Kohl s Department Stores, Inc. Report To Shareholders On Social Responsibility 2011

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1 Kohl s Department Stores, Inc. Report To Shareholders On Social Responsibility > Investor Relations -> Corporate Governance -> Report to Shareholders on Social Responsibility 1

2 Table of Contents 3 Letter from the Chairman, President and CEO Social Responsibility 4 A. Product Manufacturing 4 Our Philosophy 4 Our Policy 4 Oversight of Our Policy 5 Factory Monitoring Process 5 Corrective Action and Remediation 5 Education and Training 6 Vendor Partner Certification of Compliance 6 Social / Labor Working Group Sustainable Apparel Coalition 6 Better Work Program Participant 6 Policy Regarding Cotton from Uzbekistan 7 Clean Diamonds Trade Act 7 Social Compliance Program Performance Statistics 7 B. Community Involvement 7 Charitable Programs 8 Volunteer Efforts 9 C. Environmental Responsibility 9 Kohl s Sustainability Mission Statement 9 Expanded Strategies in Sustainability Key Accomplishments 10 Sustainable Operations: Energy and Climate Energy Highlights 11 Sustainable Operations: Energy and Climate Renewable Energy Highlights 12 Sustainable Operations: Energy and Climate Climate Highlights 12 Sustainable Operations: Recycling and Waste 14 Sustainable Operations: Building Design 17 Supply Chain Sustainability 19 D. Health and Safety 19 Workplace Health and Safety 20 Product Integrity 20 Policy on Cosmetic Testing 21 Appendix Terms of Engagement 2

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4 Social Responsibility A. Product Manufacturing Our Philosophy Kohl s Department Stores, Inc. 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 and we select Vendor Partners who we believe share our commitment to the fair and ethical treatment of employees. Our compliance philosophy focuses on taking corrective action on identified issues and continuous improvement. Our policy is posted at under the 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 worldwide to procure merchandise sold 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. Our Policy Our policy focuses on compliance with local labor laws, working conditions and spells out Kohl s expectations to our Vendor Partners regarding wages, prohibition of using child or forced labor which includes, without limitation, prison and slave labor or human trafficking for the purposes thereof, respecting the rights of workers to free association, health and safety issues and more. 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. We continually monitor social compliance and challenge our Vendor Partners to protect the health, safety and human rights of workers Oversight of Our Policy Kohl s organizational structure supports the uniform and objective application of the compliance program to all Vendor Partners. Corporate Social Compliance 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. 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 employees not involved in actual purchase negotiation. 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 compliance with our Policy. Subcontractors that a Vendor Partner desires to use in the manufacturing process require Kohl s approval. We recognize that publication of a statement of principles is insufficient to achieve compliance with these 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 reserve the right to review all 4

5 Vendor Partner facilities, including the use of unannounced on-site inspections of manufacturing facilities. Factory monitoring visits are performed by professional, independent, third party monitors on an ongoing basis. Once deemed compliant with our Policy, factories are monitored periodically based on established risk level. To date, we have performed in excess of 26,000 monitoring visits to over 5,000 manufacturing facilities in 75 countries around the world to ensure compliance with our Policy. Factory Monitoring Process We have retained the services of two professional, independent, third party firms to monitor Vendor Partner compliance with our Policy. Our monitors have auditing professionals located in the territories in which the manufacturing facilities are located, able to speak the language of workers and management, and who have extensive experience with monitoring social compliance on behalf of international customers. The monitors visit each manufacturing facility, interviewing factory workers and management, observing facility conditions and performing detailed testing of facility business records in order to complete Kohl s factory monitoring program to determine the level of compliance with our Policy and applicable laws. Our full-compliance audit program includes the following modules: Laws and Regulations Wages and Benefits Working Hours Child Labor Forced Labor/Slave Labor/Human Trafficking Discrimination Free Association Disciplinary Practices Women Rights Health and Safety Health and Safety - Dormitories Environmental Requirements Communication and Record Keeping Subcontracting Monitoring and Compliance During the course of each facility visit, the monitor documents all deficiencies related to our Policy. Upon completion of each visit, the monitor summarizes and discusses each deficiency with factory management to facilitate immediate corrective actions and sends an audit report to Kohl s. Our Policy compliance team reviews factory monitoring reports and works with our Vendor Partners to implement corrective actions. Corrective Action and Remediation We require our Vendor Partners to adopt a corrective action plan whenever possible. If noncompliance with Kohl s Policy is identified, 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 deficiencies, to canceling affected orders, to terminating our relationship with our Vendor Partner. Follow-up evaluations are completed to verify subsequent adherence to our Policy. We make every effort to attempt to bring noncompliant facilities into compliance rather than terminate our business relationship. Education and Training We provide training to our Vendor Partners on our policy and our expectation of compliance and regularly communicate with them on compliance issues. In 2011, we conducted numerous individual 5

