3M's DEI Employment Practices: What the Company's Own Documents Show — and What They Mean for Employees

Published August 27, 2026 · Last updated August 27, 2026 · By Fett Law — Michigan Employment Discrimination Attorneys

3M Company's own published reports and SEC filings describe demographic employment goals from 2015 through 2023: a global goal to "double the pipeline of diverse talent in management" from 32.6%, and U.S. goals to "double the representation of underrepresented groups" both in the overall workforce and in management, with progress reported to the decimal point each year. 3M is a long-standing federal contractor — more than $2.3 billion in federal prime-contract obligations, including an Air Force research contract running to 2028. Beginning with its 2024 annual report, 3M removed the words "diversity," "equity" and "underrepresented" from its filings. Practices of these kinds were the basis of two False Claims Act settlements with the U.S. Department of Justice — IBM's $17,077,043 in April 2026 and Deloitte's $21,500,000 in August 2026, in which the whistleblower was paid $4,300,000. Both resolved allegations only.

Key facts

Did 3M set racial representation goals for its workforce and management?

3M's first Global Diversity, Equity & Inclusion Report states the global goal and its numeric baseline in a single sentence:

"In 2015, 3M set a cumulative goal across all diversity categories to double the pipeline of diverse talent in management globally from 32.6% to 65.2%."

3M Company, first Global Diversity, Equity & Inclusion Report (covering 2020), "Driven by data" section (source)

The same report sets out the two United States goals, which are directed at named demographic groups rather than at diversity in the abstract:

"Double the representation of underrepresented groups from entry-level to senior management in our U.S. workforce"

"Double the representation of underrepresented groups in senior management positions in our U.S. workforce"

3M Company, first Global Diversity, Equity & Inclusion Report (covering 2020) (source). 3M's reports define "underrepresented groups" in the U.S. as Black/African American and Hispanic/Latino employees.

The goals were carried forward and restated, with the scope slightly widened from "senior management" to "management," in the DEI report 3M published for 2022 and still hosts today:

"Double the representation of underrepresented groups from entry-level through management in our U.S. workforce"

"Double the representation of underrepresented groups in management positions in our U.S. workforce"

"double our global diverse representation in management by 2030"

3M Company, DEI Report: Our People (2022 reporting year) (source)

These were not aspirations left unmeasured. 3M published its position against each goal every year, in its Global Impact Highlights. The 2022 edition reports:

"Reached 8.58% representation of underrepresented employee groups in U.S. workforce toward goal of doubling representation"

"Increased pipeline of diverse talent in management from 32.6% to 44.5%"

"100% pay equity globally"

3M Company, 2022 Global Impact Highlights Brochure, p. 10 (PDF)

The 2023 edition reports the same measures a year further on, and dates the commitment:

"45.1% diverse talent in management globally"

"9.02% workforce diversity from entry-level through management in the U.S."

"6.39% workforce diversity in management positions"

"2020 — We commit to invest $50 million over five years toward equitable workforce development and STEM education, to double the representation of underrepresented groups in our U.S. workforce, and to maintain or achieve pay equity globally"

3M Company, 2023 Global Impact Highlights Brochure, pp. 11–12 (PDF)

The commitment also appears in 3M's annual report to the Securities and Exchange Commission, which is a document signed and filed under federal law. The Form 10-K for fiscal 2022 states, under the heading "Diversity, Equity and Inclusion":

"3M focuses on attracting and advancing top talent and has publicly committed to advance global diversity in management across all dimensions, with additional specific goals to continue advancing pay equity and to increase the Company's diversity with underrepresented groups. 3M supports these values with an internal CEO Inclusion Council, a forum led by senior management to advance diversity, equity, and inclusion initiatives."

3M Company, Form 10-K for the fiscal year ended December 31, 2022, filed February 8, 2023, Item 1, Human Capital (source). Materially the same sentence appears in the fiscal 2021 and fiscal 2023 Forms 10-K.

