The Code, which we have enhanced as we have expanded globally, clearly outlines our expectations, consistent with International Labour Organization standards, with regard to the prohibition of child labor, forced compulsory labor, the maintenance of workplaces free of coercion and harassment, the responsibility to provide employees with a safe and healthy workplace, and respect for the rights of employees to organize and bargain collectively. The Code also communicates that suppliers are expected to meet requirements applicable to human trafficking and slavery that are in accordance with the California Transparency in Supply Chains Act of 2010 (SB 657).

Adherence to applicable laws, regulations and standards is a condition for doing business with Mohawk, and compliance extends to suppliers’ subcontractors. The Mohawk Supplier Code of Conduct is implemented for Mohawk worldwide. We conduct assessments of select new and existing suppliers to verify compliance with the Code. These include supplier questionnaires, management meetings and facility audits, which may be attended by Mohawk staff or third parties. We do not currently retain a third-party verifier, but reserve the right to retain one, and require suppliers to agree to third-party verification.

We provide training to employees and management who are responsible for the implementation, management and enforcement of our Supplier Code of Conduct. Should we discover a Code violation, we promptly address the issue with the supplier and require correction of the issue. Our internal accountability controls include unannounced audits to verify correction and compliance, as well as the potential for termination of the supplier relationship for failure to remedy the violation.

Conflict Minerals

Mohawk recognizes conflict minerals as an important supply chain issue. We have developed a strong position on our use of all minerals, along with a materials verification process that is applied to our global suppliers. These minerals constitute a very small part of our supply chain needs. To the extent that these minerals are used in our products, however, we have confirmed with our suppliers that none of these have been sourced from the Democratic Republic of Congo or an adjoining country. We will continue to monitor our use of these minerals to ensure, as accurately as possible, that they do not originate from this region.