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| Overall Assessment |
Comment |
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.
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3
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| Overall Assessment |
Comment |
Score |
| Strong |
Whirlpool has established a robust governance process for aligning its lobbying and association activities with its climate strategy, evidenced by structured executive and board oversight. It explains 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 shows a formalized process for monitoring both direct lobbying and engagement through associations. Additionally, it clarifies that “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,” naming this independent committee as the specific body responsible for oversight. The company further confirms a public commitment to the goals of the Paris Agreement, answering “Yes” to having a position statement to conduct engagement activities in line with those targets. We found no evidence of a publicly available, detailed climate lobbying audit or third-party review to assess alignment, suggesting that while the overall governance framework is strong in delineating internal review and accountability, it does not provide a comprehensive external verification or published report of its climate lobbying practices.
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3
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