Global Ethics & Compliance

Our values—Integrity, Respect, Inclusion and Diversity, One Whirlpool and Spirit of Winning—form the enduring character of our company and are an important part of our heritage. They are the moral compass for everything we do. If Our Enduring Values of Integrity, Respect, Inclusion and Diversity, One Whirlpool and Spirit of Winning are the foundation of who we are as a company, then our culture for more than 100 years is reflected in our commitment to Winning with Integrity, because “how we achieve success is equal to if not more important than the success we achieve.” This quote by our Chairman and CEO Marc Bitzer encapsulates who we are, what we stand for and forms the foundation for our Global Ethics and Compliance Program.

Whirlpool Corporation’s Global Ethics and Compliance Program is focused on enhancing and sustaining our culture of winning with integrity, empowering employees with tools and resources to act with integrity, within a risk-based framework. Our program puts our Integrity value at the forefront and empowers our employees to keep it there. A cornerstone of our program is Our Integrity Manual, or code of ethics.

The Global Ethics and Compliance Program is overseen by Whirlpool Corporation’s Board of Directors, Audit Committee of the Board, as well as by a Global Ethics and Compliance Steering Committee, which is comprised of the CEO and Chairman of the Board, Chief Financial Officer, Chief Legal Officer, Chief Human Resources Officer, Vice President of Internal Audit and Chief Compliance Officer. The Global Ethics and Compliance Steering Committee helps set the tone for ethics and compliance at Whirlpool Corporation by leading ethics, compliance and integrity initiatives and providing strategic direction to our Global Ethics and Compliance Team, which includes ethics and compliance professionals across the globe, closely embedded within our regional and functional teams.

Our commitment to winning with integrity is also reflected by strong cross-functional leadership and partnerships between the Global Ethics and Compliance Team and partners such as Internal Audit, Human Resources, Information Security, Data Privacy, Product Safety, Global Sourcing, and other teams. These partnerships permit us to leverage resources to sustain program integrity and functionality. With clear ownership of compliance risks and related policies, procedures and systems, our Global Ethics and Compliance program encourages all of us to participate and play a key role in our culture of integrity.

Additional critical components of our Global Ethics and Compliance Program are risk-based ethics and compliance communications and training, including annual training on all of the principles in Our Integrity Manual. This training, where employees certify that they have reviewed and understand Our Integrity Manual, was delivered to 57,000 employees as part of the Integrity Manual launch in 2019, and 20,933 employees in 2020 and 19,570 employees in 2021 through refresher trainings, including 100% participation by employees in high risk roles or functions.

In 2021, undeterred by the continuing global pandemic and focused on the importance of our integrity value and the How of what we do, we delivered Global Integrity Week, during which our teams delivered targeted trainings over one week in July on our most critical risk areas and to our high-risk roles, including 49 interactive, virtual trainings to more than 12,000 employees across 40 countries and more than 250 cities. With 100% participation from our Executive Committee in various trainings and participation from global leaders ranging from managers to vice presidents, the dynamic trainings, videos, communications and educational materials and resources delivered by internal and external subject matter experts, advanced our culture, empowered our employees and enabled our colleagues to achieve success the right way.

Global Integrity Week

49 Total
Training
Events

79 Global
Leadership
Videos

12,000 Total
Global
Attendance

100% Executive
Committee Member
Participation

what EMPLOYEES had to say

TOPICS OF DISCUSSION

Culture of
Integrity

Cybersecurity/
Data Privacy

Health & Safety,
Security

What We Do
(GSS & GPO)

Anti-Bribery/
Anti-Corruption

With 69,000 employees and thousands of third-party business relationships, Whirlpool Corporation continually and systematically reviews compliance risks our business faces. We are aware of these risks and take proactive actions to respond to them. Whether through risk-based audits, managing our global third-party due diligence program or implementing and sustaining integrity channels that aid our employees to speak up, listen up and/or seek support, the Global Ethics and Compliance Program brings all of its operations and resources to bear to advance Whirlpool Corporation’s culture of integrity.

We encourage our employees to ask questions and voice concerns. As stated in Our Integrity Manual, speaking up and listening up is the responsibility of all of us. Our integrity channels serve as resources our employees can use to ask questions or raise a concern. Through our integrity channels, including Our Integrity Line, or hotline, we ensure that our employees will be listened to and heard.

