Modern Slavery Report 2023

1. Introduction

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 that 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 taken during Fiscal 2023 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.

2. 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. It has 230 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 and Swash detergents. Whirlpool Canada was again recognized as a 2023 “Great Place to Work in Canada” including as one of the “Best Workplaces for Women.”

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 around the world, including Whirlpool Canada. Additionally, management over Whirlpool Corporation's Global Strategic Sourcing (GSS) is organized centrally by Whirlpool Corporation. As part of Whirlpool Corporation, Whirlpool Canada follows and reasonably relies upon Whirlpool Corporation's policies, including but not limited to its human rights, monitoring, auditing, and due diligence processes and policies, which Whirlpool Corporation implements globally across its supplier base and carries out on behalf of Whirlpool Canada and other subsidiaries globally. The efforts described in this Report are taken by Whirlpool Corporation on behalf of Whirlpool Canada.

In total, Whirlpool Canada procures goods and services from approximately 30 direct suppliers, including Whirlpool Corporation. The suppliers engaged include businesses that supply finished products sold to customers in Canada. These suppliers are located in both East and South Asia, Europe, and North America. Further information about Whirlpool Canada's business can be found in Whirlpool Corporation's 2023 Annual Report and 2023 Sustainability Report. The contents of Whirlpool Corporation's 2023 Annual Report, 2023 Sustainability Report, Integrity Manual, and Supplier Code of Conduct are not incorporated by reference in this Report.

3. Our Policies and Due Diligence Processes

Policies

Through Whirlpool Corporation's organizational and governance policies, values and expectations are communicated, setting a high bar for itself and its suppliers, and making it clear that the use of forced labour or child labour is prohibited. Whirlpool Corporation is committed to consistently evolving and improving its approach. Reasonable efforts are taken, including through carrying out due diligence and audits to monitor the performance of direct suppliers, to prevent activities from having a negative impact on human rights. Relevant policies are discussed in further detail below:

Supplier Code of Conduct (“Code”)

Suppliers are expected to act responsibly in all respects and to ensure that no abusive, exploitative or illegal conditions exist in their supply chains. Suppliers are expected to comply with all applicable laws and regulations, as well as the principles set out in the Code. One tenet of this Code is that suppliers must not use any type of involuntary or forced labour; this prohibits, among other things, slave labour 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 the Code, suppliers are required to follow the requirement in the Code. Direct suppliers must ensure that their own suppliers, service providers, and extended networks have in place and comply with ethical and business practices that are similar to the Code.

Whirlpool Integrity Manual

Whirlpool Corporation supports human rights in everything it does, respecting freedom of association and personal political involvement. Business practices reflect a commitment to ensure every person who works for Whirlpool Canada does so of his or her own free will, in a safe and healthy environment. Whirlpool Corporation opposes discrimination, slavery, and child labour, and ensures controls and protections to avoid them. It supports diversity and wage parity. It also respects the rights of employees to associate with whom they choose and to be involved in politics outside of work. The Whirlpool Integrity Manual makes it clear that Whirlpool Corporation:

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

Whirlpool Ethics & Compliance Program

Whirlpool Corporation works tirelessly to mitigate risks through robust regular monitoring, governance and audits of its supply base to ensure compliance with the Code which formalises the key principles under which suppliers are required to operate. In addition, supply chain risks are further lowered by running independent background checks to ensure direct suppliers are reputable through a third party due diligence program.

Due Diligence

Third parties with which Whirlpool Corporation works are expected to adhere to business principles and values similar to its own and to comply with all applicable laws and regulations. Before making any commitments towards third parties, steps are taken to appropriately evaluate the relationship and mitigate any associated risks by carrying out risk-based due diligence and checks.

Whirlpool Corporation acknowledges that there is a risk of forced labour or child labour in its supply chain. In order to mitigate this risk, an audit program has been adopted as described below.

Whirlpool Supplier Audit Compliance Program

Whirlpool Corporation has a longstanding history of combating forced labour in its supply chain through its well-established intensive supplier audit program. 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. All direct suppliers are contractually obligated to adhere to the Code which specifically prohibits the use of child or forced labour in any form. Direct suppliers are audited against the Code and undergo validations of labour practices in addition to all other business practices. A majority of the Code audits are performed on-site, as on-site audits are the preferred method of ensuring adherence to the Code. A smaller number of audits are conducted virtually as needed due to site restrictions, travel hazards, or other mitigating circumstances.

