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Compliance & Ethics

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WM’s compliance and ethics program is aligned with our business operations and risk profile. The Corporate Compliance and Ethics Program’s scope includes compliance with all external laws and regulations as well as internal policies and procedures. It acts as a hub and closely collaborates with the other company compliance programs. The program is responsible for our SPEAK UP | LISTEN UP | FOLLOW UP culture, Code of Conduct and related training and communications, the Integrity Helpline, investigating select compliance and ethics matters, and our culture of compliance and ethics. It is also responsible for Compliance Audit Services, which is the independent auditor for Environmental, Health and Safety compliance.

The Vice President and Chief Compliance and Ethics Officer (CCEO) is responsible for the Corporate Compliance and Ethics Program. The CCEO reports directly to the Executive Vice President and Chief Legal Officer and has an independent reporting relationship to the Board of Directors. The CCEO provides regular updates to the Board of Directors and has discussions regarding important compliance and ethics topics and initiatives. Components of WM’s compliance and ethics program include:

Values-Based Culture

WM is committed to compliance with external laws and regulations, as well as ethical and values-based decision making. Our fundamental Commitments & Values support and promote our culture of compliance and ethics. We actively and visibly promote our Commitments & Values by incorporating them into all facets of business, as well as including them in our employee performance review process, company-wide communications and Values Ambassador Program.

Operationalizing Compliance and Ethics

WM continues to operationalize its compliance and ethics program through cross-departmental compliance and ethics committees and senior leadership forums. The committees have formal charters, documented agendas and meeting minutes. They cover a variety of risk areas, including business practices, compliance training, data privacy, employment practices, environment, fraud, immigration, international and anti-corruption matters and safety.

In addition to these committees, WM holds compliance and ethics senior leadership forums that engage leadership on major compliance and ethics initiatives and issues and allow for an open dialogue on how to strengthen our culture of compliance and ethics throughout the entire organization.

Training and Communication

Employees receive tailored and risk-based compliance and ethics training and communications. These are aligned with our Code of Conduct to provide employees with the information and resources they need to demonstrate our commitments and values. These online and in-person trainings and related communications are designed to engage employees by highlighting key takeaways and include messages from senior leadership, real-life scenarios, microlearning videos and links to related policies and procedures.

Continuous Programmatic Improvement

The CCEO, as well as the other compliance leaders, continuously assesses the effectiveness of the compliance and ethics program. This includes formal self-assessments, risk assessments and the ongoing analysis of data from a variety of sources to identify trends, mitigate risks and determine ways to enhance the program. These data include employee survey responses, training and communication engagement statistics, compliance and audit findings and case management system data.