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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. With a primarily North American supply chain and employees and third-party contractors in the United States and Canada and an office in 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.

When we expand into new markets, we develop new policy documents to provide additional guidance on respect for human rights. For example, when we opened a service center in India, we created a Code of Conduct specific to that country. Having expanded beyond our traditional service areas in North America, we developed policies specific to global issues like slavery and human trafficking.

Our evaluation of human rights concerns is on-going both in terms of newly emerging concerns and the need to expand the scope of our review as our operational footprint expands. The policies and references below complement those cited in the summary of our Alignment with the UN Global Compact Ten Principles.

I. Policies & Commitments

WM Code of Conduct

“Do the Right Thing. The Right Way.” is a roadmap for how we align our daily actions with our Fundamental Commitments and Core Values. Our Code of Conduct outlines how we treat each other and how we conduct our business. It is founded on responsible, honest and ethical behavior, and the character of WM is defined by the personal integrity and honesty of its employees. WM’s Code of Conduct is in alignment with the Ten Principles of the United Nations Global Compact.

The WM Code of Conduct is the means to implement its human rights values and commitments. It provides the protections afforded by international human rights frameworks and covers WM employees who are located in North America and India. The Code of Conduct was updated in 2019, is distributed to our employees and available on our Compliance and Ethics website in English, French and Spanish.

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.

Human Rights Policy

Early in 2018, WM developed, approved and put into place a Human Rights Policy to underscore our commitment to human rights. The WM Code of Conduct is the means to implement the Human Rights 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.

WM’s Human Rights Policy is consistent with and incorporates the principles set forth in our policies that prohibit discrimination, child labor and human trafficking, modern slavery and forced labor. WM is committed to compliance with all applicable employment, labor, and human rights laws to ensure fair and ethical business practices are followed. WM’s respect for human rights is demonstrated in its employment practices, including non-discrimination, inclusion and diversity, minimum age requirements, freedom of association and respect for collective bargaining and fair compensation policies. 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.

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.

WM has a number of other internal and external policy documents and management guidelines on specific topics related to human rights, summarized in the table below. Day-to-day responsibility for embedding human rights in our operations lies with various departments and management practices. If the policy, procedure or commitment does not have a link, it is only available internally.

WM Human Rights Policy Documents
Issue Policies, Procedures & Commitments
Issue: Workplace Ethics Policies, Procedures & Commitments: WM Code of Conduct
Supplier Code of Conduct
Compliance & Ethics
Anti-Bribery Policy
Charitable Contribution Policy
Issue: Health & Safety Policies, Procedures & Commitments: Safety Policy
Supplier Code of Conduct
Supplier Safety & Health Declaration
Employee benefits that exceed national standards
Workplace Search & Inspection Policy to enforce a safe work environment
Lone Worker Safety Policy
Mobile Device Policy
Safe Workplace Policy
Issue: Labor Policies, Procedures & Commitments: Freedom of Association
Contingent Labor Policy and Program
Peer Review
Policy Prohibiting Discrimination & Harassment
US Equal Employment Policy
Whistleblower Protection Policy
Issue: Inclusion & Diversity Policies, Procedures & Commitments: WM Code of Conduct
Supplier Code of Conduct
Supplier Diversity Program
Board Diversity
Our Diversity Mission
Diversity of governance bodies and employees
Supplier Diversity Playbook
Issue: Supply Chain Policies, Procedures & Commitments: WM Code of Conduct
Supplier Code of Conduct
Supplier Diversity Program
Supplier Diversity Playbook
Issue: Impacts to Communities Policies, Procedures & Commitments: Environmental Justice
Charitable Giving Policy
Ethics hotline
WM Code of Conduct
Issue: Elimination of Human Trafficking Policies, Procedures & Commitments: Policy Against Human Trafficking and Modern Slavery

II. Awareness & Training

All employees are trained in the WM Code of Conduct, which references the Human Rights Policy, and we expect all to comply. Other trainings related to human rights include preventing harassment, discrimination training and diversity in hiring.