Global Integrity Line

The Global Integrity Line is a confidential resource that allows individuals to raise good-faith ethics, compliance and values-related questions or concerns without fear of retribution or retaliation, and to do so anonymously at the reporter’s election. The Global Integrity Line can be accessed in several ways, both externally and internally, and is administered by an independent third party with translation capabilities. All matters raised through the Integrity Line are reviewed and investigated appropriately by the Global Ethics and Compliance Team pursuant to defined processes that include confidentiality and anti-retaliation policies. Throughout the review or investigation of a report, and following its conclusion, all matters that are raised are kept confidential. No aspect of a matter is made known except to a select and limited number of authorized individuals. The Global Ethics and Compliance Team reviews reporting trends and investigation results with both the Global Ethics and Compliance Steering Committee and Regional Ethics and Compliance Committees comprised of senior leaders.

All matters raised through the Integrity Line are reviewed and investigated appropriately by the Global Ethics and Compliance Team pursuant to defined processes that include confidentiality and anti-retaliation policies.

The Global Integrity Line is regularly publicized to employees as part of annual ethics and compliance communication plans and during global and regional training. These communications are delivered through multiple platforms and delivery channels within Whirlpool Corporation, and training is provided globally by ethics and compliance professionals and other cross-functional partners (e.g., Internal Audit, Finance, Human Resources, Inclusion & Diversity).

In 2021, Whirlpool Corporation had 744 total cases globally raised through the Integrity Line, which is a 15.1% increase in the total number of average cases raised over the previous three years. The increased reporting results from recent efforts to foster and encourage a “Speak Up” and “Listen Up” culture amongst employees. During 2021, we reduced the average days to close Integrity Line cases by more than 10% leading to an average closing time of 47 days, in line with industry standards. We also took corrective actions on substantiated cases. The unsubstantiated cases provided us opportunities to enhance our controls, processes and procedures or provide training and ensure a strong ethics and compliance culture. Through using continuous improvement strategies, enhanced coordination with cross-functional partners like HR, IA, GSS, and others, and strengthened governance and coordination among the Global Ethics and Compliance team, we have been able to improve our investigation processes, procedures and ability to respond to issues and concerns raised by colleagues.

How Our Integrity Line Works

Our Integrity Manual

Our culture of integrity is put into action every day by our 69,000 global employees. Our Integrity Manual (our code of ethics) represents how we translate our integrity into action.

Our Integrity Manual is intentionally designed with two sections: a cultural section and a principles section. The cultural section describes our values, while the principles section translates our integrity value into everyday actions.

Digital Integrity Manual
Whirlpool
Corporation's Values

Whirlpool Corporation’s commitment to integrity begins with its leadership. All of Whirlpool Corporation’s top leaders globally attended training in which they reviewed and committed to action Our Integrity Manual. In turn, these leaders actively led similar training, in which nearly three quarters of our global employees participated. This commitment demonstrated our belief that how we achieve our goals is just as important as what we accomplish. Each year these same leaders, and all leaders, also complete an annual training on all of the principles in Our Integrity Manual and participate in Global Integrity Week. These training sessions emphasize to our employees that Our Integrity Manual is a resource for them to be empowered to lead and win with integrity every day, including tools, such as a decision tree, to use when faced with an ethical question. As a tool to better support our employees globally, Whirlpool Corporation launched the Digital Integrity Manual in 2020. This interactive and practical tool further helps apply Whirlpool Corporation’s values to employees’ needs in their day-to-day work.

Protocol Against
Gender Violence

In 2020, Whirlpool Argentina formalized a protocol against gender or female violence after new policy changes and the ratification of the ILO 190 Convention by Argentina. Whirlpool Corporation’s Diversity & Inclusion committee has been working on this initiative in collaboration with other companies, organizations and associations. We are currently in the process of refining the protocol with support from a local nonprofit. The main goal of the Protocol is to provide guidelines that ensure we provide a trusted and safe environment for our female employees so they can comfortably request paid time off and receive reliable support on legal issues as well as mental and health issues.

