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If you have a Business Conduct concern

Upholding 3M’s Code of Conduct 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’s Code of Conduct or law. Reporting suspected misconduct or even asking a compliance question can take courage, but it is the right thing to do. 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.

Where to go with questions.

No written principle or policy can anticipate all the situations and circumstances to which the principle or policy might apply. If you have a question about a Code of Conduct Principle, how the Principle relates to your job or how a policy may apply to a specific situation, you can go to any of the resources listed in the Employee Obligations and Reporting Principle.

How to report a suspected violation of these Principles.

Unless prohibited by your country’s law, employees have an obligation to report any suspected violation of the law or 3M’s Code and may do so anonymously in most countries.

If you are a supervisor or manager, you must be aware of and follow 3M’s Employee Obligations and Reporting Principle, which requires you to report all suspected violations of the law or 3M’s Code of Conduct to your business unit’s assigned legal counsel, the Compliance & Business Conduct Department, or your business management.

Where do I go to ask a business conduct question or report misconduct or potential misconduct?

Use any of the options below to ask a question or report a concern:

  • Your management
  • 3M’s Compliance & Business Conduct Department

  • 3M Company
    3M Center, Building 220-11-W-09
    Saint Paul, MN 55144-1000
  • 3M Legal Counsel
  • is operated by a third-party vendor, EthicsPoint. EthicsPoint is an independent professional reporting service retained by 3M to assist with the receipt of questions or business conduct concerns. In most countries, you may use this system to report your concerns anonymously.
  • Assigned Human Resources Manager
  • Audit Committee of the Board of Directors
    Deputy General Counsel & Secretary
    3M Legal Affairs
    3M Center, Building 220-09-E-02
    Saint Paul, MN 55144-1000
  • 3M Corporate Audit Department
    General Auditor
    3M Corporate Auditing Department
    3M Center, Building 224-06-N-11
    Saint Paul, MN 55144-1000

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:

  • You can go to EthicsPoint does not trace phone calls or use Caller Identification. In addition, EthicsPoint does not generate or maintain internal connection logs containing Internet Protocol (IP) addresses, so no information linking your computer to EthicsPoint would be available. Reports from your computer would come through a secure Internet portal, which does not trace or show user screen names. Finally, EthicsPoint removes Internet addresses to ensure that anonymity in the EthicsPoint system is maintained. EthicsPoint will not use information reported to it for any purpose other than passing along the information to 3M for appropriate handling.

At the end of your telephone call or web-based report, EthicsPoint will provide you with a report key and ask you to create a password. You will be asked to telephone 3M's Business Conduct Helpline, operated by EthicsPoint, or visit the EthicsPoint website two or three business days after you make your initial report. At that time, you can monitor progress on your report and learn whether any additional information is needed from you to address your concern.

  • You can mail a letter to 3M Compliance & Business Conduct Department at the address above.

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.

3M will review every 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. Any concern investigated will be 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 the Employee Obligations and Reporting Principle.

Retaliation is prohibited.

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.