This Whirlpool Corporation Supplier Code of Conduct ("Code") formalizes the key principles under which suppliers to Whirlpool Corporation and its global subsidiaries ("Whirlpool") are required to operate.
Whirlpool established its Supplier Code of Conduct in 2006, formalizing key ethical principles under which our suppliers are required to operate. In selecting suppliers, Whirlpool works hard to choose reputable business partners who are committed to ethical standards and business practices compatible with those of Whirlpool. One tenet of that Supplier Code of Conduct is that Whirlpool Suppliers must not use any type of involuntary or forced labor; this prohibits, among other things, slave labor or business practices which in any way rely on, or encourage, human trafficking. Our Code of Conduct also requires suppliers to comply with all applicable local laws in the country or countries in which they operate.
Whirlpool is presently developing e-learning courses for our sourcing professionals to educate them on the requirements of our Supplier Code of Conduct. We anticipate rolling out these courses in the second quarter of 2012. This year, in addition to requesting our suppliers to certify their compliance with our Code of Conduct, we plan on undertaking sample independent audits of our suppliers’ practices.
A material failure to comply with our Code of Conduct may result in the termination of our relationship with a supplier, as may be permitted by applicable law.
Introduction to Conflict Minerals
Whirlpool is committed to complying with federal laws and regulations requiring disclosure of the use of conflict minerals.
The term “conflict minerals” refers to certain identified minerals that may have directly or indirectly contributed to the financing of armed groups in the Democratic Republic of Congo (DRC) and neighboring countries.
In August 2012, as required by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“the Dodd-Frank Act”), the U.S. Securities and Exchange Commission (“SEC”) approved the final rule (“Conflict Minerals Rule”) on the disclosure of conflict minerals. This rule requires publicly traded companies subject to SEC regulation to annually report the presence of conflict minerals that are necessary to the functionality or production of products they manufacture or contract to manufacture. Companies subject to the Conflicts Minerals Rule must exercise due diligence on the source and chain of custody of conflict minerals if they know or have reason to believe that the conflict minerals originated from the DRC region or if they know or have reason to believe the conflict minerals may not be from recycled or scrap sources.
Columbite-tantalite, cassiterite, wolframite and gold ores – which are refined into tantalum, tin, tungsten and gold, respectively – are considered to be conflict minerals. The metals ultimately derived from conflict minerals are used in a wide variety of consumer products, and Whirlpool is currently investigating – in cooperation with our supply base - where these may be found in our products worldwide.
What is Whirlpool Doing?
Whirlpool is taking action to develop robust due diligence processes and to educate and seek information from our suppliers to ensure compliance with federal laws and regulations. The first SEC report must be filed by May 31, 2014 for the 2013 calendar year.
Whirlpool is basing its due diligence processes, in part, on the guidance provided by the Organisation for Economic Co-operation and Development (OECD). The framework of the OECD provides practical guidance to companies on a set of actions that can be taken throughout its supply chain to ensure responsible due diligence. Whirlpool has established a global team, reporting to executive leadership, to work through the OECD framework and is developing a plan to address each of its focus areas.
Whirlpool will provide updates as this process moves forward regarding its plans and actions to comply with SEC conflict mineral requirements and associated timelines.