How These Policies Are Administered

The 3M Business Conduct Committee, consisting of several senior executives and chaired by 3M’s Senior Vice President, Legal Affairs and General Counsel, has responsibility for overseeing 3M’s legal and ethical compliance program. The Business Conduct Committee reports to the Audit Committee of the 3M Board of Directors, which assists the Board of Directors in oversight of 3M’s legal and regulatory compliance program.

3M’s compliance program is administered by the Central Compliance Department, led by the Director of Business Conduct and Compliance. The Central Compliance Department oversees the strategic, systematic and operational components of 3M’s compliance program design and implementation. The Department also focuses on implementing the initiatives of the Business Conduct Committee in such areas as compliance policy drafting, compliance risk analysis, education, communication strategy and program awareness, coordination of investigations and continuous process improvement.

The Central Compliance Department is assisted by dedicated compliance organizations in the areas of government contracting, health care regulatory, and environmental health and safety. In addition, 3M utilizes a network of part-time Compliance Contacts in every business unit and staff group who assist the Central Compliance Department in ensuring that their organizations continuously demonstrate legal compliance and ethical business conduct. Compliance Contacts assist in business conduct policy training, communications and completing periodic risk assessments for their organizations.