Whirlpool Corporation

U.S. Political Contributions, Disclosure and Trade Associations

Whirlpool Corporation believes that active participation and engagement in the public policy arena is an important part of being a responsible corporate citizen, vital to the democratic process and important to our company’s success.

We are committed to engaging in a dialogue with policy makers on a wide range of public policy issues important to our company, including trade, taxes, energy, the environment, affordable housing, and intellectual property.  Our business is subject to legislative and regulatory requirements at the federal, state and local levels and changes to rules can have a significant impact on our shareholders, customers, employees and communities.  Our U.S. federal and state government affairs team represents our company on important policy issues before Congress, the Administration, regulators, and state and local governments across the United States.

In addition to our company’s advocacy efforts, Whirlpool participates in the political process through the Whirlpool Corporation Political Action Committee (WCPAC) and through corporate political contributions in those jurisdictions where it is permissible to do so.

Whirlpool maintains comprehensive compliance procedures to ensure that its activities are conducted in accordance with all relevant laws governing political contributions and lobbying activities.  Additionally, as part of its oversight role, the Board of Directors annually reviews the company’s Code of Ethics, which addresses the company’s policies and practices related to political contributions.

Whirlpool quarterly files reports with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives detailing its lobbying activities.  Copies of these filings are available at www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm.

Whirlpool Corporation Political ContributionsFederal U.S. law prohibits companies from contributing to candidates for federal offices, but many states allow corporate contributions to state and local candidates, committees, political organizations and ballot issue campaigns.  As described in our Code of Ethics, neither Whirlpool nor its representatives may make political party or candidate contributions on behalf of the company except as specifically authorized by the Whirlpool Law and Government Relations Departments, and as permitted under local law.  Any such contributions with company funds require prior approval from the Whirlpool Law Department.

Federal election law allows corporations to establish Political Action Committees (PACs), which may make contributions, to federal candidates, state candidates (as permitted by law) and other committees.  The WCPAC is supported solely by voluntary contributions from Whirlpool employees.  WCPAC is regulated by the Federal Election Commission (FEC).  WCPAC files regular reports with the FEC and the relevant state election commission on its receipts and disbursements.  Reports filed with the FEC are available to the public at www.fec.gov. 

Decisions regarding WCPAC contributions are made by the board of directors of the WCPAC, which is comprised of nine Whirlpool employees.  Corporate political contributions are determined by Whirlpool management responsible for the company’s government affairs.  

WCPAC uses six criteria to evaluate a candidate before PAC dollars are contributed:

• Pro-business philosophy
• A favorable voting record or position on key issues of importance to Whirlpool.
• Constituent relationship with Whirlpool
• Campaign finance need
• Chances of winning and closeness of race
• Committee affiliation

In 2009, WCPAC contributed $37,500 to the following federal and state candidates in the United States.

At times Whirlpool Corporation contributes, under legal guidelines, to local and state candidates or ballet issues that have an impact on the company or are deemed in the best interest of the local communities in which we operate.  These contributions are in keeping with the values of our company and are consistent with our political policies.

In 2009, Whirlpool Corporation did not contribute to any state or local political candidates or initiatives. 

Trade AssociationsWhirlpool belongs to a number of trade associations at the national, state and local level.  Our company’s position on public policy issues are often communicated through these organizations, which enables us to reach government officials more efficiently and in concert with industry partners.  We do not always agree with the positions taken by these trade associations and we regularly communicate our specific position on a wide range of issues and policies.

For each association from which Whirlpool receives a notice that the association has or will spend at least $25,000 or more than 10 percent of Whirlpool Corporation’s payments in a fiscal year on non-deductible lobbying and/or political expenditures under Internal Revenue Code Section 162(e), we will ask the trade association to identify the portion of those payments used in connection with participation or intervention in a political campaign on behalf of (or in opposition to) any candidate for political office, as defined under Subsection 162(e)(1)(B) of the Code. 

For fiscal year 2009, the following trade associations used more than $25,000 or more than 10 percent of our membership payments on non-deductible lobbying and/or political expenditures:

Contributions to 527 OrganizationsWhirlpool Corporation occasionally supports organizations operating under section 527 of the Internal Revenue Code.  527 organizations are U.S. tax-exempt organizations created primarily to influence the nomination, election, appointment or defeat of candidates for public office. 

Whirlpool Corporation made no contributions to any 527 organizations in 2009. 

In fiscal year 2008, Whirlpool made a one-time contribution of $100,000 to Fix Housing First (www.fixhousingfirst.com).