6 training sessions for Vendor Partners to promote understanding and compliance with our requirements. In this way, we clearly communicated our expectations and, in turn, our Vendor Partners had the opportunity to explain their practical challenges to us. The following topics were reviewed during training sessions: Expectations for Suppliers Policy Definitions Best Practices Site Verification Methods Reporting of Facility Assessments Remediation Methods Compliance Improvement; and, Sustainability We strongly encourage our Vendor Partners to develop and/or enhance their own internal social compliance functions to raise awareness and to sustain performance improvements. We emphasize open, ongoing Vendor Partner communication. We also conduct internal training sessions for Product Development and Buying Office employees regarding our Policy requirements on a quarterly basis. We provide relevant Kohl s employees, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chain. 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. Vendor Partner Certification of Compliance Kohl s requires direct suppliers to certify compliance with all laws and regulations, including but not limited to, laws regarding slavery and human trafficking in the country or countries in which they do business. Social / Labor Working Group Sustainable Apparel Coalition Kohl s is a member of the Social/Labor Working Group formed under the Sustainable Apparel Coalition. The working group is developing a component of the Apparel Index to align coalition members on a set of indicators meant to capture a continuum of performance from basic awareness and compliance to aspirational and industry leading practice at brand and facility levels. Better Work Program Participant Kohl s participates in the Better Factories Cambodia (BFC) and Better Work Vietnam (BWV) programs, which are International Labour Organization programs focused on strengthening labor standards in export garment industries in specified countries. Our reliance upon BFC and BWV factory monitoring results in these countries helps reduce audit fatigue and factory monitoring costs which provides factory management with more time to focus on corrective action and sustainable, continuous improvement. Policy Regarding Cotton from Uzbekistan Consistent with our commitment to social responsibility, Kohl s does not knowingly carry products that use cotton originating from any country that condones the use of child and/or forced labor. Kohl s does not source any private or exclusive brand products from Uzbekistan and, to the best of our knowledge; cotton from Uzbekistan is not used in goods produced for Kohl s in other countries. Until we are convinced that forced child labor is not being used to produce cotton in Uzbekistan, Kohl s specifically 6

7 prohibits the use of Uzbekistan cotton in the manufacture of merchandise intended for sale in our stores. Clean Diamonds Trade Act We require our suppliers of diamonds and jewelry to ensure that the merchandise they sell to Kohl s meets the requirements of the Clean Diamonds Trade Act and the Kimberly Process Certification and that this merchandise does not contain conflict diamonds. Social Compliance Program Performance Statistics Fiscal 2011 vs. Fiscal 2010 Item Description Manufacturing Facility Visits 3,445 3,672 Percentage of Visits Performed Unannounced 59% 66% Number of Facilities Visited 1,985 1,868 Percentage of Facilities in Compliance with our Policy at Year End 70% 68% Percentage of Facilities that Failed to Meet Our Standards and were Made Not Authorized Due to Noncompliance 10% 14% Percentage of Facilities Vendor Partners Withdrew from Consideration since More Appropriate Facilities were Available 3% 3% Percentage of Facilities Still in Monitoring Process at Year End 17% 15% B. Community Involvement Kohl s believes in giving back to the communities we serve, not just with money and resources, but also with time and talent. To date, our focus has been on helping communities through various initiatives known as Kohl s Cares and Associates in Action. The Kohl s Cares brand includes community involvement and environmental responsibility programs. Charitable Programs Kohl s Cares Merchandise Kohl s Cares merchandise supports a promise of hope for a brighter, healthier future for children in communities that we serve. As a family-oriented company, Kohl s dedicates 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 merchandise with 100% of the net profits from the sale of this merchandise benefiting children s health and educational initiatives nationwide. Kohl s Cares is our way of supporting our customers, communities and improving the lives of children. Through Kohl s Cares, we have raised more than $208 million for children s health and educational initiatives since Kohl s Cares 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. 7

