It was November 2009, and 3M Co. had a big problem. The St. Paul–based business known for Post-it notes, Scotch tape and myriad other inventions had learned of allegations that its subsidiary in Turkey engaged in bribery, bid rigging and other improper behavior with Turkish government officials in the supplying of reflective material used in highway signs and pavement markings. The company made the decision to disclose what it had learned to the U.S. Department of Justice and the U.S. Securities and Exchange Commission.
During the next three-and-a-half years, more than a dozen of the company’s in-house lawyers, along with outside counsel from Debevoise & Plimpton, worked with U.S. authorities. They made voluntary disclosures about their findings, and they affirmed the company’s commitment to compliance. During that period 3M’s legal department also helped to establish a compliance and business conduct department to assist with the company’s antibribery program and worked to develop an updated code of conduct. Last year 3M released a new handbook that announced ethics policies for its more than 88,000 employees in 18 languages.
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