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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. 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, 2019, and 2020, using 3MEthics.com.
The Ethics & Compliance Department maintains the investigation case management system and reports metrics from a broad range of 3M functions that conduct investigations. 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 global allegations and disciplinary actions.
Total number1 1 Data in the present chart may differ from previous reports as case management progresses.
400 200 600 1200 1000 1400 1600 1800 800 0.
Disciplinary actions 2019 2020.
Substantiated allegations 2018.
Allegations reported.
Feature stories Who we are How we work What we create About report 98 3M 2021 Sustainability Report | #improvinglives
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 the reporter expresses concern that they are being retaliated against, the investigations team will initiate a separate investigation or take other action to assure the concerned party is protected. 3M takes a strong position against retaliation, which is reflected in the Non-Retaliation Policy and within 3M’s Employee Obligations and Reporting Principle.
Assessments 3M’s Ethics & Compliance Department conducts periodic compliance and anti-bribery evaluations in various 3M subsidiaries and operating units each year. An evaluation includes a review of financial transactions, compliance records, interviews with representatives from a cross-section of employees of the entity being evaluated, and reviews of selected business partners.
The team aims to interview at least 10% of non-production employees. Subsidiaries and operating units are selected for an evaluation using objective and subjective risk factors. Our evaluation planning and site selection process leverages data to prioritize countries and operations for future review. A “local evaluation” process is used to address site-specific risk with more agility and speed.
Local evaluations provide a more focused scope than our standard deep-dive evaluation and can be organized and completed with fewer resources in less time while continuing to meet the requirements of the Ethics & Compliance Department. Our evaluation process continues to evolve. In 2020, the assessment of compliance culture was further enhanced with focus on “tone in the middle” as well as “tone at the top.” Middle managers and supervisors are critical in setting the tone for their teams. Evaluation interviews delve into understanding this and identifying opportunities for improvement.
Not only do reviews, 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.
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!
Feature stories Who we are How we work What we create About report 99 3M 2021 Sustainability Report | #improvinglives
Commitment to anti-corruption.
As a participant in the United Nations Global Compact (UNGC), 3M is committed to supporting Principle 10 on Anti-Corruption. Our commitment and involvement with the UNGC and 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 anti-bribery 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 anti-bribery policies and procedures have been communicated to all employees. Our Avoiding Bribery and Corruption training is required of most non-production employees, 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 compliance 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 due-diligence 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, the 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.
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 and accelerate 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.
Raising third-party awareness of 3M ethics and compliance expectations.
To enhance our communications with and expectations of third parties, 3M has an online training course and a brochure for our business partners, available in 30 languages. The brochure provides another way for 3M to communicate with our business partners regarding our commitment to combat global bribery.
Michael Duran, 3M vice president and chief ethics & compliance officer, says, “Our commitment to unwavering integrity in all that we do is clear and stems from the top of our organization. It has been the foundation of the company for more than a century. At 3M, we know there is only one way to do business — the right way. I am proud to work for a company that puts ethics and compliance at the forefront of everything we do.” “Our commitment to unwavering integrity in all that we do is clear and stems from the top of our organization.”
Michael Duran 3M Vice President and Chief Ethics & Compliance Officer.
Feature stories Who we are How we work What we create About report 100 3M 2021 Sustainability Report | #improvinglives
Our actions.
Global Ethics & Compliance Week.
For the first time, we held a global, virtual Ethics & Compliance Week from October 12-16, 2020. This year’s theme was “Your Roadmap to the Right Way” and focused on making the right and ethical decisions in the workplace.
On October 13, we held a global, virtual live event, with presenters and participants from 3M operations worldwide. The event featured a compilation of self-filmed videos by 3M employees from around the globe sharing their personal thoughts on what ethics and compliance means to them. 3M CEO Mike Roman provided a message about navigating ethics at 3M. Dave Dillon, 3M Board member and retired chairman of the board and CEO of The Kroger Co., joined the event and shared his experience and perspective on the importance of ethics and compliance. Following these messages, the event showcased global senior leaders discussing their own key learnings on ethics and compliance throughout their careers.
Because the most frequent resource employees go to with ethical or compliance questions is their manager, the Ethics & Compliance Department publishes a series of supervisor toolkits. These toolkits, available in 12 languages, contain 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. This year, the supervisor toolkits covered the following topics: conflicts of interest, 3M information and computer security, and respectful workplace.
We have also had great success with our leadership video series, where executives share their stories of how they have handled ethical situations in the past or their thoughts on doing the right thing at 3M. These videos are translated with subtitles and have been popular throughout the year.
“I feel very proud to work in one of the most ethical companies in the world.”
Global Ethics & Compliance Week participant.
A post-event survey confirmed that employees appreciated the global nature of the event and the leadership stories. More than 80% of the respondents said they were more confident to speak up after the event.
Communications to support our employees and supervisors.
In 2020, 3M Ethics & Compliance further enhanced our internal communications by leveraging an internal social networking platform to share compliance-related information and drive real-time conversations with global employees.
