Modern Slavery Report 2024

Introduction

This Modern Slavery Report (the “Report”) addresses the period from January 1, 2024, to December 31, 2024 (“Fiscal 2024”) and has been prepared in compliance with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the “Act”). This Report is made on behalf of WCGP Nova Scotia Co. and Whirlpool Canada LP (collectively, "Whirlpool Canada"). Whirlpool Canada are subsidiaries of Whirlpool Corporation, an American public company listed on the New York Stock Exchange (NYSE: WHR) and headquartered in Benton Harbor, Michigan. As subsidiaries of Whirlpool Corporation, Whirlpool Canada has adopted the Whirlpool Corporation's due diligence policies and practices further described in section 3 of this Report. “We” and “our” may refer collectively to Whirlpool Canada and/or to Whirlpool Corporation depending on the context.

Forced labour and child labour, each as defined in the Act, are crimes and serious violations of human rights. Whirlpool Canada recognizes the important role it has in ensuring that its operations and products, and the supply chains that support these, adhere to applicable laws and regulations, including the prevention and identification of forced labour and child labour in its supply chain. This Report sets out the steps Whirlpool Canada has taken during Fiscal 2024 to prevent and reduce the risk that forced labour or child labour is used at any step in the production of goods imported into Canada by Whirlpool Canada.

Our Business

Whirlpool Canada's history of operations in Canada dates back to 1859. Whirlpool Canada is a kitchen and laundry company headquartered in Mississauga, ON, with over $1 billion in annual revenues. The company has 213 employees and operates 750,000 square feet of warehousing and distribution in Milton, ON, and 425,000 square feet in Calgary, AB. Whirlpool Canada supplies approximately 1,100 retailers in over 3,500 locations across Canada. Its brands include JennAir, KitchenAid, Whirlpool, Maytag, Amana, Gladiator Garageworks, affresh cleaning products, everydrop water filters, and Swash detergents. Whirlpool Canada was again certified as a 2025 “Great Place to Work in Canada,” including recognition as one of the “Best Workplaces for Women” and “Most Trusted Executive Teams.”

Whirlpool Corporation has a comprehensive, globally applicable approach to mitigating the impact of forced and child labour in its supply chain. Whirlpool Corporation applies and undertakes its policies, procedures, and processes described in this Report to itself and its subsidiaries worldwide, including Whirlpool Canada. Management of Whirlpool Corporation's Global Strategic Sourcing (GSS) is organized centrally by Whirlpool Corporation. Whirlpool Canada follows and relies upon Whirlpool Corporation's policies, including those related to human rights, monitoring, auditing, and due diligence processes. Whirlpool Corporation implements these globally across its supplier base and carries them out on behalf of Whirlpool Canada and other subsidiaries. The efforts described in this Report are taken by Whirlpool Corporation on behalf of Whirlpool Canada.

Whirlpool Canada procures goods and services from approximately 30 direct suppliers, including Whirlpool Corporation. It procures finished products, including small appliances, as well as cooking, laundry, and refrigeration appliances from Whirlpool affiliates in the United States, Mexico, China, and the EU for sale in Canada. Further information about the business can be found in Whirlpool Corporation's 2024 Annual Report and 2024 Sustainability Report.

Our Policies and Due Diligence Processes

Policies

Through Whirlpool Corporation's organizational and governance policies, the company communicates its values and expectations, setting high standards for itself and its suppliers, and clearly prohibiting the use of forced labour or child labour. Whirlpool Canada is committed to consistently evolving and improving its approach, taking reasonable efforts, including due diligence and audits, to monitor the performance of its direct suppliers and prevent its activities from having a negative impact on human rights.

Supplier Code of Conduct (“Code”)

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. Suppliers must comply with all applicable laws and regulations, as well as the principles set out in the Code. A key tenet of the Code is that suppliers must not use any type of involuntary or forced labour, which prohibits slave labour or business practices that rely on or encourage human trafficking. Where local legal requirements are less strict than the Code, suppliers must follow the Code's requirements. Direct suppliers must ensure their own suppliers, service providers, and extended networks have in place and comply with ethical and business practices similar to Whirlpool's Code. Whirlpool updated its Code in 2024 to reflect its prohibition of suppliers requiring employees to pay recruitment fees.

Whirlpool Integrity Manual

Whirlpool supports human rights in all its activities and respects freedom of association and personal political involvement. Its business practices reflect a commitment to ensure every person working for Whirlpool Canada does so of their own free will, in a safe and healthy environment. The company opposes discrimination, slavery, and child labour, implementing controls and protections to avoid them. Whirlpool supports diversity and wage parity and respects employees' rights to associate and be involved in politics outside of work. The Whirlpool Integrity Manual clarifies that Whirlpool:

• Forbids forced or child labour and complies with global human rights and local laws regarding labour, time, and wages.
• Holds its suppliers and business partners accountable to comply with these same principles through its Code.

