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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 information and links to the Ten Principles of the UN Global Compact, as well as information on how to report compliance and ethics issues or concerns on our Integrity Helpline. The Code also includes guidance related to a requirement to maintain a sustainable procurement policy for their own suppliers and environmental standards for suppliers’ processes, products and services. 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 our Code 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.
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. The Supplier Code is monitored through a domestic and international WM Compliance and Ethics Helpline number. All consultants, contractors and suppliers are obligated to report any known or perceived violation of laws, regulations, WM policies or our Code. We reserve the right to audit and inspect supplier operations during the term of the contract and for a limited time after termination. WM has limited operations outside of North America. 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 ESG 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 ESG 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 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. Our goal documentation template has been updated to include supplier diversity projects and carbon footprint avoidance opportunity projects. This template is reviewed by the entire Supply Chain team throughout the year. 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 will be the core supply chain sustainability reporting tool, allowing us to systematically and consistently demonstrate our contribution to the overall ESG 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. For example, our real estate department is establishing minimum requirements for new builds, which include requirements for recycled and energy-efficient materials in its capital construction projects and working closely with them to identify suppliers for controlled lighting and HVAC, occupancy sensors, recycled-content carpet and furniture, and low-emitting paints and adhesives.
To support diversity in our communities, we seek to source from diverse suppliers. This not only helps small businesses grow but it also helps reduce supply chain risk for WM. We have an internal target to increase annual addressable spend with diverse suppliers by 10% every year. To meet this target, we hold events around the country to raise awareness about our supplier diversity efforts and inspire more diverse suppliers to reach out to us.
It is WM’s privilege, policy and practice to proactively seek diverse suppliers. Through our supplier diversity program, we build relationships with businesses that are at least 51% owned by minorities, women and service-disabled veterans capable of providing commodities and services at competitive prices. By engaging and developing diverse value-added suppliers, we create a sustainable competitive advantage and build a supplier base that reflects our diverse customer base.
To help us identify diversity suppliers, we have activated the diversity module from our supply chain operating system, COUPA, which has a best-in-class Supplier Diversity suite, which allows WM to leverage Coupa’s extensive database to scrub, clean and verify WM’s 35,000+ supplier database 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), Lesbian, Gay, Bi-sexual, Transgender and Queer (LGBTQ) and Veteran Owned Businesses; Service-Disabled Veteran-owned Small Businesses (VBE/SDVQSB).
WM, in accordance with our business values and ESG 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 review, 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.