About 3M's Code of Conduct
Political Activities Principle
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3M respects, supports, and encourages participation in the political process, and is committed to complying with all laws and regulations relating to this activity. Employees and third parties to which this Principle applies must not (1) use corporate resources to further such activities, (2) use 3M resources, such as our facilities, email, computers, telephones, email, or work time for political campaigning, fundraising, or other political activities, or (3) give the impression that 3M sponsors or endorses (or, alternatively, does not sponsor or endorse) any position or candidate. Employees also must avoid offending co-workers with inappropriate political messages.
In order to ensure 3M’s compliance with pay to play laws, officers and directors and certain employees may be required to consult with counsel for 3M PAC and 3M Government Affairs before making political contributions to candidates and political organizations in certain states and localities.
This Principle does not prohibit or restrict lawful activities or uses of 3M resources by 3M and 3M Government Affairs.
3M Political Action Committee (3M PAC) is a nonpartisan fund used to make contributions to U.S. federal, state, and local candidates as permitted by law. This Principle permits the lawful activities and the use of 3M resources by 3M PAC.
The use of corporate resources to influence the political process is strictly regulated to protect and promote the integrity of the political processes of countries around the world. In addition, the United States law and the laws of many U.S. states generally prohibit the use of corporate resources to support or oppose candidates or political committees. 3M supports and complies with these regulations and expects 3M employees, in the course of their 3M work, to comply as well.
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.
Except for the lawful political contributions and activities described below, 3M does not allow political campaign or partisan political activities at any 3M workplace or facility, or the use of company resources for political purposes:
- Candidate Visits to 3M: 3M Government Affairs may invite officeholders and candidates for public office to visit 3M facilities and address 3M employees. No 3M employee is required to attend such events. 3M may refuse or limit candidate appearances on 3M property as permitted by law. Unless expressly permitted in advance by 3M Government Affairs, no candidate may distribute literature, solicit contributions, or address employees at any 3M facility.
- 3M PAC: 3M PAC is a non-partisan fund used to make contributions to U.S. federal and, where permitted, state or local candidates, parties, and political committees. 3M has established a PAC Board to oversee 3M and 3M PAC contributions to political campaigns, parties, or committees in the United States. Chaired by a senior 3M executive, the PAC Board reports to the Chief Executive Officer. Upon request, the PAC Board also reports to the Corporate Operations Committee and the Nominating and Governance Committee of the Board of Directors on 3M’s political activities and contributions. Eligible 3M employees and shareholders may contribute voluntarily to 3M PAC. Certain management and supervisory employees and shareholders may be asked to contribute to the 3M PAC, as permitted by U.S. law. Any employee may refuse to contribute to 3M PAC without fear of reprisal. 3M will not reimburse any person for making contributions to 3M PAC or for any other political contribution. Coercion of any employee to contibute to 3M PAC or to make any political contribution is prohibited.
- Unless permitted in advance by the PAC Board, and only then to the extent allowed by applicable federal or state law, 3M does not permit employees to distribute campaign literature, solicit campaign contributions, or participate in other political activities during paid working hours.
- This Principle does not prohibit or restrict the following lawful activities or uses of 3M resources:
- The activities of the Government Affairs organization, 3M PAC, or the PAC Board.
- The use of 3M resources and facilities, including the Customer Innovation Center, for 3M PAC fundraising or 3M PAC-sponsored meetings, events, and activities.
- 3M communications on issues of concern to 3M or 3M employees.
- Other lawful activities or uses of 3M resources that are consistent with 3M’s Code of Conduct Principles and approved in advance by the PAC Board (for the U.S.) and the area vice president (outside the U.S.) and assigned 3M legal counsel.
- Pay to play laws restrict contributions by government contractors to those responsible for issuing government contracts.
Violations of the law and 3M’s Code of Conduct will result in discipline, up to and including termination from employment.