GOVERNANCE / GLOBAL ETHICS & COMPLIANCE Due Diligence Program Our global third-party due diligence program, which is applicable to all of Whirlpool Corporation’s third-party relationships, evaluates potential and future ethics and compliance risks, including risks of corruption that may be presented through our third-party relationships. In addition, we have escalation policies for raising corruption and/or bribery matters to either the Whirlpool Corporation Executive Committee and/or the Audit Committee of the Whirlpool Corporation Board of Directors. The escalation of these matters is intended to engage, inform and involve senior leaders in matters that may pose significant risk to the company and our culture of integrity. Additionally, every quarter the Global Ethics and Compliance Team reviews Integrity Line cases that may involve allegations of corruption and bribery with the Global Ethics and Compliance Steering Committee. These quarterly meetings and reports are designed to actively engage global senior leaders in the oversight and response to anti-corruption matters, including addressing policy enhancements, implementing controls and procedures, aligning on targeted risk-based trainings, and engaging input on sustaining Whirlpool Corporation’s strong culture of compliance and commitment to anti-corruption efforts. For Whirlpool Corporation, bribery means more than just money changing hands. If the intent is corrupt, anything of value—no matter how small and of what nature—can be considered a bribe. Bribery of a government official or any person or entity is illegal. Many countries also prohibit commercial bribes. Further, Whirlpool Corporation does not permit facilitation payments. Whirlpool Corporation policies proactively address bribery and facilitation, explaining that, “directly or indirectly offering, authorizing, promising, giving, accepting, soliciting, or receiving something of value to improperly influence someone or gain an improper or unlawful advantage can be considered a bribe. It may include but is not limited to cash payments or cash equivalents, gifts, hospitality, travel, vacations, political contributions and/or donations, meals, access to or special status at entertainment events, awarding contracts, and offers of future employment.” We believe that corruption occurs when there is an abuse of trust and/or our values are compromised for an improper gain or advantage. This might include falsifying documents in exchange for (or to conceal) a bribe or receiving some form of personal enrichment for performing a normal job function. Even the appearance of corruption can be enough to damage our reputation and the trust of our customers, shareholders, business partners and one another. We maintain strict controls to prevent and detect corruption. We consistently communicate that we all must apply good judgment to prevent even the perception of wrongdoing. Global Gifts & Entertainment Policy In January 2020, Whirlpool Corporation implemented our revised Global Gifts & Entertainment Policy (the “Policy”) and Gifts and Entertainment Guidelines (the “Guidelines”). The Policy and Guidelines affirm our commitment to fair, ethical and lawful business relationships. As the Policy states, “[Whirlpool Corporation] awards and earns business solely on the basis of commercial considerations such as value, quality, services and competitive pricing. Gifts, entertainment, and other special favors are not, and will not become, conditions for doing business with Whirlpool and shall never influence, or appear to influence, an employee’s ability to make impartial business decisions in the best interest Whirlpool Corporation / 2021 SUSTAINABILITY REPORT 87