MARAZZI GROUP S.R.L CODE OF ETHICSPURPOSE

Dear Marazzi Group S.r.l’s (below identified as “Company”) employees, officers and directors:
This document outlines the standards of ethical behavior, the Company expects of you.
Throughout this document, we will abbreviate these standards as the “Code”.
You should keep in mind these important considerations when reading this Code: You should follow this Code in letter and in spirit.
 You should follow this Code along with any applicable laws, regulations and otherCompany’s policies and procedures.
 This Code applies to all of our employees, officers and directors regardless of location orposition. You must report any violation of this Code. To make a report, please follow the"Whistleblowing Hotline Policy" available in the "Company Info" section of the Company's
website.
 If you do not comply with the provisions of this Code and other Marazzi Group policies andprocedures, you could be disciplined or fired. You could also face criminal penalties and civil
liabilities for violating the standards outlined in this Code.
Integrity and a high standard of ethics are fundamental to our beliefs. The Company is committed todoing what is right and deterring wrongdoing, and we expect you to uphold these beliefs, as well. If
you have questions concerning the proper course of action, please consult your immediate
supervisor, the Vice President‐Human Resources, the Internal Audit Manager or the Legal Counsel.
Senior Financial Officers

This Code contains additional guidelines and standards for the Company’s principal executive officer
and senior financial officers. These can be found under “Supplemental Standards for Senior FinancialOfficers.”
Amendments and Waivers

Only Company’s Board of Directors may amend this Code. Only the Board of Directors or anauthorized committee of the Board may waive a part of the Code for any senior financial officer,executive officer or director. The Company will promptly disclose publicly all material amendments
and any waivers for senior financial officers, executive officers or directors, to the extent required bylaw.

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REPORTING VIOLATIONS

You must report any violation of this Code, Company’s policy or legal requirement. In reportingsuspected violations, we encourage to follow the "Whistleblowing Hotline Policy" available in the"Company Info" section of the Company's website.
FAIR AND HONEST DEALING

You must deal fairly and honestly with the Company’s employees, shareholders, customers, suppliersand competitors. You must behave in an ethical manner and not take unfair advantage of anyone
through manipulation, concealment, abuse of privileged information, misrepresentation of material
facts, or any other unfair business practice.
You must respect the integrity of persons and firms with whom the Company deals. You must limit
the fees and commissions paid to agents and other representatives to amounts that are consistent
with proper business conduct. You cannot make a payment to any employee, agent or representativeof a third party with or through whom the Company does business without full, documented
disclosure to all parties.
COMPLIANCE WITH LAWS, RULES AND REGULATIONSThe Company strives to ensure all activity on its behalf is in compliance with applicable laws, rules
and regulations. You must comply with all applicable laws, rules and regulations, whether or not
specifically addressed in this Code. Please contact Marazzi's Legal Counsel for additional guidance orif you have questions.
Antitrust Laws

You must comply with applicable antitrust and similar laws that regulate competition in thecountries in which we operate. These laws prohibit: Agreements to fix prices, bid rigging, market allocation and collusion (including pricesharing) with competitors;
 Boycotts, certain exclusive dealing arrangements and price discrimination agreements; and Unfair trade practices, including bribery, misappropriation of trade secrets, deception,intimidation and similar unfair practices.
Environmental Laws

The Company complies with all applicable environmental laws, rules, and regulations. You muststrive to utilize resources appropriately and efficiently and dispose of all waste in accordance withapplicable laws, rules and regulations.

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Employment Laws

The Company believes the fair and equitable treatment of employees, customers, suppliers andother persons is critical to fulfilling its vision and goals. The Company conducts its business without
regard to race, color, religion, gender, ethnic origin, age, disability, nationality, sexual orientation orgender identity, or any other classification prohibited by law, and will otherwise comply withemployment laws. The Company will not tolerate any form of harassment or discrimination against
anyone on the basis of any classification prohibited by law. The Company will investigate allegationsof harassment or discrimination in accordance with applicable laws and human resources policies.
Insider Trading

Laws and the Company’s policies prohibit you from: Purchasing or selling securities of the group to which the Company belongs (GroupMohawk Industries Inc., below identified as “Mohawk”) while you know material, non‐public information; and Disclosing material, non‐public information to others who then trade in Mohawk’s securities.
Mohawk’s Board of Directors has adopted an insider trading policy. You should review the insider
trading policy carefully and follow the policies and procedures it describes. Because of the complexityof inside information and insider trading, and the severity of the punishments involved, which caninclude criminal prosecution, you should seek the advice of Company’s Legal Counsel on anyquestions regarding this subject.
Anti-Bribery Laws / Foreign Corrupt Practices Act

