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Code of Conduct

WM promotes a SPEAK UP | LISTEN UP | FOLLOW UP culture where employees SPEAK UP without the fear of retaliation knowing that we will LISTEN UP and FOLLOW UP. This culture is promoted through our Code of Conduct, compliance and ethics forums and committees, trainings, communications, screensavers and posters.

Our Code of Conduct is titled Do the Right Thing. The Right Way., which is our mantra to describe how we treat each other and how we conduct our business. The Code is structured and organized around our two fundamental commitments: Our People First and Success with Integrity. The Code begins with a letter from our CEO that highlights the importance of understanding and complying with our guidelines. It covers important compliance and ethics topics and outlines how our commitments and values impact our employees’ daily actions and decisions. The Code also includes an ethical decision-making visual and states WM’s expectations and guidance for its employees and leaders. In addition, it stresses the importance of our SPEAK UP | LISTEN UP | FOLLOW UP culture and highlights that WM strictly prohibits any form of retaliation against an employee who speaks up in good faith.

Our Fundamental Commitments

Our People First

The proud, caring and resilient members of the WM family are the foundation of our success. We commit to taking care of each other, our customers, our communities and the environment.

Success with Integrity

Our success is based not only on the results we achieve, but how we achieve them. We commit to being accountable, honest, trustworthy, ethical and compliant in all we do.

Our Core Values

Inclusion and Diversity

We embrace and cultivate respect, trust, open communications and diversity of thought and people.

Customers

We place our customers at the center of what we do and aspire to delight them every day.

Safety

We have zero tolerance for unsafe actions and conditions and make safety a core value without compromise.

Environment

We are responsible stewards of the environment and champions for sustainability.

The Code is designed to be reader-friendly and easy to use by including an interactive table of contents, Right Thing callout boxes to highlight key points, Right Way boxes to provide guidance on common situations, and links to related company policies and procedures. It is available in print and online in English, Spanish and French.

The Code applies to every WM employee and our Board of Directors. Signed acknowledgments are periodically required attesting that each recipient understands the responsibilities outlined. 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.

Employees and our Board of Directors receive periodic, risk-based training and communications related to select Code topics. Each year, WM administers a required Code of Conduct training that aligns with our commitments and values and is updated annually to feature different risk areas, topics and scenarios. In 2021, 100% of WM employees received training. The training requires participants to acknowledge that they understand their responsibilities for complying with the Code and reporting any violations to it or other company policies. Additionally, new hires are required to complete Code of Conduct training within a set period of time after joining the company. WM tailors its training content and delivery methods for different employees, including frontline deskless employees.

In addition to training, WM continues to focus on targeted compliance- and ethics-related communications that align with the risk areas outlined within the Code as well as information on our SPEAK UP process. The annual communication plan details the topics and modalities for effectively distributing these communications to employees through messages from senior leadership, posters, screensavers, company-wide emails and newsletters. They contain video messages from senior leaders, microlearning videos, key takeaways and links to related policies.

WM highlights a variety of reporting resources employees can use when speaking up, which include their supervisor, People Representative, any member of management, a WM employee in a different department or the Integrity Helpline, which is managed by a third party. In addition, a SPEAK UP questionnaire is sent to select employees, allowing them an opportunity to report any compliance and ethics issues or concerns that may not have been previously reported or properly addressed.

WM is committed to a timely, fair, efficient and confidential SPEAK UP process. This includes independent investigations, standardized policies and procedures, and active monitoring of our centralized case management system. The case management system captures compliance and ethics issues and concerns that are reported through our third-party Integrity Helpline. The system also captures reports that are made to the Compliance and Ethics Department, the People Organization, Corporate Security and Internal Audit.