GOVERNANCE / GLOBAL ETHICS & COMPLIANCE of Whirlpool.” Under the Policy, we do not accept gifts and any entertainment “must be reasonable, appropriate, serve a legitimate business purpose, and must not create the appearance of impropriety.” Global Anti-Bribery/Anti- Corruption Online Training Whirlpool Corporation maintains strict controls to prevent and detect corruption and follows specific accounting rules and procedures for reporting information and ensuring we have accurate and reasonably detailed books and financial records, including entertainment and travel expenses. To reinforce the importance of following Whirlpool Corporation policies and procedures, and their role in preventing bribery and corruption, in October 2020, Whirlpool Corporation launched its Global Anti- Bribery / Anti-Corruption Online training to more than 15,000 employees representing high-risk roles or functions. In 2021, as part of Global Integrity Week which reached more than 12,000 employees, we focused a full day to Anti-Bribery / Anti-Corruption training, including training on interactions with government officials, gifts and entertainment, third-party relationships and legal / regulatory compliance. We continually update, improve and enhance our Global Ethics and Compliance Program to ensure appropriate and necessary resources (economic and talent-based) are available and used to identify and respond to current and future corruption risks. Throughout 2021, the Global Ethics and Compliance team provided diverse, dynamic, and interactive training focused on interacting with government officials to various global business units and teams. Bolstered by our global policies and procedures regarding gifts and entertainment, anti-corruption, and third party due diligence, the training was designed to reinforce our commitment to doing business with integrity, educating our teams, and helping empower our employees to avoid risks and even the appearance of impropriety. The training was delivered to colleagues in various roles ranging from manufacturing to sales and marketing. Antitrust/Contact with Competitors Training Whirlpool Corporation is strongly committed to complying with antitrust laws around the world. The company has a robust antitrust compliance program that involves every level of the company (including senior leadership) and includes mandatory antitrust policies, compliance procedures and controls, an extensive training program, and processes for periodic review, monitoring and auditing. Whirlpool Corporation regularly updates our antitrust compliance program to address changing business conditions, developments in antitrust law and enforcement, and emerging risks. One aspect of Whirlpool Corporation’s program is a set of compliance procedures and related training to ensure that all contacts with competitors comply with applicable antitrust laws. In November 2021, Whirlpool Corporation launched a global awareness effort to reinforce these compliance efforts and will supplement this effort in 2022 with an updated global training program. Whirlpool Corporation / 2021 SUSTAINABILITY REPORT 88