Image of recycling facility shows paper material moving on belt

Sustainability Data Center

Intro

WM (WM.com) is North America's leading provider of comprehensive environmental solutions. Previously known as Waste Management and based in Houston, Texas, WM is driven by commitments to put people first and achieve success with integrity. The company, through its subsidiaries, provides collection, recycling, and disposal services to millions of residential, commercial, industrial, and municipal customers throughout the U.S. and Canada. With innovative infrastructure and capabilities in recycling, organics, and renewable energy, WM provides environmental solutions to and collaborates with its customers in helping them pursue their sustainability goals. WM has the largest disposal network and collection fleet in North America, is the largest recycler of post-consumer materials, and is the leader in beneficial use of landfill gas, with a growing network of renewable natural gas plants and the most landfill gas-to-electricity plants in North America. WM's fleet includes over 12,000 natural gas trucks – the largest heavy-duty natural gas truck fleet in the industry in North America. To learn more about WM and the company's sustainability progress and solutions, visit Sustainability.WM.com.

The data below is presented to provide stakeholders with quick access to key performance indicators related to WM’s business and certain sustainability efforts. Please visit our Sustainability Report and Sustainability A-Z indices for additional information and stories related to WM’s sustainability program. WM is committed to improving and staying up to date on best practices for data collection and reporting, which may also result in changes to data. Further, totals may vary from the summation due to rounding. Data presented on a yearly basis represents performance from January 1 through December 31 of that year.

Legal Notice

Many of the assumptions, standards, methodologies, metrics and measurements used in preparing this report continue to evolve, and are based on management assumptions believed to be reasonable at the time of preparation, but should not be considered guarantees. There are inherent uncertainties in providing such information, due to the complexity and novelty of many methodologies established for collecting, measuring, and analyzing sustainability-related data.

Economic Impact

 Units202120222023
Total RevenueMillion USD$17,931$19,698$20,426
Adjusted Income from Operations 1Million USD$3,033$3,474$3,828
Adjusted Operating Margin 1Percentage16.9%17.6%18.7%
Adjusted Earnings per Share 1USD$4.84$5.59$6.19
Free Cash Flow 1Million USD$2,530$1,976$1,902
Adjusted Operating EBITDA 1Million USD$5,032$5,512$5,899
Adjusted Operating EBITDA Margin 1Percentage28.1%28.0%28.9%
Cash DividendsMillion USD$970$1,077$1,136
Share RepurchasesMillion USD$1,350$1,500$1,302
Returned to ShareholdersMillion USD$2,320$2,577$2,438
Cash Flow from OperationsMillion USD$4,338$4,536$4,719
Capital expendituresMillion USD$1,904$2,587$2,895
Diverse Supplier Spend 2Million USD$335$666$691

1 This is a non-GAAP financial measure. Please see the footnotes and tables that accompany WM’s financial earnings releases dated 2/12/2024, 1/31/2023 and 2/2/2022; available at investors.wm.com, for more information on WM’s use of non-GAAP measures and a reconciliation to the most comparable GAAP measures.

2 Diverse Supplier Spend includes but is not limited to spend with Women’s Business Enterprise Network Council (WBENC), National Minority Supplier Development Council (NMSDC), Small Business Enterprise (SBE), Lesbian, Gay, Bi-sexual, Transgender and Queer (LGBTQ) and Veteran-owned Businesses and Service Disabled Veteran-owned Small Businesses (VBE/SDVQSB) certified businesses.

