If You Have a Business Conduct ConcernUpholding 3M’s Business Conduct Policies and values is the responsibility of everyone acting on 3M’s behalf. It is also everyone’s responsibility to raise a concern promptly about a possible violation of 3M policy or law. It is vital to address problems early while they are small and more easily fixed. Serious damage, fines, penalties and loss of confidence in 3M can result if small problems are allowed to grow into big ones. Where to Go with Questions No written policy can anticipate all the situations and circumstances to which the policy might apply. If you have a question about a Business Conduct Policy, how the policy relates to your job or how a policy may apply to a specific situation, you can go to any of the resources listed in How to Report a Suspected Violation of these Polices section. How to Report a Suspected Violation of These Policies Most days, you don’t have to look very hard to find newspaper articles about companies facing investigations and litigation concerning illegal or unethical behavior. No company - no matter how good its compliance program and corporate culture are - should be so naïve as to think it will never have a legal or ethical compliance issue. The measure of a good company, and a good compliance program, is whether a company finds problems early and fixes them while they are small. The best way for 3M to find out early about suspected violations is when employees and others acting on 3M’s behalf support the compliance program by being the “eyes and ears” of compliance in the company. Studies show that many people are reluctant to report a suspected violation involving a coworker. To address this natural reluctance, 3M has a strict policy prohibiting retaliation against anyone who raises a business conduct concern or cooperates in a company investigation. We stress with our employees and others acting on 3M’s behalf that reporting a suspected violation is the right thing to do, because every violation of law or 3M policy creates risk for employees, the company, customers and the communities in which 3M operates. You have a number of options to report what may be a violation of 3M Business Conduct Policy or law. You can raise a concern orally or in writing to:
If you are raising a concern under the Harassment Policy, you also can go to your local Human Resources Manager or someone higher in the 3M Human Resources organization. If you are raising a concern regarding accounting, financial reporting, internal accounting controls or auditing matters, you also can go to: General Auditor What If You Wish to Remain Anonymous First consider whether you are comfortable raising your concern directly within 3M, such as to your manager or to someone else in your department. 3M has found that internal concerns usually can be resolved most quickly and satisfactorily when they are raised with internal resources such as management or human resources. If you are uncomfortable doing so, if you do not know whom to contact, or if you believe your concern has not been satisfactorily addressed, you can submit your concern anonymously (unless anonymous reporting is prohibited by law in your country) by using the following options:
If you choose to identify yourself in reporting your concern, 3M will make every reasonable effort to hold your name in confidence during the investigation. How 3M Will Respond to a Report If warranted, 3M will commence an appropriate investigation, using internal or external resources with expertise in conducting investigations. The information in your report is shared with appropriate investigation team members, and the concern is investigated promptly and discreetly. You will be notified at the conclusion of the investigation. If you do not believe your concern has been adequately addressed, please raise it with another of those resources listed in How to Report a Suspected Violation of these Polices section. 3M prohibits retaliation against anyone who raises a business conduct concern or cooperates in a company investigation. Complaints made in good faith will not expose you to any sanctions, regardless of whether the underlying facts prove to be correct or result in any corrective action. If you believe you have faced retaliation of any kind, please report it so the 3M can investigate.
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