The Foreign Corrupt Practices Act, regulations of the Organization for Economic Cooperation andDevelopment (“OECD”), and other anti‐bribery laws prohibits bribery or unlawful payments toforeign government officials or employees for the purpose of influencing decisions or obtaining orretaining business. These laws prohibit directly (or indirectly through an agent) making suchpayments. These laws impose criminal penalties, including fines and prison sentences, oncorporations and employees who violate the law. It is also illegal to bribe government officials ofyour own country. Accordingly, you may not make any unlawful payments to or for the benefit ofany government official or employee. Relations with government representatives, even where
personal friendships may be involved, must be in good taste and such that full public disclosure
would in no way damage Company’s reputation. You are required to comply with these laws andyou should seek the advice of the Company’s Legal Counsel should you have any questions on thistopic.

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You must comply with all laws, rules and regulations governing campaign finance and lobbying
activities. You cannot use Company’s funds and assets for political campaign purposes of any kind,
except where the political contributions are consistent with state law and you obtain prior approval
from the President of the Company. You may participate in the political process by means of
personal campaign contributions, expenditures or other activity. However, the Company will notreimburse or compensate you for your personal participation in political activities.
Integrity of Records and Compliance with Accounting Principles

The Company and the law require the preparation and maintenance of accurate and reliable businessrecords. You must prepare all reports, books, and records of the Company with care and honesty.
The Company maintains a system of internal controls to ensure that transactions are carried out inaccordance with management’s authorization and properly recorded. This system includes policies,procedures, and examination by a professional staff of internal auditors. The Company expects you
to adhere to these policies and procedures.
You should make all complaints regarding accounting, internal accounting controls, or auditing
matters to the Internal Audit Manager, who will assess each complaint. Alternatively, it is possible toreport any complaint through the "Whistleblowing Hotline Policy" available in the "Company Info"
section of the Company's website.
CONFLICTS OF INTEREST

The Company requires you to avoid any relationship, activity, or ownership that might create aconflict between your personal interest and Company’s interest. A “conflict of interest” occurs whenyour private interest interferes in any way, or even appears to interfere, withthe interests the Company. A conflict of interest can arise when you take actions or have intereststhat may interfere with your ability to perform your job objectively and effectively.
Conflicts of interest also arise when you, or a member of your family, receive improper personal
benefits as a result of your position with the Company.
You owe a duty of undivided and unqualified loyalty to the Company. You may not use your position
improperly to profit personally or to assist others in profiting at Company’s expense. The Company
expects you to avoid situations that might influence your actions or prejudice your judgment inhandling Company’s business. You must not become obligated in any way to representatives of firms
with which you deal and must not show any preference to third parties based on self or familyinterest. In addition, you must communicate to the Internal Audit Manager any transaction orrelationship that could create a conflict of interest.

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While not all inclusive, the following will serve as a guide to the types of activities that might cause
conflicts of interest:
Outside Financial Interests

Owning a substantial financial interest in any company that is a competitor of Mohawk or
which does or seeks to do business with Mohawk. If you have any interest in such acompany, you must inform Internal Audit Manager.
Conducting business, not on Company’s behalf, with any vendor, supplier, contractor,agency, or any of their employees, officers or directors.
Representing the Company in any transaction in which you or a family member, havea substantial personal interest.
Disclosing or using confidential, special or inside information of or about the Company(including Company’s name, trademarks, patents and other intellectual property), foryou or a family member’s profit or advantage.
Competing with Mohawk in the purchase, sale or ownership of property or services orbusiness investment opportunities.
Engaging in outside business activities or employment incompatible with Company’s rightto your full‐time employment and efficient service.

Gifts

You may not solicit gifts, trips, cash or other incentives from vendors and suppliers. You may notaccept gifts or incentives that could influence, or reasonably appear to influence your decision‐
making, and you can never accept cash or cash equivalents.
This policy also prohibits the payment or receipt of bribes, kickbacks or illegal payments of cash. You
may not receive any commission, fee, or payment of any sort from a vendor in connection with yourwork for the Company. You may attend business lunches, dinners, and similar outings (sporting
events, golf outings, theater, shows, etc.) when conducted in the normal course of business if
attending would not influence or be expected to influence your business judgment.
LoansYou may not lend to, borrow from or guarantee any obligation of any customer, supplier, contractor
or any person connected with the same.
Services for Competitors/Vendors