Human Rights Approach

Whirlpool Corporation supports the human rights of everyone we work with and expects our global business partners to do the same. We believe in global human rights, and our business practices reflect that commitment to ensure every person who works for us throughout all of our global operations does so of their own free will, in a safe and healthy environment. We oppose discrimination, slavery and child labor, and ensure we have controls and protections to avoid them. We support diversity and wage parity. We also respect the rights of our employees to associate with whom they choose and to be involved in politics outside of work. These values are also reflected in Our Integrity Manual. Moreover, Our Integrity Line can be used both internally and externally to bring concerns about human rights issues to our attention. In addition to our internal commitment to human rights, we also hold our suppliers and business partners accountable to comply with these same principles through our Supplier Code of Conduct. See our Responsible Sourcing section below for additional details of human and labor rights.

Anti-Corruption

We do business the right way. This means that we do not tolerate bribery or corruption of any kind. Moreover, it means that we are actively adhering to this principle in all aspects of our business. In addition to Our Integrity Manual, Whirlpool Corporation maintains a global anti-corruption policy, which provides guidance and details of our anti-corruption commitment and expectations.

With leadership driven by our Executive Committee, the Global Ethics and Compliance Steering Committee, and Global Ethics and Compliance Team, and leveraging global and cross-functional resources, Whirlpool Corporation uses an anti-corruption program to identify and mitigate potential corruption risks. This includes:

Risk-based policies and procedures.
Online and in-person facilitated training.
Risk-based audits to monitor, mitigate, and eradicate corruption risks.

Due Diligence Program

Our global third-party due diligence program, which is applicable to all of Whirlpool Corporation’s third-party relationships, evaluates potential and future ethics and compliance risks, including risks of corruption that may be presented through our third-party relationships. In addition, we have escalation policies for raising corruption and/or bribery matters to either the Whirlpool Corporation Executive Committee and/or the Audit Committee of the Whirlpool Corporation Board of Directors. The escalation of these matters is intended to engage, inform and involve senior leaders in matters that may pose significant risk to the company and our culture of integrity. Additionally, every quarter the Global Ethics and Compliance Team reviews Integrity Line cases that may involve allegations of corruption and bribery with the Global Ethics and Compliance Steering Committee.

These quarterly meetings and reports are designed to actively engage global senior leaders in the oversight and response to anti-corruption matters, including addressing policy enhancements, implementing controls and procedures, aligning on targeted risk-based trainings, and engaging input on sustaining Whirlpool Corporation’s strong culture of compliance and commitment to anti-corruption efforts.

For Whirlpool Corporation, bribery means more than just money changing hands. If the intent is corrupt, anything of value—no matter how small and of what nature—can be considered a bribe. Bribery of a government official or any person or entity is illegal. Many countries also prohibit commercial bribes. Further, Whirlpool Corporation does not permit facilitation payments. Whirlpool Corporation policies proactively address bribery and facilitation, explaining that, “directly or indirectly offering, authorizing, promising, giving, accepting, soliciting, or receiving something of value to improperly influence someone or gain an improper or unlawful advantage can be considered a bribe. It may include but is not limited to cash payments or cash equivalents, gifts, hospitality, travel, vacations, political contributions and/or donations, meals, access to or special status at entertainment events, awarding contracts, and offers of future employment.”

We believe that corruption occurs when there is an abuse of trust and/or our values are compromised for an improper gain or advantage. This might include falsifying documents in exchange for (or to conceal) a bribe or receiving some form of personal enrichment for performing a normal job function. Even the appearance of corruption can be enough to damage our reputation and the trust of our customers, shareholders, business partners and one another. We maintain strict controls to prevent and detect corruption. We consistently communicate that we all must apply good judgment to prevent even the perception of wrongdoing.

Global Gifts & Entertainment Policy

In January 2020, Whirlpool Corporation implemented our revised Global Gifts & Entertainment Policy (the “Policy”) and Gifts and Entertainment Guidelines (the “Guidelines”). The Policy and Guidelines affirm our commitment to fair, ethical and lawful business relationships. As the Policy states, “[Whirlpool Corporation] awards and earns business solely on the basis of commercial considerations such as value, quality, services and competitive pricing. Gifts, entertainment, and other special favors are not, and will not become, conditions for doing business with Whirlpool and shall never influence, or appear to influence, an employee’s ability to make impartial business decisions in the best interest of Whirlpool.” Under the Policy, we do not accept gifts and any entertainment “must be reasonable, appropriate, serve a legitimate business purpose, and must not create the appearance of impropriety.”

