GFL Environmental : 2024 GRI Index (2024 GRI Index)

About this update from Gfl Environmental Inc

Statement of use GFL Environmental Inc. has reported the information cited in this GRI content index for the period 1 January 2024 to 31 December 2024 (unless noted otherwise) with reference to the GRI Standards. GRI 1 used GRI 1: Foundation 2021 GRI 2 - GENERAL DISCLOSURES DISCLOSURE LOCATION OR RESPONSE 2-1 Organizational details GFL Environmental Inc.'s (GFL) headquarters are located at 100 New Park Place, Suite 500, Vaughan, ON, L4K 0H9, Canada. GFL is the fourth largest diversified environmental services company in North America, as measured by revenue and North American operating footprint. Our operations are located across all 10 Canadian provinces and half of the states in the United States. GFL is publicly traded on the Toronto and New York Stock Exchanges under the trading symbol "GFL". See pages 29-38 of GFL's 2024 Annual Report for additional information. In this Index, "we", "us", "our", "GFL" and the "Company" refer to GFL Environmental Inc. and all entities controlled by it unless the context otherwise requires. 2-2 Entities included in the organization's sustainability reporting 2024 Annual Report - pg. 29-31, Corporate Structure 2-3 Reporting period, frequency and contact point Our reporting period is the 2024 calendar year unless otherwise noted. We report on an annual cycle. Comments and questions related to the information in this index can be directed to Investor Relations at [email protected] . 2-4 Restatements of information Any restatements of information and associated reasons are identified within GFL's 2024 Sustainability Report , 2024 Climate Report and 2024 Data Summary Table. Changes to our disclosures to exclude information regarding our Environmental Services business, including the soil remediation sites and operations, that were sold effective March 1, 2025, will be reflected beginning with our reporting for the 2025 calendar year. 2-5 External assurance Independent third-party verification of our 2024 scope 1, 2 and 3 greenhouse gas (GHG) emissions was completed in accordance with the ISO 14064-3 Standard 2-6 Activities, value chain and other business relationships 2024 Annual Report - pg. 29-47, Corporate Structure 2-7 Employees 2024 Data Summary Table - pg. 8-9 2-9 Governance structure and composition Our 2025 Proxy Circular contains information about GFL's Board of Directors and its committees. 2-10 Nomination and selection of the highest governance body 2025 Proxy Circular - pg. 10-12, Proposal 1 - Election of Directors; pg. 56-59, Committees of our Board Nomination, Governance and Compensation Committee Charter Inclusion Policy Corporate Governance Guidelines 2-11 Chair of the highest governance body 2025 Proxy Circular - pg. 13 Mr. Patrick Dovigi is the Founder, President, CEO and Chairman of the Board of GFL. | 2024 GRI INDEX GFLENV.COM | 1 GRI 2 - GENERAL DISCLOSURES DISCLOSURE LOCATION OR RESPONSE 2-12 Role of the highest governance body in overseeing the management of impacts 2025 Proxy Circular - pg. 56-59, Committees of our Board Board and Committee Charters 2024 Climate Report - pg. 5-7, Section 3. Governance 2025 CDP Response (for 2024 FY) - pg. 41-66, C4. Governance 2-13 Delegation of responsibility for managing impacts 2025 Proxy Circular - pg. A-2, Section 7 Delegations and Approval Authorities 2024 Annual Report - pg. 63-66, Committees of our Board of Directors 2024 Climate Report - pg. 5-7, Section 3. Governance 2025 CDP Response (for 2024 FY) - pg. 41-66, C4. Governance 2-14 Role of the highest governance body in sustainability reporting 2025 Proxy Circular - pg. 59-60, Sustainability Matters 2024 Annual Report - pg. 63-66, Committees of our Board of Directors 2024 Climate Report - pg. 5-7, Section 3. Governance 2025 CDP Response (for 2024 FY) - pg. 41-66, C4. Governance 2-15 Conflicts of interest 2025 Proxy Circular - pg. 50-51, Conflicts of Interest and Related Party Transactions Code of Ethics - pg. 3, Section 3.8 Conflicts of Interest Corporate Governance Guidelines - pg. 5, Section 10 Conflicts of Interest and Related Party Transactions 2024 Annual Report - pg. 67, Conflicts of Interest Our Annual Report discloses identified conflicts of interest. To our knowledge, there are no existing or potentially material conflicts of interest between the Company or a subsidiary of the Company and any director or officer of the Company or of a subsidiary of the Company. 2-16 Communication of critical concerns Audit Committee Charter As noted in disclosures above, the NGC Committee and Audit Committee are responsible for reporting to GFL's Board. This includes reporting on potential and actual impacts on stakeholders raised through grievance mechanisms and other processes. GFL's Whistleblower Policy includes a process for the anonymous reporting of complaints against the company. Our Board is updated on whistleblower complaints on a quarterly basis. 