What this meant in practice. A goal to double the share of one demographic group in a defined population is arithmetic that can only be satisfied by changing who is hired into and promoted within that population. 3M reported its position against those goals to the hundredth of a percentage point, which means somebody was counting, by group, at each level. What the public documents do not say is whether any individual hiring or promotion decision at 3M was made because of a protected characteristic in order to move those numbers. That is the question the law asks, and it is answered by internal records and by the people who ran the process — not by the report.

Did 3M tie executive pay to diversity targets?

The mechanism itself is disclosed plainly. 3M's proxy statement filed March 23, 2022 states:

"Added a new environmental, social and governance (ESG) modifier to the formula used to calculate the annual incentive compensation earned by the Company's senior executives, including our Named Executive Officers. Beginning in 2022, amounts earned by the Company's senior executives will be increased 10 percent of target, decreased 10 percent of target, or left unchanged based on the Compensation and Talent Committee's assessment of 3M's performance against a set of objective ESG metrics."

3M Company, Proxy Statement (DEF 14A), filed March 23, 2022, p. 17 (source)

The same proxy explains the modifier's purpose in a sentence that names the executive team directly: "Starting in 2022, our annual incentive program will include an ESG modifier to hold the executive team accountable for making progress toward our ESG goals" (p. 14). The proxy filed March 22, 2023 restates the modifier and cross-references a dedicated section, "Annual incentive — ESG Modifier," at page 72 of that document. The pay-elements table in the 2023 and 2024 proxies lists it as a discrete line: "ESG modifier (± 10% of target)."

What is and is not established. Two facts sit side by side in 3M's own filings during the same years: senior executive bonus pay carried a ±10% ESG modifier, and 3M had published numeric goals to double the representation of underrepresented groups. The filings reviewed here do not connect them. We are not asserting that they were connected, and no reader should treat the coincidence of dates as proof. The document that would settle it is 3M's own — the ESG-modifier section of the compensation discussion in the 2022, 2023 and 2024 proxy statements, and the internal scorecard behind it. Executives, human-resources leaders and compensation staff who worked on those plans know what the metrics were. So do the managers who were told what the company expected of them.

One further fact is on the record: the phrase "ESG modifier" appears in 3M's SEC filings only in the proxy statements filed in 2022, 2023 and 2024. It is absent from the 2025 and 2026 proxies, which introduce a relative total-shareholder-return modifier in its place.

Did 3M use race- or sex-conscious hiring?

3M's own description of the change is in its 2022 DEI report:

"We added several Historically Black Colleges and Universities (HBCUs) and Hispanic Serving Institutions (HSIs) to our mix of school partners."

"We partnered closely with organizations that would provide 3M access to diverse talent and differential development opportunities for 3Mers."

3M Company, DEI Report: Our People (2022 reporting year) (source). The named partners are the National Black MBA Association, the Society of Hispanic Professional Engineers, The Executive Leadership Council and the Association of Latino Professionals for America.

The distinction matters, in both directions. Widening where an employer looks for candidates is generally lawful; advertising a role to more people does not take a protected characteristic into account when choosing among them. That is different from the practice at issue in the IBM and Deloitte settlements, where the government's allegation was that the composition of the slate itself, or the identity of the candidates on it, was managed by race and sex. On the documents available, 3M published the first and not the second.

What a published document cannot show is how a demographic sourcing channel interacted with a published goal to double a group's representation, inside a particular requisition. Recruiters, hiring managers and human-resources staff at 3M during those years are the people who would know whether the goal ever reached a hiring decision.

Did 3M run programs restricted by race or sex?

The scholarship's original eligibility line, published by 3M's partner at launch, reads:

"Open to underrepresented minority high school seniors attending Saint Paul Public Schools or charter schools serving St. Paul students and current first-year college students attending an HBCU or FIU who graduated from Saint Paul Public Schools or St. Paul-serving charter schools."

UNCF, "UNCF, 3M Launch New Scholarship Program for St. Paul, MN Students to Attend HBCUs," January 22, 2021 (source). 3M's then Chief Equity Officer is quoted in the same release describing the program as "one of many milestones in our efforts toward creating greater equity for underrepresented populations."

By the 2024–2025 cycle the published criteria had changed. Scholarship listing services carrying the program's terms for that cycle state the applicant must "be a U.S. citizen or permanent resident of any race or ethnicity," and at least one listing service records that the scholarship is no longer available. Both versions belong on this page: the restriction is documented, and so is its removal.