Global Anti-Bribery/Anti-Corruption Online Training

Whirlpool Corporation maintains strict controls to prevent and detect corruption and follows specific accounting rules and procedures for reporting information and ensuring we have accurate and reasonably detailed books and financial records, including entertainment and travel expenses. To reinforce the importance of following Whirlpool Corporation policies and procedures, and their role in preventing bribery and corruption, in October 2020, Whirlpool Corporation launched its Global Anti-Bribery / Anti-Corruption Online training to more than 15,000 employees representing high-risk roles or functions. In 2021, as part of Global Integrity Week which reached more than 12,000 employees, we focused a full day to Anti-Bribery / Anti-Corruption training, including training on interactions with government officials, gifts and entertainment, third-party relationships and legal / regulatory compliance. We continually update, improve and enhance our Global Ethics and Compliance Program to ensure appropriate and necessary resources (economic and talent-based) are available and used to identify and respond to current and future corruption risks.

Throughout 2021, the Global Ethics and Compliance team provided diverse, dynamic, and interactive training focused on interacting with government officials to various global business units and teams. Bolstered by our global policies and procedures regarding gifts and entertainment, anti-corruption, and third party due diligence, the training was designed to reinforce our commitment to doing business with integrity, educating our teams, and helping empower our employees to avoid risks and even the appearance of impropriety. The training was delivered to colleagues in various roles ranging from manufacturing to sales and marketing.

Antitrust/Contact with Competitors Training

Whirlpool Corporation is strongly committed to complying with antitrust laws around the world. The company has a robust antitrust compliance program that involves every level of the company (including senior leadership) and includes mandatory antitrust policies, compliance procedures and controls, an extensive training program, and processes for periodic review, monitoring and auditing. Whirlpool Corporation regularly updates our antitrust compliance program to address changing business conditions, developments in antitrust law and enforcement, and emerging risks. One aspect of Whirlpool Corporation’s program is a set of compliance procedures and related training to ensure that all contacts with competitors comply with applicable antitrust laws. In November 2021, Whirlpool Corporation launched a global awareness effort to reinforce these compliance efforts and will supplement this effort in 2022 with an updated global training program.

It has become ever more important for organizations to understand cybersecurity, data privacy, crisis management and how all of that relates back to the business, so we can perform security at the speed of business. We’re focused on maturing our security capabilities and elevating our global security posture.

Juan Gomez-Sanchez,
Global Information Security Officer

Gomez-Sanchez joined Whirlpool Corporation in 2021 with more than 28 years of experience in information security, including roles at Delta Airlines, CheckFree Corporation (now Fiserv), Florida’s Turnpike Enterprise and most recently at Lennar Corporation, where his responsibilities encompassed all physical and cybersecurity initiatives. He is an industry-recognized thought leader and subject matter expert on various security-related domains to include Cyber Risk Management, Cyber Ethics and positioning security as a business enabler.

Cybersecurity & Data Privacy

We respect privacy. We want to earn and keep trust. We work hard to protect any personal information shared with us. We recognize the sensitivity of personal information, so we only seek personal information that we need for legitimate business or legal purposes, and only use it for purposes disclosed to consumers.

Equally important is our need to manage cybersecurity risk efficiently. To this end, we continue to invest in protecting our information assets and the integrity of our computing environment at the enterprise level. We have a cybersecurity and privacy training program that includes training, simulated phishing exercises and regular publications on our company portal. We have a Privacy program that manages compliance to privacy regulations globally. Our security monitoring and incident response functions are managed centrally by our Global Security Operations Center and we continue to mature our security capabilities in support of our business imperatives. Our Board is responsible for overseeing and holding senior management accountable for our global information security and privacy programs. This includes understanding our business needs and associated risks, and reviewing management’s strategy and recommendations for managing cybersecurity and privacy risks.

In line with this oversight responsibility, the Audit Committee receives reports on cyber program effectiveness periodically, and the Board of Directors receives a full presentation at least annually on cybersecurity-related trends and program updates.

In 2021, we elevated our Chief Information Security Officer role to a vice president-level position as a direct report to the Global Chief Information Officer to further focus on the strategic intent of the cybersecurity and Privacy programs.

Global Ethics & Compliance