Operations

 Units202120222023
Facilities
Landfills
Active Hazardous Waste LandfillsNumber555
Active Solid Waste LandfillsNumber255258258
Transfer StationsNumber340337332
Recycling FacilitiesNumber9697102
Organics Processing FacilitiesNumber394149
Renewable Energy—Landfill Gas Beneficial Use Projects
Landfill Gas-to-Electricity Facilities 3Number706666
Renewable Natural Gas Facilities 3Number456
Landfill Gas-to-Industrial-Processing Facilities 3Number222020
Third-Party Landfill Gas Beneficial Use ProjectsNumber484444
Natural Gas Fueling StationsNumber177181199
Fleet
Collection Vehicles 4Number18,92718,54518,347
Alternative Fuel Vehicles in Collection Fleet 5Number10,83211,30712,119
Alternative Fuel Vehicles in Collection FleetPercentage57%61%66%
Alternative Fuel Vehicles Fuel Consumption Allocated to Renewable Natural Gas 6Percentage53%47%47%
Recycling
Materials Recovered for Recycling
Paper/FiberTons7,780,3377,371,4737,880,038
OrganicsTons3,919,1983,801,5953,761,350
Fly AshTons884,281915,054757,344
GlassTons584,756546,114552,122
MetalTons417,452468,806505,220
PlasticTons516,717464,505510,254
Construction & Demolition/WoodTons1,226,0431,222,2371,228,095
E-waste/​Lamps/​BatteriesTons3,5677,6607,066
Other 7Tons5,10534,11436,249
Total Recovered MaterialsTons15,337,45614,831,55915,237,738
Inbound Recycling ContaminationPercentage16%16%16%
Customer Service & Satisfaction
Enterprise Net Promoter Score 8Number34.728.330.7
Overall Customer Satisfaction 9Percentage60.5%57.2%58.6%
Post-Contact Survey Customer Satisfaction 10Number4.064.124.11
Customers by Category 11
Residential Customers 12NumberNA1,484,3291,416,732
Commercial Customers 13NumberNA1,125,3721,139,742
Industrial Customers 14NumberNA204,347211,881
Municipal Customers 15NumberNA2,7482,610
Customers Receiving Recycling & Organics Services by Customer Type
Recycling Services
Residential Customers 12Percentage75%73%74%
Commercial Customers 13Percentage28%29%29%
Industrial Customers 14Percentage19%9%8%
Organics Services
Residential Customers 12Percentage38%39%39%
Commercial Customers 13Percentage2%<1%<1%
Industrial Customers 14Percentage<1%<1%<1%

3 Facility count is inclusive of WM-owned-and-operated facilities on WM landfills.

4 Collection Vehicles indicates the number of vehicles that register on-road hours within the reported year.

5 Alternative Fuel Vehicles include vehicles that run on compressed natural gas (CNG) and liquefied natural gas (LNG).

6 WM continues to review our methodology for calculating percent of Alternative Energy Vehicles Allocated to Renewable Natural Gas (RNG) to improve overall data accuracy.

7 “Other” includes specialty materials such as used oil, tires and textiles.

8 The Enterprise Net Promotor Score measures customer loyalty by looking at their likelihood of recommending a given business.

9 The Overall Customer Satisfaction metric is calculated based on number of responses with a 9 or 10 rating (on a scale of 1-10) divided by the total number of responses.

10 The Post-Contact Survey Customer Satisfaction score is a score provided by the customer following a customer service conversation on a scale of 1-5.

11 Tracking of customers within these categories began in 2022 as a result of technology upgrades. Prior to that, we tracked customers in line with our financial reporting which differs from this classification (indicated by ‘NA’ - Not Available).

12 Residential Customers include residences that have direct contracts with WM for curbside collection services.

13 Commercial Customers include those receiving services on a commercial collection route.

14 Industrial Customers include those that receive roll-off service.

15 Municipal Customers are defined as municipalities that have direct contracts with WM. These contracts include many residential customers as they provide services to a specific area, inclusive of all residents.

