Waste Management Inc

**POLITICAL CONTRIBUTIONS** We periodically make financial contributions to candidates who we believe recognize the value of the services we provide and the importance of environmental sustainability along with a fair, free-market approach as the best way to deliver cost-effective services. All political contributions are to promote the business interests of the company, as they may be affected by public policy decisions, without regard to political preferences of WM executives. We do not expect the candidates to whom we contribute to always agree with our positions on all issues. Contributions made to candidates must comply with company policy, and all applicable, federal, state, and local laws. **CONTRIBUTIONS PROCESS, CRITERIA AND DISCLOSURE** WM's Government Affairs Department is responsible for executing the company's policy and advocacy agenda. All contributions made to political candidates must be authorized by the Government Affairs Department. Contributions are made with funds from the WM Employees Better Government Fund Political Action Committee (WMPAC) or, where legally permissible, corporate dollars. - Participation in the WMPAC by eligible WM employees is voluntary. - Senior members of the company's Government Affairs Department initiate requests for political contributions. In the case of WMPAC contributions, the WMPAC Assistant Treasurer must give his approval. The WMPAC Assistant Treasurer is also the company's Vice President – Government Affairs & Legal. The company's Executive Vice President and Chief Financial Officer serves as WMPAC Treasurer, and its Executive Vice President and Chief Legal Officer serves as the WMPAC Chairman. - In states where it is permissible to use company dollars for contributions, the respective manager of government affairs in the state must approve contribution requests, subject to an annual, cumulative contribution limit to a candidate or political party campaign entity of $2,500. After reaching that limit, the WMPAC Assistant Treasurer must review and give approval. The state government affairs manager is responsible for assuring compliance with applicable state and local laws. No contribution may be made until entered by the state government affairs compliance coordinator into a centralized corporate political contribution data base. No contribution will be made unless and until all necessary approvals are provided. - Criteria upon which contribution decisions are made include such factors as positions on public policy issues important to WM, inclusion in committees of jurisdiction over issues impacting the company, leadership positions, diversity caucuses and representation in districts/states where we have significant operational presence. - Information on contributions made by the WMPAC or the company is available on the relevant federal or state election commission campaign contributions disclosure site. - Following each two-year election cycle, the Board of Directors discusses the detailed accounting given by the Executive Vice President & Chief Legal Officer and the Vice President, Government Affairs & Legal on political contributions by the company, including those from the WMPAC and corporate contributions. - WM will not directly or indirectly reimburse an employee or other person for political contributions. **ORGANIZATIONS WE SUPPORT** WM is a member of and pays dues to a host of business and trade associations at the national and state level. These associations are important partners in a variety of public policy issues and activities. At times, however, the company may disagree with or actively oppose a position adopted by a business or trade association of which it is a member. Requests to join business and trade associations performing federal lobbying are reviewed and approved by the WMPAC Assistant Treasurer.

WM manages these risks by influencing regulations through engagement with our trade associations and peers within our industry. This not only allows us an opportunity to leverage regulators with industry expertise and real-world application, but also aid in establishing appropriate implementation timelines and avoiding potential conflicts between competing regulations. Aligning timelines and resolving problematic rules is key to ensure WM is adequately prepared for new requirements and regulations. [...] WM manages EPR by influencing regulations through engagement with our trade associations and industry peers. WM is working with states considering EPR to ensure that our assets and existing contracts are recognized and protected. WM is also working with producers to ensure that they recognize WM's capabilities and position WM as the vendor of choice for the producers when EPR is implemented. By continuing to invest in new technology, machinery and processes, we will capture and recycle more material, thereby preparing to meet growing demand for recycled content in the years to come.

Several policy issues represent significant challenges for our industry and are areas of special focus for WM. WM's public policy team coordinates its policy positions on topics across the country while also recognizing the local nature of our business. Regional policy and regulatory variations are considered and coordinated with broader corporate policies. For WM's most up-to-date information related to our stance on policy issues, please refer to the most current 10K and our Participation in the Political Process document.

Our executive officers have primary responsibility for risk management within our Company. A key component of this process is WM's enterprise risk management (ERM) framework. We believe that our leadership team's engagement and communication methods are supportive of comprehensive risk management practices, including climate-related risks and consideration of mitigation through climate-related opportunities. Consideration of such risks and opportunities has long been a part of WM's business, including evaluating strategy for investment and risk/opportunity forecasts of WM's climate-related services, in particular, recycling, renewable energy and fuel production, fleet emissions reduction, and sustainability advisory services. As North America's leading residential recycler and a major producer of renewable energy from waste, climate-related services are core to our operations. [...] Comprehensive oversight of the ERM process is provided by the Executive Vice President and Chief Financial Officer and the Executive Vice President and Chief Legal Officer, both who report to the Chief Executive Officer. Additionally, our CSO leads the Company in the areas of climate-related risks and opportunities and also reports directly to the Chief Executive Officer. The CSO oversees the work of our climate impact, carbon footprint and climate risk analysis, as well as various issues related to our service offerings that address customer goals related to climate change, including benchmarking national accounts and municipal customers to determine the scope and nature of our customers' sustainability goals. The CSO also holds responsibility for managing information on climate-related issues, developing strategy, and adapting decisions based on climate-related information as necessary. WM has a robust cross-functional team of individuals reporting to the CSO who assist with identifying and developing climate-related opportunities and assessing, managing and mitigating climate-related risks. [...] We are active in support of public policies that encourage development and use of lower carbon energy and waste services that lower users' carbon footprints.

