Global Ethics & Compliance Program Operations
Whirlpool Corporation’s Global Ethics & Compliance Program is designed with a comprehensive risk-based framework that is sustained through the efforts of a committed global team, policies, procedures, and systems for sustaining organizational integrity.
Oversight of the Global Ethics & Compliance Program is governed by the Global Ethics & Compliance Steering Committee (“E&C SteerCo”), composed of members of the Executive Committee, including our Chairman and CEO. The E&C SteerCo sets the tone for ethics and compliance at Whirlpool Corporation, and oversees the program.
This commitment to winning with integrity is also reflected by strong cross-functional leadership and partnerships between Compliance professionals and partners such as Internal Audit, Human Resources, Product Safety, Global Sourcing, and other teams. These partnerships permit Whirlpool Corporation to leverage resources to sustain program integrity and functionality. With clear ownership of compliance risks and related policies, procedures, and systems, and by principle, our ethics and compliance program encourages all of us to participate and play a key role in our culture of integrity.
Another critical component of the Global Ethics & Compliance Program are the risk-based ethics and compliance communications and training, including training on all of the principles of Our Integrity Manual, which during 2019 was delivered to virtually all employees globally. For example, in 2019, 99% of approximately 13,000 employees globally representing high-risk roles or functions completed the Annual Ethics & Compliance Certification, wherein they certified their review and understanding of our Global Compliance Policies, including our anti-corruption policy. Of the 13,000, 1,000 represented employees at the Director level and above with 100% completion.
With over 77,000 employees and thousands of third-party business relationships, Whirlpool Corporation continually and systematically reviews compliance risks its business faces. We are aware of these risks, and, continually and systematically take proactive actions to respond to them. Whether through risk-based audits, managing the global third-party due diligence program, or implementing Integrity Channels that aid our employees to speak up and/or seek support, the Ethics & Compliance Program brings all of its operations and resources to bear to advance Whirlpool Corporation’s culture of integrity.
We encourage our employees to ask questions and voice concerns. As stated in Our Integrity Manual, speaking up is our responsibility. Our Integrity Channels serve as resources our employees can use to ask questions or raise a concern. Through our integrity channels, including our global hotline, which we call our Integrity Line, we ensure that our employees will be listened to and heard.
Our global Integrity Line is administered by an independent third party, and translated into 16 languages, that can be accessed in several ways externally and internally for reporting of concerns about potentially unethical or unlawful behavior of any employee, or raising questions about ethics and compliance matters. Whirlpool Corporation also has Regional Compliance Professionals embedded within Whirlpool Corporation’s global locations, that lead cross-functional teams ensuring in-person advice, strategic legal and compliance counseling, training, and guidance on doing business with integrity.
integrity
respect
inclusion & Diversity
one whirlpool
spirit of winning
