Supplier Code of Conduct

WM’s supplier relationships are guided by its Supplier Code of Conduct (“Supplier Code”), which sets minimum expectations and guidelines for suppliers, consultants and contractors, including how to report compliance and ethics issues or concerns and information regarding our Integrity Helpline. It is reviewed annually, was revised most recently in 2025 and is available in English, Spanish and French. Since 2012, suppliers, contractors and service providers have received this Supplier Code as part of their contract signing (and with renewals and modifications of existing contracts). Although our Supplier Code is provided online for our suppliers and is appended to new contracts, renewals and modifications of existing contracts, we do not retain a form of acknowledgement from our suppliers.

WM is North America’s leading provider of comprehensive environmental solutions and has limited international operations. WM is committed to achieving success with integrity and operating in compliance with the anti-bribery and international trade laws and regulations of the regions in which we operate. This includes having policies and procedures related to the laws and regulations that impose trade and economic sanctions, control exports, restrict participation in certain foreign boycotts, address human rights, human trafficking and modern slavery, and regulate or restrict imports of merchandise. All Suppliers are required to read and adhere to WM’s Human Rights and Modern Slavery Policy.

WM has established an International Compliance Committee under the leadership of WM’s Vice President, Chief Compliance and Ethics Officer, to provide oversight and training with respect to international and trade activities and to help ensure compliance with international laws. This includes WM’s risk-based international counterparty due diligence and sanctions screening process.

WM provides periodic and targeted international compliance training, which, among other topics, includes anti-corruption and the Foreign Corruption Policies Act (FCPA), to employees who are involved in international activities. In addition to this training, every employee receives the annual WM Code of Conduct training, which is updated annually and includes topics related to anti-corruption, such as bribery, gifts and business entertainment, and interacting with government officials, among others. The WM employees involved in joint ventures also receive the training described above.

Ensuring Compliance

We conduct periodic business reviews with Tier I critical suppliers to help ensure contract and Supplier Code compliance. The Supplier Code includes these obligations:

Reviews are generally conducted 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 the 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. 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.

The Supplier Code also expects consultants, contractors and suppliers to speak up and report any known or perceived violation of laws, regulations, or applicable policies, and it provides information on how to speak up. Contact information includes the WM Integrity Helpline at 1-800-265-9381 (U.S. and Canada) or 001.877.801.2359 (India), the website (wm.com/speakup), or the WM Compliance and Ethics department (ethics@wm.com).

The WM Integrity Helpline is maintained by a third party, and is available to all consultants, contractors and suppliers. Reports can be made anonymously 24 hours a day, seven days a week. We also typically reserve the right to audit and inspect supplier operations during the term of the contract and for a limited time after termination.

Supplier Sustainability Risks

Our supply chain team, along with other corporate functions, works to help WM advance its sustainability-related goals. WM has implemented robust processes to help identify and mitigate significant risk factors within its supply chain, including the evaluation of environmental risk exposures. As part of this initiative, the company assesses Scope 3, Category 1 GHG emissions (purchased goods and services) using spend-based data, enabling prioritization of high-impact categories and suppliers. In an effort to promote sustainability, WM collaborates with key strategic supply chain companies to help establish circularity opportunities aimed at reusing and recycling materials. These initiatives have resulted in emission avoidance projects, such as incorporating recycled rubber, recycled plastics and biofuels into operations. We have established a process designed to identify key supplier risk factors and determine how to mitigate those factors. We observe and check the progress of the supplier risk profile over a period of time. 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.

Potential sustainability-related risks include financial and insurance-related risks (including compliance and governance considerations), and safety and health. In our mission of continuous improvement, we monitor insurance declarations through an automated system, checking for expired or out of date insurance declarations, which triggers notification to supply chain managers for corrective action; we conduct site visits and unannounced inspections of suppliers’ facilities, particularly with our top fleet suppliers; and we work closely with the operations in the field to observe the service level provided to our operations. Any slippage observed from a safety or service disruption standpoint may warrant a corrective action plan.

Improving Supply Chain Sustainability

All sustainability factors articulated in our procurement policy are considered important balancing criteria and must be considered in supplier selection. There is no formal weighting template. Compliance with regulatory standards is a mandatory threshold, with GHG emission 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-related goals, we began including the following sustainability clause in all our master service agreement contracts in 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 help direct conversations with suppliers and improve the opportunity to identify and implement new projects. A key component of this Playbook is the supplier sustainability questionnaire, which is designed to allow our suppliers to document their sustainability programs and have ongoing dialogue on potential joint sustainability-related activities.

The supply chain team has also initiated sustainability-related 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-related projects that the supply chain team manages is put into a sustainability project management tool that converts the material avoidance into a useful metric, utilizing the EPA’s Waste Reduction Model (WARM) calculations to capture estimated environmental impacts. This tool is the core supply chain sustainability reporting tool, allowing the supply chain team to systematically and consistently demonstrate its contribution to the overall sustainability-related program.

Other departments within WM and local operational locations play a vital role in supporting progress towards WM’s sustainability-related goals. The supply chain team works to align processes and procedures to the operational needs for services. The supply chain team relies heavily on daily interactions with its business partners to provide feedback through a collaborative supplier vetting process. Collaboration with WM’s Corporate Sustainability team is an ongoing internal communication focus, which allows the supply chain team to continuously improve reporting.

Committed to Small Businesses

WM’s Small Business Subcontractor Program’s mission is to be an advocate and ally for often-overlooked and underutilized small businesses. We do this by taking a grassroots effort through research and analytics to help us identify businesses that can support our operations at a market area level.

WM works with small businesses to make a difference in the lives of the communities we serve. Engaging and developing small and local businesses can create a more sustainable competitive advantage and build a supplier base that reflects WM’s values and commitments.

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.