Be 3M: Corporate Code of Conduct

In 2023, we held a global Ethics & Compliance Day event to further build employee engagement around the Code of Conduct and doing business the right way. The virtual event engaged employees in business divisions and corporate functions around the theme “Unlocking the Value of Unwavering Integrity.” Ethics & Compliance teams around the globe promoted and amplified the event, with some local leaders taking the opportunity to explore the value of unwavering integrity at 3M with their teams. These activities resulted in one of our highest employee participation levels for an Ethics & Compliance event.

3M offers a comprehensive online compliance training program to employees worldwide. Employees are assigned training modules based on their role and area of responsibility. Most online courses, as well as our annual Code of Conduct certification, are mandatory for approximately 50,000 global employees. Ethics & Compliance tracks on-time completion rates, and our rate remains strong. We continually analyze scores and other course data to shape future training needs.

The Ethics & Compliance Department continues to make strides in data science. We leverage enhanced metrics dashboards to analyze emerging issues across different employee populations, as well as dashboards for third-party due diligence and business courtesies. We use metrics to monitor our evaluations and investigations.

In 2023, we implemented platform enhancements to improve efficiency and reduce risk, adapting to an evolving regulatory environment and aligning with business strategies. In addition, we continued to evolve our third-party due diligence program by implementing automation updates, enhancements for efficiency and compliance with standard processes, and better documentation of our review and management of risk associated with second-tier business partners.