Supply Chain Management

Mohawk prioritizes ethical, environmental and social standards in its relationships with global partners. To this end, we maintain a Supplier Code of Conduct, applicable for Mohawk worldwide, to help ensure that materials incorporated into Mohawk products comply with applicable laws and other requirements and that suppliers share our principles of social responsibility. Our Supplier Code of Conduct requires suppliers to also agree to comply with Mohawk’s Environmental Policy and Human Rights Policy. We expect our suppliers to understand that our requirements for compliance with the Supplier Code of Conduct extend to their subcontractors, as well, and Mohawk promptly addresses any known violations.

Our Approach to Responsible Sourcing

Assessments

We conduct assessments of 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.

In 2022, Mohawk began the development of a diverse supplier program and intends to set a target for this initiative in 2024.

Training

We provide training to individuals 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. 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.

Expectations

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 and forced compulsory labor.
  • The maintenance of workplaces free of coercion and harassment.
  • The responsibility to provide employees with a safe and healthy workplace.
  • Respect for the rights of employees to organize and bargain collectively and their right to not seek collective bargaining.

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 Chain Act of 2010 (SB 657). Suppliers are also required to comply with the U.S. Uyghur Forced Labor Prevention Act and all other applicable laws and regulations prohibiting forced labor in the supply chain.

Conflict Minerals

Mohawk is committed to responsibly sourcing raw materials for our manufacturing processes, including, when applicable, gold, tin, tungsten and tantalum (conflict minerals). Conflict minerals constitute a very small part of our supply chain needs. Nevertheless, we are committed to sourcing such minerals responsibly by not sourcing conflict minerals that fund armed groups in the Democratic Republic of Congo and its adjoining countries (Covered Countries). Our Conflict Minerals Policy due diligence framework follows the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance, and we perform an annual good faith reasonable country of origin inquiry with respect to any conflict minerals that may be necessary for the functionality or the production of our products. In addition, our suppliers are expected to survey their suppliers to determine whether the applicable conflict mineral originates from the Covered Countries and, if so, whether the mineral is conflict-free, as set forth in our Supplier Code of Conduct.

Maintaining an Ethical Supply Chain: Uyghur Forced Labor Protection Act

As part of our ongoing dedication to responsible practices, we are committed to sourcing raw material for our products as well as sourcing finished products in alignment with our policies, practices and principles. As detailed in our Human Rights Policy, Mohawk stands firmly against child labor, human trafficking, forced or underpaid prison labor and slavery practices of any kind, and continues to undertake due diligence to validate this expectation with our suppliers. Voluntary labor is a standard across the Company and a condition for doing business with Mohawk.

In response to the Uyghur Forced Labor Protection Act which addresses concerns of forced labor in Xinjiang, China, we have continued to strengthen our supply chain mapping and audits for suppliers that were deemed high risk. Mohawk also requires compliance with our Supplier Code of Conduct, which addresses involuntary labor and other human rights concerns as a condition of doing business with the Company. In addition, we have piloted ethical sourcing training to better educate Mohawk employees and suppliers about raw material inputs, and the training programs will be rolled out as each business unit validates the content for their supply chain needs.


Supplier Engagement

We recognize that by engaging and supporting a wide range of suppliers from diverse backgrounds, we enhance our business performance and contribute to the advancement of underrepresented communities. During 2023, we continued to expand our procurement standard to include supplier diversity and sustainability performance considerations as part of our bidding process with the U.S.-based purchasing teams. We partner with Dunn & Bradstreet to validate supplier diversity qualifications, enabling us to reliably quantify spend.