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Feature stories Who we are How we work What we create About report 104 3M 2021 Sustainability Report | #improvinglives
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, 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, the 3M 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.
Human rights.
We do business one way: the right way.
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 3M workers to have a respectful workplace. 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. Respect for human rights is deeply engrained in our culture.
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.
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.
Feature stories Who we are How we work What we create About report 105 3M 2021 Sustainability Report | #improvinglives
A respectful workplace.
Our Code of Conduct lays out what it means to be a 3M employee and includes the 3M Respectful Workplace Principle:
Be Respectful: Respect one another and our social and physical environment around the world. We strive to have a work environment where people treat each other with respect and conduct business activities in a manner that protects health, safety, and the environment.
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. It is a work environment that is free of inappropriate or unprofessional behavior and consistent with 3M’s ethics and values — a place where everyone can do their best, and where people 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 endeavor 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, breaks, and other wage-and-hour requirements. Additional information can be found in the Compensation section.
Freedom of association and the right to collective bargaining 3M works diligently to create a 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. At all sites, assuring a strong relationship with employees is a key responsibility of all company leaders and is supported 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 consultation and notice periods for both represented and non-represented employees.
Approximately 25% of 3M’s employees are either represented by a collective labor organization or covered by a labor agreement.
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.
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 Modern Slavery Statement; labor, employment, and business conduct policies; and the 3M 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.
Feature stories Who we are How we work What we create About report 106 3M 2021 Sustainability Report | #improvinglives
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 Modern Slavery Statement. 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. See our Supplier Responsibility Code for details on supplier requirements.
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, Modern Slavery Statement, 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; 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.
Security personnel training and procedures.
With the alarming rise in corporate security breaches worldwide, our internal 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). Improved in 2020, background checks for all suppliers, contingent workers, and candidates for employment 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 on organizational policies and procedures, as relevant for their job function.
For more information on workplace security see the Environmental, health, and safety section. Our approach to human trafficking is very simple: We do not tolerate it.
Feature stories Who we are How we work What we create About report 107 3M 2021 Sustainability Report | #improvinglives
Raising, addressing, and resolving workplace concerns.
When concerns related to human rights, labor practices, environmental, or safety issues arise, our employees and people who interact with 3M are encouraged to raise questions or report misconduct or potential misconduct and can do so anonymously if they wish.
Employees also receive training on the following mechanisms for reporting and resolving concerns: • Employee’s management • 3M Human Resources • 3M Legal Affairs • 3M Ethics & Compliance Department • 3MEthics.com (option for anonymity) • 3M Global Security Operations Center • 3M Corporate Audit Department.
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, in good faith, asks a question, reports a concern, 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.
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 • Organisation for Economic Co-operation and Development (OECD) — 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 Code of Conduct is part of the 3M Value Model and positions 3M for long-term growth. Our Code of Conduct summarizes the guidance provided in 3M’s principles, policies, standards, and procedures, which govern how we do business everywhere, every day. By living our Code, we create an inclusive workplace where each employee contributes to 3M’s vision. Our success depends on our unwavering integrity. These global corporate expectations apply to all 3M employees and third parties who act on 3M’s behalf.
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.
In our view, human rights due diligence requires a holistic approach.
Feature stories Who we are How we work What we create About report 108 3M 2021 Sustainability Report | #improvinglives
Assessing human rights.
Our assessment of human rights aligns with our corporate Human Rights Policy, as outlined under our commitment above, and includes a review of the following points: 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 Nonconformance 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 Nonconformance 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, Lobbying and Political Activities Governance, 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, merger, or divestiture diligence processes.
Prioritize and address human rights issues relative to risk and compliance; see Human Rights Policy, Respectful Workplace Principle, EHS Acquisitions, Mergers, and Divestitures Standard, and Workplace Environmental, Health, and Safety Principle for more information.
Local communities Inequitable opportunities to succeed in science, technology, engineering, and math (STEM); skilled trades occupations.
