Whirlpool Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Whirlpool Corp discloses a discernible process for overseeing its lobbying activities, noting that Annually, the Whirlpool Corporation executive leadership team reviews all lobbying activities and expenditures, as well as trade and professional association alignment with company values and priorities, which indicates an internal mechanism to check both direct lobbying and participation in trade bodies against corporate priorities. Oversight responsibility is escalated to the board level, as All public policy activities and expenditures are subject to annual review and ongoing oversight by the Corporate Governance and Nominating (CGN) Committee of the Whirlpool Corporation Board of Directors, providing clarity on who is accountable for monitoring alignment. The company also states that it has a public commitment to conduct your engagement activities in line with the goals of the Paris Agreement, linking its policy-advocacy posture to climate objectives. It has dislcosed to CDP that its climate lobbying positions are aligned with National Association of Manufacturers, Association of Home Appliance Manufacturers, and the APPLiA - Home Appliance Europe. However, the disclosure does not elaborate on specific criteria used in the reviews, nor does it describe follow-up actions such as engaging with, reforming, or exiting trade associations that are misaligned; therefore, the extent to which the review translates into concrete alignment measures is not evident. Likewise, there is no published lobbying alignment report or audit that would demonstrate the outcomes of these reviews. These gaps mean the governance framework, while present and board-level, is only moderately detailed and its effectiveness in ensuring climate-aligned lobbying cannot be fully assessed from the available information. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Whirlpool Corp discloses a discernible process for overseeing its lobbying activities, noting that Annually, the Whirlpool Corporation executive leadership team reviews all lobbying activities and expenditures, as well as trade and professional association alignment with company values and priorities, which indicates an internal mechanism to check both direct lobbying and participation in trade bodies against corporate priorities. Oversight responsibility is escalated to the board level, as All public policy activities and expenditures are subject to annual review and ongoing oversight by the Corporate Governance and Nominating (CGN) Committee of the Whirlpool Corporation Board of Directors, providing clarity on who is accountable for monitoring alignment. The company also states that it has a public commitment to conduct your engagement activities in line with the goals of the Paris Agreement, linking its policy-advocacy posture to climate objectives. It has dislcosed to CDP that its climate lobbying positions are aligned with National Association of Manufacturers, Association of Home Appliance Manufacturers, and the APPLiA - Home Appliance Europe. However, the disclosure does not elaborate on specific criteria used in the reviews, nor does it describe follow-up actions such as engaging with, reforming, or exiting trade associations that are misaligned; therefore, the extent to which the review translates into concrete alignment measures is not evident. Likewise, there is no published lobbying alignment report or audit that would demonstrate the outcomes of these reviews. These gaps mean the governance framework, while present and board-level, is only moderately detailed and its effectiveness in ensuring climate-aligned lobbying cannot be fully assessed from the available information.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Whirlpool demonstrates transparency in identifying the specific climate policies and the outcomes it pursues, though it provides only general descriptions of its advocacy processes. It names the “SEC proposed U.S. Climate Disclosure Rule” as well as the “Minimum Energy And Water Use Requirements” and their accompanying “Test Procedures for Minimum Energy and Water Use Requirements,” stating its position of support “with minor exceptions.” The company articulates clear goals for policy change, backing “requirements that reduce energy and water use, and emissions, while allowing adequate product performance” and flagging that “proposed standards [that] may have negative consequences for consumers,” while also raising concerns about provisions requiring measurement of non-material emissions and challenges in quantifying severe weather and transition disclosures. At the same time, Whirlpool notes it “advocate[s] directly to policy makers and within trade associations” without specifying which policymakers are targeted or the formats of those engagements, offering only a high-level view of its lobbying mechanisms.	3