Ethics & Diversity – Code of Conduct – Government
Focus on Integrity for our Government
and Regulatory Agencies
We partner with the government and regulators who oversee our business so that our operations and business practices are lawful.
Lobbying
It is essential that we are consistent in our approach to public policy issues. Employees must obtain prior approval from the Government Affairs Department to hire outside counsel or a public affairs firm to contact government officials about legislation, regulatory policy, or rule making. This includes grassroots lobbying contacts.
Political Activities
Waste Management encourages employees to participate in political activities on their own time and at their own expense. Such activities must not cause a conflict of interest. Employees should never put pressure on fellow employees to support or contribute time or money to a candidate or a political cause. When we participate in political activities, we do so as individual citizens. Employees are to never give the impression that they are speaking on behalf of Waste Management.
Political Contributions
Political contributions are made only in compliance with federal, provincial, state and local laws, and company policy.
A “contribution” is any direct or indirect payment, distribution, subscription, loan, advance, deposit, or gift of money, services or anything of value in connection with an election or to an organization or group formed to support or defeat a referendum or ballot issue.
Our employees are instructed to be aware of the following concerns and restrictions:
- In some states, companies are prohibited from making political contributions.
- Our Company never makes contributions to candidates running for U.S. federal offices.
- Cash contributions are prohibited.
- Contributions by Waste Management are administered by the company’s Political Action Committee (PAC).
- Waste Management will not directly or indirectly reimburse an employee or other person for political contributions he or she has made.
Regulatory Compliance
Waste Management operates in a highly regulated environment. The agencies that regulate our business include the Environmental Protection Agency, Department of Transportation, Internal Revenue Service, Occupational Safety and Health Administration, Department of Labor, and the Securities and Exchange Commission, plus many other federal, provincial, state and local agencies.
We must comply with the regulatory requirements of these agencies. We should take an active role by being knowledgeable about all laws and regulations, attending training and requesting information.
Employees are required to immediately report regulatory violations, suspected regulatory violations, or potentially harmful/dangerous conditions to a supervisor, manager, the Legal Department or the Business Ethics and Compliance Department.
Regulatory Agency Investigations, Inspections, and Requests for Information
We cooperate courteously with all government inspectors. We provide information they are entitled to during an inspection, investigation, or in response to a request for information. Notify area or corporate legal counsel immediately of any inspection, investigation, or request for information.
During a government inspection we never:
- Conceal, destroy, or alter any company documents
- Lie or make misleading statements to a government investigator
- Obstruct the collection of information, data, or records
- Attempt to cause another employee to fail to provide accurate information
Hiring Former Government Employees
The government’s rules on hiring its employees are complex. Our human resources provides guidance before discussing employment opportunities with a current or former government employee.
Doing Business Overseas
We have business relationships around the world. In some countries, we may encounter unfamiliar rules, regulations, customs, manners or cultures. However, in conducting our domestic and international business activities, it is critical that we comply with local laws and adhere to Waste Management’s values, standards and policies. Integrity serves as the foundation for all our business dealings. There are certain U.S. laws which govern our activities in international markets. It is important that any individual conducting business abroad be familiar with these laws and complies fully with them including the United States Foreign Corrupt Practices Act. This Act is intended to prevent bribery of foreign officials by American companies and their foreign subsidiaries. This law and company policy prohibits payments (including cash or anything of value such as gifts or services) either directly or indirectly or through a third party to foreign officials for the purpose of gaining business or favorable government action. This law allows for certain payment to foreign officials to facilitate routine government actions. However, before such a payment is made, it is essential that the Legal Department review the situation and approve the transaction.
When we focus on integrity for our government and regulatory agencies, we:
- Comply with both the spirit and letter of the law
- Conduct out interactions with honesty and integrity