Our Compliance & Ethics team networks with groups focused on ethics in corporate management to keep abreast of best practices. WM is a member of:

  • Business Ethics Leadership Alliance (BELA)
  • Ethics and Compliance Initiative (ECI)
  • Society of Corporate Compliance and Ethics (SCCE)
  • Greater Houston Business Ethics Roundtable (GHBER)
  • Manufacturers Alliance for Productivity and Innovation (MAPI)—Compliance & Ethics

III. Due Diligence Process

WM reserves the right, where applicable, to conduct investigations and audits to verify that business is being conducted in compliance with this policy. All WM employees and third parties through whom WM conducts business are required to fully, accurately and promptly cooperate.

WM is committed to conducting business with the highest levels of integrity, in full compliance with the spirit and integrity of the laws of each country in which we operate as well as in full compliance with our Code of Conduct. We encourage anyone who believes that this policy has been violated to report their concerns to the Chief Compliance Officer. Reports may also be made through the WM Integrity Helpline at 800-265-9381 or its website, both of which allow anonymous reporting as permitted by applicable law.

Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy as permitted by applicable law. WM will not tolerate retaliation against an employee for reporting a concern in good faith or for cooperating with a compliance investigation, even when no evidence is found to substantiate the report.

Any violation of this policy may be grounds for disciplinary action, up to and including termination, subject to applicable law. Violation of applicable laws may also result in criminal prosecution of responsible individuals.

We expect our employees, contractors and suppliers to comply with the law in each place we do business and to abide by our Compliance & Ethics, Code of Conduct or, as applicable, our Supplier Code of Conduct. Implementation of compliance with the Code of Conduct is overseen by the Chief Compliance Officer.

WM is committed to complying with all applicable securities laws and regulations, establishing and maintaining adequate reporting controls, and supporting appropriate audit practices. Of critical importance to our ability to achieve these objectives is that WM employees may submit good faith complaints without fear of any form of retaliation. WM’s Audit Committee oversees treatment of matters submitted concerning human rights. More information on the treatment, reporting and retention of complaints is available on our website under Compliance & Ethics.

Employees are required to report any noncompliance with any international anticorruption law, including the FCPA to the Chief Compliance and Ethics Officer or to the WM Ethics and Compliance Integrity Helpline at 1-800-265-9381 in North America and 0001-877-801-2359 in India.

IV. Salient Issues

Salient human rights issues, in the language of the UN Guiding Principles Reporting Framework, are “the human rights at risk of the most severe negative impact through the company’s activities and business relationships.” While all human rights issues are of concern to WM, some salient issues have been identified as more likely than others to arise during our operations.

WM identifies salient human rights risks and assesses where they could occur in our operations and supply chain using multiple internal processes, and external stakeholders are consulted as appropriate. Risk assessment processes that include human rights-related risks include Enterprise Risk Management, online Ethics Integrity Helpline, measurement of employee and contractor safety performance, supply chain sustainability risk assessment, community environmental justice risk assessments, and procedures for communicating with labor organizations. WM then focuses its attention on the most severe risks to people and operations. Our management approach is based on the scale, scope, and extent to which the impact can be addressed. The following section briefly discusses our salient human rights issues and risk mitigation plans for each.

a. Safety

Safety isn’t just one of WM’s four core values, it is our top priority. Every WM employee, contractor and vendor has a critical role in understanding potential safety risks—most notably those associated with transportation incidents and unique workplace hazards.

Risk Mitigation:
  • We have zero tolerance for unsafe actions and conditions and make safety a core value without compromise.
  • Our plan of action is called Mission to Zero (M2Z), which means zero tolerance for unsafe actions, unsafe decisions, unsafe conditions, unsafe equipment and unsafe attitudes.
  • We conduct safety awareness and training and measure, monitor and disclose safety performance of our employees and contractors.

b. Freedom of Association

WM supports employees’ rights under Section 7 of the National Labor Relations Act (NLRA) which include the right to self-organization; to form, join or assist labor organizations; to bargain collectively through representatives of their own choosing; and the right to refrain from such activities. Our company policies and procedures adhere to all applicable domestic laws concerning freedom of association, nondiscrimination, forced labor and underage workers in the workplace.

