- Sustainability A-Z
- Supply Chain
Supply Chain
Supplier Code of Conduct
The WM Code of Conduct (Code) applies to every WM employee and our Board of Directors. The Code also highlights the expectation that our consultants, contractors, vendors and other business partners will act in a manner consistent with our Code when conducting business on behalf of the company. The Code is available in print and online in English, Spanish and French.
The WM Supplier Code was launched and rolled out in 2012 and receives periodic updates. It includes that suppliers should also comply with the United States Foreign Corrupt Practices Act, the U.K. Anti-Bribery Act, the Canadian Corruption of Foreign Public Officials Act, India’s Prevention of Corruption Act and all applicable anti-corruption and anti-bribery laws and regulations as well as information on how to report compliance and ethics issues or concerns on our Integrity Helpline.
The Supplier Code includes guidance related to a requirement to maintain a sustainable procurement policy for their own suppliers, as well as environmental standards for suppliers’ processes, products and services. Additionally, the Supplier Code highlights that when doing business with or on behalf of WM, Suppliers are expected to comply with U.S., Canadian, and other applicable forced labor and modern slavery laws. All Suppliers are also required to read and adhere to WM’s Human Rights and Modern Slavery Policy. All suppliers, contractors and service providers receive this Code as part of their contract signing and with all renewals and modifications of existing contracts. All WM contract purchases are governed by the WM Supplier Code. Although it is provided online for our suppliers and is appended to all new contracts, renewals and modifications of existing contracts, we do not retain a file of acknowledgement from our suppliers.
Ensuring Compliance
We conduct periodic business reviews with Tier I critical suppliers to ensure contract and Supplier Code compliance. Reviews are conducted, at a minimum, quarterly, but no less frequently than annually based on the size and complexity of the supplier. Any noted findings are recorded for corrective actions with responsibilities and dates assigned which are reviewed at following supplier reviews. WM expects Suppliers to have processes and controls in place that help them comply with the expectations set forth in the Supplier Code of Conduct. WM also encourages Suppliers to implement their own code of conduct and other policies and procedures to cascade the business standards referenced throughout their own organizations and business practices. Additionally, WM cares and expects suppliers to SPEAK UP to report any known or perceived violations of laws, regulations, our policies, or our Code. Consultants, contractors, and suppliers can report issues confidentially through the WM Integrity Helpline at 1-800-265-9381 (U.S. and Canada) or 001.877.801.2359 (India), its website (wm.com/speakup), or to the WM Compliance and Ethics department (ethics@wm.com). The WM Integrity Helpline is maintained by a third party and reports can be made anonymously 24 hours a day, 7 days a week. We reserve the right to audit and inspect supplier operations during the term of the contract and for a limited time after termination. To ensure compliance with international laws, WM has established an International Compliance Committee, which manages the company’s international compliance activities and oversees related processes, policies and guidelines.
Supplier Sustainability Risks
We have established a process to identify key supplier risk factors and determine how to mitigate those factors. We observe and check the progress of the supplier risk profile on a yearly basis. We methodically examine the supplier risk profile for the purpose of explanation and interpretation. A risk profile is established for the supplier and the overall category. In this way, we continually assess the strengths and weaknesses of our suppliers, and the impact these could have on our business.
1. Monitor: Observe and check the progress of the supplier over a period of time
2. Analyze: Methodically examine the supplier risk profile for the purpose of explanation and interpretation
3. Mitigate: Establish plans to reduce and manage the risk profile of a supplier
4. Certify: Establish supplier risk profile and their current service level to WM
Potential sustainability risks include financial and insurance-related risks (including compliance and regulatory considerations), safety and health, and supplier diversity. In our mission of continuous improvement, we check for expired or out-of-date insurance declarations through an automated system, which triggers notification to the supply chain managers for corrective action; conduct site visits and unannounced inspections of suppliers’ facilities, particularly with our top fleet suppliers; and work closely with field operations to observe the service level provided to our operations. Any slippage observed from a safety or service disruption standpoint will warrant a corrective action plan. WM defines high-risk suppliers as those that operate or do business in or with high-risk countries, are high-dollar suppliers, are critical Tier I suppliers, provide products or services that can have a negative impact on the environment, have high safety risks, or those whose economic/operational performance is below industry peers.
