Whirlpool Corporation is strongly committed to complying with antitrust laws around the world. The company has a robust antitrust compliance program that involves every level of the company and includes mandatory antitrust policies; compliance procedures and controls; an extensive training program; and processes for periodic review, monitoring and auditing. We regularly update our antitrust compliance program to address changing business conditions, developments in antitrust law and enforcement and emerging risks.

• Board oversight
• Senior leadership oversight
• Employee training
• Enforcement program
• Public policy and/or commitment

We do business the right way. This means that we do not tolerate bribery or corruption of any kind. Moreover, it means we actively adhere to this principle in all aspects of our business. With leadership driven by our Executive Committee, the Global Ethics and Compliance Steering Committee and Global Ethics and Compliance Team, and leveraging global and cross-functional resources, we use an anti-corruption program to identify and mitigate potential corruption risks. This includes our global third-party due diligence program, which is applicable to all of Whirlpool Corporation's third-party relationships and is used to assess potential ethics and compliance risks, including risks of corruption, as well as our Integrity Line where cases that may involve allegations of corruption and bribery are investigated when received and are reviewed with leadership on a quarterly basis.

• Board oversight
• Senior leadership oversight
• Cross-functional committee
• Employee training
• Enforcement program
• Public policy and/or commitment

We work hard to earn and keep the trust of our stakeholders. To this end, we continue to invest in managing cybersecurity risk, protecting our information assets and ensuring the integrity of our computing environment at the enterprise level. Our security monitoring and incident response functions are managed centrally by our Global Security Operations Center, and we continue to mature our defensive security capabilities in support of our business imperatives.

Our Board is responsible for overseeing and holding senior management accountable for our global information security program. This includes understanding our business needs and associated risks and reviewing management’s strategy and recommendations for managing cybersecurity risks. In line with this oversight responsibility, the Audit Committee receives reports on cyber program effectiveness periodically; the Board of Directors receives a full presentation at least annually on cybersecurity-related trends and program updates; and the Global Cybersecurity and Privacy Steering Committee meets periodically to help ensure information security risks and vulnerabilities are being appropriately managed and mitigated. Our Cybersecurity program, governed by our Global Information Security Officer and executed by the Cybersecurity Team, is guided by the National Institute of Standards and Technology (NIST) Cybersecurity Framework as the foundational baseline for Whirlpool Corporation cybersecurity practices.

We educate our employees on information security and breach response through our annual Global Cybersecurity training.

• Board oversight
• Senior leadership oversight
• Employee training
• Enforcement program
• Public policy and/or commitment

Whirlpool is committed to data protection and makes every effort to meet all compliance obligations. We prioritize privacy and are transparent about the data we collect and how it is used. We are committed to safeguarding our stakeholders’ information through robust measures and ensuring compliance with all relevant legal standards. We do not sell or share any personal data except as permitted by law. Consumers can opt out of any data sale or sharing through our website.

Our privacy program, led by our Global Data Protection Officer and implemented by the Privacy Team, operates under comprehensive global policies, procedures and best practices. It incorporates training, awareness initiatives, risk assessments and management controls to ensure all information shared with us is processed in compliance with applicable legal requirements and global standards. Oversight of this program is provided by our Global Cybersecurity & Privacy Steering Committee, which ensures its continuous improvement and alignment with organizational priorities.

To enhance efficiency and effectiveness, we leverage technical solutions to automate key aspects of our privacy program, operationalize its implementation through detailed processes and procedures and subject these to regular audits.

Whirlpool Corporation’s third-party risk management process assesses the data privacy risks associated with engaging third parties and suppliers. This process aims to analyze the third-party privacy program and ensure adequate level of protection, matching that of Whirlpool standards. Our Privacy Notice for suppliers further outlines our data handling practices and ensures transparency in how supplier data is managed.

We actively monitor global legal and regulatory developments to stay ahead of emerging privacy requirements and continually review our privacy practices to ensure compliance with all relevant privacy laws and regulations.

• Board oversight
• Senior leadership oversight
• Cross-functional committee
• Employee training
• Enforcement program aligned with international standard [ISO 27001]
• Subject to external verification/audit
• Public policy and/or commitment

Whirlpool Corporation strives to protect our employees, preserve the environment and ensure physical security throughout our business operations. We are committed to meeting or exceeding all applicable laws and regulatory requirements in the countries and jurisdictions in which we operate.