Environment

 Units202120222023
Greenhouse Gas (GHG) Emissions 16
Scope 1
LandfillMetric Tons CO2e15,299,58213,743,23913,377,373
Collection FleetMetric Tons CO2e1,171,9671,116,1101,104,533
Other Energy UseMetric Tons CO2e503,775462,388456,824
Total Scope 1Metric Tons CO2e16,975,32315,321,73714,938,730
Scope 1 Emissions Covered Under Emissions-Limiting Regulations 17Percentage76%75%75%
Scope 1 Emissions Covered Under Emissions-Reporting Regulations 18Percentage79%79%78%
Scope 2 — Purchased Electricity 19
Location-BasedMetric Tons CO2e257,188301,883285,368
Market-BasedMetric Tons CO2e182,885138,743122,972
Scope 3 20
Purchased Goods & ServicesMetric Tons CO2e1,136,734288,762298,304
Capital GoodsMetric Tons CO2e1,613,209222,620249,003
Fuel & Energy-Related ActivitiesMetric Tons CO2e325,520339,725367,687
Upstream TransportMetric Tons CO2e62,668410,615525,406
WasteMetric Tons CO2e24,39723,396
Business TravelMetric Tons CO2e9,26618,54418,085
Employee CommutingMetric Tons CO2e199,333157,395145,195
Upstream Leased AssetsMetric Tons CO2e7,918——
Downstream TransportMetric Tons CO2e62,668139,108
Use of Sold ProductsMetric Tons CO2e8231,17512,551
Downstream Leased AssetsMetric Tons CO2e1,16322,73123,086
InvestmentsMetric Tons CO2e1,1082,1309,933
Total Scope 3Metric Tons CO2e3,357,7431,488,0941,811,754
Biogenic Emissions 21
Biogenic Scope 1Metric Tons CO2e12,969,52212,858,41312,988,704
Biogenic Scope 2Metric Tons CO2e985134,453
Biogenic Scope 3Metric Tons CO2e1,146,2692,285,3812,444,078
Avoided GHG Emissions
Renewable Energy GenerationMetric Tons CO2e2,163,7701,967,6701,979,621
Reuse and Recycling of MaterialsMetric Tons CO2e28,014,26226,919,97028,318,966
Carbon Permanently SequesteredMetric Tons CO2e21,855,84719,428,51521,699,308
Total Avoided GHG EmissionsMetric Tons CO2e52,033,87948,316,15551,997,895
Carbon Intensity
Net Revenue Carbon Intensity 22CO2e/$M Net Revenue957784737
Waste Disposed Carbon Intensity 22CO2e/Tons of Waste Disposed0.1370.1240.123
Miles Driven Carbon Intensity 23CO2e/1,000 Miles Driven2.202.162.30
Avoided GHG Emissions Carbon Intensity 24Avoided GHG Emissions/CO2e3.033.133.45
Landfill Gas Emissions
Landfill Gas Captured 25Metric Tons CO2e53,562,52853,408,98153,941,059
Landfill Gas Captured 25Percentage78%80%80%
Fugitive Landfill EmissionsPercentage22%20%20%
Landfill Gas FlaredPercentage55%55%57%
Landfill Gas Recovered for Beneficial UsePercentage45%45%43%
WM Landfill Gas
Total Landfill Gas RecoveredMMBTU112,680,253111,798,605117,308,771
Equipment Capacity 26
Landfill Gas-to-ElectricityMW377395355
Landfill Gas-to-Natural-GasMW636770
Total Equipment Capacity for Landfill GasMW441461424
Landfill Gas Converted to Energy for Sale/Use 27,28MMBTU56,674,42455,776,84256,621,580
Energy Consumption
Total EnergyMWh9,844,8369,038,4779,731,807
Total Non-Renewable EnergyMWh7,892,3987,008,7967,024,649
Total Renewable EnergyMWh1,952,4382,029,6812,707,158
Total Fuels 29MWh9,153,7008,214,7648,904,626
Non-Renewable FuelsMWh7,389,8046,530,9876,654,805
Renewable FuelsMWh1,763,8961,683,7772,249,821
Total ElectricityMWh691,136823,713827,181
Non-Renewable ElectricityMWh502,594477,809369,844
Renewable Electricity 30MWh188,542345,904457,337
Percent Renewable EnergyPercentage20%22%28%
Percent Renewable ElectricityPercentage27%42%55%
Energy Intensity31
Energy per Waste ManagedMWh/1,000 tons72.6572.8279.25
Energy per Operating RevenueMWh/$10k5.104.594.76
Energy per EmployeeMWh/employee188.59183.27203.23
Non-Compliance Associated With Environmental Impacts
Environmental Compliance ViolationsNumber575
Significant SpillsNumber863
Non-Compliance Associated with Air EmissionsNumber331
Emissions of Air Pollutants 32
Emissions of NOxMetric Tons4,4794,7744,812
Emissions of SOxMetric Tons722780802
Emissions of VOCsMetric Tons96104107
Toxic Release Inventory (TRI) Chemical Containment at WM Hazardous Waste Facilities 33
RCRA Subtitle CPounds26,839,04134,622,616——
Underground InjectionPounds5,223,0535,041,977——
Transfer Off-Site to Treatment/ContainmentPounds137,98155,183——
TRI Releases to WaterPercentage<1%<1% ——
Waste Generated 34
Total Waste Generated 35Metric Tons4,4694,5614,405
Total Waste RecycledMetric Tons1,1851,2041,168
Percentage RecycledPercentage27%26%27%
Total Waste to LandfillMetric Tons3,2843,3573,237
Percentage LandfilledPercentage73%74%73%
Total Waste to IncineratedMetric Tons000
Percentage IncineratedPercentage0%0%0%
Total Waste Generated per EmployeePounds203204203
Water Consumption
Total Municipal Water SuppliesMillion Cubic Meters3.563.243.86
Fresh Groundwater 36Million Cubic Meters0.130.130.13
Total WithdrawalMillion Cubic Meters3.693.373.99
Total Net Fresh Water ConsumptionMillion Cubic Meters0.840.860.83
Water Returned to the Source of Extraction at Similar or Higher Quality as Raw Water ExtractedMillion Cubic Meters2.852.513.16

