Ethics & Diversity – Code of Conduct – Employees
Focus on Integrity for our Employees
Creating an environment of trust and respect for each other is the key to our future success.
Mutual Respect
In working together we emphasize teamwork, dignity, and mutual respect. We are fair, reasonable, and courteous in all of our interactions with each other.
Equal Employment Opportunity
We provide a positive working environment in which all individuals may grow, contribute, and participate free from discrimination. We are committed to lawful human resource policies and practices in all aspects of employment, including recruiting, hiring, evaluation, training, discipline, work and service assignments, career development, compensation, promotion, and termination. We will not tolerate unlawful discrimination of any kind.
Each employee is responsible for promoting a good working environment. It is our responsibility to treat our colleagues fairly without regard to race, color, religion, gender, age, national origin, marital status, or whether an individual is disabled, a veteran, or holds other protected status as defined by federal, provincial, state, or local laws.
Preventing Harassment
Behavior that targets an employee because of his or her race, color, religion, gender, age, national origin, marital status, disability, or veteran status or any other protected status as defined by federal, provincial, state, or local laws is prohibited. Such verbal or physical conduct that unreasonably disrupts another employee in his or her work is harassment. Each employee has the right to be free from improper or offensive conduct at work. Waste Management employees, customers, vendors, and visitors should be treated with respect, courtesy, and dignity. Unwelcome, insulting, or offensive remarks or actions have no place at Waste Management. To maintain a work atmosphere free from harassment, each employee should exercise good judgment in our relationships with coworkers.
If an employee experiences/observes workplace harassment, they should report the incident to a supervisor, Human Resources Department, Legal Department, Business Ethics and Compliance Department, Security Department, or any member of management for immediate resolution of the problem.
Safety and Health
Waste Management is committed to providing a safe and healthy work environment. We follow all federal, provincial, state, and local laws regarding workplace safety and health. Each employee must immediately report any work-related accident, illness, unsafe condition or practice to the appropriate supervisor or manager.
Alcohol and Illegal Drugs
We maintain a workplace that is free from the effects of drug and alcohol abuse. Alcohol abuse and illegal drug use threatens our ability to serve our customers. It compromises the safety of our products and services. Waste Management will not tolerate any use or abuse of drugs or alcohol while employees are engaged in company business or while working at a company location. All employees are subject to pre-employment screening, reasonable suspicion, periodic, and/or random drug and alcohol testing.
Employees, who are taking a prescription drug which may interfere with the ability to perform their job, must discuss the situation with an immediate supervisor or the Human Resources Department.
Employees are encouraged to contact the Employee Assistance Program for help with drug and alcohol related problems before these problems affect job performance.
Workplace Violence
We provide a safe working environment for everyone. Waste Management has a zero tolerance policy on acts of violence and verbal or physical behavior that could lead to or cause workplace violence. Waste Management does not tolerate violent behavior at our workplaces, whether committed by or against our employees. These behaviors are prohibited: making threatening remarks, causing physical injury to someone else.
Employees should use good judgment and inform their supervisor, manager, human resources or corporate security if they observe behavior that could be dangerous.
Privacy
Employee information and data are confidential and are used only for valid business purposes. This includes information in an employee’s personnel file such as Social Security number, home address, telephone number, medical information, and other confidential information.
While Waste Management respects employee privacy, employees should not expect privacy when using company provided services and equipment. We reserve the right to inspect our facilities and property, such as computers, telephone records, lockers, e-mail, internet usage, business documents, offices and other workplaces.
Confidential Information
Confidential company information and proprietary information is a valuable Waste Management asset. This includes among other things pricing and cost data, merger, acquisitions and divestiture information, business processes and procedures, financial data, trade secrets and know-how, computer programs, wage and salary information, marketing and sales programs, customer/supplier/subcontractor information and other information and developments which have not been released to the general public.
All of this information must be used solely for company purposes and never for personal gain. Confidential information must not be shared with anyone outside of Waste Management unless they have a legitimate need to know in order to do business with us. Inappropriate disclosure of confidential information may damage our business and the business of our customers, suppliers, and subcontractors.
Employees who have access to company confidential information must protect that information from disclosure. The duty to protect our information continues even after an employee leaves employment with Waste Management.
Conflicts of Interest
Each employee should base business decisions on the needs and interests of Waste Management rather than their own personal interests. Employees should not participate in any activity that could conflict with—or appear to conflict with—our responsibilities to Waste Management.
Any activity which might appear to present a conflict of interest must be approved in writing by a supervisor or a member of local management.
Here are some situations where conflicts of interest can occur:
Personal Business Relationships
Employees must take care that personal business relationships never influence the decisions made for our company. Employees must disclose any financial interests that they or their immediate family have in Waste Management’s suppliers, customers or competitors. As an exception to this rule, employees may own up to 2% of the stock of a publicly traded company that is a competitor, supplier, or customer.