On 3M's internal programs, the honest answer is a negative one. 3M's first Global DEI Report lists Employee Resource Networks with missions written around particular communities — the African American Network's stated mission is to "accelerate the inclusion and advancement of diverse talent at 3M," the Latino Resource Network's is "to attract and advance Latinos," and the Women's Leadership Forum's is to "accelerate the inclusion and advancement of women." Those are mission statements, not membership rules. We found no 3M document stating that any network, training program, mentoring program or leadership program was closed to employees on the basis of race or sex, and this page does not suggest otherwise. Whether any internal program in fact operated an eligibility screen is a question the public record does not answer.

Which 3M DEI documents disappeared from its website?

The fiscal 2024 Form 10-K, filed February 5, 2025 — two weeks after Executive Order 14173 — reads in full:

"Inclusion: 3M believes that bringing together people from diverse perspectives, backgrounds, and identities sparks even greater innovation, and helps 3M serve its customers. 3M maintains gender pay parity globally and is committed to continuing these efforts. Additionally, 3M focuses on attracting top talent from a variety of backgrounds and geographies and providing equal opportunities for advancement. 3M supports these values with an internal CEO Inclusion Council, a forum led by senior management to advance inclusion. Since 2020, the Company has invested $50 million to address opportunity gaps through workforce development initiatives in the communities in which its employees live and 3M business operates."

3M Company, Form 10-K for the fiscal year ended December 31, 2024, filed February 5, 2025, Item 1, Human Capital (source)

Set that against the fiscal 2023 version quoted earlier in this page. The sentence committing 3M to "advance global diversity in management across all dimensions, with additional specific goals … to increase the Company's diversity with underrepresented groups" is gone. "Racial opportunity gaps" has become "opportunity gaps." "Advance diversity, equity, and inclusion initiatives" has become "advance inclusion." One year later, in the Form 10-K filed February 3, 2026, the "Inclusion" subsection itself is gone, replaced by subsections headed "Performance Culture" and "People and Community," and the words diversity, equity, inclusion and underrepresented do not appear anywhere in the human capital section.

The same pattern runs through 3M's other channels. As of August 2026:

• 3M's 2025 Global Impact Report contains no occurrence of "diversity," "inclusion," "equity" or "DEI," no representation percentages, and no goals. Its pay-equity claim is narrowed to gender: "Our process has led to gender pay parity in every country where we do business." The racial and ethnic pay-equity claim carried in earlier reporting is absent.
• The 2023 Global Impact Report PDF, previously public, now redirects to a 3M account login page.
• 3M's news-center pages announcing its DEI reports return 404, and the 2020 announcement of the $50 million racial-equity commitment now resolves to the news homepage.
• 3M's sustainability goals page lists only environmental goals. The diversity, representation and pay-equity goals that headlined the 2022 and 2023 Global Impact Highlights are not there.
• The careers page still lives at a URL ending in "diversity-and-inclusion," but is now titled "3M People & Community" and contains no goals, no metrics and no employee-network information.

Two documents quoted on this page — the 2022 DEI report at equity.3m.com and the first Global DEI Report on 3M's third-party publishing host — are still live at the addresses given in the Sources section. If any part of your situation depends on what they say, download them. Documents that are no longer linked from any navigable page are one configuration change away from being gone.

How 3M's DEI program changed, 2015–2026

Why these practices matter legally

Title VII protects everyone, in both directions

Title VII makes it unlawful for an employer to discriminate against any individual with respect to compensation, terms, conditions or privileges of employment because of race, color, religion, sex or national origin. In Ames v. Ohio Department of Youth Services, decided June 5, 2025, a unanimous Supreme Court rejected the "background circumstances" rule that several federal circuits had used to require majority-group plaintiffs to make an extra showing before their claims could proceed. In Muldrow v. City of St. Louis (2024), the Court held that a plaintiff challenging a discriminatory job transfer need show only some harm to an identifiable term or condition of employment, not a "significant" disadvantage.

