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.

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.

This Code formalizes Whirlpool’s practices and makes clear that, recognizing differences in cultures and legal requirements, we expect that wherever our products and the components that comprise them are produced, they are produced in a manner compatible with the high standards that contribute to the outstanding reputation of Whirlpool and our brands. Suppliers are required to comply with this Code and to have and maintain practices similar to those in the Whirlpool Code of Ethics (available at www.whirlpoolcorp.com).

This Code applies to all facilities involved in the production of products and components for Whirlpool or any of its subsidiaries (“Whirlpool Suppliers”).

Whirlpool strongly encourages suppliers to exceed the requirements of this Code and promote best practices and continuous improvement throughout their operations. If there is no local legal requirement, or if a local legal requirement is not as strict as the requirement included in this Code, Whirlpool Suppliers are required to follow the requirement in this Code.

Laws and Regulations
Whirlpool Suppliers must operate in full compliance with all applicable laws and regulations of the countries in which they operate, and also in full compliance with this Code.

Child Labor
Whirlpool Suppliers must comply with local laws regarding the minimum age of employees. The minimum age for workers must be the greater of: (a) 15 years of age or 14 years of age where the local law allows such an employment age consistent with International Labor Organization guidelines; or (b) the age for completing mandatory (compulsorily) education; or (c) the minimum age established by law in the country of manufacture.

In addition, Whirlpool Suppliers must comply with all legal requirements for the work of authorized young workers, particularly those pertaining to hours of work, wages, working conditions, and the handling of certain materials.

Forced Labor
Whirlpool Suppliers must not use any type of involuntary or forced labor, including indentured, bonded, or prison labor.

Harassment
Whirlpool Suppliers must treat all workers with respect and dignity. No worker shall be subject to corporal punishment, physical, sexual, psychological or verbal harassment or abuse. In addition, Whirlpool Suppliers will not use monetary fines as a disciplinary practice.

Wage and Benefits
Whirlpool Suppliers must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers must be paid for overtime hours at such premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly payment rate.

Hours of Work
Whirlpool Suppliers must ensure that on a regularly scheduled basis, except in extraordinary business circumstances, workers are not required to work more than (a) 60 hours a week, including overtime, or (b) the limits on regular and overtime hours allowed by the law of the country of manufacture. In addition, except in extraordinary business circumstances, all workers are entitled to at least one day off in every seven day period.

Health and Safety
Whirlpool Suppliers must provide workers a clean, safe and healthy work environment in compliance with all legally mandated standards for workplace health and safety in the countries in which they operate. This includes any residential facilities a Whirlpool Supplier provides to its workers.

Nondiscrimination
Whirlpool Suppliers must ensure employment – including hiring, payment, benefits, advancement, termination and retirement – is based on ability and not on beliefs or any other personal characteristics.

Women’s Rights
Whirlpool Suppliers will ensure women workers receive equal treatment in all aspects of employment. Pregnancy tests will not be a condition of employment and pregnancy testing – to the extent provided – will be voluntary and the option of the worker. In addition, workers will not be forced to use contraception.

Freedom of Association and Collective Bargaining
Whirlpool Suppliers must recognize and respect any rights of workers to exercise lawful rights of free association, including joining or not joining any association. Whirlpool Suppliers also must respect any legal right of workers to bargain collectively.

Environment
Whirlpool Suppliers must comply with all local environmental laws applicable to the workplace, the products produced, and the methods of manufacture. Additionally, Whirlpool Suppliers must not use materials that are considered harmful to the environment.

Subcontracting
Whirlpool Suppliers must not use subcontractors in the manufacture of Whirlpool products or product components without prior approval from Whirlpool, and only after the subcontractor has agreed to comply with this Supplier Code of Conduct. Whirlpool Suppliers must ensure that any subcontractor used has ethical and business practices that are similar to Whirlpool’s practices.

Communication
Whirlpool Suppliers must communicate this Code and its provisions to workers and supervisors.

Monitoring and Compliance
Whirlpool will take affirmative measures, such as announced and unannounced inspections of production facilities, to ensure compliance with this Code. Whirlpool Suppliers must maintain at each production facility all documents necessary to demonstrate compliance with the Code. Whirlpool Suppliers must allow representatives from Whirlpool and, if requested, Whirlpool’s customers, full access to production facilities, worker records and workers for confidential interviews.

Whirlpool Suppliers are expected to take necessary corrective actions to promptly remedy any identified noncompliance. Whirlpool reserves the right to terminate its business relationship with any Whirlpool Supplier who is unwilling or unable to comply with this Code.