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Further, the Ethics & Compliance Department collaborates with 3M Legal Affairs on due-diligence processes related to potential equity investments and mergers and acquisitions. These processes help identify risks in the target company before an acquisition or investment is initiated. This process accelerates our efforts to integrate an acquired company’s employees into 3M’s compliance program and culture. Ultimately, the Ethics & Compliance Department is charged with conducting a risk review and implementing any necessary remediation activities upon the closing of every acquisition. As a part of our ethics and compliance integration process, in 2019, we completed a compliance culture survey with an acquisition to identify and prioritize compliance integration activities. Acquisition culture surveys help identify whether new employees understand 3M’s compliance expectations and where further assistance or training can be provided. |
Finally, the Ethics & Compliance Department has a group of specialists focused on assuring that 3M conducts government contract and subcontractor business in compliance with all laws. This group trains, assists, and coaches 3M employees on all government contracting needs, including providing guidance and advice on identifying, managing, and mitigating risk. |
Political values 3M respects our employees’ right to engage in the political process, and, at the same time, 3M is committed to preventing potential corruption. When allowed by law, any corporate political contributions outside of the United States require approval by the Area Vice President and assigned legal counsel. |
For additional information, please visit the Ethics and Compliance webpage. |
Raising third-party awareness of 3M Ethics & Compliance expectations. |
To enhance our communications and expectations with third parties, 3M has an online training course and a brochure for our business partners. In 2019, we moved to a new vendor and refreshed the content of the online third-party training course on antibribery. The course is available in 30 languages. The brochure, available in 27 languages, provides another way for 3M to communicate with our business partners regarding our commitment to combat global bribery. |
“For more than a century, 3M has done things the right way, assuring integrity is at the heart of what we do. Our Code of Conduct provides the foundation for the values we live by. These values can be felt all over the world.” — Michael Duran 3M Vice President and Chief Ethics & Compliance Officer. |
How we work 102 103 3M 2020 Sustainability Report #improvinglives Corporate Code of Conduct |
To assure global accessibility, in 2019, these publications were translated into the languages most frequently requested by our global team. This year, the supervisor toolkits covered speaking up; conflicts of interest; respectful workplace; and gifts, entertainment, and meals. |
Data analysis and metrics. |
Through the work of a data scientist on the Ethics & Compliance Team, we have seen positive impacts in our reporting and metrics analysis. The cycle time to create our compliance reporting metrics was cut in half, allowing quicker access to current data. We now also provide our compliance partners and leaders with a user-friendly platform to review and analyze their relevant data through custom dashboards. |
This year, we again implemented an ethical culture survey for 3M sales professionals. |
Through analyzing the survey results, we were able to correlate the frequency of discussion that a manager has with their employees about ethics and compliance with other measures, including the willingness of employees to speak up. This data finding was used in manager training to emphasize the importance of speaking about compliance. |
The day featured an outside speaker who discussed his personal experience in making poor ethical choices and the impact such choices had on his personal life and professional career. Additionally, several 3M leaders participated in the day. All participants shared their perspectives on the importance of doing business the right way, the resources available to help employees in the “gray zone,” and the potential consequences of poor choices. The event included a fair, where representatives from various compliance functions were stationed at booths where they held interactive discussions with employees. |
Communications to support our employees and supervisors. |
We recognize the power in storytelling to inspire and influence ethical behavior. In 2019, the Ethics & Compliance Department launched a new video series called “My Moment of Truth,” which leverages the personal stories of 3M employees who had the courage to speak up and do the right thing. The series was intentionally unpolished and showed real employees in their workspaces and was filmed on cell phones or other readily available video equipment. The participants included employees from all over the world and were subtitled in English and nine other languages. |
The most frequent resource employees go to with ethical or compliance questions is their manager. The Ethics & Compliance Department publishes a series of toolkits containing reference materials and case studies to help supervisors effectively address employee questions and respond appropriately when dealing with potential violations of the law or the 3M Code of Conduct. |
Our actions. |
Ethics & Compliance Department. |
The teams within the Ethics & Compliance Department were reorganized in 2019, allowing for greater efficiencies and collaboration, further enhancing our established Centers of Excellence. A Platforms and Strategic Transactions Team was created to provide greater focus on simplifying and automating processes. We also established a dedicated team for risk monitoring and metrics management. |
