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.

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.

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

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.

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.

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

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.

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.

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.

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