How these Principles are administered
The 3M Business Conduct Committee, consisting of several senior executives and chaired by 3M’s Vice President, Associate General Counsel, and Chief Compliance Officer, 3M Compliance & Business Conduct, has responsibility for overseeing 3M’s compliance program and Code of Conduct.
3M’s compliance program is administered by the Compliance & Business Conduct Department, which is led by the Vice President, Associate General Counsel, and Chief Compliance Officer, 3M Compliance & Business Conduct. The Chief Compliance Officer reports to the Chair of the Audit Committee of 3M's Board of Directors. The Compliance & Business Conduct Department oversees the strategic, systematic and operational components of 3M’s business conduct and compliance program, and 3M’s anti-bribery compliance program, in particular. 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 & Business Conduct Department partners with dedicated corporate and business 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 resources in business units and staff groups who assist the Compliance & Business Conduct Department in ensuring that their organizations continuously demonstrate legal compliance and ethical business conduct. These compliance resources assist in business conduct policy training, communications and completing periodic risk assessments for their organizations.