This year, we rebranded the department, changing its name from Compliance and Business Conduct to Ethics & Compliance. We did this to establish a name that reflects our mission of assuring employees conduct business ethically. The new name also brings greater alignment with 3MEthics.com, our external website that is used to raise concerns and ask questions. Our Chief Compliance Officer became the Vice President and Chief Ethics & Compliance Officer. Finally, we updated our 3MEthics.com website to reflect the rebranding and, while doing so, created a refreshed and simplified user interface to facilitate the “Speak Up” process. |
Global Ethics & Compliance Day. |
All over the world, we held Ethics & Compliance Day events to further build employee engagement around the Code of Conduct and doing business the right way. For the third year in a row, we held a compliance day at our global headquarters. The theme was “The Gray Area: where doing the right thing isn’t always black and white.” |
Training enhancements. |
In 2019, we transitioned to a new online training vendor for ethics and compliance courses. The new vendor offers adaptive learning technology and will provide more data to leverage. To drive improvement in on-time online training course completions, we implemented a pop-up notification that reminds a user of their need to complete their compliance training each time they open certain desktop applications. This pop-up helped on-time online training course completions reach the highest level ever achieved. Additionally, we introduced a third-party code certification in 22 languages that can be leveraged any time there is a need to communicate or clarify our Code of Conduct expectations. |
As 3M’s business models change over time, ethics and compliance remain at the core of what we do for our employees, customers, communities, and shareholders. The Ethics & Compliance Department will continue to evolve, establishing appropriate governance bodies and partner networks to assure we continue to drive a culture of speaking up and doing business the right way. As we do so, we will optimize opportunities to continually improve our program. We will support supervisors and managers globally, so they are prepared with necessary information and resources. |
Data analysis will remain a priority for the Ethics & Compliance Department as we leverage it to understand our risks. We will continue to empower global leadership to take ownership of key performance indicators by providing access to tools and metrics. In 2020, we will use our technology and reporting platforms to create tools and measures that identify risk and increase our visibility into those risks. |
We will continue to evolve our acquisition integration process, assuring effective integration of newly acquired businesses into our Ethics & Compliance program and platforms. We will provide those new to 3M with a strong support network from the Ethics & Compliance Department during times of transition. |
3M will continue to hold Ethics & Compliance Days around the world to engage global employees in our culture of compliance. These events will be opportunities to create energy and enthusiasm around compliance, with active participation from our divisions and functions and across levels of seniority and tenure in the company. |
Looking forward 20% |
The survey participation rate improved by approximately. |
How we work 104 105 3M 2020 Sustainability Report #improvinglives Corporate Code of Conduct |
Our commitment. |
Our Human Rights Policy applies to all 3M employees, contingent workers, candidates for hire at 3M, anyone doing business with or on our behalf, and others acting on 3M’s behalf. |
In 2014, we became a United Nations Global Compact (UNGC) participant, thereby committing to align our operations and strategies with the UNGC principles on business and human rights. We support its “protect, respect, and remedy” framework and its principles of due diligence. Furthermore, our Code of Conduct and its underlying principles require compliance with all applicable laws and also require respect for internationally recognized human rights in all global operations. |
We also recognize the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work. Adopted in 1998, the declaration commits member states to respect and promote principles and rights in four categories, whether or not they have ratified the relevant conventions: freedom of association and elimination of discrimination in employment and occupation; the right to collective bargaining; the elimination of forced or compulsory labor; and the abolition of child labor. |
Guided by deeply engrained principles in our culture. |
Respect for human rights is deeply engrained in our culture. Within our own business, 3M’s approach to managing and assuring human rights is derived from the 3M Code of Conduct, which recognizes the right of employees to have a respectful workplace. This culture extends through our human resources policies, programs, and management systems, including 3M’s Leadership Behaviors. We continue to implement our human rights program through our global policies, management system, assessments, audits, training, and, ultimately, our metrics tracking. Our audit process provides us with a global perspective over all of our sites and our supply chain. |
Human rights elements brought to life. |
Our commitment to upholding human and workplace rights is embodied in the 3M Human Resource (HR) Principles, which respect the dignity and worth of all individuals, encourage the initiative of each employee, challenge individual capabilities, and provide equal opportunity for development. |
A respectful workplace. |
Our Code of Conduct lays out what it means to be a 3M employee and includes the 3M Respectful Workforce Principle: |
