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plan to invest. |
Feature stories Who we are How we work What we create About report 89 3M 2021 Sustainability Report | #improvinglives |
Through engagement with our Board of Directors, executive leadership team, and business units, our work across 3M’s Strategic Sustainability Framework is advancing progress toward our Sustainability Goals. |
Additional information can be found in our 2021 Proxy Statement, Commitment to Sustainability. |
Governance links. |
For more information on corporate governance at 3M, see: • Corporate Officers • Board of Directors • Committee Composition • Governance Documents • Annual Reports & Proxy Statements. |
Group Function. |
Board of Directors Receives regular sustainability updates at Board meetings. |
Reviews sustainability-related risks as part of 3M’s enterprise risk program. |
Science, Technology & Sustainability Committee of the Board of Directors. |
Provides primary oversight of 3M’s sustainability and stewardship activities. |
Reviews 3M’s sustainability policies and program to identify and analyze significant sustainability, materials vulnerability, and geopolitical issues that may impact 3M’s overall business strategy, global business continuity, and financial results. |
Innovation Steering Committee Provides leadership, oversight, and strategy to encourage and ensure sustainability opportunities are recognized. |
Develops and monitors adherence with strong sustainability-related policies and procedures. |
Includes 3M’s CEO, CTO, and SVP Environmental Responsibility, General Counsel, SVP Corporate Affairs, and EVP Consumer Business Group. |
Chief Sustainability Officer Leads 3M’s sustainability activities. |
Reports to the Science, Technology & Sustainability Committee of the Board of Directors, the Innovation Steering Committee, and other internal and external groups. |
Sustainability leaders in business, areas, and enterprise-wide Drives Strategic Sustainability Framework priorities and initiatives consistent with the scope of their role. |
Leads customer relationships to solve shared global challenges. |
Feature stories Who we are How we work What we create About report 90 3M 2021 Sustainability Report | #improvinglives |
We regularly post governance news, events, and presentation information in the Investor Relations section of our website. See 3M Events & presentations. |
Looking forward. |
Our work across 3M’s Strategic Sustainability Framework is advancing progress toward our Sustainability Goals. |
Feature stories Who we are How we work What we create About report 91 3M 2021 Sustainability Report | #improvinglives |
Our commitment. |
The concept of risk appetite and tolerance is an essential component of our strategic planning, and it’s the responsibility of our senior business leaders to plan accordingly. |
We firmly believe that good corporate governance practices serve the longterm interests of our stockholders, strengthen 3M’s Board of Directors and management, and further enhance the public trust 3M has earned from more than a century of operating with unwavering integrity and doing business the right way. Governance includes broad risk oversight by the Board and its committees. Risk analysis is reported to the full Board by both the general auditor and the chief ethics & compliance officer. The general auditor and the chief ethics & compliance officer are vice president positions appointed by, and reporting to, the Audit Committee of the Board. |
Risk oversight. |
The Board has delegated primary responsibility for the oversight of risks facing the company to the Audit Committee of the Board of Directors. The Audit Committee Charter states that the committee will “discuss policies and procedures with respect to risk assessment and risk management, the company’s major risk exposures, and the steps management has taken to monitor and mitigate such exposures.” |
The vice president and general auditor, Corporate Auditing, whose appointment and performance is reviewed and evaluated by the Audit Committee, is responsible for leading the formal risk assessment and management process within the company. The general auditor, consulting with the company’s senior management, annually assesses the major risks facing the company and works with those executives responsible for managing each specific risk. The general auditor periodically reviews with the Audit Committee the major risks facing the company and the steps management has taken to monitor and mitigate those risks. |
Enterprise risk. |
Understanding, assessing, and planning for risk. |
While the Board’s oversight of risk is primarily performed by the Audit Committee, the Board has also delegated to other committees the oversight of risks within their areas of responsibility and expertise. We believe this governance of risks by Board committees, who share information with the full Board, is appropriate for a diversified technology and manufacturing company like 3M. 3M’s Annual Report on Form 10-K, Item 1A outlines risk factors applicable to the company. In addition, 3M’s Proxy Statement provides details on Board oversight committees and members. |
Feature stories Who we are How we work What we create About report 92 3M 2021 Sustainability Report | #improvinglives |
Our actions. |
Corporate-level 3M’s Enterprise Risk Management (ERM) initiative, launched in 2001, has helped assure adequate recognition and ownership of the most significant potential risks to the company’s shareholder value, using a process that proactively identifies and communicates enterprise risks within the company. This includes confirming that appropriate plans and oversight exist for all major risks, providing for ongoing review and assessment of risk, and aiding in generating awareness and engagement of general risk matters throughout the company. The approach provides a customized capability that leverages 3M’s comprehensive, experience-based global knowledge and capabilities while also considering tools often used in financial or insurance-oriented businesses. |
