Supplier Code of Conduct

Last modified: 2/12/2020

At GFL Environmental, Inc. and its subsidiary and affiliated companies, “Green Today. Green for Life.” is more than just a motto. Every aspect of our business, from collecting and properly disposing of household waste, to solving complex environmental challenges for some of North America's largest businesses, is conducted with a view towards building a better tomorrow for our world. As such, GFL is built on a commitment to treating all workers with respect and dignity, ensuring safe working conditions, and conducting environmentally responsible and ethical operations. We strive to work with suppliers who demonstrate their commitment to sustainability by adopting environmental practices that seek to minimize their environmental impact as well as labor and health and safety practices that ensure the well-being of their employees. We expect our suppliers in the GFL supply chain, and their downstream suppliers, to hold to our same high standards, and embrace the following social, environmental, and ethical responsibilities.

Supplier Conformance with GFL’s Supplier Code of Conduct

  • Underlying Obligations. In addition to the responsibilities below, suppliers must comply with all applicable laws, legal regulations, and legally binding directives, and guidelines; and all obligations in any contract a supplier may have with us.
  • On-Site Work. Suppliers using our properties or facilities or accessing our customers' sites as our subcontractors will comply with all applicable policies and requirements that we will provide to you.
  • Shared Commitment and Cooperation. Suppliers will cooperate with any information requests or audits we may initiate to confirm their fulfillment of these responsibilities. Though we seek to work with suppliers to improve conditions, we may terminate our relationship with any supplier that fails to meet these responsibilities.

Labor and human rights

GFL is committed to upholding human rights of workers and treating them with dignity and respect. As a result, suppliers must manage their own workforce in order to achieve the following results:

  • Freely Chosen Employment and Fair Wages. All work must be voluntary, and all workers must be free to terminate their employment on reasonable notice. . Suppliers will pay legally-mandated wages and benefits, will comply with applicable laws regarding deductions from wages, and will be transparent with workers with the basis on which workers are paid.
  • Young Workers. Suppliers will not use child labor. The employment of workers below the age of majority as defined and permitted by applicable local law shall not be permitted in hazardous conditions and should only be permitted with the appropriate training in advance of commencing employment.
  • Employee Grievances. Suppliers are expected to permit workers to openly communicate and share grievances with management about working conditions without fear of reprisal or harassment.
  • No Discrimination or Harassment. Suppliers are expected to provide a professional atmosphere for employees which promotes equal opportunities and prohibits discriminatory practices.

Health and safety

GFL’s highest focus is always on the safety of our employees. We expect the same from our Suppliers. Suppliers will abide by the following health and safety management requirements:

  • Occupational Safety and Health. At a minimum, Suppliers will comply with all applicable safety and health laws and regulations. Suppliers will implement procedures to prevent, manage, track, and report occupational injury and illness. Suppliers will ensure they have proper emergency preparedness plans and that workers are properly trained for such contingencies.
  • Proper Equipment. Workers will have access to proper equipment, and materials to conduct their work safely. Suppliers will comply with applicable laws regarding such equipment and materials.

Environmental

GFL’s core expertise is providing environmentally sound solutions to some of the largest companies and municipalities in North America, where it conducts its operations. Suppliers will strive to create sustainable processes and will commit to being forward thinking and environmentally responsible in all their business activities. In addition:

  • Environmental Permits and Reporting. Suppliers will obtain and keep current all required environmental permits, approvals, and registrations, and follow the operational and reporting requirements of such permits, etc. and on request, provide GFL with copies of such permits, etc
  • Resource Efficiency and Clean Energy. Throughout their operations, suppliers will work to reduce consumption of resources, including raw materials, energy, and water. Suppliers will seek to minimize energy consumption and greenhouse gas emissions, and seek ways to improve energy efficiency and use cleaner sources of energy.
  • Waste, Wastewater, and Stormwater Management. Suppliers will manage and control all waste streams to comply with applicable laws and regulations, and in an environmentally responsible and secure way.

Ethics and compliance

Suppliers will uphold the highest standards of ethics to promote honesty and integrity in business operations, including:

  • Business Integrity. Suppliers will avoid even the appearance of conflicts of interest in their work with us. Suppliers will accurately reflect their business dealings in their books and records. Suppliers will implement monitoring and enforcement procedures to ensure compliance with anti-corruption and anti-bribery laws.
  • Privacy and Information Security. Suppliers will protect the privacy of personal information of everyone with whom they do business, including suppliers, customers, consumers, and workers.

Compliance

Suppliers will take all reasonable steps to monitor their own compliance with this code of conduct and to diligently correct identified instances of non-compliance. GFL reserves the right to audit this compliance at any time, and to request records, documents, and other information to verify Supplier’s commitment to, and compliance with, this code of conduct including a self-assessment questionnaire

References

The following documents were reviewed in the creation of this policy:

Responsible Business Alliance Code Of Conduct (previously known as the electronic industry citizenship coalition)

United Nations Guiding Principles on Business and Human Rights

Universal Declaration of Human Rights