8 Kohl s Cares Scholarship Program The Kohl s Cares Scholarship program is a signature program under the Kohl s Cares 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 Cares 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 Fundraising Card Program Kohl s has created a simple, effective way to help raise much needed funds for schools and youthfocused nonprofit organizations, while eliminating many of the challenges characteristically associated with fundraising. The Kohl s Cares 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. Breast Cancer Research In support of women s health initiatives, Kohl s will donate $7 million between 2010 and 2012 to breast cancer charities in Wisconsin through partnerships with the Milwaukee Wisconsin chapters of the American Cancer Society and Susan G. Komen for the Cure. The funding will help support education on cancer detection, a marketing campaign to encourage women to take action and for assistance to breast cancer patients and those unable to bear the cost of a mammogram. US Youth Soccer For the past ten years, Kohl s has served as the Official Department Store sponsor of US Youth Soccer through a partnership with US Youth Soccer which extends through 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 Associates in Action Associates in Action is an associate volunteer program under the Kohl s Cares umbrella that supports youth-serving health, educational and environmental nonprofit organizations in communities nationwide. 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 2011, more than 123,000 Kohl s associates representing stores, district offices, distribution centers and the corporate headquarters volunteered over 400,000 hours and Kohl s donated over $12.4 million on behalf of those volunteer efforts to nonprofit youth-serving organizations. Since 2001, more than 500,000 Kohl s associates volunteered more than 1.6 million hours and Kohl s donated more than $47 million on behalf of those volunteer efforts. In 2011, Kohl s associates across the country again took part in the company s Kohl s National Go 8

9 Green (NGG) initiative. This initiative combined the Kohl s Associates in Action and environmental platforms, encouraging associates to participate in green youth-serving Associates in Action events during the month of April, C. Environmental Responsibility Kohl s Sustainability Mission Statement At Kohl s, we are committed to protecting and conserving the environment by seeking innovative solutions that encourage long-term sustainability. From large-scale initiatives like constructing environmentally friendly buildings, to everyday practices like recycling hangers, we re taking steps both big and small to ensure we leave a smaller footprint. Expanded Strategies in 2011 In 2011, Kohl s revised its sustainability strategies to reflect a focus beyond the core operation of its stores, distribution centers and offices to include efforts it is making in the merchandise supply chain. Operational sustainability will be the foundation of Kohl s environmental efforts by continued engagement of all stakeholders. Kohl s takes its environmental commitment seriously and is working to collaborate with the merchandise supply chain to champion efficiency and conservation in the global marketplace. Our strategies are simple and our results are making a big difference. Sustainable Operations Energy and Climate Waste Reduction Building Design Supply Chain Sustainability Merchandise Sustainable Apparel Coalition Sustainable Transportation 2011 Sustainability Key Accomplishments: 677 ENERGY STAR labeled stores 121 activated solar sites #1 Retailer for Green Power Purchases, #2 Overall company for Green Power Purchases and #12 for On-Site Generation (October 2011 ranks) 100% of all Power used by Kohl s is offset via the use of renewable energy credits in % of all waste in Kohl s Store Operations is recycled. 203 locations have earned LEED certification by US Green Building Council Kohl s announced its carbon reduction goal with EPA Climate Leaders in December 2009 to be carbon neutral beginning 2010 through Carbon neutrality was achieved in 2010 and 2011 per this goal. 9

