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Principle Statement:

3M is committed to engaging in fair and vigorous competition, in compliance with all antitrust and competition laws and regulations globally. Certain business activities such as agreements between competitors that fix prices, always violate these laws and this Principle. Many other business activities, such as certain restrictive supply or distribution agreements or unfair use of a strong market position to harm competition, may violate these laws and this Principle. Because antitrust and competition laws vary from country to country and are complex, 3M employees must consult their business unit’s assigned 3M legal counsel whenever their business activities might be regulated by these laws.

Purpose:

This Principle helps ensure that 3M complies with all antitrust and competition laws globally. Failure to comply with these laws could lead to criminal and civil penalties for 3M and for employees personally, significant business disruptions, and harm to 3M’s reputation.

This Principle applies globally to all employees and may apply to third parties acting on behalf of 3M.

See the Compliance Principle for information on when a third party might be covered by the Code of Conduct Principles.

Additional Guidance:

  • Any proposed discussions with competitors must be reviewed with your assigned 3M legal counsel in advance.
  • Do not propose or reach an agreement or understanding with any competitor regarding any aspect of competition, including:
    • Prices
    • Terms or conditions of sale
    • Bids or bidding activities
    • Allocations of customers, channels, or product lines
    • Allocations of territories or geographies
    • Production, capacity or volumes
    • Industry or market conditions
    • Costs, profits or margins
    • Whether or not to do business with any customer, supplier, or other firm
  • Avoid discussions or interactions with competitors that may create the appearance of improper agreement or interaction.
  • Seek clearance from your assigned 3M legal counsel before joining or participating in trade associations or standard-setting organizations.
  • The application of antitrust competition laws is complex, and you should consult with your assigned 3M legal counsel early, as you begin considering any of the following arrangements:
    • Exclusive sale or purchase arrangements
    • Relations with or terminations of distributors
    • Selective price discounting
    • Bundling of goods or services
    • Restrictions on resale of 3M products or services
    • Technology licensing agreements that restrict the licensee or licensor
    • Activities or programs designed to gain or maintain a dominant market position

Penalties:

Failure to comply with antitrust and competition laws could lead to criminal and civil penalties for 3M and for you personally, significant business disruptions, and harm to 3M’s reputation. Violations of 3M’s Code of Conduct will result in discipline, up to and including termination from employment.