The Integrity Manual was updated this year to remain relevant and effective in supporting the commitment to acting with integrity. The updated manual specifically references Whirlpool's Global Human Rights Policy (GEP-14), adopted in 2022, to formally reflect Whirlpool's long-standing commitment to human rights.

Whirlpool Ethics & Compliance Program

Whirlpool works to mitigate risks through robust regular monitoring, governance, and audits of its supply base to ensure compliance with the Code. It further lowers supply chain risks by running independent background checks to ensure direct suppliers are reputable through its third-party due diligence program.

Due Diligence

Whirlpool expects third parties to adhere to business principles and values similar to its own and to comply with all applicable laws and regulations. Before making commitments, Whirlpool takes steps to appropriately evaluate relationships and mitigate associated risks through risk-based due diligence and checks.

Whirlpool acknowledges the risk of forced or child labour in its supply chain and has adopted an audit program to mitigate this risk.

Whirlpool Supplier Audit Compliance Program

Whirlpool Corporation has a history of combating forced labour in its supply chain through its well-established supplier audit program. This program incorporates recognized industry standards provided by:

• Responsible Business Alliance (“RBA”): a nonprofit coalition of leading companies dedicated to improving social, environmental, and ethical conditions in their global supply chain.
• Whirlpool is a member of the Responsible Minerals Initiative (RMI).
• amfori BSCI: a recognized methodology for identifying and remediating risks in global supply chains.
• Sedex (“Supplier Ethical Data Exchange”): an online system allowing suppliers to maintain data on ethical & responsible practices and share this information with customers.

As part of the onboarding process, all new direct suppliers must successfully pass a Supplier Code of Conduct audit (or equivalent) and third-party due diligence (TPDD) screening prior to being awarded work. Direct suppliers are contractually obligated to adhere to the Code, which prohibits the use of child or forced labour. Audits are performed against the Code, validating labour practices and other business practices. A majority of audits are performed on-site, with a smaller number conducted virtually when necessary due to site restrictions or travel hazards.

Existing direct suppliers are continuously monitored through various mechanisms, including annual audit plans based on criteria such as spend, location, and engagement strategy, as well as input from tools like TPDD screenings and Transparency International's Corruption Perception Index (CPI). Whirlpool does not tolerate suppliers with non-compliant findings in Human Rights (child labour, forced labour) or Business Ethics. Critical findings trigger swift responses, such as discontinuing business operations with an existing supplier or ceasing onboarding activities with a new direct supplier.

Assessing Our Risk

Whirlpool Corporation, on behalf of Whirlpool Canada and other subsidiaries, engages in activities to identify, assess, and manage supplier risk, including the risk of forced and child labour. Whirlpool Corporation has partnered with a third-party supply chain assessment company to provide end-to-end solutions for supply chain monitoring, including forced labour concerns, customized by sector, geography, and size. These reviews produce supplier scorecards with actionable ratings, audit results, and improvement management.

Whirlpool recognizes that the risk of forced or child labour is increased in parts of Asia and where labour and other laws are less stringent, including countries with elevated corruption risks (e.g., those ranking high in the Corruption Perception Index). The third-party supply chain assessment includes a labour & human rights risk mapping process focusing on two areas: (1) human rights issues, including child and forced labour, human trafficking, diversity, discrimination, harassment, and external stakeholder human rights; and (2) human resources, including health & safety, working conditions, structured social dialogue, career management, and training.

These assessments cover more than twenty sustainability criteria across four main themes: Environment, Labor & Human Rights, Ethics, and Sustainable Procurement. Criteria are based on international standards such as the UN Global Compact, ILO conventions, GRI standards, ISO 26000, CERES Roadmap, and UN Guiding Principles on Business and Human Rights. Assessments are analyzed by sustainability experts and verified using evidence-based methodologies based on ISO 26000.

Targeted suppliers are requested to complete and maintain an assessment within the third-party platform. The assessment provides insights into practices related to labour & human rights risks. Results are shared with Whirlpool Corporation's GSS Center of Excellence team for Code audits to determine if suppliers scoring low warrant an immediate additional audit. Ongoing monitoring ensures currency with any major changes affecting potential supplier issues. The third-party assessment complements Whirlpool Corporation's established audit and supplier oversight programs, illuminating supplier risks.

Our Commitments

At Whirlpool Canada, the company supports human rights in all its activities, ensuring every person working across its global operations does so of their own free will, in a safe and healthy environment. Whirlpool Canada supports the human rights of everyone it works with and expects its global business partners to do the same.

This commitment to human rights is based on the United Nations Global Compact principles, derived from the Universal Declaration of Human Rights and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work. This commitment is integrated throughout the Whirlpool Integrity Manual, Code, and other employee policies and procedures.

Whirlpool Corporation has a robust program to identify, assess, and manage supplier risk, including the risk of forced labour. As evidenced by its programs, Whirlpool takes reasonable efforts to identify, prevent, and reduce the risk of forced and child labour in its operations and supply chain.