You may not perform work or render services for any competitor of Mohawk or for any organization
which does business or seeks to do business with Mohawk, outside of the normal course of your

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employment with the Company, without the approval of the Company’s CFO and Mohawk’s CFO (orthe Board of Directors, if you are an executive officer, senior financial officer or director). You cannot
serve as a director, officer, or consultant of that organization, or permit your name to be used in away that would suggest a business connection with that organization, without the approval of theCompany’s CFO and Mohawk’s CFO
Participation on Boards of Directors

Employees and officers may not serve as a director of any other for‐profit company, other than onbehalf of the Company, without the written approval of the Company’s and Mohawk’s Chief
Executive Officer or the Company’s and Mohawk’s Chief Financial Officer.
CORPORATE OPPORTUNITIESYou owe a duty to the Company to advance its legitimate interests and you are prohibited fromcompeting with the Company You cannot take any business opportunity you learn of as a result ofyour employment or use any Company’s property for your personal benefit or for the benefit of afamily member. For example, you should not acquire any interest in a company when you know thatMohawk may take or is taking steps to acquire an interest in that company. If you learn of a business
opportunity that is within Mohawk’s existing or proposed lines of business, you should inform yoursupervisor/manager, or the Company’s Legal Counsel. You may not personally pursue the business
opportunity until Mohawk, or the Company decide not to pursue it.
PROTECTION AND PROPER USE OF COMPANY ASSETS

You must strive to preserve and protect Company’s assets and resources and to ensure their efficientuse.
Personal Use of Corporate Assets

You should use Company’s property only for legitimate business purposes and conduct Company’sbusiness. You may not use or take Company’s equipment, supplies, materials or services, except inthe normal course of your employment, without approval of your supervisor/manager.
CONFIDENTIAL AND PROPRIETARY INFORMATION
ConfidentialityConfidential information includes all non‐public information that might be of use to competitors or
harmful to Mohawk or its customers, if disclosed. The Company owns all information, in any form
(including electronic information), that is created or used in support of its activities. This information
is a valuable asset, and the Company expects you to protect it from unauthorized disclosure. Thisinformation includes the Company’s customer, supplier, business partner and employee data.

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Applicable law may restrict the use of this information and may penalize you if you use or disclose it.
You should protect information pertaining to the Company’s competitive position, businessstrategies and information relating to negotiations with employees or third parties and share it onlywith employees who need to know it in order to perform their job.
You must maintain the confidentiality of information entrusted to you by the Company, itscustomers, vendors or consultants, except when disclosure is authorized or legally required. You
must take all reasonable efforts to safeguard confidential information that is in your possession
against inadvertent disclosure and must comply with any non‐disclosure obligations imposed on theCompany.
Intellectual Property and Proprietary Information

You must carefully maintain and manage the intellectual property rights of the Company, including
patents, trademarks, copyrights, licenses and trade secrets, to preserve and protect their value. Inaddition, you must respect the intellectual property rights of others. If you violate other’s intellectual
property rights, you and the Company could face substantial liability, including criminal penalties.
Intellectual property that you create during the course of your employment belongs to the Company.
You must share any innovations or inventions you create with your supervisor/manager so that theCompany can take steps to protect these valuable assets.
SUPPLEMENTAL STANDARDS FOR SENIOR FINANCIAL OFFICERS

The Company’s Board of Directors has established certain additional ethical standards for its
principal executive officer and senior financial officers. These officers include the President and Chief
Executive Officer, the Chief Financial Officer and Accounting/Controlling Managers. The principal
executive officer and all senior financial officers of the Company must comply with these standards inaddition to all the other standards contained in this Code.
Integrity and Accuracy of Public Disclosures

Company’s principal executive officer and senior financial officers must take all reasonable steps toensure that the disclosures in the reports and documents that Mohawk and the Company file with orsubmit to the Securities and Exchange Commission and in other public communications are full, fair,accurate, timely and understandable. In the event that the principal executive officer or a seniorfinancial officer learns that any such report, document or communication does not meet thisstandard, and the deviation is material, then such officer will review and investigate the deviation,
advise the Board of Directors or the appropriate Board committee and, where necessary, revise therelevant report, document or communication.

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Accounting Treatment

Although a particular accounting treatment for one or more of the Company’s operations may bepermitted under applicable accounting standards, the principal executive officer and senior financial
officers will not authorize or permit the use of such an accounting treatment if the effect is to distortor conceal Company’s true financial condition.

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