To assure long-term success, we are committed to discovering and preparing for all potential threats to our Vision. Risk owners familiar with the environmental, economic, and business aspects within the company are interviewed and requested to complete a thorough assessment for their respective risk(s). Together with subject-matter experts and senior management, the outcomes are mapped to demonstrate the relative level of risk and likelihood of risk. This “heat map” identifies the highest-risk areas and shows where to focus our internal efforts. In addition, external resources and data are continually reviewed to assist in the risk identification process. The results of our various risk assessment exercises are shared with the Corporate Operating Committee and the company’s full Board of Directors. |
Shifting focus in light of the COVID-19 pandemic 3M places particular emphasis on protecting our company against emerging risks in an ever-changing world. In 2020, we moved quickly to reassess our risks in light of the COVID-19 pandemic. In response to the pandemic, we identified new risks and increased our focus on certain existing risks. |
In 2020, we moved quickly to reassess our risks in light of the COVID-19 pandemic. |
Our top priorities in response to the COVID-19 pandemic have been keeping our people and communities safe, supporting the fight against the pandemic, and assuring business continuity. In response to our top priority to keep our people and communities safe, we added a new enterprise risk highly focused on employee health and safety. To help support the fight against the pandemic, we increased our focus on third-party risk. And to assure business continuity, we increased our focus on several risks, including material vulnerability. |
Feature stories Who we are How we work What we create About report 93 3M 2021 Sustainability Report | #improvinglives |
Board members and general auditor meet 1:1. |
In 2020, 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 group planning 3M serves our 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. Each presentation includes the following: an overview of the business group, short- and long-term financial performance and goals, an assessment of portfolio growth opportunities, and strategic priorities to drive our Value Model. |
Site-level planning. |
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. |
In addition to conducting environmental, health, safety, and security risk analysis, we have a business resilience plan for each manufacturing site and distribution center. 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, full approval of management, and regular audits or assessments. Scenario exercises are conducted periodically at sites to evaluate the effectiveness of the plans. We have a business resilience plan for each manufacturing site and distribution center. |
Feature stories Who we are How we work What we create About report 94 3M 2021 Sustainability Report | #improvinglives |
Looking forward 3M will continue to advance our processes to identify and mitigate enterprise risk in our ever-changing environment by engaging all levels of leadership. Our priority is the comprehensive management of enterprise risks through an ethical tone, governance processes, and clear roles, responsibilities, and accountability. |
Our priority is the comprehensive management of enterprise risks. |
Feature stories Who we are How we work What we create About report 95 3M 2021 Sustainability Report | #improvinglives |
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 their 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. |
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. |
Corporate Code of Conduct. |
Keeping ethics and compliance front and center 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. Leaders are accountable for creating an inclusive workplace environment that encourages asking questions and raising concerns. |
The Code of Conduct is our guide, answering questions and providing direction when the right choice may not be clear. |
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. |
We have one Code of Conduct that applies to our 96.1K employees in over 70 countries globally. |
Global Code of Conduct 1. |
Contents. |
Global Code of Conduct. |
Be 3M. |
Be Good. |
Be Honest. |
Be Fair. |
Be Loyal. |
Be Accurate. |
Be Respectful. |
Feature stories Who we are How we work What we create About report 96 3M 2021 Sustainability Report | #improvinglives |
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-level Corporate Operating Committee. Additionally, similar committees exist at country, regional, and area 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’ antibribery 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 50,000 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. |
Examples of recent training modules include: • Data Privacy and Protection • Confidential Information and Computer Security • Gifts, Entertainment, and Travel • Avoiding Bribery and Corruption: A Global Overview • Understanding Global Competition • Preventing Workplace Harassment • 3M Code of Conduct and Ethical Decision-Making • Identifying and Navigating Conflicts 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. Online courses are offered in 22 languages. |
Feature stories Who we are How we work What we create About report 97 3M 2021 Sustainability Report | #improvinglives |
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. 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. |
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