That change is not abstract at 3M. In Barnes v. 3M Company, Inc., No. 6:22-cv-01543 (N.D. Ala.), a white male former employee alleged that 3M applied a workplace rule inconsistently by race and sex. The court granted summary judgment to 3M on March 12, 2025, applying the Eleventh Circuit's comparator and "convincing mosaic" framework — three months before Ames was decided. The allegations were not proven and 3M prevailed; the case is noted here because it shows how these claims were analyzed before the Supreme Court unsettled part of that framework.

Section 1981 reaches race discrimination in employment contracts

42 U.S.C. § 1981 guarantees all persons the same right to make and enforce contracts as is enjoyed by white citizens, and it applies to employment relationships. It carries a four-year limitations period, requires no charge with the Equal Employment Opportunity Commission before suit, and has no cap on damages.

The False Claims Act route for federal contractors

On April 10, 2026, the U.S. Department of Justice announced that IBM would pay $17,077,043 to resolve False Claims Act allegations that it failed to comply with anti-discrimination requirements in its federal contracts — the first settlement under the Department's Civil Rights Fraud Initiative. In August 2026 the government resolved a second, larger matter: under a settlement agreement effective August 21, 2026, five Deloitte entities agreed to pay $21,500,000, of which $9,995,000 was restitution, covering conduct from January 1, 2017 through the settlement date. The certification hook is specific — Title VII as incorporated into federal contracts and FAR clause 52.222-26 — and the government's theory reached not only what Deloitte certified to its contracting agencies but what it "publicly represented" about its compliance. The agreement adds a second and independent theory: that Deloitte "allocated costs to its federal government contracts relating to these practices and sought payment and reimbursement under its federal government contracts for such costs." The whistleblower was paid $4,300,000. Both settlements resolved allegations only, with no determination of liability, and Deloitte denies the conduct.

The Covered Conduct the government described in the Deloitte agreement included "non-public race and sex-based workforce composition goals for business units," goals that in some instances the company "recognized … if achieved, would result in a reduction in the representation of certain other racial groups," and programs "where eligibility to participate was limited on the basis of race and sex." 3M Company's position on the government-business side is a matter of federal record: federal spending data shows more than $2.3 billion in prime-contract obligations to the 3M corporate family, 3M's own procurement page names the GSA, the Defense Logistics Agency and the Department of Veterans Affairs as customers, and an Air Force Research Laboratory contract awarded in September 2024 runs through September 2028. 3M has also already resolved a False Claims Act case arising from what it sold the government: on July 30, 2018 it agreed to pay $9.1 million to settle allegations in United States ex rel. Moldex-Metric, Inc. v. 3M Company, No. 3:16-cv-1533-MBS (D.S.C.), concerning Combat Arms earplugs supplied to the Defense Logistics Agency; the relator received $1,911,000. That settlement also resolved allegations without a determination of liability, and it concerned product performance rather than employment practices — but it establishes the contractual architecture on which a False Claims Act theory would rest.

One limit belongs in its own sentence. A Justice Department settlement resolves only the United States' claims. The Deloitte agreement expressly reserves any pending or future charges before the Equal Employment Opportunity Commission — including "charges which may allege the same covered conduct described in this Agreement" (¶ 5(d)) — reserves "any liability of individuals" (¶ 5(g)), and reserves suspension and debarment (¶ 5(c)).

To be clear about what is and is not established: no court or agency has found that 3M's practices violated any law, we located no discrimination charge, OFCCP action, False Claims Act matter or Civil Rights Fraud Initiative activity involving 3M's employment practices, and both federal settlements described above resolved allegations without any determination of liability. But practices like those documented above — numeric goals to double a demographic group's representation at defined levels, measured and reported annually — are precisely the category these claims examine. For the complete framework — the four illegal DEI practice categories and when you can sue — see our guide, Is DEI Illegal? 4 Illegal DEI Practices & When You Can Sue.

Were you affected by these practices at 3M?

