Mohawk Industries Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Mohawk Industries reports a clear stance of non-engagement in dedicated climate lobbying, stating that “Mohawk does not employ dedicated lobbyists, and no individuals within the business devote 20 percent or more of their time to lobbying activities in any quarter.” The company acknowledges indirect engagement through membership in trade associations—listing organizations and fees paid—and clarifies that “Mohawk does not direct these efforts and sometimes does not agree with political positions of the trade associations.” It identifies engagement with two specific regulatory frameworks—the U.S. SEC’s forthcoming climate-related disclosure standards (“Thanks to the cross-functional work with your team, Legal, Accounting, Internal Audit and the businesses, we are prepared to include the required disclosures in future filings once the timeframe is finalized”) and the European Sustainability Reporting Standards under the EU Corporate Sustainability Reporting Directive (“We take the European Sustainability Reporting Standards (ESRS) very seriously, and we are doing the necessary work preparing for them”)—demonstrating transparency about the policy landscapes it monitors. The company further notes that “while Mohawk may express political engagement by offering technical information to elected officials or governmental agencies, this is not accompanied by donations.” However, it does not detail any direct lobbying actions such as meetings, letters, or consultations with named policymakers, nor does it set out any specific legislative or regulatory outcomes beyond general compliance and alignment goals. Overall, Mohawk’s disclosures offer a limited view of its climate-related advocacy, clearly describing what it does not do, but providing only sparse details on any indirect efforts and no explicit outcomes sought.	1

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Mohawk Industries discloses a targeted approach to aligning its indirect lobbying activities with its climate strategy by stating it "works with each association directly" and providing the example that "Mohawk’s Director of Sustainability is on the Board of Directors for CARE, which allows the Company to directly influence its engagement activities." The company also enhances transparency through its "annual Prior Year Direct & Indirect Political Activity report" that lists each trade organization and "a range of the dues for each one of them," and by disclosing "a list of trade associations and chambers of commerce that may engage in lobbying activities, including each organization’s name and membership fees paid by the Company in 2021." However, the company does not disclose a formal, recurring process for monitoring or managing climate-related lobbying, and we found no evidence of similar mechanisms governing direct lobbying or of a designated committee or individual—beyond occasional board seats—whose role is to oversee or review all company lobbying activities and assess alignment with its climate commitments. Additionally, while the ESG Executive Council and the Nominating and Corporate Governance Committee "help formulate strategies to respond to public policy, legislative, regulatory, political and social topics," the company does not explain how these bodies specifically examine or approve the positions of trade associations in relation to its climate objectives.	2