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3M places particular emphasis on protecting our company against emerging risks in an everchanging world. |
Case in point: cybersecurity. Strong cybersecurity programs are essential, and we continue to invest in information technology systems and activities around cybersecurity training and awareness, especially when it comes to avoiding phishing and other threats targeting 3M. |
For more information on corporate-level risks, see 3M’s 10-K, Item 1A, as well as the Climate and energy section and Environmental management section. |
How we work 94 95 3M 2020 Sustainability Report #improvinglives Enterprise risk |
3M will continue to advance our processes to identify and mitigate enterprise risk by engaging all levels of leadership. Our priority is the comprehensive management of enterprise risks through an ethical tone, 3M Leadership Behaviors, governance processes, and clear roles, responsibilities, and accountability. |
Looking forward. |
Board members and General Auditor meet 1:1. |
In 2019, the Vice President and General Auditor met with each independent 3M Board member to discuss risk management in general as well as specific risk-related topics facing the company. These meetings gave Board members an opportunity to share what risk issues were top of mind for them and which should be reviewed and addressed by the Board. |
Business-level 3M serves customers through our four business groups. Annually, leadership from each business group presents to the Board, and the Board discusses and approves detailed long-term strategic plans for the company, both at the area and business-group level. Each presentation includes the following: an overview of the business group, shortand long-term financial performance and goals, an assessment of portfolio growth opportunities, and strategic priorities to drive our Value Model. |
Site-level. |
Our Environmental, Health, and Safety (EHS) management system looks carefully at each 3M site and new acquisition and performs a risk assessment that considers factors such as potential impact to the environment, the community, and 3M employees. Each site is ultimately ranked based on the risk it poses to the company, and necessary steps are taken to minimize potential risks. We also place particular focus on bringing acquisitions into alignment with 3M’s protocols, standards, and training. |
Strong cybersecurity programs are essential, and we continue to invest in information technology systems and activities around cybersecurity training and awareness. |
In addition to conducting environmental, health, and safety risk analysis, we have Business Resiliency plans for each 3M site. Although we hope to never use them, it’s critically important they are in place, current, and that employees understand what to do should an emergency occur. All plans are prepared in accordance with good engineering practices and full approval of management. Scenario exercises are conducted periodically at sites to evaluate the effectiveness of the plans. |
How we work 96 97 3M 2020 Sustainability Report #improvinglives Enterprise risk |
Executives and managers are accountable for creating an inclusive workplace environment that encourages asking questions and raising concerns. |
The Code of Conduct is available in 25 languages and sets clear expectations not only for employees but also for relevant stakeholders and business partners. All new employees receive a copy of the Code of Conduct. |
Our commitment. |
The Code of Conduct is part of 3M’s Value Model and positions 3M for long-term growth. Our Values bind us together as 3M employees — across business groups and across geographies. |
Great companies are built on trust — from customers, shareholders, employees, and communities. We’ve earned that trust and a reputation for integrity over many decades, and no one at 3M is free to compromise it. |
We have one Code of Conduct that applies to our 96,000 employees in over 70 countries globally. Our Code of Conduct summarizes 3M’s compliance principles and raises awareness about how to do business the right way, at all times and at every site. |
The Code of Conduct is our guide, answering questions and providing direction when the right choice may not be clear. |
3M’s Code of Conduct defines the expectations for how we work: • Be Good • Be Honest • Be Fair • Be Loyal • Be Accurate • Be Respectful 3M employees, including all supervisors, managers, and other leaders, are responsible for knowing and following the ethical, legal, and policy requirements that apply to their jobs and for reporting any suspected violations of law or the Code of Conduct. |
Corporate Code of Conduct A “Speak Up” culture that keeps ethics and business conduct front and center. |
Code of Conduct Be 3M. |
Obey the law and 3M’s Code of Conduct. |
Be Good. |
Be Accurate Be Respectful. |
Be Fair Be Honest. |
Act with uncompromising honesty and integrity. |
Respect one another and our social and physical environment around the world. |
Keep complete and accurate business records. |
Play by the rules, whether working with government, customers, or suppliers. |
Protect 3M’s interests, assets, and information. |
Be Loyal. |
Business Conduct Committee. |
The 3M Business Conduct Committee is comprised of several senior executives and is chaired by 3M’s Vice President and Chief Ethics & Compliance Officer. This committee oversees 3M’s compliance efforts to assure that 3M has an effective and world-class compliance program — one that is agile and anticipates changes in the external landscape and internal business strategy. |
