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, compliance and ethics risk assessments, 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 Audit Committee of the Board of Directors. The CCEO provides regular updates to the Audit Committee of the Board of Directors and has discussions regarding important compliance and ethics topics and initiatives.

Values-Based Culture

WM is committed to compliance with external laws and regulations, as well as ethical and values-based decision making. Our Commitments & Values support and promote our culture of integrity. 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, incentive and recognition programs such as our Integrity in Action Award, company-wide communications, trainings, and employee IMPACT groups.

Equal Opportunity Employer

WM is an equal opportunity employer and is committed to maintaining a workplace environment free from discrimination. Employment decisions are made by placing the most qualified person in each job without regard to race, color, sex, pregnancy, sexual orientation, gender identity, relation, marital status, age, national origin, disability, genetic information, veteran status, citizen status or other protected group status as defined by federal, state or local laws. In Canada, we comply with the Employment Equity Program laid out by the Canadian Federal Contractors Compliance Criteria.

Code of Conduct

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. The Code covers important compliance and ethics topics and outlines how our commitments and values impact our employees’ daily actions and decisions. It 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.

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.

SPEAK UP | LISTEN UP | FOLLOW UP

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.

WM highlights a variety of reporting resources employees can use when speaking up, which include their supervisor, Human Resources 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, and the ability to disclose any potential or actual conflicts of interest.

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, Human Resources, the HR Investigation Center of Excellence, Corporate Security, and Internal Audit. No matter how an issue or concern is reported, it will be reviewed and appropriately investigated based on the information provided.

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, as well as information on our SPEAK UP process. 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, key takeaways, and links to related policies and procedures.

Each year, WM administers a required Code of Conduct training that is updated annually to feature different risk areas, topics, and scenarios. All WM employees receive this 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 desk-free employees.

Operationalizing Compliance and Ethics

WM continues to operationalize its compliance and ethics program through cross-departmental compliance and ethics committees and senior leadership and manager compliance and ethics 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 forums that engage leadership and varying levels of managers 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.

International & Trade Compliance

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 they 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.

WM has established an International Compliance Committee under the leadership of the Company’s VP, CCEO to provide oversight and training with respect to the Company’s international and trade activities. This includes the Company’s risk-based international counterparty due diligence and sanctions screening process.

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. This data includes employee survey responses, training and communication engagement statistics, compliance and audit findings, and case management system data.

Human Rights

WM endeavors to respect human rights throughout our operations and in our relationships with vendors, suppliers, partners and the communities we serve and in which we live and work. WM is committed to compliance with all applicable employment, labor, and human rights laws to ensure fair and ethical business practices are followed.

To solidify this commitment, WM developed, approved, and put into place a Human Rights & Modern Slavery Policy. The Human Rights policy is guided by the Ten Principles of the United Nations Global Compact and is in accordance with The Universal Declaration of Human Rights, the International Bill of Human Rights and the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work. The Human Rights Policy applies to all personnel employed by or engaged to provide services to WM, including, but not limited to, WM’s employees, officers and Board members, and contingent workers, as well as WM’s contractors and suppliers.

With a primarily North American supply chain and employees and third-party contractors in the United States, Canada and India, we have processes in place to identify and assess the risk of potential human rights issues including the issues relevant to our countries of operation and more broadly across our supply chain. WM further demonstrates its dedication to human rights in the commitment to providing healthy, safe, and secure workplaces, and to promoting the health and safety of the communities in which it operates.

Human Trafficking and Modern Slavery

With increased concerns about human trafficking and modern slavery, WM developed and put into place a written Human Rights & Modern Slavery Policy to bring awareness of this important issue as our employees work and travel, both for business and otherwise. The WM Code of Conduct and Supplier Code of Conduct include references to this policy. We do not believe our workforce is at risk for incidents of child or forced/compulsory labor.