Be Respectful: We strive to have a work environment that reflects and values the best in all of us, where we treat each other respectfully and professionally, and where individual differences are valued. |
3M’s Respectful Workplace Principle states that “everyone is entitled to respectful treatment in the 3M workplace. Being respectful means being treated honestly and professionally, with each person’s unique talents, background, and perspectives valued. A respectful workplace is free from unlawful discrimination and harassment, but it involves more than compliance with the law. |
Human rights Doing business the right way is the only way we do business. |
It is a work environment that is free of inappropriate or unprofessional behavior and consistent with 3M’s ethics and values — a place where all employees can do their best and are free to report workplace concerns without fear of retaliation or reprisal.” |
Working hours and living wages 3M complies with minimum wage legislation globally, and we make every effort to exceed the legal minimum wage. Our competitive compensation reflects our practice of establishing competitive salary ranges based on actual pay data from benchmark peer companies in manufacturing. 3M also complies with all applicable laws relating to overtime and breaks. Additional information can be found in the Compensation section. |
Freedom of association and the right to collective bargaining 3M works diligently to create a work culture that affords all employees the opportunity to work without fear of intimidation, reprisal, or harassment, in an environment where employees can have their questions and concerns addressed in a fair and timely manner. In all sites, the company’s relationship with employees, whether union or non-union, is a key responsibility of all company leaders, and is assisted by human resources representatives. Human resources professionals work with employees to maintain positive employee relations. |
Our Human Rights Policy has a specific subdivision on the freedom of association, which assures that we respect “the ability of employees to choose whether or not to join unions and engage in collective bargaining, as permitted by applicable laws in the countries where 3M does business.” In the event of business operations changes, we follow all applicable local laws and regulations regarding notice periods for both union and non-union employees. |
We are aware that, in some countries, collective bargaining rights are not protected or recognized. Nevertheless, 3M assures employees that freedom of association and collective bargaining aspects of our Human Rights Policy apply to all 3M employees worldwide. |
8% |
Approximately of 3M’s global workforce is unionized 22% with the number rising to when labor agreements are included. |
How we work 106 107 3M 2020 Sustainability Report #improvinglives Human rights |
Security personnel training and procedures. |
With the alarming rise in corporate security breaches worldwide, our Human Resource Security Standard provides the controls required to achieve human resource security based on industry standards and best practices. |
Roles and responsibilities of information security employees, contingent workers, and suppliers must be defined and documented in accordance with the 3M Information Security Management System (ISMS). Background checks verify all suppliers, contingent workers, and candidates for employment. Background checks must be carried out in accordance with relevant laws, regulations, and ethics, and must be appropriate for the business requirements, classification of the information to be accessed, and the perceived risks. Contingent workers and suppliers in the United States are required to review and acknowledge 3M’s Systems Access Control Standard and other 3M policies and standards. |
Management requires employees, contingent workers, and suppliers to apply security practices in accordance with established policies and procedures. All 3M employees and, where relevant, contingent workers and suppliers, must receive appropriate awareness training and regular updates in organizational policies and procedures, as relevant for their job function. |
Raising, addressing, and resolving workplace concerns. |
When concerns related to human rights, labor practices, environmental, or safety issues arise, our employees and non-employees are encouraged and trained to raise questions or report misconduct or potential misconduct. |
We provide a variety of mechanisms for reporting and resolving concerns: • Employee’s management and/or human resource manager • 3M legal counsel • 3M Ethics & Compliance Department • 3MEthics.com • 3M Global Security Operations Center. |
See 3M’s Ethics & Compliance website for more information regarding how to report a concern. Additional information can be found in the Corporate Code of Conduct section. |
3M prohibits retaliation against anyone who asks a question, reports a concern in good faith, or participates in a company investigation. This position is reflected in the Non-Retaliation Policy and within 3M’s Employee Obligations and Reporting Principle. |
In addition, we conduct audits of site, workplace, and human resource practices, and we conduct assessments and audits of suppliers to assure compliance with 3M’s expectations related to labor practices. See the Suppliers section for more details. |
Modern slavery. |
Modern slavery, as an umbrella term, encompasses several human rights issues, including forced labor, bonded labor, child labor, human trafficking, and slavery-like practices. We have a robust stance against these practices as set out in our labor, employment, and business conduct policies, and our Supplier Responsibility Code. These policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls, so this practice does not take place within our organization and supply chains. Additional information can be found at 3M Supplier Direct, Transparency in Supply Chains and Modern Slavery Disclosures. |