The Business Conduct Committee, annually or as needed, updates the Audit Committee of the 3M Board of Directors and 3M’s executive Corporate Operating Committee. Additionally, similar committees exist at country and regional levels to operationalize and prioritize compliance activities. |
Global compliance program 3M’s global compliance program is managed and administered by the Ethics & Compliance Department, led by the Vice President and Chief Ethics & Compliance Officer. The department is staffed with compliance professionals stationed around the world. The Vice President and Chief Ethics & Compliance Officer reports directly to the Audit Committee of the 3M Board of Directors. The Audit Committee assists the Board in overseeing 3M’s legal and regulatory compliance efforts. This direct reporting line assures the independence of the Ethics & Compliance Department, which is responsible for overseeing and administering strategic, systemic, and operational components of 3M’s compliance program. |
The compliance program is designed to meet the U.S. Federal Sentencing Guidelines and, as designed, meets similar global standards and requirements of other countries’ anti-bribery laws. |
The program consists of: • A core set of business conduct principles • Education and training • Periodic evaluations, audits, risk assessment, and procedures to measure and assess the compliance program’s effectiveness • A 24-hour global helpline and website through which employees, customers, vendors, and other external parties can report concerns and ask questions, anonymously in most countries • Risk-based due diligence on business partners, potential acquisitions, equity investments, and candidates for hiring and promoting • Investigation expertise • Incentives and discipline to address compliance successes and failures. |
Compliance training and education 3M offers a comprehensive online compliance training program to employees worldwide. |
The program’s training modules are assigned to employees based on their role and area of responsibility within the company. Most courses are mandatory for approximately 46,000 global employees. |
An annual training plan is established each year based on an assessment of internal and external factors to prioritize topics and timing of deployment. Online courses are offered in 22 languages. |
Examples of recent training modules include: • Data Privacy and Protection • Understanding Information Security and Protection • Gifts, Entertainment, and Travel • Avoiding Bribery and Corruption: A Global Overview • Understanding Global Competition • Creating a Harassment-Free Workplace • Code of Conduct and Ethical Decision-Making • Recognizing Conflict of Interest. |
The Ethics & Compliance website on 3M’s intranet offers additional on-demand online training courses. In addition to offering online training, the Ethics & Compliance Department — in close collaboration with 3M Legal Affairs, local compliance partners, finance, and human resources — provides frequent, tailored, in-person training to businesses, subsidiaries, staff groups, and third parties. Some of this training occurs as part of an annual schedule, while other training occurs as requested or when deemed appropriate. |
How we work 98 99 3M 2020 Sustainability Report #improvinglives Corporate Code of Conduct |
Not only do audits, evaluations, and risk assessments help detect opportunities for improvement and gaps in processes or procedures, they also reinforce the importance of operating in an ethical, compliant manner. |
Recipients of the Living the Code Award receive a letter from our Vice President and Chief Ethics & Compliance Officer along with an engraved crystal glass globe. |
3MEthics.com is a 24-hour confidential and anonymous (where permitted by local law) helpline and online reporting system. |
It is managed by a third-party vendor and is available to 3M employees and others internally and externally. The system does not trace phone calls or use caller identification, nor does it generate or maintain internal connection logs containing internet protocol (IP) addresses. Web-based reports are made through a secure internet portal that does not trace or show user screen names. |
The Ethics & Compliance Department has the responsibility to review every business conduct concern that is reported. After review, the department determines which reports require an investigation. If an investigation is needed, an appropriate investigation resource is assigned to the matter. For concerns that are substantiated, disciplinary actions may be taken. Discipline comes in a range of forms consistent with similar past violations, from warnings to suspensions to termination. Disciplinary actions may impact one or more persons associated with a single substantiated violation. The 3M global allegations and disciplinary action graph illustrates business conduct-related reports raised in 2018 and 2019, using our reporting tools found at 3MEthics.com. |
Reporting concerns: “Speak Up” |
Upholding 3M’s Code of Conduct and values is the responsibility of everyone acting on 3M’s behalf. We encourage our employees to ask questions or report concerns to management, 3M’s Ethics & Compliance Department, 3M legal counsel, 3MEthics.com, their assigned human resources manager, 3M Corporate Audit Department, or the Audit Committee of the Board of Directors. Our strong ethical culture requires and empowers employees to make the right choices every day. 3M makes it clear that speaking up is the right thing to do. We know our employees care about the company and want to do the right thing. On a quarterly basis, the Ethics & Compliance Department recognizes 3M employees around the globe who have gone above and beyond to bring the 3M Code of Conduct and our values to life in the work they do and the decisions they make. |