10 Sustainable Operations: Energy and Climate Energy Highlights ENERGY STAR Kohl s is a member of the United States Environmental Protection Agency (EPA) ENERGY STAR program. Using the ENERGY STAR portfolio manager tool, Kohl s voluntarily measures the energy performance of every Kohl s store on a 1 to 100 scale. Stores that achieve a score of 75 or higher are eligible for the ENERGY STAR label which is displayed in top performing stores. On average, stores earning ENERGY STAR recognition use 35% less energy than similar buildings. Kohl s was named 2011 ENERGY STAR Partner of the Year for Energy Management for the 2 nd consecutive year by the EPA and U.S. Department of Energy (DOE). This distinction recognizes Kohl s commitment to energy management and reductions in greenhouse gas emissions. Better Buildings Challenge In 2011, Kohl s joined the Department of Energy s Better Building Challenge. Through this challenge Kohl s has set the following goal: Achieve a 20% Reduction in energy intensity by 2020 of 112 million square feet of occupied building space. As a challenge participant, Kohl s has agreed to take even more action in the area of energy efficiency by detailing energy savings sub goals in the near term, selecting a pilot project store and continued reporting of progress on the challenge. Kohl s commitment will contribute to goal of reducing our nation s commercial building energy use by 20% by Energy Management System (EMS) Upgrades Since 2009, Kohl s has upgraded the energy management systems in over 850 stores. These upgrades consist of new software that allows more precise control of Heating, Ventilation and Cooling (HVAC) units and lighting. The upgraded building control systems are now able to automatically adjust temperature and lighting through sensor monitoring as well identifying maintenance issues. Light Emitting Diode (LED) Lighting In 2011, over 130 new and remodeled Kohl s stores received 3x4 Light Emitting Diode (LED) track head lights, as well as LED jewelry showcase lighting. These lights have a longer lamp life lasting up to 10 years, compared to the 2-year life of the previous lamps. In addition, each of the new LED lights uses about 60% of the energy used by traditional lighting solutions. Electric Vehicle Charging Station To promote energy efficiency and maximize customer convenience, Kohl s began installing electric vehicle charging stations at select Kohl s store locations in These charging stations allow customers to fuel their cars while they shop, for no additional charge. As of November 2011, there are 34 Kohl s stores with between one and four charging stations. Kohl s stores with charging stations also provide free radio frequency identification (RFID) cards to customers, which allow access to the charging stations. Energy Efficiency Innovation: Store Recommissioning In 2011, Kohl s executed an energy recommissioning program at 421 of its existing stores. This program conducts a thorough engineering review of all controls and lighting, plus heating and cooling equipment at the store site to assure optimal operations of energy-intensive equipment. Kohl s has set a goal to complete this program at 75 stores annually when targeted for remodeling or energy performance improvements. A typical recommissioning study will result in energy savings that covers the cost of the review within two years. 10

11 Sustainable Operations: Energy and Climate Renewable Energy Highlights Renewable Energy Credits Kohl s has made a voluntary commitment to use renewable energy as a member of United States Environmental Protection Agency (EPA) Green Power Partnership. Renewable energy credits are a method for large companies to offset or green the power used in operations. In 2011, Kohl s purchased more than 1.4 billion kilowatt hours of renewable energy credits representing more than 100% of its power use. This ongoing commitment has been recognized by the EPA five times with Green Power Leadership Awards and in 2011 Kohl s earned its third Green Power Partner of the Year Award. Kohl s purchase of Renewable Energy Credits in the United States supports the development of wind and biomass renewable energy sources nationwide. Solar Array Host Kohl s was host to 119 activated solar arrays through a twenty year solar power purchase agreement with Sun Edison. The arrays are located on store rooftops in California, Wisconsin, New Jersey, Connecticut, Pennsylvania, Colorado and Oregon. These sites generate nearly 35 megawatts of power without any capital outlay to Kohl s. This use of silent, clean power is cost saving and great for the environment. In 2011, these 119 arrays generated in excess of 46 million kilowatt hours of power. Owned Solar Arrays In 2011, Kohl s activated its first two fully owned solar power arrays operating on two store rooftops at the Marana and Oro Valley, Arizona locations. Together they have 3322 solar panels and are estimated to generate 1.3 million kilowatt hours power annually. This capital investment demonstrates Kohl s continued commitment to on-site renewable power generation. Aerial View of Kohl s Oro Valley, Arizona Photo Voltaic System Wind Turbines Kohl s activated its first wind turbines in spring 2011 at the Findlay, Ohio Distribution Center and Corpus Christi, Texas store. Kohl s is currently in the testing phase of the wind project, determining which turbine styles are the best fit and most cost effective for its locations. The Findlay Distribution Center has a traditional, vertical turbine generating 40,000 kwh annually for a cost savings of $5,000 per year. The Corpus Christi store has a horizontal turbine generating 14,000 kwh annually for a cost savings of $2,000 per year. 11

