Compliance - Recology
California Cont.

At Recology, we are committed to acting ethically in everything that we do. As an employee-owned company, we have a heightened sense of our commitment to the communities we serve, and we have an employee-ownership structure that fosters a culture of teamwork and accountability. How we conduct business reflects directly on our individuals, and we take that very seriously. Acting in an ethical way is the right thing to do and fosters a sustainable business—one where employees, businesses, and communities trust each other and are invested in our shared success.

Our compliance program helps guide our employee-owners at every level of the company, from the day-to-day operations to the boardroom and top-level executives. The compliance program is built upon a culture of ethical decision-making and sound judgment: doing the right thing is incentivized, empowering employees to speak up is prioritized, and following up on reported concerns is expected. We provide our employees with the training and the tools they need to perform their roles with integrity and to protect our company’s ethical standing by complying with all legal and ethical obligations.

Our leaders must set the tone at the top that demonstrates our commitment to acting with the highest ethical standards. This starts with oversight by our board of directors, our executives, and our corporate and operational leadership and management. Leaders at all levels and departments are empowered to embody our Guiding Principles and set an example for exemplary ethical conduct.

Our employee-owners are empowered to act with integrity in every aspect of their jobs and speak up when something is not right. Our culture of compliance supports the ethical actions of our employee-owners, including raising questions or reporting concerns through our various communication avenues, such as the Ethics & Compliance Hotline.

Our written policies and procedures provide guidance to our employee-owners, partners, and third parties on our guiding principles and our expectation that, when conducting business on behalf of Recology, they will comply with all our legal and ethical obligations. Our Code of Conduct summarizes the key ethical expectations including compliance with both the letter and the spirit of all applicable laws and regulations. The Code of Conduct applies to all Recology employee-owners, members of the Board of Directors, and anyone else acting with, for, or on behalf of Recology, including agents, consultants, and lobbyists.

We conduct training regularly to ensure our employee-owners understand the ethical and legal obligations applicable to their job functions and geographic areas. Employee-owners receive training on a range of topics, from Anti-Bribery and Anti-Corruption, conflicts of interest, gifts and entertainment to public officials and employees, charitable and political contributions, and our Code of Conduct.

We have several systems in place to help detect, deter, and prevent unethical behavior. These systems include software that tracks charitable and political contributions, government reporting requirements, case management for reported concerns, and an independent helpline and website for reporting ethical concerns.

We conduct compliance audits and continually monitor the compliance program so that it can evolve to account for new and changing risks. Our internal enterprise risk management team works with outside expert partners, including a renowned accounting firm, to conduct specialized risk assessments in addition to a regular enterprise risk assessment.