Global Ethics & Compliance

Our values form the enduring character of our company and are an important part of our heritage. They are the moral compass for everything we do. If Our Enduring Values of Integrity, Respect, Inclusion and Diversity, One Whirlpool and Spirit of Winning are the foundation of who we are as a company, then our culture for more than 100 years is reflected in our commitment to winning with integrity, because there is No Right Way to Do a Wrong Thing. This commitment forms the foundation for our Global Ethics and Compliance Program.

Whirlpool Corporation’s Global Ethics and Compliance Program is focused on enhancing and sustaining our culture of winning with integrity, empowering employees with tools and resources to act with integrity within a risk-based framework. A cornerstone of our program is Our Integrity Manual, or code of ethics.

Oversight of the Global Compliance and Ethics Program is governed by the Global Ethics and Compliance Steering Committee (“E&C SteerCo”), which includes members of the Executive Committee, including our Chairman and CEO. The E&C SteerCo sets the tone for ethics and compliance at Whirlpool Corporation and oversees the global program.

20,933

Whirlpool Corporation employees completed the Annual Ethics and Compliance Certification in 2020, representing more than 100% of required employee participants.

Our commitment to winning with integrity is also reflected in strong cross-functional leadership and partnership between Compliance and functions such as Internal Audit, Human Resources, Product Safety, Global Sourcing and other teams. These partnerships permit us to leverage resources to sustain program integrity and functionality. With clear ownership of compliance risks and related policies, procedures and systems, our global ethics and compliance program encourages all of us to participate and play a key role in our culture of integrity.

Another critical component of the Global Ethics and Compliance Program is risk-based ethics and compliance communications and training, including training on all of the principles of Our Integrity Manual, which in 2019 was delivered to virtually all employees. In 2020, more than 20,000 employees, including 100% of all required participants, completed our Annual Ethics and Compliance certification. Certification documents employees’ review and understanding of our Global Compliance Policies, including the principles in Our Integrity Manual and our anti-corruption policies.

We held our annual Global Compliance Weeks from October 12, 2020 through December 9, 2020 in a virtual format. Global Compliance Weeks delivered content to Whirlpool Corporation’s employees across all regions and at all levels of the organization. Between Global Compliance Weeks and other 2020 training events we held more than 150 ethics and compliance training sessions globally, reaching over 32,000 employees.*

With 78,000 employees and thousands of third-party business relationships, Whirlpool Corporation continually and systematically reviews compliance risks our business faces. We are aware of these risks and we take proactive actions to respond to them. Whether through risk-based audits, managing our global third-party due diligence program or implementing Integrity Channels that aid our employees to speak up and/or seek support, the Global Ethics and Compliance Program brings all of its operations and resources to bear to advance Whirlpool Corporation's culture of integrity.

We encourage our employees to ask questions and voice concerns. As stated in Our Integrity Manual, speaking up is our responsibility. Our Integrity Channels serve as resources our employees can use to ask questions or raise a concern. Through these channels, including our Global Integrity Line, or hotline, we ensure that our employees will be listened to and heard.

Our Global Integrity Line is administered by an independent third party and translated into 16 languages. It can be accessed in several ways, externally and internally, for reporting of concerns about potentially unethical or unlawful behavior of any employee, or for raising questions about ethics and compliance matters. Whirlpool Corporation also has Regional Compliance Directors embedded within our global locations who lead cross-functional teams ensuring in-person advice, strategic legal and compliance counseling, training and guidance on doing business with integrity.

*These numbers do not include online anti-corruption and anti-bribery training, which are described on Anti-Corruption.