GOVERNANCE / OUR ESG APPROACH 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. 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. Whirlpool Corporation / 2021 SUSTAINABILITY REPORT 81
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