16 Our GHG Emissions Inventory Scope 1, 2 and 3 is third-party reviewed and verified annually.

17 As aligned with Sustainabiltiy Accounting Standards Board (SASB) definitions, this includes only emission sources that are regulated under a permit-based mechanism.

18 As aligned with SASB definitions, this includes only emission sources that meet a regulatory threshold for reporting.

19 Location-Based reflects emissions from total electricity consumption. Market-Based reflects emissions from retirement of renewable energy credits (RECs) in accordance with the GHG Protocol Corporate Standard.

20 WM continues to improve our Scope 3 accounting and transparency by working closely with our suppliers and aligning with best practice methodologies. Not only does this result in fluctuations in reported emissions, but it may also lead us to shift emissions into different categories, eliminating some while expanding others.

21 Biogenic Emissions are reported separately from WM’s Corporate GHG Inventory in line with the GHG Protocol Corporate Standard. These emissions are considered carbon neutral as they derive from decomposition of biological material. Biogenic Scope 2 emissions are associated with retired RECs from landfill gas-to-electricity.

22 Carbon Intensity metrics include Scope 1 and 2 emissions normalized to $M net revenue, tons of waste disposed and 1,000 miles driven.

23 Miles Driven Carbon Intensity metric reflects Scope 1 Collection Fleet emissions normalized to 1,000 miles driven.

24 Avoided GHG Emissions per CO2e is calculated by dividing total potential emissions avoided from Renewable Energy Generation, Reuse and Recycling of Materials and Carbon Permanently Sequestered by direct operating emissions (Scope 1 and 2).

25 Landfill gas generated from waste is cyclical over a period of decades. The amount and rate of gas generation is dependent on several factors, including waste volume, composition, climatic factors and operational controls.

26 Equipment Capacity presents MWs of capacity at WM Renewable Energy (WMRE) facilities only.

27 Landfill gas converted to energy is a measure of energy produced at renewable energy facilities on WM landfills, inclusive of WM-owned-and-operated and third party. WM has updated this metric based on alignment between various data sources and an enhanced measurement approach.

28 Note, landfill gas processed at a renewable energy facility has a higher energy content than the enterprise-wide average energy content.

29 Total Fuels are inclusive of fuels used in collection fleet, off-road fleet, facility heating, direct operations and aviation.

30 Renewable Electricity is comprised of RECs generated from WM landfill gas-to-electricity facilities and then retired against WM's direct electricity usage.

31 Energy Intensity is enterprise-wide energy including electricity and fuels normalized to energy per 1,000 tons waste managed, $10k operating revenue and employee.

32 Air emissions data is reported in metric tons per year based on emissions at landfill sites only.

33 Toxic Release Inventory (TRI) data is reported a year behind.

34 Waste generated in operations is calculated using an average waste and recycling generation tonnage per employee, per day for each of our facility types. Each WM facility type (i.e., landfill, hauling, recycling, office, etc.) has its own waste factor calculated based on historical waste audit data.

35 Total Waste Generated includes non-hazardous waste.

36 Ground water usage at sites without meters is estimated based on employee count.

Workforce 37

Units202120222023
Safety
Days Away Restricted or Transfer - EmployeesDays/200,000 work hours2.42.62.4
Days Away Restricted or Transfer - Contractors and Contingent LaborDays/200,000 work hours0.090.040.04
Vehicle Accident Recordable RateTotal Driver Hours/ Vehicle Accident19,63119,85118,672
Hourly Accident Recordable RateTotal Driver Hours/ All Vehicle Accident11,61110,7918,899
Total Recordable Injury RateInjuries/200,000 work hours3.03.023.08
Employees
Hires
New Employee HiresNumber12,74413,7919,904
Open Positions Filled by Internal Candidates (Internal Hires)Percentage22%26%35%
Employee Turnover
Employee Turnover RatesPercentage25.4%25.3%21.0%
Voluntary Employee Turnover RatesPercentage20.9%20.0%15.0%
Employees by Pay Type
HourlyPercentage80.3%79.6%78.8%
SalariedPercentage19.7%19.6%21.2%
Salary Ratio
Ratio of Basic Salary and Remuneration of Female to Male 38Number0.970.930.95
Employees by Region
Total EmployeesNumber48,34849,31747,886
United StatesNumber45,22646,14944,446
CanadaNumber2,0552,1352,160
IndiaNumber1,0671,0331,280
Diversity & Inclusion (United States only unless otherwise noted)
By Age (Global)
<30 Years OldPercentage11.5%11.7%11.8%
30 – 50 Years OldPercentage48.4%48.2%48.0%
>50 Years OldPercentage39.7%40.1%40.2%
Senior Leadership Team 39
MinorityPercentage22%22%20%
Female (Global)Percentage33%33%30%
WM Leadership 40
MinorityPercentage21.5%22.9%26.4%
Female (Global)Percentage22.6%27.8%28.3%
Share as Percentage of Total Workforce 41
AsianPercentage1.5%1.5%1.5%
Black or African AmericanPercentage18.6%18.2%18.0%
HispanicPercentage21.0%21.1%21.7%
WhitePercentage50.3%48.7%47.6%
American Indian or Alaska NativePercentage0.6%0.6%0.5%
Native Hawaiian or other Pacific IslanderPercentage0.4%0.4%0.4%
Two or More RacesPercentage0.9%0.6%0.7%
Not Disclosed 42Percentage6.8%9.0%9.5%
Share in All Management Positions, as Percentage of Total Management Workforce 41
AsianPercentage2.6%2.6%2.9%
Black or African AmericanPercentage7.9%7.8%8.4%
HispanicPercentage11.0%11.7%12.2%
WhitePercentage71.3%69.1%67.1%
American Indian or Alaska NativePercentage0.3%0.2%0.2%
Native Hawaiian or other Pacific IslanderPercentage0.2%0.3%0.2%
Two or More RacesPercentage0.7%0.8%0.9%
Not Disclosed 42Percentage5.9%7.4%8.0%
Female Representation (Global)
ExecutivesPercentage19.7%14.1%17.3%
ManagersPercentage21.7%22.2%22.9%
ProfessionalsPercentage47.1%46.7%48.0%
Operatives & Craft WorkersPercentage4.0%4.3%3.7%
Total WorkforcePercentage19.4%18.9%18.8%
Minority Diversity
ExecutivesPercentage10.5%10.3%13.5%
ManagersPercentage23.5%24.5%27.0%
ProfessionalsPercentage33.0%32.9%34.6%
Operatives & Craft WorkersPercentage48.2%48.3%50.1%
Total WorkforcePercentage44.9%44.8%46.2%
Additional Representation
VeteransPercentage5.0%4.0%5.8%
Labor Relations
Workforce Covered Under Collective Bargaining AgreementsPercentage18%17%17%
Work StoppagesNumber002
Training 43
Average Training 44Hours/Employee303020
Average Spend on TrainingUSD/Employee$650$572$795
Total Annual Training Among Full-Time EmployeesHours438,631520,839951,413

37 Workforce data is for WM’s total workforce, unless otherwise stated. Workforce percentage figures are a representation of plus or minus 1%. Diverse and minority representation references both racial and ethnic characteristics self-identified by U.S. team members only.

38 In 2022, WM updated our methodology for calculating Salary Ratio to align with industry best practices, which resulted in a slight year-over-year difference. The updated methodology is an average of all female employees’ pay compared to all male employees’ pay.

39 The composition of WM’s Senior Leadership Team varies, but as of year-end 2023, it was comprised of the following roles: Chief Executive Officer, Chief Sustainability Officer, Chief Financial Officer, Chief Legal Officer, Chief Operating Officer, Chief Human Resources and Diversity & Inclusion Officer, Chief Customer Officer, Senior Vice President Operations East Tier, Senior Vice President Operations West Tier and Senior Vice President Enterprise Strategy.

40 WM Leadership is comprised of supervisors and above roles, including functional and/or people leaders.

41 Race groups and population data are based on the categories provided by the U.S. Census Bureau. This includes six single-origin race groups (White, Black or African American, American Indian or Alaska Native, Asian, Native Hawaiian or Other Pacific Islander and Some Other Race) and one multiple-origin race group (Two or More Races). Each race group is divided into two ethnic categories: Hispanic or Latino and non-Hispanic or non-Latino. This data aligns with EEO-1 reporting.

42 This includes the following: Employee chose not to report, “not specified” and/or employees in Canada and India.

43 In 2023, WM updated our training programs through a few key strategies: 1) focus on employee development including our extended leadership development programs; 2) through targeted compliance training to better meet the needs of the business; and 3) more personalized training experiences.

44 Average hours of training per employee includes training completions tracked in WM’s Talent Management System and an estimate of blended learning techniques (e.g., daily training huddles, weekly safety training, monthly observations and post-training reinforcement methods such as videos and practice sessions) that occur in the field. In 2023, average training per employee decreased as a result of improved targeted training programs for total front-line employees, improving the overall quality and resulting in fewer hours needed per employee.

Community

 Units202120222023
Charitable contributions
Contributions (Monetary)Million USD$12.8$14.1$14.7
In-Kind ServicesMillion USD$1.5$1.8$2.0
Workforce Development Donations to Nonprofits 45Million USD$2.0
Total Charitable Giving 46Million USD$14.3$15.9$18.7
Environmental Stewardship 47
Wildlife Habitat Council Certified ProgramsNumber737474
Land Actively Managed for Wildlife PreservationAcres13,72113,41313,413
Habitat, Species and Education Certified Projects 'On-the-Ground'Number278291320
Sustainability Education 48
Participants in WM-Supported/Hosted Education Events and ProgramsNumber536,738
People Positively Impacted Number302,998526,462

45 These donations are supporting our Innovative Employment Pathways (IEP) program.

46 Expanded reporting in 2023 to include donations that support select workforce development programs and earmarked local donations.

47 Environmental acres and projects reported here are actively managed through the Wildlife Habitat Council programs.

48 2021 data includes participants in WM-supported sustainability education events and programs. In 2022, we updated our reporting methodology to align with the 2030 Social Impact goal to positively impact people through targeted social impact programs. Cumulative people positively impacted is 829,460 for years 2022-2023, towards our goal of 10 million people positively impacted by 2030.

Governance

 Units202120222023
Board of Directors
Minority 49Percentage22%22%33%
FemalePercentage33%33%33%
Annual Total Monetary Political and Lobbying Contributions50
Federal Lobbying, Interest Representation or SimilarUSD$310,000$296,500$279,000
Local, Regional or National Political Campaigns/​Organizations/​CandidatesUSD$223,817$390,512$300,204
Trade Associations or Tax-Exempt Groups (e.g., think tanks)USD$916,341$975,677$1,113,734
Total Monetary Political and Lobbying Contributions and Other SpendingUSD$1,450,158$1,662,689$1,692,938
Reports of Potential Misconduct 51
Number of Reports of Potential MisconductNumber3,4893,5753,190
Reports via Confidential Integrity HelplinePercentage62%49%38%
Reports via Other Avenues 52Percentage38%51%62%
Total Reports Made AnonymouslyPercentage33%27%21%
Reports of Employment Practices Matters 53Percentage83%77%72%
Reports of Fraud-Related Matters 54Percentage6%6%7%
Reports of Security-Related Matters 55Percentage6%8%11%
Reports of Other Code of Conduct Matters 56Percentage5%9%10%

49 Diverse representation is voluntarily self-identified. Minority representation references both racial and ethnic characteristics self-identified by U.S. directors only.

50 The data presented above is annual total monetary contributions to and spending for political campaigns, political organizations, lobbyists or lobbying organizations, trade associations and other tax-exempt groups. Note the amounts are based on the information provided by the association or organization. WM PAC contributions are excluded and can be found in our publicly available disclosure Participation in the Political Process https://investors.wm.com/static-files/3013b95e-be0a-40a7-830f-22cdd9e3c50a

51 WM’s SPEAK UP culture encourages employees to report issues and concerns through several channels, including directly to their manager, Human Resources, Compliance and Ethics or directly to the third-party-administered Integrity Helpline.

52 Includes Human Resources (HR), Corporate HR Investigation Team, Corporate Security, Internal Audit, Senior Leadership and Compliance and Ethics.

53 Includes, but not limited to, harassment, discrimination, unprofessional behavior, employee relations, etc.

54 Includes, but not limited to, bribery, business practices, fraud, payroll fraud, etc.

55 Includes, but not limited to, burglary, identity theft, privacy concerns, property damage, workplace violence, etc.

56 Includes, but not limited to, conflicts of interest, gifts and entertainment, etc.