Our values—Integrity, Respect, Inclusion and Diversity, One Whirlpool and Spirit of Winning—form the enduring character of our company and are an important part of our heritage. They are the moral compass for everything we do. If Our Enduring Values of Integrity, Respect, Inclusion and Diversity, One Whirlpool and Spirit of Winning are the foundation of who we are as a company, then our culture for more than 100 years is reflected in our commitment to Winning with Integrity, because “how we achieve success is equal to if not more important than the success we achieve.” This quote by our Chairman and CEO Marc Bitzer encapsulates who we are, what we stand for and forms the foundation for our Global Ethics and Compliance Program.
Whirlpool Corporation’s Global Ethics and Compliance Program is focused on enhancing and sustaining our culture of winning with integrity, empowering employees with tools and resources to act with integrity, within a risk-based framework. Our program puts our Integrity value at the forefront and empowers our employees to keep it there. A cornerstone of our program is Our Integrity Manual, or code of ethics.
The Global Ethics and Compliance Program is overseen by Whirlpool Corporation’s Board of Directors, Audit Committee of the Board, as well as by a Global Ethics and Compliance Steering Committee, which is comprised of the CEO and Chairman of the Board, Chief Financial Officer, Chief Legal Officer, Chief Human Resources Officer, Vice President of Internal Audit and Chief Compliance Officer. The Global Ethics and Compliance Steering Committee helps set the tone for ethics and compliance at Whirlpool Corporation by leading ethics, compliance and integrity initiatives and providing strategic direction to our Global Ethics and Compliance Team, which includes ethics and compliance professionals across the globe, closely embedded within our regional and functional teams.
Whirlpool Corporation’s Global Ethics and Compliance Program is focused on enhancing and sustaining our culture of winning with integrity, empowering employees with tools and resources to act with integrity, within a risk-based framework.
Our commitment to winning with integrity is also reflected by strong cross-functional leadership and partnerships between the Global Ethics and Compliance Team and partners such as Internal Audit, Human Resources, Information Security, Data Privacy, Product Safety, Global Sourcing, and other teams. These partnerships permit us to leverage resources to sustain program integrity and functionality. With clear ownership of compliance risks and related policies, procedures and systems, our Global Ethics and Compliance program encourages all of us to participate and play a key role in our culture of integrity.
Additional critical components of our Global Ethics and Compliance Program are risk-based ethics and compliance communications and training, including annual training on all of the principles in Our Integrity Manual. This training, where employees certify that they have reviewed and understand Our Integrity Manual, was delivered to 57,000 employees as part of the Integrity Manual launch in 2019, and 20,933 employees in 2020 and 19,570 employees in 2021 through refresher trainings, including 100% participation by employees in high risk roles or functions.
In 2021, undeterred by the continuing global pandemic and focused on the importance of our integrity value and the How of what we do, we delivered Global Integrity Week, during which our teams delivered targeted trainings over one week in July on our most critical risk areas and to our high-risk roles, including 49 interactive, virtual trainings to more than 12,000 employees across 40 countries and more than 250 cities. With 100% participation from our Executive Committee in various trainings and participation from global leaders ranging from managers to vice presidents, the dynamic trainings, videos, communications and educational materials and resources delivered by internal and external subject matter experts, advanced our culture, empowered our employees and enabled our colleagues to achieve success the right way.
Global Integrity Week
TOPICS OF DISCUSSION
(GSS & GPO)
With 69,000 employees and thousands of third-party business relationships, Whirlpool Corporation continually and systematically reviews compliance risks our business faces. We are aware of these risks and take proactive actions to respond to them. Whether through risk-based audits, managing our global third-party due diligence program or implementing and sustaining integrity channels that aid our employees to speak up, listen up and/or seek support, the Global Ethics and 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 and listening up is the responsibility of all of us. Our integrity channels serve as resources our employees can use to ask questions or raise a concern. Through our integrity channels, including Our Integrity Line, or hotline, we ensure that our employees will be listened to and heard.
Global Integrity Line
The Global Integrity Line is a confidential resource that allows individuals to raise good-faith ethics, compliance and values-related questions or concerns without fear of retribution or retaliation, and to do so anonymously at the reporter’s election. The Global Integrity Line can be accessed in several ways, both externally and internally, and is administered by an independent third party with translation capabilities. All matters raised through the Integrity Line are reviewed and investigated appropriately by the Global Ethics and Compliance Team pursuant to defined processes that include confidentiality and anti-retaliation policies. Throughout the review or investigation of a report, and following its conclusion, all matters that are raised are kept confidential. No aspect of a matter is made known except to a select and limited number of authorized individuals. The Global Ethics and Compliance Team reviews reporting trends and investigation results with both the Global Ethics and Compliance Steering Committee and Regional Ethics and Compliance Committees comprised of senior leaders.
All matters raised through the Integrity Line are reviewed and investigated appropriately by the Global Ethics and Compliance Team pursuant to defined processes that include confidentiality and anti-retaliation policies.
The Global Integrity Line is regularly publicized to employees as part of annual ethics and compliance communication plans and during global and regional training. These communications are delivered through multiple platforms and delivery channels within Whirlpool Corporation, and training is provided globally by ethics and compliance professionals and other cross-functional partners (e.g., Internal Audit, Finance, Human Resources, Inclusion & Diversity).
In 2021, Whirlpool Corporation had 744 total cases globally raised through the Integrity Line, which is a 15.1% increase in the total number of average cases raised over the previous three years. The increased reporting results from recent efforts to foster and encourage a “Speak Up” and “Listen Up” culture amongst employees. During 2021, we reduced the average days to close Integrity Line cases by more than 10% leading to an average closing time of 47 days, in line with industry standards. We also took corrective actions on substantiated cases. The unsubstantiated cases provided us opportunities to enhance our controls, processes and procedures or provide training and ensure a strong ethics and compliance culture. Through using continuous improvement strategies, enhanced coordination with cross-functional partners like HR, IA, GSS, and others, and strengthened governance and coordination among the Global Ethics and Compliance team, we have been able to improve our investigation processes, procedures and ability to respond to issues and concerns raised by colleagues.