Supplier Code of Conduct / Supply Chain Transparency
This Whirlpool Corporation Supplier Code of Conduct (the “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, reflecting our fundamental expectations. The principals in the Code state Whirlpool’s expectation for its Suppliers on identified business practices.
In selecting suppliers, Whirlpool seeks to do business with reputable business partners who are committed to ethical standards and business practices compatible with those of Whirlpool. This Code applies to all suppliers of Whirlpool including all of the Whirlpool Suppliers’ facilities. Whirlpool strongly encourages suppliers to exceed the requirements of this Code and promote best practices and continuous improvement throughout their operations.
Whirlpool expects its Suppliers to act responsibly in all respects and to ensure that no abusive, exploitative or illegal conditions exist in their supply chains. Whirlpool requires that Suppliers comply with all applicable laws and regulations, as well as the principles set out in the Code. One tenet of this 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. Where 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.
Whirlpool has established e-learning courses for our sourcing professionals to educate them on the requirements of our Supplier Code of Conduct. Our Code of Conduct and our training programs undergo review and are refreshed and updated from time to time to reflect changes in circumstances. In addition to requesting our suppliers to certify their compliance with our Code of Conduct, we have engaged a third party agency who has conducted, and will continue to conduct, independent audits of a sampling of our suppliers’ practices. Material failures to comply with our Supplier Code of Conduct may result in the termination of our relationship with a Supplier, as may be permitted by applicable law.
Whirlpool’s Suppliers are vital business partners, and together, these principles provide us with an opportunity to better the lives of the people we touch.
WHIRLPOOL’S PERSPECTIVE ON ADDRESSING CONFLICT MINERALS
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 has Whirlpool Done to Date?
Whirlpool has developed a conflict mineral due diligence framework that conforms with the internationally recognized due diligence framework developed by the Organisation for Economic Co-operation and Development (“OECD”). Per SEC guidelines, we have also filed the Whirlpool Corporation Conflict Minerals Report for the Year Ended 2015, available at the link below:
Our conflict minerals due diligence framework is based on the following steps: plan and implement management systems; assess supply chain risk; design and institutionalize the due diligence process; and publicly report on our supply chain due diligence. Each of these steps is described in detail in the Conflict Minerals Report.
For 2015 calendar year, Whirlpool took a number of actions to support responsible in-region 3TG sourcing, including the following:
- We continued to enhance follow-up procedures and performed due diligence measures to improve the transparency over the supply chain and increase our supplier response rates;
- We established a process to gather smelter information from the Conflict Free Sourcing Initiative (CFSI) on a continuous basis to validate the status of smelters and refiners identified by our suppliers, which helped us identify the percentage of suppliers on our smelter list that are CFSI compliant;
- We actively participated in CFSI, the multi-stakeholder group convened by the Responsible Sourcing Network (RSN), and other industry groups to support solutions aimed at improving supply chain transparency; We continued to monitor leading practices of peer companies to enhance our conflict minerals program;
- We implemented a process to identify new direct suppliers of Whirlpool and of acquired entities to include them in the RCOI efforts; and
- We created further awareness within the organization regarding conflict minerals compliance by providing training to various groups including but not limited to procurement, sales and marketing and finished product sourcing.
What did Whirlpool Find through this Process?
We have evaluated our global supply chain and surveyed 100% of our in-scope suppliers to understand potential risks in their supply chains, organized and analyzed their responses and have filed an annual Conflict Minerals Report to share our due diligence process.
While our continued efforts in 2015 have not provided us with enough information to conclusively determine whether our products contain 3TG that directly or indirectly financed or benefited armed groups in the DRC Zone, our efforts in 2015 have improved supply chain transparency and created further awareness within the organization regarding conflict minerals compliance that will allow us to further improve due diligence and mitigate risk in 2016 and beyond.
As a result of these continued efforts in 2015, we are unable to determine if our products contain tin, tantalum, tungsten or gold that directly or indirectly financed or benefited armed groups in the DRC Zone.
Details of the process we have followed and the results to date can be found in the Whirlpool Conflict Minerals Report, and within our Conflict Minerals Policy, linked below:
What is Whirlpool Continuing to Do?
To further mitigate the risk that 3TG minerals in the supply chain benefit armed groups and to identify the origin of those minerals, Whirlpool continues to:
- Perform its supply chain due diligence measures to increase the number of suppliers responding to CMRT surveys and to obtain detailed information from suppliers that responded that they may be sourcing 3TG minerals from the DRC Zone;
- Improve transparency over the supply chain by collaborating with CFSI, as a member, to provide information on the smelters and refiners provided by our suppliers, that are not found in the CFSI list; and
- Institutionalize the conflict minerals compliance program by improving our standard operating procedure, rolling out the procedure to identified business units, and identifying and prioritizing improvement opportunities.
Whirlpool will provide updates as this process moves forward regarding its plans and actions to comply with SEC conflict mineral requirements and associated timelines.