We recognize the power of storytelling to inspire and influence ethical behavior. We continued our video series called “My Moment of Truth,” which shares 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, filmed on cell phones or other readily available video equipment. The participants included employees from all over the world and were subtitled in eight languages, including English.
which is 10 times greater than any single previous in-person Ethics & Compliance Week event.
During the week, dedicated messages were shared to build on what was learned during the virtual event, including communications on Living the Code, Speak Up, pressure, organizational justice and fairness, and conflicts of interest. The global event was followed by area events in Latin America; Asia Pacific; and Europe, Middle East, and Africa.
This virtual platform provided an opportunity to reach over 10K participants,
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Data analysis and metrics.
The Ethics & Compliance Department continued to make strides in data science. Data modeling was used to further refine risk assessment processes related to compliance evaluations and business partners. The cycle time to create our compliance reporting metrics continued to improve, and reports were automated for delivering timely metrics to internal stakeholders across the company. In addition to report automation, we explored the area of predictive data analytics so that our program can respond proactively to trends observed by analyzing available data and then provide areas of global and/or local focus as needed.
In alignment with 3M’s new global operating model, we leveraged a business analytics tool to quickly adapt our compliance reports to accommodate the new reporting structures.
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 as well employees’ perceptions of leaders as ethical role models. In addition, we found that in some specific geographies, employees felt increased pressure to achieve business results, as well as a general lack of understanding of our investigation process and efforts to assure organizational justice. Based on the survey findings, we launched an extensive communications campaign to address these concerns to both managers and employees throughout the year.
Training enhancements.
In 2020, our online adaptive learning training platform has continued to be well-received by employees. Leveraging data from our training platform, Ethics & Compliance is able to identify additional training needs through data analysis. To drive improved on-time online training course completions, we continue to leverage a pop-up notification that reminds a user each time they open certain desktop applications of their need to complete course assignments.
Recognizing that people have different learning styles, Ethics & Compliance identified and launched two new video series to engage learners with fresh content. The videos became available at the end of 2020 and will continue into 2021.
Acquisition integration.
Over the course of 2020, leveraging novel tracking tools and cross-team, cross-geography work groups, we successfully integrated 3M’s largest acquisition into our ethics and compliance platforms, processes, and culture. Through this work, the Ethics & Compliance Department established a close partnership with 3M’s Health Care Compliance Team whose global health care compliance leader has a dotted line reporting to the vice president and chief ethics & compliance officer to assure alignment and to enhance work efficiencies between the two groups.
In 2020, our online adaptive learning training platform has continued to be well-received by employees.
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Adaptations to our ethics and compliance program based on the COVID-19 global pandemic.
In response to the COVID-19 crisis, the Ethics & Compliance Department made adaptations to our program to accommodate the challenges of the year while still meeting compliance requirements.
• In March 2020, Ethics & Compliance Department employees transitioned to a virtual work environment, including the shift of our ethics and compliance investigation and evaluation processes to a remote model, leveraging technology to gather information that would have been previously sought in-person.
• We adjusted our training schedule by allowing employees to complete scheduled courses earlier than its scheduled deployment and expanded the time to complete courses from four weeks to six weeks.
• In collaboration with other corporate functions, we leveraged ethics and compliance platforms to address risks associated with the current environment, including communication on insider trading, and separate compliance attestations for employees’ return to the workplace and for those in business with increased pressure and corruption risks.
Despite the challenging remote work environment, our operations continued to remain strong and effective. Organizational enhancement.
The Ethics & Compliance Department continues to leverage and strengthen our global ethics and compliance network. In December 2020, a series of enhancements were announced, including standardization of the roles and titles of people who support the network, clarification on the time spent in these roles, and creation of a consistent model framework with reporting lines for all geographies. These improvements were driven through a collaborative project between the 3M Corporate Affairs organization and the Ethics & Compliance Department to assure the design aligns with 3M core strategies. This enhancement resulted in a number of employees moving to the Ethics & Compliance Department given their scope of work and responsibilities. This realignment assures that there are resources in our geographies with a dedicated compliance mindset.
We reached 100% completion of our annual code certification in the quickest time in our history.
We had the highest ever on time completion rate for our online compliance courses. We saw a significant increase in calls to our hotline, with much of the increase related to the COVID-19 crisis. We communicated to executives this increase, as well as our strategy, so they were better able to understand the complexity of the issues being reported.
We successfully evolved our in-person training to a virtual environment, reaching approximately 25K employees.
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Looking forward.
In 2021, ethics and compliance will remain at the core of what we do for our employees, customers, communities, and shareholders.
Data analysis will remain a focus to drive efficiencies and prioritize our actions with more agility. We will continue to empower global leadership to take ownership of key performance indicators by providing access to tools and metrics.
The Ethics & Compliance Department will continue the evolution of our compliance partner networks to drive a culture of compliance, speaking up, and doing business the right way. Additionally, we will continue our collaboration and coordination with the 3M Health Care Compliance Team.
The Ethics & Compliance Department will optimize opportunities to continually improve our program and platforms, engaging with employees through new and different modalities. We will continue to equip employees with guidance, information, and tools to do business the right way and manage third-party risk through integrated user-friendly platforms.