Steps to Prevent and Reduce Risks of Forced and Child Labour

Among the steps taken are:

• Mapping supply chains.
• Conducting internal assessments of risks of forced labour and/or child labour in the organization's activities and supply chains.
• Contracting external assessments of risks of forced labour and/or child labour.
• Developing and implementing action plans for addressing forced labour and/or child labour.
• Gathering information on worker recruitment and maintaining internal controls to ensure workers are recruited voluntarily.
• Addressing practices that increase the risk of forced labour and/or child labour.
• Implementing due diligence policies and processes for identifying, addressing, and prohibiting the use of forced labour and/or child labour.
• Requiring direct suppliers to contractually commit to abiding by Whirlpool's Supplier Code of Conduct, child protection policies, and processes.
• Implementing anti-forced labour and/or child labour contractual clauses.
• Developing and implementing anti-forced labour and/or child labour standards, codes of conduct, and compliance checklists.
• Auditing direct suppliers.
• Monitoring direct suppliers.
• Enacting measures to provide for, or cooperate in, remediation of forced labour and/or child labour.
• Developing and implementing grievance mechanisms to address workplace complaints.
• Developing and implementing training and awareness materials on forced labour and/or child labour.
• Developing and implementing procedures to track effectiveness in addressing forced labour and/or child labour.

Remediation Measures

The Whirlpool's Integrity Manual encourages all employees and contract workers to report actual or possible misconduct. Multiple channels are provided for reporting potential misconduct, including a third-party managed anonymous hotline. Whirlpool has a zero-tolerance policy for retaliation against those who report potential or actual misconduct or violations of policies or applicable law.

Whirlpool Corporation undertakes diligence efforts on behalf of Whirlpool Canada to mitigate the risk of forced labour and child labour. In the event of discovering actual or potential forced labour or child labour, Whirlpool will investigate and remediate promptly. Disciplinary action may be taken against involved employees or suppliers, up to and including termination of employment or business relationships.

The approach is to prevent any forced labour situations through robust due diligence during supplier onboarding and continuous monitoring of vendors. Regular compliance screenings and on-site inspections ensure fair treatment of workers and supplier adherence to ethical standards. Whirlpool will not engage with new suppliers or will terminate existing suppliers that do not meet its high standards.

In 2024, no instances of forced or child labour were identified, and therefore no remediation measures were taken.

Training

Whirlpool Canada personnel at all levels are required to complete a mandatory certification process to ensure understanding and application of the Whirlpool Integrity Manual (Code of Business Conduct and Ethics). Employees receive ongoing and periodic training. While Whirlpool Canada's employee training did not explicitly include dedicated training on forced and child labour, Whirlpool Canada, with Whirlpool Corporation, is exploring reviewing training tools to include this topic. A module related to preventing forced and child labour has been included in the 2025 annual integrity certification course, which is approximately 30 minutes long and covers human rights topics, including definitions of forced labour and red flags. The course instructs employees to report signs of forced labor to the Legal Team or through Whirlpool's Integrity Line and is mandatory for all employees in Canada.

Our Progress and Effectiveness

Whirlpool Corporation's governance processes monitor compliance with policies on an ongoing basis and review concerns raised through the Integrity Line and other employee feedback mechanisms. Whirlpool Corporation's Senior Vice President for Global Strategic Sourcing regularly reviews the results of third-party due diligence and audits. Any identified non-conformance is handled by appropriate teams, with support provided to suppliers to resolve issues.

The effectiveness of policies is assessed by regularly auditing direct suppliers for compliance with the Code. The supplier due diligence process is subject to audit by Whirlpool Corporation's Internal Audit function. In 2024, the supplier due diligence process was reviewed by Internal Audit with no significant adverse findings. A total of 271 on-site audits were conducted for Whirlpool Corporation suppliers in 2024. In cases where non-compliances were identified, 100% had corrective action plans in place.

Approval & Signature

This Report was approved by WCGP Nova Scotia Co.'s Board of Directors on May 22, 2025, in accordance with section 11(4)(b)(ii) of the Act, and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada. The Report is also available on company websites:

• https://whirlpoolcorp.com/canada/
• https://whirlpoolcorp.com/canada-french/
• https://www.whirlpool.ca/en_ca/owners.html
• https://www.whirlpool.ca/fr_ca/owners.html

In accordance with the Act, the signatory attests to having reviewed the information contained in this Report for WCGP Nova Scotia, for itself, and on behalf of Whirlpool Canada LP, and that the information is true, accurate, and complete.

Gary Power
General Manager and Vice President
Date: May 22, 2025

Whirlpool Additional Information: This Report includes forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995. These statements are based on expectations and beliefs concerning future events and involve risks and uncertainties that may cause actual results to differ materially from current expectations. These risks and uncertainties may include regulatory changes and judicial developments relating to forced labour and child labour, changes in products or supply chains, and industry developments. Other risks and uncertainties are discussed in reports filed with the Securities and Exchange Commission. Forward-looking statements speak only as of their date, and Whirlpool disclaims any obligation to update or revise them.