Existing direct suppliers are also continuously monitored through many mechanisms such as annual audit plans, which are based on a variety of criteria including: annual spend, location, engagement strategy, input from other supplier evaluation tools such as TPDD screenings and Corruption Perception Index (CPI) from Transparency International. Whirlpool Corporation does not tolerate suppliers with non-compliant findings in the areas of Human Rights (i.e., child labour and forced labour) and Business Ethics. Positive findings in any of these areas are considered “Critical,” and trigger swift responses in regards to discontinuing business operations with an existing supplier, or ceasing onboarding activities with a new direct supplier.

4. Assessing Our Risk

Whirlpool Corporation, on behalf of Whirlpool Canada and other subsidiaries, engages in various activities to identify, assess, and manage supplier risk. In assessing the risk of forced and child labour in its business and supply chains, 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, customised according to sector, geography and size. These reviews produce supplier scorecards with actionable ratings, complete audit results, and improvement management.

Whirlpool Corporation recognizes that the risk of forced or child labour is increased in parts of Asia and where enforcement of labour and other laws is less stringent than other parts of the world, including countries with elevated risks associated with corruption (e.g., those countries which rank 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 and harassment and external stakeholder human rights; and (2) human resources, including health & safety, working conditions, structured social dialogue, career management, and training.

Initially, the review covered significant global direct suppliers for the first wave with an external third party due diligence provider. An additional wave has been initiated and diagnostics performed on direct suppliers in regional locations highlighted by recent forced labour news & enforcement. Selected direct suppliers are required to provide significant information through the third party due diligence platform for data analysis and supplier scorecarding. Results are then shared with Whirlpool Corporation's GSS Center of Excellence team responsible for Code audits to determine if suppliers scoring low warrant an immediate additional audit, if they are not already included in the annual intensive audit plan. Ongoing monitoring of supplier compliance status, through several screening programs, ensures Whirlpool Corporation stays current with any major changes affecting potential supplier issues.

The enhancements and visibility provided by the third-party supply chain assessment company complements the significant efforts of Whirlpool Corporation's established rigorous audit and supplier oversight programs undertaken on behalf of Whirlpool Canada, which illuminate supplier risks in the supply chain.

5. Our Commitments

At Whirlpool Canada, human rights are supported in everything it does, and business practices reflect a commitment to ensure every person who works for Whirlpool Canada throughout all of 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.

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

As noted above, through Whirlpool Corporation, Whirlpool Canada has a robust program to identify, assess and manage supplier risk, including the risk of forced labour presented by its supply chain. As is evident from the robust programs described in this Report, reasonable efforts are taken to identify, prevent, and reduce the risk of forced and child labour in operations and supply chain.

Steps to Prevent and Reduce Risks of Forced and Child Labour

Among the steps taken to prevent and reduce risks of forced and child labour are the following:

• Mapping supply chains;
• Conducting an internal assessment of risks of forced labour and/or child labour in the organization's activities and supply chains;
• Contracting an external assessment of risks of forced labour and/or child labour in the organization's activities and supply chains;
• Developing and implementing an action plan for addressing forced labour and/or child labour;
• Gathering information on worker recruitment and maintaining internal controls to ensure that all workers are recruited voluntarily;
• Addressing practices in the organization's activities and supply chains that increase the risk of forced labour and/or child labour;
• Developing and implementing due diligence policies and processes for identifying, addressing and prohibiting the use of forced labour and/or child labour in the organization's activities and supply chains;
• Carrying out a prioritization exercise to focus due diligence efforts on the most severe risks of forced and child labour;
• Requiring direct suppliers to contractually commit to abiding by Whirlpool's Supplier Code of Conduct, child protection policies and processes;
• Developing and 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/or 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;
• Developing and implementing training and awareness materials on forced labour and/or child labour;
• Developing and implementing procedures to track performance in addressing forced labour and/or child labour;
• Engaging with supply chain partners on the issue of addressing forced labour and/or child labour;
• Engaging with civil society groups, experts and other stakeholders on the issue of addressing forced labour and/or child labour;

Remediation Measures

The Whirlpool Integrity Manual, which applies to Whirlpool Canada, encourages all employees and contract workers of Whirlpool Corporation and its subsidiaries to report actual or possible misconduct. A number of channels are provided by which anyone can report potential misconduct including a third party managed anonymous hotline. Whirlpool Corporation has a zero-tolerance policy for retaliation against those who report potential or actual misconduct or violations of its policies or applicable law.