12 Wind turbines in operation at the Kohl s Findlay, Ohio Distribution Center. Sustainable Operations: Energy and Climate Climate Highlights Kohl's recognizes that as a retailer, one of our biggest operating impacts on the environment comes from energy use. With this in mind, we are seeking ways to lessen our carbon foot print. In 2009, Kohl s publically announced its goal to be carbon neutral for a period of three years beginning in Kohl s marks the second consecutive year of achieving this goal in Our focus on energy management provides the annual consumption data necessary to accurately measure its carbon generated by operating Kohl s stores nationwide. Kohl s does not stop with energy management but also measures the footprint related to business travel. Additionally, our progress on reducing, managing and verifying our footprint is reported annually to the Carbon Disclosure Project. Carbon Footprint by the Numbers Year Scope 1 Direct Scope 2 Indirect Scope 3 Travel Total Emissions Number of Stores Operating Emissions Reductions Renewable Energy Credits Reductions/Carbon Offsets Total Reductions , ,519 6, ,950 1,089 1,064,131 33,000 1,097, , , , ,108,961 33,000 1,141,961 Sustainable Operations: Recycling and Waste In 2011, Kohl s has expanded its Recycling and Waste strategy to move beyond just disposal and recycling of materials to create closed loop systems redirecting used material to be recycled and reused in throughout Kohl s operations. In addition, programs to identify actions that illustrate resource conservation through waste avoidance have been put in place. The Kohl s logistics teams work with Kohl s merchandise vendors to improve shipment packaging as well. Learn more about these programs below. 12

13 Recycling by the Numbers Year Waste Type Tons Recycled Corrugated Cardboard 118, ,459 Construction Debris 15,873 28,457 Mixed Plastic/Hangers 10,802 8,822 Mixed Office Paper Wood Pallets 2,833 2,197 Metal 1,414 1,940 Carpet 500 1,354 Bottles & Cans Electronics Light Bulbs/Fluorescent Lights Total 151, ,193 Closed Loop Recycling Highlights Kohl s recycles and reuses items like hangers, electronic article surveillance (EAS) tags, plastic, and gift cards. These four items are accumulated and shipped together from Kohl s stores to Kohl s Distribution Centers, before being sent overseas for proper recycling and redistribution. This closedloop system represents considerable cost, labor, material, and transportation savings for Kohl s as well as diversion of thousands of items from landfills. Hangers Hangers are either reused or their material is recycled. Excess hangers are accumulated through Kohl s distribution network and shipped to a recycle partner for sorting and re-packaging. Over 10 million hangers have been sent to Kohl s private label manufacturers worldwide for reuse on new garments destined for Kohl s. Excess or broken hangers identified in the recycle process are shredded and recycled into plastic pellets which are used to mold Kohl s plastic shipping totes, which are used throughout Kohl s store distribution network. Plastic totes have a lifecycle eight times as long as a cardboard tote and take up less space during shipping. Electronic Article Surveillance (EAS) Tags EAS tags arrive at Kohl s stores on garments as a method to help reduce inventory shortages. These reusable hard tags are removed at point of sale when a garment is sold. Every store accumulates excess tags for recycling. In the recycle process, tags are cleaned and re-packaged for use on new shipments to Kohl s. The recycled EAS tags are sold to back to Kohl s at a significant discount and create a closed loop for reuse once again. Plastic Plastic is collected from merchandise shipped to each store and from customers who return unwanted merchandise bags of all types. This plastic is bagged and returned to the store s supporting distribution center where it is baled for recycling. Baled plastic is recycled in to plastic pellets that are used to manufacture Kohl s grey merchandise bags. Recycling plastic results in overall cost savings for Kohl s and assures a steady supply of recycled material for merchandise bags. Gift Cards Gift cards are collected and accumulated once redeemed at Kohl s stores. These used cards are shredded and melted into PVC sheets for printing of new gift cards to be sold at Kohl s stores. This closed loop system saves in disposal fees and provides recycled content for newly created cards. 13

