GOVERNANCE / RESPONSIBLE SOURCING Child Labor Forced Labor Wages and Benefits Hours of Work Women’s Rights Freedom of Association and Collective Bargaining 1 Tenets of Our Supplier Code of Conduct 2 3 4 6 Subcontracting Nondiscrimination Health and Safety Environment Integrity and Transparency Monitoring and Compliance 5 7 8 9 10 12 11 Supplier Code of Conduct: What is it and what does it include? In selecting suppliers, Whirlpool Corporation seeks to do business with reputable business partners who are committed to ethical standards and business practices compatible with those of Whirlpool Corporation. Our Supplier Code of Conduct (the “Code” or “SCoC”) formalizes the key principles under which suppliers to Whirlpool Corporation and its global subsidiaries (“Whirlpool”) are required to operate. This SCoC applies to all suppliers of Whirlpool including all the Whirlpool suppliers’ facilities. Whirlpool strongly encourages suppliers to exceed the requirements of this SCoC and promote best practices and continuous improvement throughout suppliers to conduct SCoC audits based on the following criteria established in 2021: - Critical suppliers: All supplier factories that operate in a country with Corruption Perception Index 1 (CPI) score of less than 45 and an annual spend of greater than US$100,000, supplying to any of Whirlpool Corporation’s facilities, if unaudited previously. - We also reserve the right to conduct audits on any existing supplier, irrespective of whether or not they meet the critical supplier criteria in case of any perceived or observed risks. • All new suppliers must go through an on-site audit by our third-party auditor We increased our spend covered for risk management through the Supplier Code of Conduct program by 4x their operations. We also expect suppliers to ensure that their suppliers, service providers and extended networks have ethical and business practices that are similar to Whirlpool’s practices. One tenet of our SCoC 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. Other areas covered are related to business ethics, labor management, health and safety, environmental practices, governance and compliance. Where there is no local legal requirement, or if a local legal requirement is not as strict as the requirement included in our SCoC, Whirlpool suppliers are required to follow the requirements outlined in our SCoC policy. Our Criteria We use a risk-based criteria to identify suppliers in scope for audits to ensure compliance with our SCoC policy. • Existing Suppliers: We classify our existing direct material and finished product sourcing suppliers as critical prior to being selected for conducting business with Whirlpool Corporation. Our Approach Audits & Corrective Action Plan We have retained a third party to conduct, evaluate and remediate all our audits. The main audit types conducted are: • Onsite Audits: Our preferred method of audits is onsite audits, which accounts for the majority of our audits. • Equivalent Audits: Equivalent audits are accepted if conducted in the last two years with any of these organizations: RBA, Amfori BSCI, SMETA (4 Pillar), ICTI, and Intertek WCA. For an equivalent audit to be accepted, the report must be validated by our third-party auditor, before it is accepted by Whirlpool Corporation. • Remote Audits: Only accepted due to site restrictions, travel hazards or other mitigating circumstances. All suppliers who undergo audits work with our third-party auditors to create and align on a Corrective Action Plan (CAP). Suppliers must provide evidence of resolving the CAP. Our auditors are also assigned to follow up on all audits that were completed to verify that the findings were closed to ensure continuous improvement in our processes. We had 33 remedial re-audits in 2021, out of which 21 suppliers have approved CAPs and are working on closing the action items; others are working on CAP approvals. Mitigation Actions We conduct annual training for suppliers in scope to ensure clear understanding of our SCoC and audit actions to ensure compliance. In 2021, we also conducted global training for all our procurement employees to ensure they were aware of the expectations and requirements of the SCoC and work proactively with suppliers to ensure any risks are identified and mitigated proactively, where possible. 1 Per Transparency International at transparency.org Whirlpool Corporation / 2021 SUSTAINABILITY REPORT 94