Kohl : Political Activity Policy and Fiscal 2025 Report

Published: 2026-04-13 14:20:09 ET KSS

Published on 04/13/2026 at 02:20 pm EDT

Version 2.0 | Effective February 2025

Kohl's Corporation, together with its subsidiaries ("Kohl's" or the "Company") engages with the communities in which we do business and encourages its associates to participate in civic and community activities, including participation in the democratic process.

This Political Activity Policy (this "Policy") sets fiorth key principles and policies concerning political contributions, trade associations, and political and civic activities by and on behalfi ofi Kohl's, and it applies to Kohl's and the Company's associates. All political and civic activity by the Company and its associates must comply with applicable law, Kohl's Code ofi Ethics, and this Policy.

As a matter ofi policy and practice, Kohl's:

Kohl's does not make contributions using company resources (including monetary and in-kind resources) to candidates, political parties, ballot initiatives, refierendum campaigns, electioneering communications, or non-candidate organizations (such as political convention host committees), even where permitted by law. Additionally, Kohl's does not make contributions to entities organized under Section 527 ofi the Internal Revenue Code or social welfiare organizations created under Section 501(c)(4) ofi the Internal Revenue Code.

As set fiorth in the Company's Code ofi Ethics, any departure firom this policy would require prior written approval firom Kohl's Chiefi Legal Officer and must confiorm to all applicable laws. In this event, Kohl's would disclose any such contributions and make all legally required filings, including with the Federal Elections Commission.

Kohl's is a member ofi select trade associations and industry groups organized under Section 501(c)(6) ofi the Internal Revenue Code. The purpose ofi Kohl's membership with these groups is to advance the common interests and goals ofi the retail industry through advocacy and to maintain awareness on retail trends.

Kohl's may pay membership fiees and make other contributions (e.g., fior confierences or training), including on behalfi ofi its associates, to certain trade associations or industry groups. Kohl's will pay membership fiees only to trade associations that management has determined are meaningfiul to Kohl's business and its associates' profiessional development. Kohl's does not make additional contributions to these organizations to support the organization's political activities.

We monitor the activities ofi these organizations to ensure ongoing alignment with Kohl's objectives and perspectives. Kohl's participation in such organizations does not mean the Company endorses the organization's entire agenda or the views ofi its leaders or other members.

We will publicly disclose and update annually on corporate.kohls.com a list ofi trade associations to which Kohl's paid membership dues (representing the non-deductible portion ofi such dues) in excess ofi $25,000 per annum.

Kohl's associates are permitted to participate in political and civic activities, provided such activities are on their own time and at their own expense and do not otherwise interfiere with the conduct ofi Kohl's business.

Associates may make personal political contributions with their own personal fiunds. Kohl's associates will not be reimbursed, directly or indirectly, by the Company fior personal political contributions. Associates should always make it clear that their political activities and contributions are in their personal capacity and not attributed to or made on behalfi ofi Kohl's.

Kohl's Chiefi Legal Officer has oversight over political, trade association, and civic advocacy activities and communications. Annually, the Nominating and ESG Committee ofi Kohl's Board ofi Directors, which is comprised solely ofi independent directors, reviews the Company's political and civic advocacy activities, including payments made with respect to these activities, and monitors the Company's compliance with this Policy.

This Policy is consistent with Kohl's Code ofi Ethics, which expressly prohibits Kohl's associates firom using company resources to make political contributions. The Company's Code ofi Ethics is reviewed and approved by the Board ofi Directors on an annual basis.

This Fiscal 2025 Political Activity Report outlines Kohl's political activities fior Fiscal 2025, in accordance with the Company's Political Activity Policy.

Consistent with the Company's Political Activity Policy, in Fiscal 2025, Kohl's did not make any contributions:

using company resources (including monetary and in-kind resources) fior political purposes, including to candidates, political parties, ballot initiatives, refierendum campaigns, electioneering communications, or non-candidate organizations (such as political convention host committees);

to entities organized under Section 527 ofi the Internal Revenue Code; or

to social welfiare organizations created under Section 501(c)(4) ofi the Internal Revenue Code.

In Fiscal 2025, Kohl's paid membership dues (representing the non-deductible portion ofi such dues) in excess ofi $25,000 to the fiollowing trade associations:

National Retail Federation (NRF); and

Retail Industry Leaders Association (RILA).

Fiscal 2025

Political Activity Report

Kohl s Corporation | Political Activity Policy | Effective February 2025

Disclaimer

Kohl's Corporation published this content on April 13, 2026, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on April 13, 2026 at 18:19 UTC.