Risk Mitigation:
  • We are currently signatory to 161 separate collective bargaining agreements in the U.S. and Canada, covering 9,026 employees in 2021 approximately, or about 21 percent of our workforce.

There were no work stoppages, strikes or lockouts in 2021. We do not believe any of our operations are at risk of infringing on the right to freedom of association, therefore zero sites have mitigation plans.

c. Contingent Labor

Our internal Contingent Labor Policy is applicable to all contract workers, temporary workers or other non-employee workers providing time- and expense-based work at WM outside of a Statement of Work agreement with Waste Management National Services, Inc.

Risk Mitigation:
  • We approach contingent workers with the same vision for teamwork, dignity and mutual respect with which we approach employees.
  • Our safety vision, diversity and non-discrimination policies fully extend to contingent workers.
  • Contingent workers are evaluated for opportunities for direct employment with WM and career development, with WM managers encouraged to seek opportunities for new contract labor when full-time opportunities open.
  • Our ethics hotline is available to contingent workers.

d. Supply Chain

WM strives to conduct business with those who share our commitment to the same principles, as outlined in the WM Code of Conduct and a separate Supplier Code of Conduct.

Risk Mitigation:
  • WM requires commitment to human rights from contractors and suppliers. To ensure this commitment is met, WM assesses human rights risks in its supply chain and includes in its supplier and service provider agreements a requirement that its business partners operate under business and ethics standards consistent with WM’s own standards.
  • The company is committed to developing a growing, diverse portfolio of viable and competitive small businesses, including those owned by minorities, women and service-disabled veterans, that will enable our company to increasingly use a supplier base that truly reflects the diversity of our customer base. Our goal is to have 10% growth in annual spend with diverse suppliers through 2038. The two main agencies we use to impact our diversity spend are the Women’s Business Enterprise National Council (WBENC) and the Minority Supplier Development Council (MSDC).

e. Living Wage

WM complies with all applicable rules governing minimum wage in North America. For the fraction of a percent of our employees living abroad, we comply with all applicable rules and pay locally competitive compensation rates.

Risk Mitigation:
  • WM currently pays 100% of our employees a living wage and has a goal to do so through 2025 and beyond.

WM’s commitment to a living wage applies to WM sites in the United States, Canada and India.

f. Impacts on Communities

WM’s goal is to help make communities in which we live and work safe, resilient and sustainable. We conduct ourselves in a safe, responsible and respectful manner while helping to build better communities, protecting our natural resources and doing the right thing. We focus on initiatives that support our employees, enhance our environment, promote education and improve the livability of our communities.

WM has specific guidelines regarding the programs it supports through charitable giving donations. We concentrate on initiatives that enhance our environment, promote education and improve the livability and resiliency of our communities.

We are responsible stewards of the environment and champions for sustainability. There are a variety of federal, state, provincial and local laws and regulations that apply to our business. We have developed processes and tools to achieve a high standard of environmental performance and compliance. These processes and tools have been pulled into one company-wide program that we call WM’s Environmental Management System (EMS). The focus of the EMS is integrating environmental functions into the core of our business. It enables us to reduce our environmental impacts and increase our operating efficiency. Every employee should be aware of our EMS. Our daily actions and decisions must reflect our commitment to advance environmental stewardship. We do this by aligning our environmental priorities with those of our customers, communities and regulators. This can be seen in our efforts to:

  • Reduce our use of natural resources.
  • Eliminate potentially harmful environmental impacts.
  • Foster a culture that considers the environment in every business decision.
  • Implement proactive environmental practices that differentiate us from our competitors.

Openly discussing the importance of protecting the environment supports this commitment and promotes a strong culture of compliance. WM has also completed an assessment of its siting and operations of its facilities, identifying sites in communities with income above the state average and below the state average, as well as assessing the non-Hispanic white representation in those communities. To mitigate the risk of our siting, we consult with local communities, and assess environmental justice in siting our operations and facilities and disclose the results of our assessment.

Human Trafficking and Modern Slavery

With increased concerns about human trafficking and modern slavery, in late 2017 WM developed and put into place a written Policy Against the Trafficking of Humans and Modern Slavery 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.