Organizational Relationships
If an employee serves as a director, officer or consultant with any company that does business with us, they must disclose these obligations to the vice president of business ethics and compliance even if they receive no money for their services.
Corporate Opportunities
If employees become aware of a business opportunity that Waste Management would have an interest in pursuing, they cannot divert that opportunity for personal gain. Employees must make this opportunity available to Waste Management.
Outside Employment
Before employees accept employment outside of Waste Management, they consider whether this job could create a conflict of interest with their work here. Employees should not accept outside employment with our competitors, suppliers, or customers.
Use of Company Assets
The assets of Waste Management are intended to be used in a way that benefits our company. Employees must preserve these assets and use them wisely. The use of company time, equipment, supplies, and facilities for personal use or taking company owned equipment off company premises for personal use is permitted only when approved in advance by their department manager.
Accepting Gifts
Employees should never accept gifts that would appear to undermine or influence good business judgment. Employees should never solicit gifts or favors from the people with whom we do business. On occasion, employees may accept novelties, promotional items of a nominal value or modest gifts if:
- The gift complies with the giver’s company’s rules
- This happens only occasionally
- The gift was not solicited
- Open disclosure of the gift would not embarrass our company or the people involved
- The value of the gift is under $100.00 (U.S.)
Acceptance of cash gifts such as tips given during the holiday season is acceptable. However, employees should never ask for a tip. Tips must be given as outright gifts and not as payments for or with the expectation of extra services or pick-ups.
Accepting Entertainment
Employees may accept an occasional invitation to a sporting activity, entertainment or meals if:
- The activity is infrequent and of reasonable value
- The $100.00 (U.S.) limitation does not apply to entertainment
A representative of the company offering the invitation should be present. Moderation and appearance is the key.
Accuracy of Books and Records
Accurate record keeping is critical. We have a responsibility to accurately report all business information such as reporting of hours worked, business and travel expenses, shipping and receiving data, and financial figures in a timely and accurate manner.
No employee may falsify company information whether stored in writing or electronically.
All transactions must be properly authorized, completely and accurately recorded on the company’s books, and recorded in accordance with generally accepted accounting principles. No secret, undisclosed, or unrecorded funds or assets may be established or maintained for any purpose.
Retention and Disposal of Records and Documents
Business records and documents should be retained and destroyed in accordance with the company’s retention policy as well as department’s policies and regulatory requirements.
Quality
Quality services and products that meet or exceed our customers’ expectations will set Waste Management apart from our competition and assure our future success. It is our responsibility to understand our customer’s requirements and to satisfy those requirements with quality products and services.
Copyrights, Patents and Trademarks
Our intellectual property is a valuable asset. This includes copyrights, patents, and trademarks. We respect and protect intellectual property, whether it belongs to us or to others. We are prohibited from making unauthorized copies of copyrighted written documents or computer software.
Waste Management owns all inventions, discoveries, ideas, and trade secrets created by employees on the job or produced using company resources.
Insider Information and Securities Trading
We may learn of material, inside information about our company or about other companies before such information is known publicly. It is illegal to buy or sell stock based on inside information or to pass this information on to someone else who then buys or sells stocks. These rules apply to an employee’s spouse, children or other family members living in the same household and to trading in an individual’s trust account. To confirm the appropriateness of trading a security under these circumstances, employees should contact the Legal Department or refer to Waste Management’s policy on Insider Trading.
To assure compliance with the federal laws about insider trading, all directors, executive officers, designated executives and other employees in possession of material non-public information must seek clearance from the general counsel’s office prior to engaging in any transaction involving the company’s securities.
Use of Electronic and Computer Technology
Company provided electronic and/or computer technology, including email, voice mail, cellular telephones, personal computers, computer networks, software, access to the internet or other electronic services are the property of Waste Management. Limited, occasional personal use of the phone system, e-mail, internet and voice mail is acceptable provided that the use is appropriate and lawful. However, information created, received or disseminated through these systems is not private. Authorized company representatives may, without advance notice, monitor these systems.
These systems are not to be used to create, store or transmit information that is hostile, malicious, unlawful, sexually explicit, discriminatory, profane, or abusive. Employees should not send or receive messages that are derogatory toward others. Web sites, which contain illegal, sexually explicit, adult oriented, or discriminatory content are not to be accessed.
Our computers should be used in accordance with applicable software agreements, copyright, trademark, patent and other laws. These services, including internet chat rooms, should never be used to communicate company confidential, non-public or proprietary information, copyrighted information, or information which may be harmful to the company or its employees.
When we focus on integrity for our employees, we:
- Respect the dignity of each individual
- Listen openly to concerns and suggestions
- Approach disagreements with an open mind
- Carefully follow the laws and rules that govern how we conduct our business