14 Waste Avoidance Programs Digital Signs Kohl s has implemented digital signing in 476 stores nationwide. This initiative replaces paper signs which can change multiple times per week based on advertising events. This project saves nearly 3100 cases of paper per month in these stores and improves signing as well as store associate productivity. Kohl s plans to expand this program to further avoid waste in the future. Paperless Paycheck Kohl's introduced web-based pay statements in Associates are paid electronically via direct deposit to their bank and check stubs are available online. This eliminated the printing of nearly 6,000,000 check stubs annually, saving paper, printing, shipping and mailing costs. As of 2011, about 16.2 million sheets of paper have been saved through this initiative alone. Units per Carton By consistently increasing the number of units that can be transported per single merchandise shipping carton, Kohl s raised the average carton size by one full unit. This translated in to an annual savings of 1.5 million cartons that did not have to be used or handled when shipping Kohl s merchandise. Additional savings were realized in transportation and handling of the cartons throughout the supply chain as well. Footwear Packaging With over 33 million footwear units shipped annually, using smaller boxes, varying box sizes and removing unnecessary tissue paper from packaging has made a significant impact on resource conservation and freight costs. Box size reductions resulted in a 15% total volume savings or 1.1 million square feet of material. Varied sizes of foot wear boxes resulted in a 10% total volume saving o 10.7 million square feet of material. Finally, tissue paper reductions resulted in an 18% total volume reduction or 38.8 million square feet of packaging material. Sustainable Operations: Building Design Kohl's is committed to achieving long-term sustainability through improved building design and operation. To focus this strategy Kohl s uses the criteria developed by the United States Green Building Council (USGBC) in its Leadership in Energy and Environmental Design (LEED) programs. To be LEED certified, a building must meet the criteria which guide best practices for the design, construction and operation of high-performance green buildings. This section highlights Kohl s work in three USGBC programs. 14

15 Building Design by the Numbers LEED Certification Type EBOM LEED Certification Description Total Number of Kohl's Buildings Certified Existing Building and Operations Management 108 NC New Construction 94 CI Commercial Interiors 2 Total Leadership in Energy and Environmental Design Buildings: 203 LEED Certification Level Total Gold Silver Certified Total LEED for Existing Buildings Operations & Maintenance Program Description Through the LEED for Existing Buildings: Operations and Maintenance (EBOM) program, Kohl s works to secure LEED certification for qualifying existing stores. These stores are evaluated and upgraded with features that maximize operational efficiency and minimize environmental impact. All Kohl s stores are maintained and operated using many LEED EBOM guidelines and policies, even when not qualifying for certification. EBOM Program Highlights Sustainable Purchasing: Kohl s sustainable purchasing policy gives preference to products with reduced impact on the environment. There is recycled content in our merchandise bags, office supplies, corrugated boxes, restroom paper and gift boxes. A minimum of 60 percent (by cost) of our operating purchases for Kohl s stores are sustainable products. Operational Recycling: Kohl s stores recycle office paper, cans, glass, cardboard, hangers and plastic goods. There are designated areas within the stores for sorting recyclable materials, including an area for employees and customer to bring in plastic bags from home. Green Cleaning: Kohl s stores are cleaned using green housekeeping methods and green chemicals and equipment. All restroom paper products are made from 100 percent recycled materials. Energy Efficiency: All Kohl s LEED EB stores are ENERGY STAR labeled. Earning the ENERGY STAR label indicates the location is among the top 25 percent of retail stores in the country for energy performance. ENERGY STAR labeled buildings use an average of 35 percent less energy than similar buildings and generate one-third less carbon dioxide. 15