• Board oversight
• Senior leadership oversight and responsibilities
• Employee training
• Public policy and/or commitment

Whirlpool Corporation is dedicated to achieving global leadership in all of our product categories. We have built our Executive Compensation programs around a strong pay-for-performance philosophy. Each member of our Executive Committee has elements of our environmental, social and governance priorities included in their individual objectives for the purposes of individual performance ratings, which influence each executive’s incentive compensation.

• Board oversight
• Senior leadership oversight
• Public policy and/or commitment

Whirlpool Corporation supports human rights in everything we do, and our business practices reflect our commitment to ensure every person who works for us throughout all of our global operations does so of their own free will, in a safe and healthy environment. Whirlpool supports the human rights of everyone we work with and expects our global business partners to do the same. We oppose discrimination, slavery and child labor and have controls and protections to avoid them. We are committed to creating and maintaining an inclusive working environment that values diversity and protects the right of each employee to fair and equitable treatment. Further, we respect the rights of our employees to associate with whom they choose.

In addition to our internal commitment to human rights, we strive to hold our suppliers and business partners accountable to comply with these same principles through our Supplier Code of Conduct (SCoC). Moreover, our Integrity Line can be used both internally and externally to bring concerns about human rights issues to our attention. In 2024, no instances of child labor were found in any of the audited supplier facilities.

• Board oversight
• Senior leadership oversight
• Employee training
• Enforcement program
• Public policy and/or commitment

Whirlpool Corporation respects the rights of our employees to associate with whom they choose. We estimate that, during 2024, 50% of our hourly employees globally were covered by a collective bargaining agreement.

As outlined in Whirlpool Corporation's SCoC, our suppliers must recognize and respect any rights of workers to exercise lawful rights of free association and bargain collectively. Through our SCoC audits, Whirlpool did not have any instances in 2024 in which our suppliers violated freedom of association or collective bargaining.

• Senior leadership oversight
• Public policy and/or commitment

Whirlpool believes that respectful, professional conduct furthers the company’s mission, promotes productivity, minimizes disputes and enhances our reputation. We expect every employee to show respect for all of our colleagues, consumers and vendors. Harassment by co-workers, supervisors or any third parties is a form of misconduct that destroys our work environment and undermines the integrity of the employment relationship. We are committed to providing a work environment that is free from unlawful discrimination, including harassment that is based on any legally protected status. Whirlpool will not tolerate any form of discrimination or harassment that violates this policy.

• Senior leadership oversight
• Employee training
• Enforcement program
• Public policy and/or commitment

Whirlpool Corporation’s compensation programs are designed to support our focus on creating sustainable value for all our stakeholders. Our objective is to provide a total compensation opportunity that is competitive with external market practices, considers internal equity and provides a true pay-for-performance approach. We evaluate external market competitiveness and internal equity at least annually, and our actual pay outcomes have been demonstrated to align with the performance results that we have delivered. Regardless of employees’ gender or background, we provide the same career and remuneration opportunities. All employees have equal access to the compensation and benefit programs that are relevant to their roles in the company.

On an annual basis in many countries, we complete a pay equity practices review by an external law firm that examines pay between employees of different gender and racial demographics doing similar work. We intend to continue to engage in this pay practice review process on a regular basis in an effort to uphold our compensation principles and our commitment to global pay equity.

• Board oversight
• Senior leadership oversight
• External verification
• Public policy and/or commitment

Whirlpool Corporation is committed to complying with all legal and regulatory requirements applicable to its products and operations. To fulfill this goal, we have developed a number of global and regional policies and procedures for promoting business compliance, including the development of a management system for implementing and promoting compliance to our global policies, maintaining appropriate documentation and implementing periodic and independent audits of our product compliance management system.

Through our Global Issue Action Teams, regional policy and regulatory steering committees and our government relations and regulatory affairs teams, we aim to drive thoughtful and sustainable policy outcomes on a variety of issues important to our company, including energy, environment, climate change, technology, product safety, trade, taxes, affordable housing and intellectual property. All lobbying activities and expenditures, as well as trade and professional association engagement, are reviewed on an annual basis by the Whirlpool Corporation Executive Committee and by the Corporate Governance and Nominating Committee of the Whirlpool Corporation Board of Directors that provides alignment with company values and priorities.

• Board oversight
• Senior leadership oversight
• Cross-functional committee(s)
• Enforcement program
• Public policy and/or commitment

Our global tax principles are based on the company’s overall core values; thus, we seek to manage our tax obligations in a responsible way. We seek to comply with both the letter and intent of tax laws. We understand that tax is an important component of our overall corporate social responsibility and recognize that taxes we pay are critical to the orderly function of civil society and support the communities in which we operate.

• Board oversight
• Senior leadership oversight
• Public policy and/or commitment