Introduction

The Mohawk Manufacturing Company (MMC) is committed to integrity and social responsibility in the way we treat our employees, customers, suppliers and subcontractors.

This policy outlines the efforts MMC makes to uphold these values by refusing to knowingly support or tolerate human rights abuse in any part of our business.

Purpose

To eliminate human trafficking, including sex trafficking, slavery, forced, involuntary or coerced labor, and child labor from our operations and supply chain.

Definitions

Human trafficking or “trafficking in persons” is an umbrella term for the act of recruiting, harboring, transporting, providing, or obtaining a person for compelled labor or commercial sex acts through the use of force, fraud, or coercion.  Other terms employed interchangeably include involuntary servitude, slavery, and debt bondage.

Sex trafficking occurs when an individual is coerced, forced, or deceived into prostitution.  An individual’s initial consent is not legally determinative; if they later revoke consent but are forced to continue prostituting, they become victims of sex trafficking.  When a child is induced to perform a commercial sex act, the crime constitutes trafficking regardless of whether coercion, force, or fraud were used.

Forced labor or “labor trafficking” encompasses the range of activities – including recruiting, harboring, transporting, providing, or obtaining – involved when an individual uses force or physical threats, psychological coercion, deception, or other coercive means to compel another to work.

Child labor does not include all work performed by minors; rather, only that which harms their physical and mental development.  Such labor deprives children of their childhood, potential, and dignity.

Applicability

This Policy applies to all MMC Employees, agents, subcontractors, and suppliers when acting within their scope of employment or contract with MMC.

Policy

MMC will not tolerate and will not condone the use of human trafficking in any form, including sex trafficking, slavery, forced, involuntary or coerced labor, and child labor on our properties or by any emploiyee, agent, subcontractor or supplier in the operation or support of our business.  To that end, MMC shall, and requires that its businesses, employees, agents, subcontractors, and suppliers shall:

1. Not engage in or allow any form of human trafficking, whether by force, fraud, or coercion; or any form of involuntary servitude or slavery; or any form of sex trafficking or the procurement of any commercial sex act;
2. Not use any form of forced, involuntary or coerced labor, including through the use of: A) threats of serious harm to, or physical restraint against, a person or another person; or B) any scheme, plan, or pattern intended to cause a person to believe that, if the person did not perform such labor or services, that the person or another person would suffer serious harm or physical restraint; or C) any abuse or threatened abuse of law or the legal process;
3. Not engage in, or support the use of child labor and shall comply with all applicable local child labor laws;
4. Not destroy, conceal, confiscate, or otherwise deny access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses;
5. Not use misleading or fraudulent practices during the recruitment of employees or offering of employment, and shall endeavor to the extent possible to disclose to employees, in a format and language accessible to the employee, basic information regarding the key terms and conditions of employment, including wages and fringe benefits;
6. Comply with all applicable local wages, benefits, and working hours labor laws;
7. Not charge employees recruitment fees and shall not use recruiters that do not comply with local labor laws.

Employee Compliance

MMC shall periodically review and evaluate its internal operations and its supply chain to identify and assess activity that potentially risks violating this Policy.

As part of its training MMC will include training on human trafficking to employees responsible for managing other employees as well as those employees responsible for its supply chain.

Third Party Compliance

MMC subcontractors and suppliers who supply any products or services are required to review this Policy and comply with it.  Such subcontractors and suppliers will be required to periodically certify that they (a) have read, understand, and comply with both the Policy and (b) comply with the national human trafficking laws and labor standards.

Reporting

Any MMC employee that is informed of or witnesses a violation of this Policy, or is uncertain about the proper course of action relating to the matters addressed in this Policy, is encouraged to immediately contact his or her supervisor.  If the issue is not resolved or the employee is not comfortable raising the issue with his or her supervisor, they should use other reporting channels including MMC’s open door policy.

Violations

MMC has a zero tolerance policy regarding any of its employees, subcontractors or suppliers who engage in or support the use of human trafficking including sex trafficking, slavery, forced, involuntary or coerced labor, and child labor.  Failure to comply with this Policy will result in disciplinary action up to and including termination of employment.  If a subcontractor or supplier is found in violation of this policy, MMC will take prompt, remedial measures to address the violation, up to and including termination of the business relationship.