About 3M's Code of Conduct
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Lobbying is highly regulated and 3M is committed to complying with all lobbying related laws and regulations in the U.S. and around the world. 3M’s Government Affairs Department manages 3M’s lobbying activities. Before hiring a lobbyist, engaging in direct lobbying, or communicating with public officials on 3M’s behalf, 3M employees must engage with 3M Government Affairs. All 3M employees interacting with government or engaging lobbyists must learn and comply with the lobbying laws that affect their business activities, including registration, reporting, and record-keeping requirements.
Lobbying is an appropriate way for companies like 3M to educate policymakers about the legitimate interests of 3M and our employees, but these communications must be conducted and reported in compliance with all applicable laws.
This Principle applies globally to all employees and may apply to those acting on behalf of 3M. See the Compliance Principle for information on when a third party might be covered by the Code of Conduct Principles.
- “Lobbying” means communicating with lawmakers and other public officials to help shape public policy on issues (laws, regulations, and issues that affect our business and our employees).
- In most cases, normal sales and marketing activities involving government customers do not constitute regulated “lobbying,” unless communications are directed at adopting specific legislation or urging official action to approve specific contracts. Employees must know the lobbying laws of the area in which they do business including changes to the laws over time.
- In the United States, 3M employees and others acting on 3M’s behalf must comply with federal, state, and local lobbying laws. Lobbying laws vary depending on the level of government and government body. For example, in the United States, state lobbying laws vary from state to state and change frequently. In some states, traditional sales activities may constitute lobbying, triggering registration and reporting requirements. Contact 3M’s Government Affairs Department for additional guidance. To ensure that 3M has followed registration and reporting laws that may apply, all employees must consult with 3M Government 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 laws, and tax and financial reporting requirements, including the portion of trade association dues that are used for lobbying activities. Even if employees spend little time contacting public officials and don’t consider themselves a “lobbyist,” time and expenses must be reported to Government Affairs. For further assistance, employees must talk to their assigned 3M counsel or 3M Government Affairs.
- Any engagement of an external (i.e., non-employee) lobbyist or government affairs consultant must first be reviewed and approved by the Vice President of Government 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 Code of Conduct Principles. Be sure to work with Sourcing and Government Affairs to obtain the appropriate written contract requirements.
- 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 Principle, 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.
- 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 Government Affairs and your assigned 3M legal counsel.
Violations of the law and 3M’s Code of Conduct will result in discipline, up to and including termination from employment.