GOVERNANCE / RESPONSIBLE SOURCING We continue to undertake the following actions to improve due diligence and further mitigate the risk that 3TG minerals in our products benefit armed groups: • Enhance escalation and follow-up procedures to increase the response rate of our suppliers to the CMRT, and to enhance due diligence measures to obtain detailed information from suppliers that responded that they may be sourcing 3TG minerals from the covered countries. • Participate in our Raw Materials Initiative (RMI) with other industry groups to support an increase in the number of smelters and refiners participating in the RMAP and other solutions aimed at improving supply chain transparency. • Make additional investments in conflict minerals due diligence tools. • Monitor leading practices of peer companies to enhance our own conflict minerals program. • Follow processes to identify newly added direct suppliers to Whirlpool Corporation and acquired entities and incorporate them into our Reasonable Country of Original Inquiry (RCOI) efforts. • Develop further awareness within the organization and supply base regarding conflict minerals compliance through outreach and training. • Institutionalize 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. • 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 covered countries, work with them to establish alternative sources of 3TG. Mitigating Supply Risks During COVID-19 We have all witnessed how disasters of varying degrees (pandemic, weather, etc.) can impact our day-to-day business operations. These issues have challenged us to look beyond traditional risk management and adopt a more agile, holistic approach to business continuity. In 2021, we launched a Disaster Risk Management survey for all our Direct and Finished Product Sourcing suppliers to better understand business continuity risks in their operations and their supply bases. The survey covered the following risk assessments: Environmental, Socio-economic, Operational, Financial and Compliance risks. We stated our expectations that our suppliers be prepared with a solid disaster recovery plan in the event we face further challenges. Responsible Sourcing Program: Continuous Improvement Actions We strive to continuously strengthen and enhance our compliance programs to ensure we mitigate risk, minimize negative impacts and make a positive contribution to the businesses, people and communities we support through ethical purchasing practices. While we expect our Tier 1 suppliers to extend our SCoC to their entire supply chain, the audit program is only extended to our Tier 1 suppliers, and we look forward to expanding it for Tier 2 suppliers with directed spend in the near future. Whirlpool Corporation / 2021 SUSTAINABILITY REPORT 97
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