16 LEED for New Construction Program Description Using the USGBC s LEED volume certification process, Kohl s achieved a Gold pre-certified LEED for Retail New Construction (NC) prototype. The Kohl s Gold NC prototype includes all standard new store formats and will be utilized to LEED certify all ground-up new stores built nationwide as they are constructed. These stores feature numerous sustainable design, construction, and operational attributes that maximize efficiency and minimize environmental impact. Takeover locations, though not qualified for LEED volume certification, are still designed, constructed, and operated using many of the LEED NC standards. New Construction Program Highlights Sustainable Building Materials An estimated 20 percent of the total building materials (by cost) used in the construction of a new Kohl s contain recycled content and are regionally sourced from within 500 miles of each new store site. Building materials such as steel, carpeting, ceiling tiles, drywall and insulation are selected to contain the maximum amounts of post and pre-consumer recycled content. Heat Island Effects Kohl s stores use a reflective ENERGY STAR rated roofing material that mitigates the heat island impact caused by asphalt and other dark surfaces. Construction Waste Reduction All construction waste generated by the construction of new Kohl s stores is carefully managed to ensure the least possible amount of debris is sent to landfills and incinerators. Recycling efforts reduce landfill waste by an estimated 75 percent. Water Efficiency: Using native and adaptive vegetation and a smart irrigation controller, new Kohl s stores have reduced water usage for landscaping irrigation. We have also reduced water consumption over 30% by using water-conserving plumbing fixtures in new Kohl s stores. Air Quality New Kohl s stores are constructed with low VOC (Volatile Organic Compound) materials and also feature increased fresh air ventilation, carbon dioxide monitoring and a strict no-smoking policy within 25 feet of building entrances. LEED Certified Corporate Facilities Program Description Since construction of the Kohl s Photo Studio in 2007, Kohl s has made a commitment to build all new corporate projects to LEED standards to meet our environmental goals. San Antonio Call Center The Kohl s Call Center in San Antonio, TX is a LEED for Commercial Interiors Gold certified project constructed inside a LEED Silver certified Core & Shell building. Currently Kohl s is expanding on the site into a second building, which is currently registered as a LEED for New Construction project. New York Design Office: The Kohl s New York Design Office is registered as a LEED for Commercial Interiors project. Located in central Manhattan, the project is expected to achieve exemplary performance for development density and public transportation access. E-Fulfillment Center 3 The Kohl s E-Fulfillment Center (EFC-3) in Maryland will be Kohl s first industrial facility to seek LEED certification. Currently registered as a LEED for New Construction project, EFC-3 consists of a 600,000 square foot existing building and 400,000 square foot addition. 16

17 Supply Chain Sustainability In 2011, Kohl s formally extended its sustainability program to include Supply Chain Sustainability. This strategy builds on Kohl s sustainable operations strategy as well as the company s commitment to engaging stakeholders. This sustainability effort began in its early form in 2009 by surveying merchandise vendors, and has grown to the actions outlined in this report. Kohl s works hard to keep its operations sustainable and actively collaborates with its supply chain partners to drive the concept of efficiency and resource conservation. Supply Chain Sustainability by the Numbers 17

