Supply Chain Transparency and
Supplier Code of Conduct
This Whirlpool Corporation Supplier Code of Conduct (the “Code”) formalizes the key principles under which suppliers to Whirlpool Corporation and its global subsidiaries (“Whirlpool”) are required to operate.
Whirlpool established its Supplier Code of Conduct in 2006, reflecting our fundamental expectations. The principals in the Code state Whirlpool’s expectation for its Suppliers on identified business practices.
In selecting suppliers, Whirlpool seeks to do business with reputable business partners who are committed to ethical standards and business practices compatible with those of Whirlpool. This Code applies to all suppliers of Whirlpool including all of the Whirlpool Suppliers’ facilities. Whirlpool strongly encourages suppliers to exceed the requirements of this Code and promote best practices and continuous improvement throughout their operations.
Whirlpool expects its Suppliers to act responsibly in all respects and to ensure that no abusive, exploitative or illegal conditions exist in their supply chains. Whirlpool requires that Suppliers comply with all applicable laws and regulations, as well as the principles set out in the Code. One tenet of this Supplier Code of Conduct is that Whirlpool Suppliers must not use any type of involuntary or forced labor; this prohibits, among other things, slave labor or business practices which in any way rely on, or encourage, human trafficking. Where there is no local legal requirement, or if a local legal requirement is not as strict as the requirement included in this Code, Whirlpool Suppliers are required to follow the requirement in this Code.
Whirlpool has established e-learning courses for our sourcing professionals to educate them on the requirements of our Supplier Code of Conduct. Our Code of Conduct and our training programs undergo review and are refreshed and updated from time to time to reflect changes in circumstances. In addition to requesting our suppliers to certify their compliance with our Code of Conduct, we have engaged a third party agency who has conducted, and will continue to conduct, independent audits of a sampling of our suppliers’ practices. Material failures to comply with our Supplier Code of Conduct may result in the termination of our relationship with a Supplier, as may be permitted by applicable law.
Whirlpool’s Suppliers are vital business partners, and together, these principles provide us with an opportunity to better the lives of the people we touch.
WHIRLPOOL’S PERSPECTIVE ON ADDRESSING CONFLICT MINERALS
Introduction to Conflict Minerals
Whirlpool is committed to complying with federal laws and regulations requiring disclosure of the use of conflict minerals.
The term “conflict minerals” refers to certain identified minerals that may have directly or indirectly contributed to the financing of armed groups in the Democratic Republic of Congo (DRC) and neighboring countries.
In August 2012, as required by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“the Dodd-Frank Act”), the U.S. Securities and Exchange Commission (“SEC”) approved the final rule (“Conflict Minerals Rule”) on the disclosure of conflict minerals. This rule requires publicly traded companies subject to SEC regulation to annually report the presence of conflict minerals that are necessary to the functionality or production of products they manufacture or contract to manufacture. Companies subject to the Conflict Minerals Rule must exercise due diligence on the source and chain of custody of conflict minerals if they know or have reason to believe that the conflict minerals originated from the DRC region or if they know or have reason to believe the conflict minerals may not be from recycled or scrap sources.
Columbite-tantalite, cassiterite, wolframite and gold ores – which are refined into tantalum, tin, tungsten and gold, respectively – are considered to be conflict minerals and are collectively referred to as the “3TG’s”. The 3TG’s are used in a wide variety of consumer products, and Whirlpool is currently investigating – in cooperation with our supply base – where these may be found in our products worldwide.
What has Whirlpool Done to Date?
Whirlpool has developed a conflict mineral due diligence framework that conforms with the internationally recognized due diligence framework developed by the Organisation for Economic Co-operation and Development (“OECD”). Per SEC guidelines, we have also filed the Whirlpool Corporation Conflict Minerals Report for the Year Ended 2019, available at the link below:
Whirlpool has taken a number of actions to support responsible in-region 3TG sourcing, including the following:
- We continue to enhance escalation, follow-up procedures and performed due diligence measures to improve the transparency over the supply chain and increase our supplier response rates;
- We have established a process to gather smelter information from the Responsible Minerals Initiative (RMI) on a continuous basis to validate the status of smelters and refiners identified by our suppliers, which has helped us identify the percentage of suppliers on our smelter list that are RMI compliant;
- We actively participate in RMI, the multi-stakeholder group convened by the Responsible Sourcing Network, and other industry groups to support solutions aimed at improving supply chain transparency;
- We have made additional investments in conflict due diligence tools;
- We continue to monitor leading practices of peer companies to enhance our conflict minerals program;
- We have implemented a process to identify new direct suppliers to Whirlpool and to acquired entities to include them our Reasonable Country of Origin Inquiry efforts;
- We continue to develop further awareness within the organization and supply base regarding conflict minerals compliance through outreach and training;
- We have institutionalized our conflict minerals compliance program by improving our standard operating procedures, rolling out the procedure to identified business units, and identifying and prioritizing improvement opportunities; and
- In the event that any of our suppliers are found to be providing us with components or materials containing 3TG from sources that support conflict in the DRC region, we have committed to work with them to establish alternative sources of 3TG.
What did Whirlpool Find through this Process?
We have evaluated our global supply chain and surveyed 100% of our in-scope suppliers to understand potential risks in their supply chains, organized and analyzed their responses and have filed an annual Conflict Minerals Report to share our due diligence process.
While our continued efforts in 2019 have not provided us with enough information to conclusively determine whether our products contain 3TG that directly or indirectly financed or benefited armed groups in the DRC Zone, our efforts have improved supply chain transparency and created increased awareness within the organization regarding conflict minerals compliance that will allow us to further improve due diligence and mitigate risk in 2020 and beyond.
Details of the process we have followed and the results to date can be found in the Whirlpool Conflict Minerals Report (link above), and within our Conflict Minerals Policy, linked below: