3M Co – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	3M discloses several elements that indicate a structured, though not yet comprehensive, approach to governing its lobbying activities in relation to climate policy. The company states that "3M’s Government Affairs organization coordinates and oversees 3M’s lobbying and political activities," identifying an internal body that has responsibility for oversight. It also makes a public commitment that its engagement will be "in line with the goals of the Paris Agreement," and notes that it has "voluntarily published a detailed explanation of the company’s political activities in our Lobbying and Political Activities Principle" since 2007, signalling a standing policy framework. Transparency is further supported through disclosure of trade-association dues, as the company "disclose[s] the trade associations 3M has joined in which $25,000 or more of the dues are allocated for lobbying purposes," and by providing links to PAC and quarterly lobbying reports so that “shareholders [receive] useful information about our public policy engagement.” These points show that 3M has a policy commitment, an oversight body, and some mechanisms for monitoring and publicly reporting its lobbying. However, the disclosure does not describe how the Government Affairs organization or any higher-level committee formally reviews the climate alignment of specific lobbying positions, nor does it outline criteria for engaging, correcting, or exiting trade associations whose positions conflict with the company’s climate strategy; in other words, “extensive public policy engagement on both climate change and energy conservation” is referenced, but the company does not disclose a structured process for assessing the consistency of that engagement with its climate goals. The absence of a publicly available climate-lobbying alignment review, board-level involvement, or evidence of corrective action with trade bodies suggests the governance framework remains moderate rather than strong. View Sources	C

Overall Assessment

Analysis

Score

Moderate

3M discloses several elements that indicate a structured, though not yet comprehensive, approach to governing its lobbying activities in relation to climate policy. The company states that "3M’s Government Affairs organization coordinates and oversees 3M’s lobbying and political activities," identifying an internal body that has responsibility for oversight. It also makes a public commitment that its engagement will be "in line with the goals of the Paris Agreement," and notes that it has "voluntarily published a detailed explanation of the company’s political activities in our Lobbying and Political Activities Principle" since 2007, signalling a standing policy framework. Transparency is further supported through disclosure of trade-association dues, as the company "disclose[s] the trade associations 3M has joined in which $25,000 or more of the dues are allocated for lobbying purposes," and by providing links to PAC and quarterly lobbying reports so that “shareholders [receive] useful information about our public policy engagement.” These points show that 3M has a policy commitment, an oversight body, and some mechanisms for monitoring and publicly reporting its lobbying. However, the disclosure does not describe how the Government Affairs organization or any higher-level committee formally reviews the climate alignment of specific lobbying positions, nor does it outline criteria for engaging, correcting, or exiting trade associations whose positions conflict with the company’s climate strategy; in other words, “extensive public policy engagement on both climate change and energy conservation” is referenced, but the company does not disclose a structured process for assessing the consistency of that engagement with its climate goals. The absence of a publicly available climate-lobbying alignment review, board-level involvement, or evidence of corrective action with trade bodies suggests the governance framework remains moderate rather than strong.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	3M offers a solid level of transparency around its climate-policy lobbying. It names concrete U.S. measures it has engaged on, including the Inflation Reduction Act and proposals for a federal Clean Electricity Standard, and it references pending legislation on energy efficiency, grid modernisation and clean energy deployment, giving a clear sense of the policy arenas it targets. The company also explains how it seeks to influence those debates: it “engages with the US Congress and Department of Energy,” “actively supports and advocates for policies in Congress,” participates in voluntary government programmes such as the Better Buildings Challenge, and uses indirect channels through trade associations like the U.S. Chamber of Commerce and the Business Roundtable. Finally, 3M is explicit about the outcomes it wants, calling for the “adoption of a Clean Electricity Standard,” “more rapid deployment and utilisation of clean energy,” policies that “encourage the utilisation of energy-efficient solutions,” and measures to “increase the amount of renewable energy available on the grid, minimise the environmental footprint of transmission systems, and ensure the more efficient distribution of energy.” Taken together, these disclosures provide a strong, though not exhaustive, picture of the company’s climate-related lobbying activities and objectives.	B