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 2014, 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.
At a summary level, the following steps have been followed [see Report for comprehensive list]:
- Plan and Implement Management Systems:
- Developed and published a Conflict Minerals Policy Statement (the “Policy Statement”) and began establishing internal management systems to support supply chain due diligence.
- Established and continue to enhance an internal management system where senior management having the necessary expertise, knowledge and experience oversees the supply chain due diligence process
- Established Conflict Minerals Steering Committee (the “Steering Committee”) comprised of representatives from multiple internal organizations, including Procurement, Legal, Communication, Global Information Systems, Internal Audit, and our Controller’s Office.Established a global Project Management Organization (“PMO”), which includes representatives from each of Whirlpool’s reportable segments, to support the Steering Committee
- Assess Supply Chain Risk
- Identified suppliers whose products we considered in-scope and subject to the Reasonable Country of Origin Inquiry (“RCOI”).
- Identified the risks in its product supply chain by using a global risk-based scoping approach to assess the likelihood of 3TG mineral presence in commodities, parts or components included in its products.
- Defined strategy and developed guidelines and procedures to conduct RCOI and due diligence on suppliers of commodities, parts and components that were determined to have a higher likelihood of containing 3TG minerals to respond to risks identified through the scoping approach.
- Sent communication letters to notify the suppliers of the RCOI and due diligence efforts, the revisions to the Supplier Code of Conduct, and Whirlpool’s expectations from the suppliers.
- Used the Conflict Minerals Reporting Template (“Template”) issued by the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative (EICC-GeSI) and a survey tool to facilitate our due diligence efforts.
- Collected detailed information from the suppliers who reported 3TG minerals originating in the DRC Zone.
- Design and Implement the Due Diligence Process
- Designed guidelines and procedures to be followed if Whirlpool identified risks that a supplier sources 3TG minerals from the DRC Zone.
- Started institutionalizing the conflict minerals compliance program by developing a standard operating procedure and establishing transparency over the supply chain, rolling out the procedure to identified business units and identifying and prioritizing improvement opportunities.
- Publicly Report on Our Supply Chain Due Diligence
- Submitted the “Whirlpool Conflict Minerals Report for the Year Ended 2014” to the SEC on May 29, 2015.
What did Whirlpool Find through this Process?
Whirlpool received survey and due diligence responses from the majority of our surveyed suppliers. This process has provided us with a deeper understanding of our supply base and the source of 3TG minerals that our suppliers purchase. However, overall, we have insufficient information for the 2014 calendar year regarding whether our products — laundry appliances, refrigerators and freezers, cooking appliances, dishwashers, mixers and other portable household products, and hermetic compressors for refrigeration systems — contain 3TG minerals that directly or indirectly financed or benefited armed groups in the DRC Zone.
What is Whirlpool Continuing to Do?
To mitigate the risk that funds for 3TG minerals will benefit armed groups and to identify the origin of those minerals, Whirlpool continues to perform its supply chain due diligence measures for suppliers of commodities, parts or components deemed to have high likelihood of containing 3TG minerals, and began to perform its supply chain due diligence measures for suppliers of commodities, parts or components deemed to have medium or low likelihood of containing 3TG minerals.
In addition, we continue to implement the relevant conflict minerals provisions in our revised Supplier Code of Conduct, and continue our efforts to institutionalize the conflict minerals compliance program by developing a standard operating procedure and establishing transparency over the supply chain, 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.