If you worked at 3M Company — or applied there — between roughly 2015 and 2025, the documented goals above may have touched your career in ways worth examining:

• You were passed over for a promotion into management during years when 3M published a goal to double the representation of underrepresented groups in management positions and reported its progress against that goal annually.
• You applied and never reached an interview, and cannot account for it against your record, during a period when 3M had added HBCU and Hispanic-Serving Institution channels and demographic professional organizations to its sourcing mix while carrying published representation goals.
• You were a manager, recruiter, or human-resources or compensation professional with first-hand knowledge of how the doubling goals were cascaded — what business leaders were told, what was tracked, and whether the ESG modifier on executive bonus pay was measured against any demographic result.
• You were an executive or leader whose own objectives referenced representation numbers — the people who set and reported those figures know how they were meant to be achieved.
• You were a student outside the eligible schools for the UNCF · 3M scholarship in its 2021–2023 form, and the recruiting track attached to it.
• You worked on 3M's federal contract business and know what the company certified about its compliance with anti-discrimination requirements, or how the costs of its diversity programs were treated.

A federal settlement is not a substitute for your own claim: when the Justice Department resolved the Deloitte matter, it expressly preserved the EEOC's right to pursue charges alleging the very same conduct, and preserved individual liability. Nothing about that settlement compensated a single employee or applicant.

There is a separate question worth asking if your work touched 3M's federal business. The False Claims Act's qui tam mechanism lets an individual bring a claim on the government's behalf, and potentially share in any recovery, where a company certified compliance with federal anti-discrimination requirements while doing something else — the theory the Justice Department used against IBM and Deloitte. Qui tam complaints are filed under seal, so a whistleblower's identity is initially protected while the government investigates. Both Title VII and the False Claims Act prohibit retaliation against people who assert their rights or report violations.

If any of these fits, it costs nothing to find out where you stand — meet our DEI discrimination lawyers, or start below.

What could a claim against 3M be worth?

Whistleblower rewards under the False Claims Act

Under 31 U.S.C. § 3730(d), a qui tam relator receives 15–25% of the government's recovery when the Department of Justice intervenes, and 25–30% when the relator proceeds without intervention. The Deloitte settlement supplies a paid benchmark rather than a projection: the relator received $4,300,000 — exactly 20% of a $21,500,000 recovery. That settlement also shows why False Claims Act exposure outruns the money actually lost. Of the $21.5 million, $9,995,000 was restitution — roughly the government's single damages — so the resolution came to about 2.15 times the actual loss, because FCA recoveries are built on multiplied damages plus per-claim penalties. As a second illustration, arithmetic alone: an intervened case resolving at IBM's $17,077,043 would pay a relator roughly $2.6–$4.3 million. A contractor with a larger federal book or a longer conduct period could produce a materially larger number. Relator expenses, fees and costs are resolved separately from the relator's share. For scale on 3M's own history with the statute: the relator in the 2018 Combat Arms earplug case received $1,911,000 of a $9.1 million settlement.

Damages in individual discrimination cases

Back pay and front pay are uncapped under Title VII. Compensatory and punitive damages under Title VII are capped by employer size — $300,000 for employers with more than 500 employees, the bracket 3M Company occupies — but race claims under 42 U.S.C. § 1981 carry no damages cap at all, which is one reason race discrimination cases are often pleaded under it. Several state civil-rights statutes are likewise uncapped, including Michigan's Elliott-Larsen Civil Rights Act. Prevailing plaintiffs generally recover attorney's fees on top. For a sense of what employment discrimination cases can produce, Fett Law's own results include a $10.5 million race and age discrimination class action against Ford Motor Company, a $1.1 million jury judgment against the Michigan State Police, and a $460,000 reverse-discrimination settlement for three corrections officers. Prior results do not guarantee a similar outcome.

Class action potential

Class actions are built on a single policy applied to many people. A companywide goal to double a demographic group's representation in management, reported annually to two decimal places, is by construction companywide. Historic employment-discrimination class settlements show the range such cases can reach: Coca-Cola paid $192.5 million (2000), Texaco $176.1 million (1996) and Novartis $175 million (2010) to resolve class claims.

Every case depends on its own facts — these figures show the range the law makes possible, not a promise of any outcome. The fastest way to learn where your situation falls is to start a confidential intake or request a free consultation.

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