Assess community partnerships to assure we are providing support to underrepresented populations, so they have equal opportunity for success in STEM and skilled trade employment areas; see the Community section for additional information.
Customers Failing to produce products that are safe for their intended uses; compliant with applicable environmental, health, and safety regulations, and 3M expectations.
See Product Safety, Quality, and Stewardship Principle and Innovation management section for more information * Risks as per human rights policy (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)
Feature stories Who we are How we work What we create About report 109 3M 2021 Sustainability Report | #improvinglives
Within our own business.
Within 3M, our approach to managing and assuring human rights aligns with the 3M Code of Conduct, which recognizes the right of employees to have a respectful workplace.
As stated in the Code of Conduct Global Handbook, which is available in 25 languages, all 3M employees are held to the same high standards. If the Code of Conduct sets a higher standard than the law, we are expected to follow the Code of Conduct and do business the 3M Way. 3M’s success depends on each of us doing the right thing. No matter our job title, we are all leaders when it comes to ethics and integrity, and we must meet these important commitments: • Know and follow the guidance set forth in our Code of Conduct • Foster a positive, inclusive work environment and a strong culture of ethics • Complete compliance courses and certifications on time • Report suspected violations of the law or our Code of Conduct unless prohibited to do so by local law • Do not engage in workplace retaliation • Report any known or suspected retaliation • Cooperate with investigations 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. Executives and managers are accountable for creating an inclusive workplace environment that encourages asking questions and raising concerns.
For additional details on our employee processes, see the Employee diversity, equity, and inclusion and Employee programs sections.
Assuring human rights through training.
We provide training globally to assure that all 3M employees comply with the law, 3M’s Code of Conduct, supporting policies, standards, and procedures, including human rights.
In addition to offering online training, the Ethics & Compliance Department — in collaboration with 3M Legal Affairs, local compliance partners, finance, and human resources — provides frequent, tailored, in-person training opportunities to businesses, subsidiaries, staff groups, and third parties. Some of this training occurs as part of an annual schedule, and some training occurs as requested or when deemed appropriate.
Each manager and supervisor must assure that those who report to them complete mandatory compliance training and Code of Conduct certification as required in 3M’s Code of Conduct Global Handbook. See the Corporate Code of Conduct section for more information.
Employees are assigned courses based on their job function, country location, production/non-production status, and supervisor/non-supervisor and management-level status. Email notifications are sent to the employee’s or their supervisor’s 3M email address informing them of their course requirements and their timeline for completion. New employee courses are due within 60 days of assignment.
If an employee does not have a 3M email address in the HR system, it is the responsibility of their supervisor (or designated trainer) to inform them of their course requirements. The email notifications include a course announcement and up to three reminders.
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.
Training for 3M employees on the Supplier Responsibility Code processes and tools includes a self-check exercise and final quiz to understand the effectiveness of the training. Training is available online and will be updated when there have been significant changes to the Supplier Responsibility Code, process, or tools.
Supplier Responsibility Code training and information for suppliers reside on the 3M Supplier Direct website. Supplier Responsibility Code information is sent to suppliers prior to conducting an assessment to assure awareness of expectations — which are also addressed during supplier status review meetings.
Others acting on 3M’s behalf.
Upholding 3M’s Code of Conduct and 3M Values is the responsibility of everyone acting on 3M’s behalf. Multiple processes are in place to assure 3M’s principles are being upheld by these parties. A good example is our approach to health and safety.
Feature stories Who we are How we work What we create About report 110 3M 2021 Sustainability Report | #improvinglives
Under the Workplace Environmental, Health, and Safety Principle, 3M’s Code of Conduct requires 3M employees to select and retain suppliers, contractors, or outsourced manufacturers and service providers who comply with all applicable laws and regulations and meet 3M’s environmental, health, and safety values. In addition, at 3M sites, all visitors, suppliers, contingent workers, and contractors are held to the same safety and health requirements as 3M employees.