We do business the right way. This means that we do not tolerate bribery or corruption of any kind. Moreover, it means that we are actively adhering to this principle in all aspects of our business. In addition to Our Integrity Manual, Whirlpool Corporation maintains a global anti-corruption policy (the Global Compliance Policy on Business Conduct, Anti-Bribery and Foreign Corrupt Practices Act), which provides guidance and details of our anti-corruption commitment and expectations.
With leadership driven by our Executive Committee, the Global Ethics and Compliance Steering Committee and Global Ethics and Compliance team, and leveraging global and cross-functional resources, Whirlpool Corporation uses an anti-corruption program to identify and mitigate potential corruption risks. This includes:
- Risk-based policies and procedures
- Online and in-person facilitated training
- Risk-based audits to monitor, mitigate and eradicate corruption risks
Due Diligence Program
Our global third-party due diligence program, which is applicable to all of Whirlpool Corporation’s third parties, 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 presents Integrity Line cases that may involve allegations of corruption and bribery to the Global Ethics and Compliance Steering Committee, which is comprised of the CEO and Chairman of the Board, Chief Financial Officer, Chief Legal Officer, Chief Human Resources Officer, Vice President of Internal Audit and Chief Compliance Officer.
These quarterly meetings and reports are designed to actively engage the involvement and support of 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. As Whirlpool Corporation states in its policies and training, “[d]irectly 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 its revised Global Gifts & Entertainment Policy (the “Policy”) and Gifts and Entertainment Guidelines (the “Guidelines”). The Policy and Guidelines affirm our commitment to anti-corruption efforts and principles and that we always pursue only fair, ethical and lawful business relationships. Under the Policy, no gifts and/or entertainment are permitted unless within clearly and narrowly defined boundaries. And no gifts and/or entertainment to or for government officials can occur unless pre-approved by our Global Ethics and Compliance team. Our Policy is another example of our commitment to ethical and lawful action within the marketplace. Conducting ourselves The Whirlpool Way means we award and earn business solely on the basis of commercial considerations such as value, quality, services, and competitive pricing and avoid inappropriate conduct and 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, regardless of with whom an employee may be interacting. 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 our Global Anti-Bribery/Anti-Corruption online training (the “Global ABAC Training”) to more than 15,000 employees, representing potential high-risk roles or functions. 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.
The Whirlpool Integrity Line is a confidential resource that permits a reporter to bring good-faith ethics and compliance concerns to the forefront without fear of retribution or retaliation, and to do so anonymously at the reporter’s election. All matters raised through the Integrity Line are kept confidential throughout the review or investigation and following the conclusion of the matter. No aspect of a matter is made known except to a select and limited number of authorized individuals.
Whirlpool Corporation’s Integrity Line and its availability, accessibility and use is regularly made known to all Whirlpool Corporation employees through annual communication plans and as part of global and regional training. These communications are delivered through multiple platforms and delivery channels within Whirlpool Corporation. The training is provided globally by Regional Compliance professionals and other cross-functional partners (e.g., Internal Audit, Finance, Human Resources, Inclusion & Diversity). Access to the Integrity Line is also made available on Whirlpool Corporation’s external-facing website(s).
Throughout Global Compliance Weeks, and as part of specific programming focused on Whirlpool Corporation’s “Speak Up” culture, specific emphasis was placed on the Integrity Line and encouraging its use to raise concerns confidentially, anonymously and without fear of retaliation.
In 2020, Whirlpool Corporation had 690 total cases globally raised through the Integrity Line, which is a significant increase in the total number of cases raised over the previous three years. This reflects the highest number of cases raised, which is an indication of Whirlpool employees embracing our “Speak Up” culture and being empowered to do so. It is also important to note that during 2020, Whirlpool Corporation reduced its average days to close investigation and remediation of Integrity Line cases by more than half. Thus, the global average days to close an Integrity Line matter is about 40 days.
During 2020, the Global Ethics and Compliance team, in collaboration with cross-functional partners, received and resolved ethics and compliance matters on a range of issues. All of these matters are investigated and reported to dedicated ethics and compliance steering committees at the global and regional levels; each Ethics and Compliance Steering Committee is comprised of one or more EC members, a dedicated Human Resources leader, a leader from the Global Legal Team and a member of the Global Ethics and Compliance team. The most significant matters are escalated to the Global Ethics and Compliance Steering Committee and the Board of Directors (Audit Committee).