What these Policies Require
These Business Conduct Policies help employees and others acting on 3M’s behalf take a consistent, global approach to key compliance issues. 3M employees, including supervisors, managers and other leaders are responsible for understanding the legal and policy requirements that apply to their jobs and for reporting any suspected violations of law or these policies.
3M Business Conduct Policies apply to all parent company and subsidiary employees throughout the world. They also apply to employees of joint ventures and other business affiliates in which 3M has a controlling interest. These global policies apply to all locations and situations where 3M business is conducted and to all company-sponsored events.
... Of 3M Employees
Every 3M employee needs to:
- Read the introductory sections of this manual, so you know what is required of you and how 3M’s compliance program works.
- Know the issues covered by each Business Conduct Policy.
- Understand, in detail, those Business Conduct Policies that relate to your work responsibilities. Additional details employees need to know about these policies can be found on the 3M employee Business Conduct Web site (intranet.mmm.com/businessconduct). You don't need to memorize all the details, but you need to know the policies that apply to your job well enough that you will know when to come back to the policies for details, and when to seek help from the resources listed in the Where to Go with Questions section of this manual.
- Know that violating a 3M Business Conduct Policy is a serious matter that can result in disciplinary action, up to and including immediate termination of employment.
- Use company resources available to you, including your management and assigned 3M legal counsel, when you need help determining whether a Business Conduct Policy or law applies or what it requires of you.
- Understand the various ways you can report a business conduct concern by reading the How to Report a Suspected Violation of These Policies section of this manual.
- Know that you have several ways to report a business conduct concern anonymously, unless anonymous reporting is not permitted by law in your country, as detailed in the What If You Wish to Remain Anonymous section of this manual.
- Be assured that the company prohibits retaliation against anyone who raises a business conduct concern or cooperates in a company investigation.
- Know that 3M expects all employees to report violations of any law or Business Conduct Policy.
- Cooperate in support of this program and provide any assistance the company needs when 3M investigates a possible violation of law or Business Conduct Policy.
- If asked, sign a statement acknowledging you have read the 3M Business Conduct Policies and will comply with the law and 3M Business Conduct Policies.
- Periodically revisit 3M’s Business Conduct Policies to refresh your recollection and ensure that you keep abreast of recent policy revisions.
... Of Others Acting on 3M’s Behalf
All 3M business units and staff groups must require that any third party acting on 3M’s behalf, such as a consultant, agent or independent contractor, agree to follow applicable 3M policies. 3M managers and employees must:
- Require the third party to comply with relevant 3M policies and provide appropriate training so the third party understands the requirements of the policies.
- Monitor the third party’s work, and take necessary action, up to and including immediately terminating 3M’s engagement with the third party in the event the party fails to honor the agreement to abide by 3M policies.
... Of 3M Leadership
3M supervisors, managers and other leaders have additional responsibilities for employees and others acting on 3M’s behalf. 3M leaders, up to and including the Chief Executive Officer, the Chief Financial Officer and other members of senior management, must:
- Ensure that everyone in your area of responsibility understands and complies with laws and 3M policies that relate to 3M business activities.
- Create a work environment in which employees and others acting on 3M’s behalf understand that you believe in 3M’s values and are not merely paying lip service to 3M’s commitment to doing business the right way.
- Take steps to prevent violations of law and 3M policies by taking the initiative to address compliance risk areas and provide necessary compliance training to your organization.
- Detect and report violations of law and 3M policies.
- Take prompt and appropriate action to address violations, and correct process failures that allowed the violations to occur.
- Ensure that anyone who reports a suspected violation or who cooperates in a company investigation is protected from retaliation.