2-17 Collective knowledge of the highest governance body 2025 Proxy Circular - pg. 52, Skills Matrix; pg. 53-54, Orientation and Continuing Education | 2024 GRI INDEX GFLENV.COM | 2 GRI 2 - GENERAL DISCLOSURES DISCLOSURE LOCATION OR RESPONSE 2-18 Evaluation of the performance of the highest governance body 2025 Proxy Circular - pg. 57-59, Nomination, Governance and Compensation Committee Corporate Governance Guidelines - pg. 5, Section 11 Board Self-Assessment 2-19 Remuneration policies 2025 Proxy Circular - pg. 22-44, Proposal 3 - Advisory Vote on Executive Compensation 2-20 Process to determine remuneration 2025 Proxy Circular - pg. 22-44, Proposal 3 - Advisory Vote on Executive Compensation 2-22 Statement on sustainable development strategy 2024 Climate Report - pg. 4, Climate Strategy Sustainability Action Plan 2-23 Policy commitments We believe that we have appropriate policies and processes in place that align with UNGC Principles and the OECD guidelines that ensure that we are conducting our business operations responsibly. GFL has adopted corporate governance policies that include our Human Rights Policy, Code of Ethics, Supplier Code of Conduct, Environmental Policy and Anti-Corruption Policy, as well as a Whistleblower Policy. Our processes include regular updates to our Board of Directors on any material incidents that may arise. Copies of our policies and more information regarding our governance practices are available on our website here. 2-24 Embedding policy commitments GFL's Board is responsible for monitoring the implementation of procedures, policies and initiatives relating to corporate governance, risk management, corporate social responsibility, health and safety, ethics and integrity. The majority of our policies include provisions related to oversight and/or how the requirements of the policy are to be implemented in the organization. As we form or continue business relationships with our various partners, suppliers, contractors or other parties, we inform them of applicable policies (e.g. Supplier Code of Conduct) and any related obligations they may have. At the time of hire or onboarding, all GFL employees are required to review and acknowledge our corporate policies. Annually thereafter those employees with supervisory responsibilities (salaried and hourly) are required to re-acknowledge these policies. 2-26 Mechanisms for seeking advice and raising concerns Code of Ethics Whistleblower Policy 2-27 Compliance with laws and regulations 2024 SASB Report - pg. 2-3 2-28 Membership associations 2024 Data Summary Table - pg. 10 2-29 Approach to stakeholder engagement 2025 CDP Response (for 2024 FY) - pg. 93-94, C5. Business Strategy 2024 Sustainability Report - pg. 22-24, Our Communities 2-30 Collective bargaining agreements 2024 Annual Report - pg. 37, Employees | 2024 GRI INDEX GFLENV.COM | 3 2024 GRI Content Index GRI 3 - MATERIAL TOPICS DISCLOSURE LOCATION OR RESPONSE 3-1 Process to determine material topics In 2021 we undertook our first materiality assessment to ground our Sustainability Action Plan in what matters most to our business and our stakeholders, and to identify risks and opportunities in implementing our business strategy. In completing our materiality assessment, we considered the perspectives of our stakeholders including our employees, customers, and shareholders. The analysis also drew from desktop research and internal working sessions with our employees including our executive leadership. Our process for conducting materiality assessments is noted in the diagram below. Steps in Our Materiality Assessment Defined list of sustainability Finalized approach for Gathered and researched Incorporated GFL business Validated materiality topics and stakeholder groups desktop research, including stakeholder perspectives perspectives (internal) assessment results (informed by GRI Standard research sources and (external) and SASB) assessment methodology As we continue to implement the actions within our Sustainability Action Plan, we intend to review and update our materiality assessment as necessary to help inform our progress and identify new or emerging interests among our stakeholders as well as priorities for our business. 3-2 List of material topics GFL Materiality Analysis Priority Material Topics Environment Climate mitigation and resiliency Responsible waste management Recycling and recovery Innovation Environmental management system Social Health and safety Diversity, equity, inclusion and belonging Other Material Topics Governance Labour practices Potential to Impact Business Success Stakeholder Interest | 2024 GRI INDEX GFLENV.COM | 4 2024 GRI Content Index GRI 200 - ECONOMIC DISCLOSURE DISCLOSURE TITLE LOCATION OR RESPONSE GRI 201: Economic Performance 3-3 Management of Economic Performance 2025 Proxy Circular 2024 Annual Report - pg. 1 - 30, Management's Discussion and Analysis of Financial Condition and Results of Operations 201-1 Direct economic value generated and distributed 2024 Annual Report - pg. F1- F43, Consolidated Financial Statements for the year ended December 31, 2024 201-2 Financial implications and other risks and opportunities due to climate change 2025 CDP Response (for 2024 FY) - pg. 28-40, Section C3. Disclosure of Risks and Opportunities GRI 205: Anti-Corruption 3-3 Management of Anti-Corruption Human Rights Policy Code of Ethics Supplier Code of Conduct Anti-Corruption Policy 205-2 Communication and training about anti-corruption policies and procedures At the time of hire or onboarding, all GFL employees are required to review and acknowledge our corporate policies including our anti-corruption policies and procedures. Annually thereafter those employees with supervisory responsibilities (salaried and hourly) are required to re-acknowledge these policies. The anti-corruption policies provide that violations must be reported pursuant to our Whistleblower Policy, and our Board is updated on whistleblower complaints on a quarterly basis. In addition, GFL's Board annually reviews our corporate governance policies including our Anti-Corruption Policy. Our Supplier Code of Conduct also includes provisions to ensure conformance of our suppliers with our anti-corruption and anti-bribery policies. 205-3 Confirmed incidents of corruption and actions taken None. | 2024 GRI INDEX GFLENV.COM | 5

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