Whirlpool Corp. 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 and includes mandatory antitrust policies, compliance procedures and controls, an extensive training program and processes for periodic review, monitoring and auditing. We regularly update our antitrust compliance program to address changing business conditions, developments in antitrust law and enforcement and emerging risks.

• Senior leadership oversight
• Employee training
• Enforcement program
• Public policy and/or commitment

• Whirlpool Corp. Free and Fair Trade Policy
• Whirlpool Corp. Our Integrity Manual
• Whirlpool Corporation Global Integrity Line

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. 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, we use an anti-corruption program to identify and mitigate potential corruption risks. This includes our global due diligence program, which is applicable to all of Whirlpool Corp.’s third-party relationships and evaluates potential and future ethics and compliance risks, including risks of corruption, as well as our Global Integrity Line where cases that may involve allegations of corruption and bribery are reviewed on a quarterly basis.

• Senior leadership oversight
• Crossfunctional committee
• Employee training
• Enforcement program
• Public policy and/or commitment

• Whirlpool Corp. Our Integrity Manual
• Whirlpool Corporation Global Integrity Line
• Whirlpool Corp. Global Gifts and Entertainment Policy

We work hard to earn and keep the trust of our stakeholders. To this end, we continue to invest in managing cybersecurity risk, in protecting our information assets and ensuring the integrity of our computing environment at the enterprise level. Our security monitoring and incident response functions are managed centrally by our Global Security Operations Center, and we continue to mature our defensive 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, the Board of Directors receives a full presentation at least annually on cybersecurity-related trends and program updates; and the Global Cybersecurity and Data Privacy Steering Committee meets periodically; to help ensure information security risks and vulnerabilities are being appropriately managed and mitigated. Our Cybersecurity program, as governed by our Global Information Security Officer and executed by the Cybersecurity Team, is guided by National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) as the foundational baseline for Whirlpool Corporation cybersecurity practices.

We educate our employees on information security and breach response through our annual Global Cybersecurity and Privacy training.

• Board oversight
• Senior leadership oversight
• Employee training
• Enforcement program
• Public policy and/or commitment

• Whirlpool Corp. Privacy Commitment
• Whirlpool Corp. Data Privacy Policy

We respect privacy. We are transparent about the data we collect and the purposes for which it will be used — and we work hard to ensure its safety. Through corporate policies and procedures, training and awareness initiatives, risk assessment and management controls, our global privacy program provides that all information shared with us is processed in accordance with all applicable legal requirements and global best practices. Through our Global Privacy & Cybersecurity Steering Committee, our leadership champions our privacy program and oversees its development closely. We leverage technical solutions to automate every possible aspect of our privacy program and operationalize the program’s effectiveness through documented processes and procedures which are subjected to periodic audits.

Whirlpool Corp.’s third-party risk management process is designed to evaluate and assess the data privacy risks presented by engagement with a particular third party. Modeled on the ISO 27001:2013 standard, the security and privacy exhibit requires the third party to maintain adequate measures to ensure data security and requires those contractual provisions to be extended to subsequent third parties. We monitor legal and regulatory developments globally to keep abreast of new privacy requirements worldwide. We regularly review our privacy program to promote compliance with all relevant privacy laws and regulations.

• Board oversight
• Senior leadership oversight
• Cross-functional committee
• Employee training
• Enforcement program aligned with international standard [ISO 27001]
• Subject to external verification/audit
• Public policy and/or commitment

• Whirlpool Corp. Privacy Commitment
• Whirlpool Corp. Data Privacy Policy

Whirlpool Corp. is dedicated to achieving global leadership in all of our product categories and to always delivering superior and sustainable value for shareholders and other stakeholders. We have built our Executive Compensation programs around a strong pay-for-performance philosophy. Each member of our Executive Committee has elements of our ESG priorities included in their individual objectives for the purposes of individual performance ratings, which influence each executive’s incentive compensation.

• Board oversight
• Senior leadership oversight
• Public policy and/or commitment

• 2024 Proxy Statement

Whirlpool Corp. supports the human rights of everyone we work with and expects our global business partners to do the same. Our business practices reflect that commitment to provide that 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 have controls and protections to avoid them. Further, we support diversity and wage parity, and respect the rights of our employees to associate with whom they choose and to be involved in politics outside of work. In addition to our internal commitment to human rights, we strive to hold our suppliers and business partners accountable to comply with these same principles through our SCoC. Moreover, our Integrity Line can be used both internally and externally to bring concerns about human rights issues to our attention.