**POLITICAL CONTRIBUTIONS** We periodically make financial contributions to candidates who we believe recognize the value of the services we provide and the importance of environmental sustainability along with a fair, free-market approach as the best way to deliver cost-effective services. All political contributions are to promote the business interests of the company, as they may be affected by public policy decisions, without regard to political preferences of WM executives. We do not expect the candidates to whom we contribute to always agree with our positions on all issues. Contributions made to candidates must comply with company policy, and all applicable, federal, state and local laws. **CONTRIBUTIONS PROCESS, CRITERIA AND DISCLOSURE** WM's Government Affairs Department is responsible for executing the company's policy and advocacy agenda. All contributions made to political candidates must be authorized by the Government Affairs Department. Contributions are made with funds from the WM Employees Better Government Fund Political Action Committee (WMPAC) or, where legally permissible, corporate dollars. - Participation in the WMPAC by eligible WM employees is voluntary. - Senior members of the company's Government Affairs Department initiate requests for political contributions. In the case of WMPAC contributions, the WMPAC Assistant Treasurer must give his approval. The WMPAC Assistant Treasurer is also the company's Vice President – Government Affairs & Legal. The company's Executive Vice President and Chief Financial Officer serves as WMPAC Treasurer, and its Executive Vice President and Chief Legal Officer serves as the WMPAC Chairman. - In states where it is permissible to use company dollars for contributions, the respective manager of government affairs in the state must approve contribution requests, subject to an annual, cumulative contribution limit to a candidate or political party campaign entity of $2,500. After reaching that limit, the WMPAC Assistant Treasurer must review and give approval. The state government affairs manager is responsible for assuring compliance with applicable state and local laws. No contribution may be made until entered by the state government affairs compliance coordinator into a centralized corporate political contribution data base. No contribution will be made unless and until all necessary approvals are provided. - Criteria upon which contribution decisions are made include such factors as positions on public policy issues important to WM, inclusion in committees of jurisdiction over issues impacting the company, leadership positions, diversity caucuses, representation in districts/states where we have significant operational presence. - Information on contributions made by the WMPAC or the company is available on the relevant federal or state election commission campaign contributions disclosure site. Following each two-year election cycle, the Board of Directors discusses the detailed accounting given by the Executive Vice President & Chief Legal Officer and the Vice President, Government Affairs & Legal on political contributions by the company, including those from the WMPAC and corporate contributions. - WM will not directly or indirectly reimburse an employee or other person for political contributions - Compliance with all applicable federal, state and local requirements regarding political contributions as well as the provisions of this policy are part of the WM Code of Conduct. Each employee of the company, as well as all officers and directors, are given a copy of the Code of Conduct when they join the company and updates are provided as revisions are made. In connection with annual Code of Conduct training, signed acknowledgments are required attesting that each recipient understands the responsibilities outlined. We expect employees to report violations, and we provide an anonymous and confidential Integrity Help Line should a concern arise. The Integrity Help Line reporting, annual Business Ethics questionnaire and whistleblower processes in accordance with the Code of Conduct are reviewed, audited and verified by an outside auditing firm. **ORGANIZATIONS WE SUPPORT** WM is a member of and pays dues to a host of business and trade associations at the national and state level. These associations are important partners in a variety of public policy issues and activities. At times, however, the company may disagree with or actively oppose a position adopted by a business or trade association of which it is a member. Requests to join business and trade associations performing federal lobbying are reviewed and approved by the WMPAC Assistant Treasurer.

**Annual Total Monetary Contributions to and Spending for Political Campaigns, Political Organizations,** **Lobbyists or Lobbying Organizations, Trade Associations and Other Tax-Exempt Groups** Federal Lobbying, Interest Representation or Similar $264,344 $250,000 $260,000 $310,000 Local, Regional or National Political Campaigns/Organizations/ $572,558 $392,814 $210,350 $223,817 Candidates Trade Associations or Tax-Exempt Groups $550,241 $989,392 $860,605 $916,341 (e.g., think tanks) Other (e.g., spending related to ballot measures $18,500 $18,500 $10,500 $0 or referendums) Total Contributions and Other Spending $1,405,643 $1,650,706 $1,341,455 $1,450,158 **Contributions to or Expenditures to Trade Associations to Influence Political Campaigns or Public Policy and Legislation** _Note the amounts are based on the information provided by the association or organization. WM PAC contributions are excluded and_ _[can be found in our publicly available disclosure Participation in the Political Process.](https://sustainability.wm.com/downloads/WM_Participation_in_the_Political_Process.pdf)_ WM works with NAM to address key issues facing the waste and recycling industries, including trade barriers to recycling, renewable electricity and fuel policies, congressional engagement on sustainability matters and environmental justice. WM works with ETC to address specific issues facing our hazardous business units, including advocacy and agency outreach on improvements to the tracking of hazardous waste shipments, destruction and disposal of materials containing per- and polyfluoroalkyl substances, and the long-term storage and management of elemental mercury. WM works with NWRA to address a wide range of federal and state issues, including tax reform, incentives to increase domestic recycling infrastructure, environmental policies impacting landfill and recycling operations, extended producer liability, international recycling standards, vehicle safety and employee health issues, infrastructure permitting, safety, the impacts of tariffs on recycling markets, recycling infrastructure legislation, the emerging contaminant PFAS (commonly found in discarded household products) and other workforce development issues. WM advocates EPA's Renewable Fuel Standard Program as well as federal and state incentives to produce and use renewable transportation fuel and renewable electricity. ISRI represents the interests of the scrap recycling industry and its members at the federal and state level as well as regulatory agencies and international bodies around the world. WM participates in several committees including the Paper Stock Industries (PSI), the Plastics Division and the MRF Committee.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes