3M utilizes contingent workers (formerly referred to as non-3M workers) to meet business objectives. In order to promote a productive and safe work environment and comply with various laws and regulations, 3M has established access/pre-assignment requirements for contingent workers (formerly referred to as non-3M workers). References to Supplier and Seller have the same meaning.
3M CWS Supplier Business Process Map
All contingent workers and other individuals requiring unescorted access to 3M facilities and/or access to 3M corporate systems.
Requirements & Policy Statements
Contingent workers must meet defined access/pre-assignment requirements prior to the first day of assignment. Unless otherwise noted, the supplier is responsible for ensuring that contingent workers meet these requirements and retain support documentation. 3M may periodically request copies of documentation for audit purposes, but unless otherwise noted, suppliers should not send copies of the documentation to the 3M requesters or locations.
What is the Contingent Workforce Access/Pre-Assignment Requirements Policy?
It is a set of requirements that must be met prior to a contingent worker being given:
Unescorted facility access (Person ID for badge)
3M internal system access (User PIN)
It outlines 3M’s requirements to comply with laws and regulations and to promote a productive and safe work environment
All requirements below to be implemented unless legally prohibited
Apply to All Contingent Workers
Additional due diligence and 3M legal and/or business approvals are required if the contingent assignment requires contact with any government official, sales to public entities (e.g. university hospitals), government inspectors, entities that are partially or wholly government-owned, international organizations (U.N., Red Cross), political parties/candidates, etc. All contingent workers will be required to review and sign the Contingent Workforce Anti-Bribery Policy. Suppliers are responsible for ensuring that this requirement is met prior to the start of assignment.
Contingent workers are required to protect 3M’s confidential and proprietary information and must be subject to a signed agreement containing confidentiality provisions. The Seller Personnel Agreement is the preferred confidentiality agreement for most contingent workers. Supplier will review the confidentiality agreement with the contingent worker and obtain their signature prior to the start of an assignment at 3M. Given the diversity of agreements that already exist between suppliers, contingent workers and 3M, it may be possible that the worker's confidentiality agreement obligation is addressed through another agreement already in place with 3M that includes confidentiality obligations. These agreements may include a supplier agreement, a confidential disclosure agreement, or equivalent agreement.
Exhibit I: Data Privacy Notice and Consent
Suppliers of contingent workers will review the Exhibit I Data Privacy Notice and Consent form with the contingent worker and obtain their signature prior to transmitting any sensitive personal information to 3M. Contingent suppliers must upload the signed Exhibit I Data Privacy Notice and Consent form into the Contingent Workforce System when submitting their candidate to a request. Service worker suppliers must provide the signed Exhibit I Data Privacy Notice and Consent form to the 3M requester for uploading into the Contingent Workforce System when the service assignment is created. Note: the form must be signed within thirty (30) days of the candidate's submission to the request/assignment. Supplier should also retain a copy of the signed form for their records.
Privacy Notice and Consent Regarding Personal Information Transfer and Storage
Suppliers of contingent workers will review the Privacy Notice and Consent Regarding Personal Information Transfer and Storage form with the contingent worker and obtain their signature on the Privacy Notice and Consent Regarding Personal Information Transfer and Storage prior to transmitting any sensitive personal information to 3M. Note: contingent workers that have signed the current Seller Personnel Agreement do not need to sign this form.
Prohibited Parties List
Suppliers of contingent workers will verify that the contingent worker is not on any of the U.S. Government’s “Prohibited Parties Lists,” which are: (a) the Commerce Department’s Denied Persons List, Unverified List and Entity List; (b) the Treasury Department's Specially Designated Nationals List; and (c) the State Department's Debarred List and Nonproliferation Sanctions list. To access these lists, reference the Department of Commerce website at: http://www.bis.doc.gov/complianceandenforcement/liststocheck.htm
Update: 3M has added the State Department's Nonproliferation Sanctions list to this requirement. Please ensure this list has been reviewed for all workers on assignment at 3M.
In order to create a unique identification number in the Contingent Workforce System, suppliers are required to provide the contingent worker's month and date of birth as well as the worker's middle initial. Contingent worker suppliers should enter this information when submitting candidates in the Contingent Workforce System; service worker suppliers should provide this information to the 3M requester.
*Note: All candidates should be submitted with their legal name.
Additional Access/Pre-Assignment Requirements:
Apply to all Contingent Workers With Noted Exceptions
3M desires to provide a safe and secure work environment for all individuals who do business with 3M. 3M policy is to control physical access to all 3M facilities and to create and maintain records of individuals entering and exiting 3M facilities.
Suppliers of contingent workers working at 3M will review 3M’s Contingent Workforce Access Control Policy with the contingent worker and obtain their signature prior to the start of an assignment at 3M.
Former 3M Employees or Former Contingent 3M Workers
Former 3M employees or former contingent workers may be ineligible for assignment. Supplier is responsible for verifying with the worker if they have worked at 3M as an employee or contingent worker; contingent worker suppliers should indicate this status in the resource's profile in the Contingent Workforce System, and service worker suppliers should provide this information to the 3M requester. The Contingent Workforce Solutions program team will verify eligibility for assignment. Contingent workers in Delivery Driver, Offsite Third Party Worker and Volunteer assignments may be exempt if their access to 3M facilities or corporate systems is limited.
Verification of Work Authorization
Suppliers of contingent workers will verify that contingent workers have valid work authorization. A third party supplier will verify work authorization for independent contingent workers. Only contingent workers with valid work authorization are eligible for assignment.
3M requires all suppliers to comply with applicable laws concerning work authorization. Suppliers may be exempt from detailed verification or audit requirements if placing contingent workers in Delivery Driver, Offsite Third Party Worker or Volunteer assignments as access to 3M facilities or systems is limited.
Selective Access/Pre-Assignment Requirements:
Apply to Contingent Workers Based on the Role Performed
Conflict of Interest/Former or Current Government Employee
Suppliers will comply with 3M’s process if a contingent worker or household member (household member is defined as persons living with you on a regular basis) currently or ever have been employed by a U.S. Federal, State, Local or Foreign Government (either as a civilian or in the military), or in a Reserve or Guard component of the Armed Services, or in any other position that may either: (1) prevent the contingent worker from entering into a contract with 3M, or (2) place restrictions on what work assignments 3M may give the contingent worker due to U.S. Federal, State, Local or Foreign Government "revolving door" or conflict of interest laws.
If the assignment is subject to Conflict of Interest, suppliers will ask whether a contingent worker is a former or current government employee.
If contingent worker indicates a positive response, Supplier will issue the Conflict of Interest Questionnaire to the contingent worker and attach the completed questionnaire to the candidate's profile in the Contingent Workforce System for 3M review.
Upon review, 3M will advise the supplier of any further requirements which may include additional questions.
A third party supplier will perform this service for independent contingent workers.
Contingent workers in the following Assignments are exempt: Cafeteria Worker, Construction/Maintenance, Custodian/Janitor, Delivery Driver, EAP Professional, Mail/Shipping Handler, Occupational Health Nurse, Offsite Third Party Worker, Service Worker, Trainer and Volunteer.
Contingent workers in the following Job Categories are exempt: Manufacturing and Warehouse.
As a global company, 3M must comply with various export regulations, collectively known as export controls. All 3M businesses must adhere to these regulations in order for 3M to sell or otherwise export from the U.S. certain products, technology, and equipment, as well as share certain export-controlled technology with "non-U.S. persons" within the United States. If an assignment is subject to export control requirements, suppliers of contingent workers will comply with 3M’s export control process.
3M will notify suppliers if the assignment is subject to the export control requirements through the request in the Contingent Workforce System. If the assignment is subject, the contingent worker must disclose their country of birth, current citizenship(s) and the order in which they were obtained, if more than one.
Suppliers will provide birth country and citizenship information, and any requested supplemental information, to 3M through the Contingent Workforce System in order for 3M to determine whether contingent workers are eligible for an export controlled assignment.
Upon completion of the determination of eligibility for the export controlled assignment, 3M will notify the supplier or the independent worker of the determination and next steps.
A third party supplier will perform this service for independent contingent workers.
Note: 3M may periodically request copies of documentation for audit purposes, but unless otherwise noted, suppliers should not send copies of the documentation to the 3M requesters or locations.
For Puerto Rico Requirements, click here: PR
For US Specific Requirements, click here: US
For UK Specific Requirements, click here: UK
For all other countries, inquire with your 3M contact for country-specific requirements.