Whirlpool Corp.’s Ethics and Compliance Program represents our sustained commitment to empowering employees, sustaining a living “Speak Up, Listen Up” culture and ensuring that our integrity value is activated every day so we can maintain the trust of consumers, colleagues, stakeholders and the communities where we live and work.

Ethics and Compliance is the manifestation of what we do as an organization. Our strategic approach is to have a dynamic, agile and evolving risk-based global ethics and compliance program that inspires stakeholder confidence in a culture of high integrity, empowers confident and educated teams that understand the importance of integrity in the global marketplace, and proactively manages and responds to risks, whether potential or current.

Whirlpool Corp.’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.

An example of this strong leadership by our Global Ethics and Compliance Team and cross-functional partners was our response to the geopolitical and global economic events of 2022. From the Global Ethics and Compliance Team’s leadership during our response, to the sanctions and export control issues raised by Russia’s invasion of Ukraine, to working with our cross-functional partners to address a myriad regulatory and legal issues related to human rights and supply chain disruptions, the Global Ethics and Compliance Team and cross-functional partners met every challenge, not only with strategic solutions but with systematic and operational tools that enhanced how we do business the right way. Throughout their efforts, they never lost sight of taking steps that strengthen our culture of integrity. The successes of 2022 are leading to a comprehensive and dynamic review and expansion of our Global Trade Compliance Program and our Global TPPD Program in 2023.

Global Integrity Week

In 2022, empowered by the Executive Committee’s mandate that with so many challenges facing the company, Integrity Week was needed more than ever, we delivered Global Integrity Week (Living the Whirlpool Way: Caring, Sharing, Inspiring) over one week in July, including one day fully devoted to community service.

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, which are composed of senior leaders.

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 Corp., and training is provided globally by ethics and compliance professionals and other cross-functional partners (e.g., Internal Audit, Finance, Human Resources, Inclusion and Diversity). In 2023, we expect to launch a new Speak Up, Listen Up campaign to all our employees with new posters and messaging to emphasize our commitment to listening to their voices and encouraging them to continue to raise them.

In 2022, Whirlpool Corp. had 831 total cases raised globally through the Integrity Line, which is a 19.9% 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. Despite an increased volume in cases, our median days to close the investigations in 2022 was 29 days, which is well below industry benchmarks. We continue to implement and improve investigation tools and processes to help maintain and reduce closure rates. We also took corrective actions on substantiated cases. The unsubstantiated cases provided us with opportunities to enhance our controls, processes and procedures, or provide training to promote a strong ethics and compliance culture. Through continuous improvement strategies; enhanced coordination with cross-functional collaborators like our Human Resources, Internal Audit, Procurement, Global Security and Information Technology teams, among 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.

Our Integrity Manual

Our culture of integrity is put into action every day by our 61,000 global employees. Our Integrity Manual (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.

Whirlpool Corp.’s commitment to integrity begins with its leadership. All of the company’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 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 Corp. utilizes the Digital Integrity Manual. This interactive and practical tool further helps apply company values to employee needs in their day-to-day work.