Child labor and minimum hiring age 3M is committed to doing our part to help abolish child labor. This commitment is evident in our Human Rights Policy and Supplier Responsibility Code. Although the permissible hiring age for employees may vary based on the laws of different countries, 3M has adopted global expectations regarding the hiring of minors. Even if local law permits it, 3M will not hire any employee nor engage a contingent worker (an individual provided by a third-party staffing agency to perform temporary work) below the age of 16 for any job. If the applicable laws impose a higher minimum age requirement than 16, 3M follows the stricter standard in compliance with the law. |
Forced and compulsory labor 3M complies with all applicable laws and employment regulations and does not engage or participate in forced labor. We have those same expectations for all suppliers doing business with us. This commitment is evident in our Human Rights Policy and Supplier Responsibility Code. |
Human trafficking. |
Our approach to human trafficking is very simple: We do not tolerate it. |
Our Human Rights Policy details our prohibition of human trafficking. We are committed to using effective systems and controls to prevent human trafficking from taking place anywhere within our business or supply chains. |
These prohibitions apply to 3M and its subsidiaries as well as to our federal contracts and subcontracts for either commercial or non-commercial items. |
Our Supplier Responsibility Code details expectations regarding labor and human resource practices for all of our suppliers worldwide. 3M suppliers must comply with all local country labor and human resource laws and cannot use labor that is obtained through mental or physical coercion, physical punishment, slavery, or other oppressive labor conditions, and cannot engage in any form of human trafficking. Additional information can be found in the Suppliers section. |
How we work 108 109 3M 2020 Sustainability Report #improvinglives Human rights |
Our actions. |
Strong support for human rights charters 3M continues to support several human rights charters. Among them: • United Nations Global Compact • Universal Declaration of Human Rights • European Convention on Human Rights • United Nations Guiding Principles on Business and Human Rights • International Labor Organization’s Declaration on Fundamental Principles and Rights at Work • OECD — Organization for Economic Co-operation and Development Guidelines for Multinational Enterprises, including OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas • Agenda 21 — United Nations Convention against Corruption. |
Holistic approach to human rights due diligence. |
The 3M Corporate Code of Conduct describes the company’s business conduct principles, or core values, which set forth global corporate expectations for all 3M employees and third parties who act on 3M’s behalf. The principles in this Code of Conduct remain consistent with 3M’s longstanding business conduct principles, its values, and our shared ethical standards for conducting business with uncompromising honesty and integrity. |
In our view, human rights due diligence requires a holistic approach. We assess our own business as well as those who are acting on our behalf — in supply roles, government relationships, acquisitions, mergers, and divestitures — to identify the salient human rights issues applicable to our business. We have a grievance mechanism in place, 3MEthics.com, which can be used to raise a concern regarding any adverse human rights impacts. We also comply with all applicable laws and honor the principles of internationally recognized human rights when faced with conflicting requirements. |
Assessing human rights. |
Our assessment of human rights aligns with our corporate Human Rights Policy, as outlined under our commitment, and includes these points of review: safe and healthy workplace, respectful workplace, workplace security, work hours and wages, freedom of association, child labor, forced labor, human trafficking, or recruitment fees to obtain employment. Evaluations are integrated into other assessment and management processes and are based on material issues regardless of where they’re identified within the value chain. |
Based on this assessment process, we have determined that in our various spheres of influence (our own business and in others acting on 3M’s behalf), the sphere with the greatest potential for human rights impact is within our supply chain. |
Segment Salient risk* Action plan to address 3M employees Assuring conformance with the 3M Code of Conduct. |
See Corporate Code of Conduct section for additional details on our actions. |
Others acting on 3M’s behalf Unsafe working conditions, mistreatment of workers. |
See Workplace Environmental, Health, and Safety Principle. |
Suppliers Assuring conformance with 3M Supplier Responsibility Code expectations. |
See Suppliers section for details on our risk-based supplier assessment process. |
Government relations Not adhering to all applicable laws, rules, and regulations. |
See Lobbying and Political Activities Principle; Political Activities and Issues Advocacy, and Doing Business with Government Agencies and Contractors Principle for more information. |
Acquisitions, mergers, and divestitures. |
Failing to recognize human rights issues during the acquisition integration or divestiture process. |
Prioritize and address human rights issues relative to risk and compliance; see Human Rights Policy, Respectful Workplace Principle, and Workplace Environmental, Health, and Safety Principle for more information. |