Business Conduct Policies

Doing Business with Government Agencies and Government Contractors Policy

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Policy statement

It is 3M policy to conduct its government contract and subcontract business in strict compliance with all applicable national, state, province and local laws and regulations and all contract requirements.

What it means

3M employees and others acting on 3M's behalf must:

• Understand and follow the Government Contract Compliance Policies, Standards and Procedures posted in the Policy Center on 3M Source.
• Follow contract negotiation requirements, such as special bidding rules and the prohibition against obtaining "inside information" about the procurement.
• Set up processes to abide by contract obligations and inform other employees who have responsibility for contract performance regarding special pricing, intellectual property rights, subcontracting requirements and other special government contract requirements.
•  Ensure all consulting services from government officials (such as seminars led by nurses employed by government-owned hospitals) are provided under contracts prepared by 3M legal counsel with fees that are reasonable and proportionate to bona fide services provided.
•  Ensure all 3M research grants to government agencies or employees follow the process set forth by the 3M Corporate Technical Operations Committee to ensure the grants are legitimately awarded and appropriately valued.
•  Ensure all donations to government agencies are reviewed by 3M legal counsel to ensure the donations are legally permitted.
• Be honest and accurate in all dealings with government officials, government agencies, government contractors, and government subcontractors.  Ensure that certifications and representations are accurately made.
• Understand and follow 3M's Business Gifts and Entertainment Policy regarding gifts to U.S. and international government employees.
• Be aware that applicable laws and regulations may vary from state to state, province to province, country to country, and government agency to government agency.  If you have questions about any law or regulation applicable to government contracts, subcontracts or purchase orders, seek advice from your assigned 3M legal counsel. Also, understand and follow 3M's Anti-Bribery Policy.
• Obtain prior clearance from Human Resources and assigned legal counsel to discuss employment with or offer employment (either as an employee or consultant) to former and current government employees, as detailed in 3M's Hiring Former and Current Government Employees and Consultants Policy.

What to avoid

• Violating national, state, province, or local government laws or regulations concerning offering or providing business gifts and gratuities to government employees or employees of government contractors or subcontractors.
• Making false statements or certifying false data to government employees, government agencies, or government contractors or subcontractors.
• Deviating from government contract or subcontract requirements or making unauthorized contract or subcontract substitutions, including failure to perform required tests and inspections.