 18
    • • Women’s Rights: All Business Partners will ensure that workers who are women receive equal treatment in all aspects of employment. Pregnancy tests will not be a condition of employment or continuation thereof and pregnancy testing, to the extent it is provided, will be voluntary and at the option of the worker. Workers will not be exposed to hazards that may endanger their reproductive health and Business Partners will not force workers to use contraception. • Health & Safety: Kohl's will only utilize Business Partners who provide workers with a clean, safe and healthful work environment designated to prevent accidents and injuries arising out of or occurring while in the course of work or as a result of the operation of a Business Partner’s facility. All Business Partners must comply with all applicable, legally mandated standards for workplace health and safety. Where applicable, Business Partners who provide residential facilities for their workers must provide safe and healthy facilities, separate from production facilities, that comply with legally mandated standards for health and safety. ETHICAL STANDARDS Kohl's will seek to identify and work with Business Partners who aspire as individuals and in the conduct of their business to a set of ethical standards which are compatible with Kohl's standards. Bribes, kickbacks or other similar unlawful or improper payments are strictly prohibited to be given to any person or entity to obtain or retain business. ENVIRONMENTAL REQUIREMENTS Kohl's will only do business with Business Partners who comply with all applicable government laws and regulations, international standards, U.S. regulations prohibiting the use of ozone depleting chemicals (hydrochlorofluourocarbons) and the International Trade in Endangered Species of Wild Fauna and Flora, as listed in the United States Endangered Species Act of 1973. LEGAL REQUIREMENTS Kohl's policy is to obey the laws of each country in which merchandise is manufactured for Kohl’s. Business Partners will comply with all applicable local and national laws, rules and regulations pertaining to all aspects of factory operations. This includes compliance with these Terms of Engagement and the terms and conditions of purchase orders issued by Kohl's or on Kohl's behalf and also requires attention to U.S. country of origin regulations which govern quota classification and the marking of products. Business Partners manufacturing facilities will comply with US Customs-Trade Partnership Against Terrorism (C-TPAT) requirements. COMMUNICATION All Business Partners must post the Terms of Engagement in places in their factories readily accessible to workers, translated into the language of the workers and supervisors and communicate these provisions to all workers. Business Partners shall take appropriate steps to ensure the provisions of these Terms of Engagement are communicated to all workers. Upon employment, as part of worker orientation, the Terms of Engagement shall be presented to workers and explained to them. From time to time Business Partners shall periodically review these Terms of Engagement with workers. MONITORING/ COMPLIANCE Kohl's takes affirmative measures to monitor compliance with Kohl’s Terms of Engagement and Kohl’s Purchase Order Terms and Conditions. Such measures may include prescreening Business Partners, scheduled or random, announced and unannounced on-site inspections of factories by Kohl's representatives, or certification by Kohl's Business Partners that Kohl's Terms of Engagement have been complied with. 19
    • Kohl’s associates and representatives have been asked to be watchful for violations of Kohl’s Terms of Engagement on visits to factories or manufacturing facilities and to report questionable conduct to management for follow up and when appropriate, for corrective action. RECORD KEEPING All Business Partners must maintain in the factories producing merchandise for Kohl’s all documentation necessary to demonstrate compliance with Kohl’s Terms of Engagement. Business Partners must furnish Kohl’s representatives reasonable access to production facilities, employment records and workers for confidential interviews in connection with monitoring factory or inspection visits. Business Partners must promptly respond to reasonable inquiries by Kohl’s representatives concerning the operations of factories with respect to Kohl’s Terms of Engagement. SUBCONTRACTING Business Partners shall not utilize subcontractors for the production of Kohl’s merchandise, or components thereof, without Kohl’s prior written approval and only after the subcontractor has agreed to comply with Kohl’s Terms of Engagement. Business Partners shall require each Kohl’s approved subcontractor to abide by the Terms of Engagement. Business Partners shall be held accountable for a subcontractor’s failure to abide by Kohl’s Terms of Engagement. CORRECTIVE ACTION If a Business Partner is in violation of Kohl's Terms of Engagement, Kohl's will work with the Business Partner to remediate the violation if at all possible. If this effort is unsuccessful or not possible, Kohl’s shall reevaluate its business relationship with the Business Partner and shall take appropriate corrective action. Corrective action may include cancellation of the affected order, prohibition of subsequent use of a factory or termination of Kohl's business relationship with any Business Partner found to be in violation of these Terms of Engagement, or exercising any other rights and remedies to which Kohl's may be entitled under Purchase Orders issued by Kohl's or on behalf of Kohl's, at law or otherwise. COUNTRY EXCEPTIONS Business Partners will not produce merchandise for Kohl’s in countries which are considered by Kohl’s to deny basic human rights. Kohl’s will not initiate or continue its business relationship with Business Partners that produce merchandise for Kohl’s where there are gross and systematic violations of human rights and when there is a recognized movement from within the country calling for withdrawal. For questions or for information pertaining to Kohl’s Terms of Engagement e-mail: factory.compliance@kohls.com 20