Whirlpool Corporation undertakes diligence efforts (as further described in this Report) on behalf of Whirlpool Canada to ensure that the risk of forced labour and child labour is mitigated in its business. In the event that any actual or potential forced labour or child labour is discovered in its business and supply chains, Whirlpool Corporation will investigate and remediate those circumstances promptly. As part of the investigation and remediation process, disciplinary action may be taken against employees or suppliers who are involved, up to and including termination of employment or business relationship.

The approach is to prevent any presence of forced labour situations in the supply chain through robust due diligence activities during supplier onboarding and continuous monitoring of vendors described in this Report. By conducting regular compliance screenings of suppliers and onsite inspections of their facilities, Whirlpool Corporation ensures that workers are treated fairly and suppliers uphold stringent ethical standards. Whirlpool Corporation will not engage with a new supplier or hesitate to terminate an existing supplier that does not meet its high standards and expectations.

In 2023, no instances of forced or child labour were identified in the reporting period, and therefore no remediation measures were taken, nor any measures to remediate the loss of income to the most vulnerable families arising from such a measure.

Training

Every year, Whirlpool Canada personnel at all levels are required to complete a mandatory certification process to ensure that the Whirlpool Integrity Manual, which is its Code of Business Conduct and Ethics, is understood and properly applied to daily activities. Employees are provided with ongoing and periodic training opportunities to ensure current knowledge. Although Whirlpool Canada's employee training did not include dedicated training on forced and child labour explicitly, Whirlpool Canada aims to explore the possibility of reviewing employee training tools to include training dedicated to preventing forced and child labour.

6. Our Progress and Effectiveness

Through Whirlpool Corporation's governance processes, compliance with policies is monitored on an ongoing basis and any concerns raised through the Integrity Line, which is managed by a third party and allows reporters to remain anonymous, and other mechanisms of employee feedback (e.g., Human Resources, supervisors, Legal) are reviewed.

Additionally, Whirlpool Corporation's Senior Vice President for Global Strategic Sourcing regularly reviewed the results of third-party due diligence and audits. Any non-conformance identified is dealt with by the appropriate teams. Support is provided to suppliers where necessary to resolve any issues raised.

The effectiveness of policies is also assessed by regularly auditing direct suppliers to ensure compliance with the Code. Additionally, the supplier due diligence process is subject to audit by Whirlpool Corporation's Internal Audit function.

7. Approval & Signature

This Report was approved by WCGP Nova Scotia Co.'s Board of Directors in accordance with section 11(4)(b)(ii) of the Act on May 30, 2024 and has been submitted to the Minister of Public Safety and Emergency Preparedness in Canada. This Report is also available on company websites at:

• 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 requirements of the Act, and in particular section 11 thereof, Gary Power attests that he has reviewed the information contained in this Report for WCGP Nova Scotia, for itself, and on behalf of Whirlpool Canada LP. Based on his knowledge, and having exercised reasonable diligence, he attests that the information in this Report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.

Gary Power
General Manager and Vice President

May 30, 2024

Gary Power has the authority to bind WCGP Nova Scotia Co.

Whirlpool Additional Information

This Report includes forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995, including (but not limited to) statements about expected future supplier diligence efforts, development of company processes supporting those efforts and expectations regarding those company processes. Many of the forward-looking statements contained in this document may be identified by the use of words such as “believe,” “expect,” “anticipate,” “should,” “planned,” “estimate” and “potential,” among others. These forward-looking 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 are difficult to predict accurately and may be beyond control, and may include (but are not limited to) regulatory changes and judicial developments relating to forced labour and child labour, changes in or developments related to products or supply chain, and industry developments relating to supply chain diligence, disclosure and other practices. Other risks and uncertainties relevant to forward-looking statements are discussed in greater detail in reports filed with the Securities and Exchange Commission. Forward-looking statements in this document speak only as of the date made, and Whirlpool Corporation disclaims any obligation to update or revise these statements as a result of new developments or otherwise.