Code of Conduct

Waste Management’s Code of Conduct is entitled “Focus on Integrity and Inclusion.” Compliance with our Code is central to our business success, and each employee of the company, as well as all officers and directors, is given a copy of the Code of Conduct yearly. It provides standards for ethical behavior across the scope of our business, including providing equal employment opportunities, ensuring employee safety, maintaining quality in our services, honoring relationships with suppliers and vendors, preserving privacy and confidential information, controlling access to electronic information and equipment, and complying with all applicable rules and regulations, including those related to bribery and corruption. See Anti-Bribery Policy.

Our goal is for all employees to receive training on the Code of Conduct within 60 days of joining the company and periodically thereafter. On average, between 85 and 90 percent of all incumbent employees have completed the Code of Conduct training (initial and refresher courses) within the past 12 months. In addition to the Code of Conduct training, the Integrity Helpline process, sample case scenarios and general investigation outcome statistics are shared with employees periodically, utilizing the company's internal newsletter as well as any other feasible communication methods. In 2015, there were six different communications specifically to these points. To escalate the focus on the importance of compliance, in 2016, Waste Management Ethics and Compliance has committed to publishing at least one article a month in the internal newsletter, along with accompanying messages from a senior executive to different key employees when appropriate.

The Code applies to all employees, and signed acknowledgments are required attesting that each recipient understands the responsibilities outlined. We expect employees to report violations, and we provide an anonymous and confidential Waste Management Compliance and Ethics Integrity Helpline should a concern arise. Employees are highly encouraged to utilize all internal reporting resources, including the Help Line. The Integrity Helpline reporting, an annual Business Ethics questionnaire and whistleblower processes in accordance with the Code of Conduct are reviewed by an outside auditing firm. Amendments to the Code require the Board of Directors’ approval.

Today, over 99 percent of Waste Management employees reside in North America, and 99 percent of suppliers are based in North America or Europe. In these markets, we are fortunate to operate within strong regulatory requirements regarding minimum wage, competitive corporate compensation packages, and enforced bans on involuntary labor, discrimination, uncompensated overtime, child labor and other key human rights assurances. As we begin to make very modest expansions in our supply chain and employee base beyond our historical reach, we are getting ahead of the potential for human rights concerns by creating new applications of our Code of Conduct to ensure that our fundamental values remain applicable globally.

For example, as we anticipated expanding our service center in India during 2016, we created a specific Code of Conduct for Indian employees. This Code was deployed with the same scope of coverage, monitoring and access to confidential Help Line response that we employ in North America. By the end of 2016, we anticipate all employees will be trained on these policies and procedures. In light of this modest increase in our international footprint, we also reviewed our Code of Conduct to confirm its alignment with the 10 principles of the United Nations Global Compact (UNGC) so that we can direct employees to the UNGC for helpful background and information. Our Corporate Security Group has an important role in assisting with investigation of both North American and international questions involving compliance with our Code of Conduct. The Security Department has a role in supporting compliance with privacy, intellectual property, physical and personnel security as well as the broader Code requirements, which can be downloaded at https://www.wm.com/about/company-profile/ethics/our-values.jsp.

The Code of Conduct is published in English, Spanish and French and can be found on our corporate website here. www.wm.com/about/company-profile/ethics/our-values.jsp. Our privacy policy appears at http://www.wm.com/privacy-policy.jsp.