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Principle Statement:

3M employees and those third parties to which this Principle applies must comply with all legal requirements regarding the recruitment and hiring of past and current government employees and elected officials, including members of their immediate families. Whether 3M wants to retain someone as an employee or a consultant, laws restrict what may be discussed with these people, when such discussions can occur, when government employees can be hired, and the type of work they may do for 3M. 3M employees must obtain prior clearance from 3M Human Resources staff before discussing possible 3M consulting or employment or making offers to hire former or current government employees or their family members.

Purpose:

Hiring or discussing possible employment with former and current government employees could create the perception, even if inaccurate, that 3M is attempting to influence or reward the government employee’s decision to purchase 3M’s products or influence how laws and regulations affecting 3M are enforced. To avoid the appearance of improper influence, it is important to follow this Hiring Former and Current Government Employees Principle.

This Principle applies globally to all employees and may apply to those 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:

  • Many countries have laws that regulate the hiring, as employees or consultants, of former or current national, state, province, or local government employees. 3M employees must:
    • Comply with all laws and regulations concerning the recruitment and employment of former and current national (military and civilian), state, provincial, and local government employees.
    • Consult with the business unit’s assigned legal counsel, or in the U.S., with the Government Contract Compliance Department, with questions.
    • Consult with 3M legal counsel before contacting former or current national, state, provincial, or local government employees regarding employment, either as 3M employees or consultants.
  • The laws and regulations that govern the recruitment and employment of former and current government employees are frequently complex. Applicable laws and regulations may: (1) place restrictions on discussions of employment opportunities with certain government employees, either as an employee or consultant; (2) prohibit 3M from hiring certain former or current government employees for a certain period of time, either as an employee or consultant; and/or (3) place restrictions for certain periods of time on the type of work that certain former government employees may perform for or on behalf of 3M after they have been hired, either as an employee or consultant.
  • Consistent with this Principle and applicable local laws, obtain prior clearance from 3M Human Resources before discussing possible 3M consulting or employment, or making offers to hire (whether the discussions are in person, by telephone, fax or e-mail) with:
    • Any current or former national (military or civilian), state, province or local government employee or legislator; or
    • Any family member of a current or former national, federal (military or civilian), state, provincial, or local government official.
  • The U.S. Foreign Corrupt Practices Act and other countries’ bribery or corruption laws may consider the hiring of a family member of a Government Official as bribery, depending on why the family member was hired, his or her qualifications, and the Government Official’s ability to make decisions that could affect 3M business. Consult the Anti-Bribery Principle for information on the definition of a “Government Official”. Relatives of Government Officials may be hired by 3M. However, special care must be taken when an applicant is the close relative (such as a spouse, child, sibling, niece, nephew, aunt or uncle) of a Government Official who is in a position to influence a decision related to the purchase, prescription, or use of a 3M product or 3M service, or to any other governmental action that would benefit 3M’s business. In such cases, close relatives of that Government Official may be hired only if:
    1. the individual hired meets standards and qualifications that apply to all individuals that 3M hires for similar roles;
    2. the position was properly approved with a clear business purpose and not created as a special position for the relative; and
    3. the individual hired follows the transparency and conflict of interest procedures 3M expects of all employees when interacting with Government Officials.
    But, if the candidate is only being considered because of his/her relatives’ ability to influence a decision in 3M’s favor, the candidate may not be hired. In such circumstances, even offering that candidate employment could violate this Principle.
  • In the United States, applicable laws and regulations vary according to the employment status of the U.S. government employee (whether active or retired, whether a Department of Defense or civilian agency employee, whether an enlisted member of the military or a commissioned officer, and whether an employee of the Executive Branch or Legislative Branch), whether the employee or his/her subordinates were involved in any matter that affected 3M’s financial or business interests, the employee’s last salary grade or rank while in government service, and the length of time since the employee left government service. Each situation must be considered on a case-by-case basis. Human Resources and the Government Contract Compliance Department in the U.S. have a collaborative process in place to disclose and consider relevant information.
  • Postpone any discussions about possible 3M employment or consulting relationships that are initiated by current or former national, state, province or local government employees or legislators until you have consulted with Human Resources, your assigned 3M counsel or, in the United States, Government Contract Compliance Department, and it is determined that such discussions are legally permitted.
  • Former national, state, province, or local government employees or legislators who become 3M employees or consultants must follow all government conflict of interest (“revolving door”) laws applicable as a result of their former government employment. Generally speaking, this means that they must avoid involvement with any 3M matter in which they or their subordinates were significantly involved while employed by the government. 3M must also ensure the former government employee does not disclose to 3M any inside information he or she learned while in government service that could give 3M an improper advantage in competitive government procurement or in some other manner.

Penalties:

Violations of the law and 3M’s Code of Conduct will result in discipline, up to and including termination from employment.