GOVERNANCE / RESPONSIBLE SOURCING Our Criteria & Approach For Suppliers • All new suppliers must be screened through the “319 Anti-Corruption Tool” and approved through this due diligence process before inviting them to submit requests for quotations and/or awarding business requests for quotations. • All existing suppliers are also evaluated through this program through mass screening with the tool. Decision Making Any supplier who fails the background check is either not awarded business (new supplier) during a sourcing event or put on notice for new business hold until clarification is received on actions taken to resolve the identified issues (existing supplier). Suppliers who pass the Third Party Due Diligence are then screened through our Cybersecurity/Privacy Due-Diligence process managed by our Corporate Information Security Office, and must pass before awarding business. Conflict Minerals Program Whirlpool Corporation 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 U.S. Securities and Exchange Commission (SEC) guidelines, in May 2021 we filed the Whirlpool Corporation Conflict Minerals Report for the year ended 2020, which included reporting requirements on issuers if their products contain metals derived from minerals defined as “conflict minerals,” which currently include cassiterite (the metal ore from which tin is extracted), columbite-tantalite (the metal ore from which tantalum is extracted), wolframite (the metal ore used to produce tungsten) and gold. These minerals—tin, tantalum, tungsten and gold—are referred to collectively as “3TG” or “3TG minerals”. Our Criteria & Approach For calendar year 2020, we identified 782 suppliers from across the globe which used smelters and refiners in producing parts and components sold to Whirlpool Corporation. These suppliers are in commodity groups that are known to have metal components in their parts, thereby higher chances of using smelters and refiners in their process. 61% (478 of 782) of our in-scope suppliers surveyed responded with Conflict Minerals Reporting Template (CMRT) declarations. The majority of our responding in-scope suppliers provided data at a company or divisional level, or otherwise were unable to fully identify specific entities that had processed the 3TG minerals contained in the products or components supplied to us. As a result, we were unable to definitively determine whether our products contain 3TG minerals that may have directly or indirectly financed or benefited armed groups. Since we are unable to verify the full source and chain of custody for all of the 3TG in our supply chain, we have elected not to present the smelter and refiner names provided by our supply chain in our conflict minerals 2020 report to the SEC. Of the smelters or refiners reported by our supply chain, 77% were classified as not from conflict affected or covered countries, and had statuses of “compliant” or “active” by the Responsible Minerals Assurance Process (RMAP) guidelines. The remaining smelters or refiners had other RMAP classifications. Measures to Improve Due Diligence and Mitigate Risk We continue to improve our program with the actions outlined below: • We invested in conflict minerals diligence tools by launching our conflict minerals survey through our Global Material Compliance Platform in 2020, enabling us to centralize our material compliance declarations into one database. • We increased the response rate of our in-scope suppliers by 8% in 2020 through improved escalation and follow-up procedures. • We developed further organizational and supplier awareness by conducting four compliance training (inclusive of conflict minerals training) with all our procurement employees, and sharing details of our conflict minerals compliance program in a global call with our entire supply base. Whirlpool Corporation 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). Whirlpool Corporation / 2021 SUSTAINABILITY REPORT 96