18 Supply Chain Survey Every quarter, Kohl s merchandise vendors are asked to complete a forty-two question survey on six areas of sustainability as listed in the table below. This year, scoring emphasis was placed on the area of Energy/Climate to engage vendors in footprint measurement. The survey is a voluntary selfassessment on sustainability and vendor results are included on the company s supply chain scorecard, but did not affect the overall vendor grade in It was our goal to encourage vendor sustainability in a collaborative format regardless of level of sustainability sophistication. Sustainability Survey Scoring 2011 Area Possible Survey Points Management / Policy 20 Energy/ Climate 35 Waste Management 15 Packaging 15 Partnerships 5 Supply Chain Sustainability 10 Total 100 Vendor Education Efforts In 2011, to help vendors improve their supply chain survey performance, Kohl s increased its collaboration with the vendor community by hosting a series of educational webinars on the sustainability survey. The webinars covered topics such as sustainability policy, energy measurement, recycling and supply chain sustainability. The webinars were held throughout third quarter of 2011, broadcasting a total of 12 sessions. The project brought in 325 total participants representing over 100 different companies. Sustainable Apparel Coalition The Sustainable Apparel Coalition (SAC) is a group of apparel manufacturers, retailers, and nongovernmental Organizations (NGOs) working to modernize the merchandise supply chain by information to facilitate more sustainable decisions in everyday business. The information used by the SAC is a synthesis of years of past work done independently by other companies and organizations as well as new collaboration between industry leaders. The tools provided by the SAC include environmental impact metrics of facilities as well as life cycle analyses of raw materials. Kohl s is proud to be a founding circle member and administrative leader on the coalition. In 2011, the SAC finalized its first pilot of V1.0 Eco Index to be distributed and completed by all founding circle members. Kohl s participated in the pilot test by ranking the sustainability of two of the company s staple products throughout their entire production process; from field to production to end of life. In addition to piloting two key items, Kohl s also piloted the SAC s facilities module to measure relative sustainability of more than 20 factory locations worldwide that produce private and exclusive brands for Kohl s. To learn more about the SAC, please visit Business for Social Responsibility Energy Efficiency Pilot In 2010 and 2011, Kohl's participated in the Business for Social Responsibility (BSR) Energy Efficiency Pilot to engage with five factories located in China on energy efficiency education and action plans. The BSR sponsored four educational sessions for factories in China in both Guangdong and Shanghai to learn about energy programs and set action plans for future improvements. Kohl's is looking for ways to bring sustainability and business efficiency to its business partners in a worldwide marketplace. Through the membership in BSR, Kohl's can leverage its resources to accomplish mutually beneficial goals. 18

19 Transportation In 2011, Kohl's executed 18,880 backhaul trips to our Distribution Centers from our vendors on return trips to stores. This eliminated 4,355,796 empty miles. These once-empty trailers now carry merchandise from our vendors, ultimately reducing the number of inbound transportation trips. Kohl's also uses rail transportation for 52% of all inbound transportation. Rail uses less fuel and causes fewer emissions than truck services. Our transportation carriers are doing their part in fuel efficiency as well. In 2011, 100% of our top merchandise carriers were active members of the EPA SmartWay Transport program. The program stresses fuel efficiency and carbon-reduction strategies. In January 2011, new regulation from the California Air Resources Board (CARB) in partnership with SmartWay required shippers to install aerodynamic truck skirts and low-rolling-resistance tires. Shippers are required to equip 20% of their fleet every year until After the first year in the program, Kohl s has 33% of its trailers equipped with aerodynamic skirts. Kohl s is now in the process of converting over 4,000 of its tires to SmartWay-certified, low-rolling-resistance tires. The CARB / SmartWay program is expected to reduce CO2e by 1 million MT by Environmental Memberships EPA ENERGY STAR since 1998 EPA Green Power Partnership EPA Wastewise EPA SmartWay Transport Shipper United States Green Building Council Business for Social Responsibility Wisconsin Partners for Clean Air Climate Counts Sustainable Apparel Coalition 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 our associates and the communities in which we operate begins with our operating principles and extends to our associate training and all physical components of the working and shopping experience. Our commitment to safety is demonstrated through the Company s risk management programs. Health and Safety initiatives focus on four key areas: 1) Accountability, which 19

20 includes frequency reporting, trend identification and performance; 2) Engagement, which includes management responsibility and awareness; 3) Compliance, which focuses on OSHA and regulatory requirements; and 4) Environment, which focuses on creating and maintaining a safe, well-designed and clean working and shopping environment. Kohl s utilizes a unique safety communication platform to reach every associate in the organization. C.A.R.L., the safety cone, establishes safety as a brand that makes identification of safety materials fun, noteworthy and effective. C.A.R.L. s four fundamental principles: Cleanliness, Awareness, Responsibility and Leading by Example provide the basis for training and positive recognition of safety materials. The associate s role in maintaining a safe environment is clear and consistently highlighted in daily huddles, monthly training materials, contests and an Annual Safety Week. Kohl s is committed to maintaining a comprehensive safety program that demonstrates the importance of our associates and the communities in which we operate. The engagement of our Company ensures Kohl s Risk Management programs are on-going, meaningful and valuable. 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,

21 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, 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 EMPLOYMENT PRACTICES 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. 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 21

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