United States securities and exchange commission logo
October 6, 2022
James W. Peters
Chief Financial Officer
Whirlpool Corporation
2000 North M-63
Benton Harbor, MI 49022-2692
Re: Whirlpool
Corporation
Form 10-K for
Fiscal Year Ended December 31, 2021
Response Dated
September 23, 2022
File No. 001-03932
Dear James W. Peters:
We have reviewed your September 23, 2022 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
September 1, 2022 letter.
Response Dated September 23, 2022
Risk Factors, page 13
1. Your response to prior
comment two indicates that you expect to mitigate carbon pricing
impacts on operating
expenditures and profit margins by "encouraging low-carbon
behavior and the
innovation of cleaner options within our supply chain and products."
Tell us more about
these potential changes in your supply chain and products, and
describe the transition
risks related thereto.
James W. Peters
FirstName LastNameJames W. Peters
Whirlpool Corporation
Comapany
October NameWhirlpool Corporation
6, 2022
October
Page 2 6, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
28
2. We note your response to prior comment four. Please further address
the following:
The first part of your response appears to focus on
climate-related opportunities and
references transition risks. Tell us how you considered
disclosure that specifically
refers to business trends related to climate change. In your
response, describe your
actual experience regarding changes in demand for goods or
services that produce
significant greenhouse gas emissions or are related to
carbon-based energy sources.
The final part of your response refers to disclosure in your
Form 10-K regarding
reputational considerations and potential risks associated with
your response to
climate change. Please clarify this disclosure to more directly
address reputational
risks resulting from the production of greenhouse gas emissions
from your operations
or products and to explain the resulting potential adverse
consequences to your
business operations or financial condition (e.g., on access to
capital, debt servicing
costs, customer sentiment, etc.).
3. We note your response to prior comment five and reissue it in part.
Please provide us
with quantitative information for the periods covered by your Form
10-K regarding
weather-related damages to your property or operations and the cost of
property insurance
and tell us whether the cost of insurance is expected to increase in
future periods. In
addition, please tell us how you considered disclosing the potential
for indirect impacts to
you from weather-related disruptions to your customers.
4. We note your response to prior comment six and reissue it in part.
Please quantify your
compliance costs related to climate change for the last three fiscal
years.
Please contact Patrick Fullem at (202) 551-8337 or Jennifer Angelini at
(202) 551-
3047 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing
cc: Ava Harter