• Senior leadership oversight
• Employee training
• Enforcement program
• Public policy and/or commitment

• Whirlpool Corp. Our Integrity Manual
• Whirlpool Corp. Global Human Rights Policy
• Whirlpool Corp. Global Labor and Employment Guidelines
• Whirlpool Corporation Integrity Line
• Whirlpool Corp. Supplier Code of Conduct

Whirlpool Corp. respects the rights of our employees to associate with whom they choose. We respect the right of employees to join or not join an independent trade union and will bargain in good faith with these associations when they are properly elected. We estimate that, during 2023, 56% of our hourly employees globally were covered by a collective bargaining agreement.

• Senior leadership oversight
• Public policy and/or commitment

• Whirlpool Corp. Global Labor and Employment Guidelines

Whirlpool Corp. believes that respectful, professional conduct furthers the company’s mission, promotes productivity, minimizes disputes and enhances our reputation. Whirlpool expects every employee to show respect for all of our colleagues, customers and vendors. Harassment by co-workers, supervisors or any third parties is a form of misconduct that destroys our work environment and undermines the integrity of the employment relationship. The company is committed to providing a work environment that is free of unlawful discrimination, including harassment that is based on any legally protected status. The company will not tolerate any form of discrimination or harassment that violates this policy.

• Senior leadership oversight
• Employee training
• Enforcement program
• Public policy and/or commitment

• Whirlpool Corp. Non-Discrimination and Anti-Harassment Policy

Whirlpool Corp.’s compensation programs are designed to support our focus on creating sustainable value for all our stakeholders. Our objective is to provide a total compensation opportunity that is competitive with external market practices, considers internal equity and provides a true pay-for-performance approach. We evaluate external market competitiveness and internal equity at least annually, and our actual pay outcomes have been demonstrated to align with the performance results that we have delivered. Regardless of employees’ gender or background, we provide the same career and remuneration opportunities. All employees have equal access to the compensation and benefit programs that are relevant to their roles in the company.

On an annual basis in many countries, we complete a pay equity practices review by an external law firm that examines pay between employees of different gender and racial demographics doing similar work. We intend to continue to engage in this pay practice review process on a regular basis in an effort to uphold our compensation principles and our commitment to global pay equity.

• Board oversight
• Senior leadership oversight
• External verification
• Public policy and/or commitment

• Whirlpool Corp. Global Labor and Employment Guidelines

Whirlpool Corp. is committed to complying with all legal and regulatory requirements applicable to our products and operations. To fulfill this goal, we have developed a number of global and regional policies and procedures for promoting business compliance, including the development of a management system for implementing and promoting compliance to our global policies, maintaining appropriate documentation and implementing periodic and independent audits of our product compliance management system.

Through our Global Issue Action Teams, regional policy and regulatory steering committees and our government relations and regulatory affairs teams, we aim to drive thoughtful and sustainable policy outcomes on a variety of issues important to our company, including energy, environment, climate change, technology, product safety, trade, taxes, affordable housing and intellectual property. All lobbying activities and expenditures, as well as trade and professional association engagement, are reviewed on an annual basis by the Whirlpool Corp. Executive Committee and by the Corporate Governance and Nominating Committee of the Whirlpool Corp. Board of Directors that provides alignment with company values and priorities.

• Board oversight
• Senior leadership oversight
• Cross-functional committee(s)
• Enforcement program
• Public policy and/or commitment

• Whirlpool Corp. Global Public Policy Engagement
• Our Integrity Manual

Our global tax principles are based on the company’s overall core values; thus, we seek to manage our tax obligations in a responsible way. We seek to comply with both the letter and intent of tax laws. We understand that tax is an important component of our overall corporate social responsibility and recognize that taxes we pay are critical to the orderly function of civil society and support the communities in which we operate.

• Senior leadership oversight
• Public policy and/or commitment

• Whirlpool Corp. Statement on Policy of Taxes