GOVERNANCE / RESPONSIBLE SOURCING guidelines; or (b) the age for completing mandatory (compulsorily) education; or (c) the minimum age established by law in the country of manufacture. In addition, suppliers must comply with all legal requirements for the work of authorized young workers, particularly those pertaining to hours of work, wages, safety, working conditions and the handling of certain materials. In addition, suppliers must ensure that on a regularly scheduled basis, except in extraordinary business circumstances, workers are not required to work more than (a) 60 hours a week, including overtime, or (b) the limits on regular and overtime hours allowed by the laws of the country of manufacture. In addition, except in extraordinary business circumstances, all workers are entitled to at least one day off in every seven-day period. Pursuant to our SCoC, our suppliers must meet these requirements and be compliant with the law, codes and policies. Whirlpool also utilizes a cross-functional team led by Global Strategic Sourcing (procurement) and consisting of Legal, Ethics and Compliance, and Government Affairs to help identify, review, analyze and respond to any issues of forced or compulsory labor, including, but not limited to, monitoring multiple public websites, periodicals and reports that may identify forced labor violations or issues. Additionally, Whirlpool utilizes a Global Third-party Due Diligence Program that identifies forced or compulsory labor violations, claims or past conduct against new and current suppliers. Based on due diligence findings, Whirlpool can respond appropriately to forced or compulsory labor issues and risks. Material failures to comply with our SCoC may result in the termination of our relationship with a supplier. In order to ensure our suppliers are meeting our standard of integrity, we will continue to conduct independent audits of a representative sampling of our suppliers’ practices. In 2021, as a result of our SCoC audits, eight minor incidents of labor risk were identified. Four of these suppliers have corrected the findings by updating procedures and one new supplier was not awarded business. At the time of publishing the report, three of the eight have been put on new business hold until the findings are remediated. Environmental Assessments Our environmental assessment, which is part of our SCoC audits, requires suppliers to follow all local environmental laws applicable to the workplace, the products produced and the methods of manufacture. Additionally, we encourage the use of processes and materials that support sustainability of the environment. In 2021, in addition to our SCoC audits, we launched our Global Material Compliance System (also known as Global Critical Materials Management system) in all regions for various programs to collect, record and monitor the use of restricted materials from suppliers that may be harmful to the environment. The system has already been in use in our Europe, Middle East and Africa region since 2019 and replaced the manual collection of restricted materials in other regions this year. See our section on Technology & Innovation Inclusive of Design for Environment for additional details on this topic. Third-Party Due Diligence Program While we previously had third-party due diligence checks in place, in 2021 we launched an online centralized system “319 Anti-Corruption Screening Process” (the 319 TPDD Process) to continue driving global anti-corruption due diligence. The 319 TPDD Process is facilitated by Refinitiv Services—World Check program and review and analysis by Whirlpool Corporation’s global 319 TPDD compliance team. The program aims at lowering the risk exposure of working with high-risk third parties by running independent background checks to ensure the suppliers we do business with are reputable. The main information collected from third parties to conduct the screening includes their legal entity demographic information, primary contact and owner information, their interaction level details with the government in countries where they operate and ownership structure. In 2020, we launched our Global Material Compliance System in all regions to replace manual collection, recording, and monitoring the use of restricted and environmentally harmful materials from suppliers. Whirlpool Corporation / 2021 SUSTAINABILITY REPORT 95