How These Policies Are Administered

The 3M Business Conduct Committee, consisting of several senior executives and chaired by 3M’s Vice President, Compliance and Business Conduct, has responsibility for overseeing 3M’s 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 Compliance and Business Conduct Department, led by the Vice President, Compliance and Business Conduct. The Compliance and Business Conduct 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 Compliance and Business Conduct 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 Compliance and Business Conduct 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.