直言不諱! |
Speak up! 3M Ethics & Compliance. |
Be 3M. |
Speak up. Ask a question. Raise a concern. |
Go to 3MEthics.com. |
ROZMAWIAJ Z NAMI! |
Sprechen Sie mit uns. |
Spregovori. |
NGRIJE ZËRIN. |
Progovori Говори открыто Parla apertamente ¡ HAZLO SABER! |
Exprimez-vous อย่าละเลยไม่รายงานพฤติกรรมผิดจรรยาบรรณ |
Pozovite ΜΙΛΗΣΤΕ ΑΝΟΙΧΤΑ 非倫理的な行動 - 報告する義務があります。 |
Vorbeste. |
Fale! |
Tala ut! Высказывайте сомнения! Çekinme Söyle! 直言不讳! |
Hãy lên tiếng! |
Ungkapkan! 솔직하게 말하기! |
Prehovorte! |
Suarakan Kecurigaan! |
Our strong ethical culture requires and empowers employees to make the right choices every day. |
2018 2019 400 200 600 1200 1000 1400 1600 1800 800 0. |
Disciplinary actions. |
Substantiated allegations. |
Allegations reported. |
Our evaluation planning and site selection process was enhanced in 2019 by incorporating additional data and analytical tools to prioritize countries and operations for future review. |
Additionally, a “local evaluation” process was developed to address site-specific risk with more agility and speed. Now part of the annual evaluation planning process, a local evaluation has a more focused scope than our standard deep-dive evaluation, and it can be completed with fewer resources in half the time. This approach is more adaptable to local needs while continuing to meet the requirements of the Ethics & Compliance Department. |
Assessments. |
A dedicated team within 3M’s Ethics & Compliance Department conducts periodic compliance and anti-bribery evaluations in various 3M subsidiaries and operating units each year. Subsidiaries or operations are selected for an evaluation using objective and subjective risk factors. An evaluation process includes a review of financial transactions, compliance records, interviews with business personnel, and audits of selected business partners. Our evaluation process continues to evolve. In 2019, we continued to interview at least 10% of non-production employees as part of the evaluation process. |
3M global allegations and disciplinary actions. |
Total number. |
Based on a project in 2018, the Ethics & Compliance Department has continued to report metrics from a broader range of 3M functions that conduct investigations and track employee concerns. This provides a more complete view of the frequency and type of concerns reported globally and better reflects the healthy “Speak Up” culture that exists within 3M. This data is used to prioritize resources and focus strategies. |
3M encourages all employees to speak up to raise a concern or suspected violation of the Code of Conduct. The “Speak Up” poster that encompasses many of our most frequently used languages continues to be widely used globally. |
3M’s non-retaliation process 3M prohibits retaliation against anyone who raises a business conduct concern in good faith or cooperates in a company investigation. To monitor this risk, a compliance investigator contacts the reporter several times after an investigation closes to discuss if the person has experienced any form of retaliation. This is done either by phone or via email for non-anonymous reporters. For anonymous reporters who used 3MEthics.com to raise a concern, the follow-up is handled through 3MEthics.com to maintain anonymity. If claims of retaliation are identified, the investigation team will follow up on them. 3M takes a strong position against retaliation, which is reflected in the Non-Retaliation Policy and within 3M’s Employee Obligations and Reporting Principle. |
1 Data in the present chart may differ from previous reports as case management progresses. |
How we work 100 101 3M 2020 Sustainability Report #improvinglives Corporate Code of Conduct |
Commitment to anti-corruption. |
As a participant of the United Nations Global Compact (UNGC), 3M is committed to supporting Principle 10 on Anti-Corruption. Our commitment and involvement with the UNGC, and with our community of peer companies, provides us with the opportunity to collaborate and share best practices related to work against corruption in all its forms. Additionally, the compliance professionals on our team regularly participate, present, and are members of organizations and associations working to improve compliance controls and reduce legal risk. |
3M’s Code of Conduct requires compliance with all applicable antibribery laws, including the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, Brazil’s Clean Company Act, and local laws where 3M operates. It applies to 3M employees, as well as to our business partners. In addition, 3M’s Anti-Bribery Principle and antibribery policies and procedures have been communicated to all employees. Our Avoiding Bribery and Corruption training is required of most nonproduction employees and specifically employees in higher-risk roles, including those in legal, audit, sales, marketing, export, and global trading. The Vice President and Chief Ethics & Compliance Officer provides quarterly updates on all activities to the Audit Committee of the Board of Directors and the 3M Business Conduct Committee. |
3M’s commitment to anti-corruption is also reflected in our management of third-party intermediaries and other business partners. 3M conducts duediligence reviews of our third parties based on an assessment of risk factors, including transaction size, type of relationship, government interactions, and geography. Depending on the outcome of the review, we respond to any identified risks with specific actions, such as training, inclusion of relevant contractual terms, and other risk-mitigating controls. 3M may end a relationship with a business partner if the risk presented is determined to be too high and cannot be appropriately mitigated. |