Business Conduct Policies

Printer Friendly Format
(Adobe PDF, 21.3 KB)

Policy statement

“Lobbying” means communicating with lawmakers and other public officials to help shape public policy on laws and regulations that affect our business and our employees.  Provided these communications are conducted and reported in compliance with all applicable laws, lobbying is an appropriate way for companies like 3M to educate policymakers about the legitimate interests of 3M and our employees. 3M strictly complies with all lobbying laws and regulations, which can vary considerably around the world. 3M Public Affairs is responsible for coordinating 3M’s lobbying and other engagements with governments at all levels, and must always be informed before 3M businesses engage in lobbying or other communications on 3M’s behalf with public officials.

What it means

• In the United States, 3M employees or others acting on 3M’s behalf who contact federal, state, or local government officials or employees to influence legislation,  regulations, or other government action may be engaged in regulated lobbying activities. Therefore, to ensure that 3M has followed registration and reporting laws that may apply, all employees must consult with 3M Public Affairs and assigned 3M legal counsel in advance to determine whether the proposed contact constitutes lobbying and requires registration, reporting, or other action.
• Reporting procedures have been established as part of 3M’s Global Financial Standards to help 3M comply with federal, state and local laws pertaining to lobbyist registration and reporting of lobbying activities and expenses.  Employees must properly report lobbying expenses to ensure compliance with lobbying law, tax, and financial reporting requirements.
• Governments at all levels are important customers.  In most cases, normal sales and marketing activities do not constitute regulated “lobbying,” unless communications are directed at adopting specific legislation or urging official action to approve specific contracts.
• Any engagement of an external (i.e., non-employee) lobbyist or public affairs consultant must first be reviewed and approved by the Vice-President of Public Affairs and be made under a written contract that requires the lobbyist to comply with all applicable registration and reporting laws, as well as 3M’s Business Conduct Policies. 
• 3M employees have the right to participate personally in their government, including lobbying government officials, on their own time as long as the activity does not interfere with or impair the performance of their duties.  Except for lawful activities permitted under 3M’s Political Activities Policy, 3M employees may not use the company’s name, use any company resources (letterhead, e-mail accounts, etc.), or otherwise convey or suggest that their personal political activities are undertaken on behalf of or with the support of 3M.

What to avoid

• Discussions on 3M’s behalf with any government official or employee about legislation, rulemaking, policy development, or other government action, unless you are a registered lobbyist or have obtained prior review and approval from 3M Public Affairs and your assigned 3M legal counsel.

Rev. 05/11