How long has the WM Compliance Program been in existence?

WM's Compliance program started in August 2018 and continues to this day. It is important to say that a compliance program is constantly developing and improving according to different risks over time.

With Compliance, operations are protected from possible collateral damage that may occur during the import process

Because of its commitment to ethics in daily practices, we were winners of the 2019 Integrity Award. Recognition is the result of continuous work to ensure the safety of all involved in the company’s activities.

To manage and give a greater foundation to the Compliance Program, we have developed Policies that guide the company’s behaviors and guidelines.

These Policies address topics ranging from anti-corruption to the internal regulations of the Compliance Committee.

Commitment and transparency are basic values present in our culture, thus, following this aspect, we make some of these Policies available for access.

This way we can get closer to our stakeholders in ensuring compliance with current laws, and legal and internal policies established by the company.

If you still have any questions about the Program, please visit our FAQ.

Solve them with our explanations below:

How does WM protect itself and its customers from possible fraud, illegal acts and non-compliance?

WM performs periodic and constant due diligence on all its third-party intermediaries, as well as making them undergo training and sign Codes of Conduct. All steps are approved by the Compliance Committee and an audit is carried out on this information every 6 months. This is a procedure that seeks to minimize the risks of non-compliance and fraud for all the company's stakeholders.

What is the legal basis used by the WM Compliance Program?

WM is based on law 12.846/2013 to strengthen its Program.

Given the pandemic scenario, did WM take any action vis a vis maintaining the Program?

WM has developed the training of its third party intermediates online, so that there was a greater control and availability to all agents involved in our activities.

How is the protection of customer and supplier information done internally?

WM has a serious commitment to information security. We have encryption systems at various levels in order to prevent hackers from invading the system. In addition, we have an independent power generator system for maintaining these systems, so that power outages or problems derived from this do not impact the company's information security and consequently from its customers. All computer rooms are air -conditioned and properly studied to avoid short circuits and keep their full operation.

Does WM have any type of control over complaints or a means of communicating with its stakeholders to capture them?

WM has an independent ombudsman channel that aims to capture complaints, nonconformities, or any other type of unlawful act related to the public and private power. Not only for this, the reporting channel also serves to make compliments, suggestions and other comments.

Does the WM Compliance Program undergo any type of audit?

WM's compliance program undergoes an independent audit every six months. In this way new risks can be mapped, and therefore mitigated, as well as the guarantee that the program acts fairly with everyone involved in daily activities

How does WM promote the Compliance Program internally?

Aiming at the greater absorption of the program at WM, we promote campaigns from the time of hiring even the termination of the contract of all agents involved in our activities. We create constant training and maintain a strong organizational culture focused on the development and maintenance of the program. We apply constant training and close monitoring of all activities. In this way, we were able to map the Program's adherence and, therefore, its conservation.

How does WM promote its Program with internal and external audiences?

Through constant communications and training, WM is based on its culture a great involvement of high leadership with all sectors of the company. We follow the “Tone From The Top” model, where leaders are engaged in different compliance activities and constantly undergo new improvement training for later reflex in the program internally.

How do you give the relationship of WM with public agents - politically exposed people (PEP)?

WM has strict policies regarding meetings with PEPs and any other public official. Corruption prevention measures are taken both internally and externally and these are subject to strict control.

Does WM have any kind of control over potential conflicts of interest?

WM manages conflict of interests by adopting the principles of segregation of duties that may generate conflicts. Therefore, the company periodically applies the following controls:

A - Internal conflict of interest control B - Control of external interest conflicts C - Control of kinship conflict D - Conflict control favoring family members

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