Improving Supply Chain Sustainability
All sustainability factors articulated in our procurement policy are considered essential balancing criteria and must be considered in supplier selection. There is no formal weighting template. Compliance with regulatory sustainability standards is a mandatory threshold, with carbon footprint reduction initiatives considered along with sustainability, cost, risk and other factors.
To align with our values, we include specific contract language describing the importance of sustainability to WM. In addition to communicating our sustainability goals, we plan to include the following sustainability clause in all our master service agreements contracts by 2025.
"WM has positioned itself as the leader in environmental services, developing strategies and implementing actions to reduce our overall impact on the environment. We encourage our suppliers to develop and participate in sustainability programs and engage their supply chain networks to be aware of our joint impact on the environment. We will support suppliers’ efforts to cut waste, use recycled materials and maximize the use of their resources to help us meet our sustainability goals."
WM Supply Chain team has developed a Sustainable Supplier Partnership Playbook to direct conversations with suppliers and maximize the opportunity to identify and implement new projects. A key component to this Playbook is the supplier sustainability questionnaire which will allow our suppliers to document their sustainability programs and have ongoing dialogue on joint sustainability activities.
The Supply Chain team has also initiated sustainability projects as a required individual goal in the WM annual goal planning process. To be considered a Project, an initiative must have a proven environmental or social benefit, such as material reduction, use of recycled content materials or GHG emissions avoidance. Each of the sustainability projects that the Supply Chain team manages is put into a sustainability project Management Tool that converts the environmental avoidance into a useful metric utilizing the EPA’s Waste Reduction Model (WARM) calculations to capture environmental impacts. This tool is the core supply chain sustainability reporting tool, allowing us to systematically and consistently demonstrate our contribution to the overall sustainability program.
Other departments within WM and local operational locations play a vital role in ensuring our ESG goals are met. The Supply Chain team aligns our processes and procedures to the operational needs for services. We rely heavily on daily interactions with our business partners to provide feedback through our collaborative supplier vetting process. Collaboration with the Corporate Sustainability team is an ongoing internal communication focus, which allows us to continuously improve our reporting to external parties.
Supplier Diversity
WM’s Supplier Diversity Program mission is to be an advocate & ally for often-overlooked and underutilized small diverse businesses. We do this by taking a grassroots effort through research & analytics to help us identify businesses that can support our operations at a market area level. Additionally, we believe that through education, training and development, we not only help these businesses become great partners for WM but also for other large corporations. Finally, empowering our Supply Chain organization to drive diversity and inclusion initiatives at the ground level will enable our team to increasingly utilize a supplier base which truly reflects the diversity of our customer base.
WM has a goal to drive 10% of addressable spend to diverse businesses every year. To meet this target, we hold multiple supplier diversity events across multiple market areas to raise awareness about our supplier diversity efforts and inspire more diverse suppliers to reach out to us. We also seek to amplify the positive impact of the supplier diversity program by asking our suppliers to also do business with diverse companies.
WM partners with qualified suppliers to make a difference in the lives of the communities we serve. Empowerment and Inclusion in supplier diversity is at the core of our procurement practices. Through our supplier diversity program, we look to build relationships with businesses that are at least 51% owned by minorities, women, veterans, service-disabled veterans or members of the LGTBQ community, whose businesses are capable of providing commodities and innovative services to WM at competitive prices. By engaging and developing diverse value-added suppliers, we create a sustainable competitive advantage and build a supplier base that reflects WM’s values and commitments.
To help us identify diverse suppliers, we leverage the diversity module from our supply chain operating system, COUPA, which has a best-in-class Supplier Diversity suite. This allows WM to leverage Coupa’s extensive database to scrub, clean and verify WM’s 35,000+ supplier base against Coupa’s 120+ industry data sources, highlighted by the following groups: Women’s Business Enterprise Network Council (WBENC), National Minority Supplier Development Council (NMSDC), Small Business Enterprise (SBE), National LGBT Chamber of Commerce (NGLCC) and Veteran-Owned Businesses/ Service-Disabled Veteran-owned Small Businesses (VBE/SDVQSB).
WM, in accordance with our business values and sustainability strategies, strives to conduct business with all suppliers in an environment that demonstrates mutual trust, fairness, integrity and inclusion of different perspectives. As a critical strategy, we have added supplier diversity to our project review documentation that is evaluated throughout the year during category reviews and is a requirement on all supply chain members’ yearly goals.