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Benchmarking Alert: Here is 3M’s anti-bribery policy

Minnesota-based 3M has over 100,000 patents and produces around 60,000 products — including the N95 face mask. Here are five interesting points from its anti-bribery policy.

1. Local customs aren’t a defense.

3M employees and any third party to whom this Principle applies, must not provide, offer or accept bribes, kickbacks, corrupt payments, facilitation payments, inappropriate gifts, to or from Government Officials or any commercial person or entity, regardless of local practices or customs.

2. You’re responsible for our business partners’ bad acts. 

3M employees must not allow any Business Partner to provide, offer or accept bribes, kickbacks, corrupt payments, facilitation payments, or inappropriate gifts, or 3M and the employee may be held responsible for the actions of the Business Partner. 

3. Facilitating payments are bribes.

Facilitation payments are bribes and are prohibited . . . A facilitation payment or “grease payment” is a small sum of money paid to a Government Official in order to expedite routine and nondiscretionary activities, such as obtaining a visa or work order, installing telephone service, or initiating electrical service. 3M prohibits facilitation payments, which can violate the UKBA and other countries’ anti-bribery laws.

This is similar to Apple, Novartis,  MicrosoftVolkswagenAirbus, and GM which ban all facilitating payments. Coca-Cola and Tesla might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. Cups of coffee aren’t bribes.

Small courtesies, such as a cup of coffee, a token gift of nominal value, or a reasonably priced lunch or dinner, are not bribes.

5. Hiring decisions can be bribes. 

The U.S. Foreign Corrupt Practices Act and other countries’ bribery or corruption laws may consider the hiring of a family member of a Government Official as bribery, depending on why the family member was hired, his or her qualifications, and the Government Official’s ability to make decisions that could affect 3M business. Relatives of Government Officials may be hired by 3M. However, special care must be taken when an applicant is the close relative (such as a spouse, child, sibling, niece, nephew, aunt or uncle) of a Government Official who is in a position to influence a decision related to the purchase, prescription, or use of a 3M product or 3M service, or to any other governmental action that would benefit 3M’s business.

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View more anti-corruption policy benchmarks here.

Here’s the full three-page anti-bribery principle:

3M_Anti-Bribery Principle-PDF_FCPABlog

 

Click here to download the 3M anti-bribery principle

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