UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, DC 20549

 

FORM SD

 

Specialized Disclosure Report

 

3M COMPANY

(Exact name of registrant as specified in Its charter)

 

Delaware

(State or other jurisdiction of incorporation)

 

 

Debora Fronczak, Vice President

3M Strategic Sourcing & Packaging Solutions (651) 733-1110

(Name and telephone number, including area code, of the person to contact in connection with this report.)

 

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

 

x  Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.

 

 

 

Section 1 — Conflict Minerals Disclosures

 

Item 1.01 Conflict Minerals Disclosure and Report

 

This Specialized Disclosure Report (“Form SD”) for 3M Company (“3M,” “Company,” “we,” “our”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1 to December 31, 2019. References to 3M’s website are provided for convenience only, and its contents are not incorporated by reference into this Form SD or the Conflict Minerals Report, nor are they deemed filed with the U.S. Securities and Exchange Commission (“SEC”).

 

Conflict Minerals are defined by the SEC as cassiterite, columbite-tantalite, wolframite and gold, and their derivatives, which are limited to tin, tantalum and tungsten (collectively “3TG”). During calendar year 2019, 3M manufactured and contracted to manufacture products in which 3TG were necessary to the functionality or production of those products.

 

3M therefore conducted a “reasonable country of origin inquiry” (“RCOI”) to determine whether any of those minerals (1) originated in the Democratic Republic of Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (together, the “Covered Countries”); or (2) are from recycled or scrap sources.

 

A.            Introduction:

 

1.              3M’s Business: 3M is a diversified technology company with a global presence in the following businesses: Safety & Industrial; Transportation & Electronics; Health Care; and Consumer. 3M is among the leading manufacturers of products for many of the markets it serves. These businesses have worldwide responsibility for virtually all 3M product lines.

 

2.              3M Supply Chains: 3M supply chains are complex, including thousands of suppliers spread over different tiers in those chains. Supplied materials are used in products serving numerous industry sectors. 3M is typically many tiers removed from smelters or refiners (“SORs”) that would have information on mines supplying 3TG. Moreover, to the extent 3TG are present in 3M products the content may be at trace levels. Supply chains have significantly improved their capacity to obtain and transmit SOR identities as compared to the first year that 3M conducted its 3TG supplier inquiry which reflects in part the value of the Responsible Minerals Initiative (“RMI”), in building cross-industry collaboration, due diligence guidance and common supplier inquiry templates that support a more robust infrastructure for multi-tier supply chain inquiry. Still, obtaining information regarding smelters, refiners and mine locations remains challenging. Challenges include delayed supplier responses, incomplete or inconsistent data, and in some cases the need for extensive supplier follow-up.

 

3.              3M’s Responsible Minerals Sourcing Policy: 3M first adopted a Conflict Minerals Policy in 2011. The Conflict Minerals Policy was updated in 2019 and renamed to Responsible Minerals Sourcing Policy (“Policy”) to include 3TG and cobalt and is available on the 3M Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/) along with other information on 3M’s Responsible Minerals program. 3M is committed to responsible sourcing of 3TG and cobalt using the Organisation for Economic Cooperation and Development Guidance, so as not to support conflict or human rights abuses in the Covered Countries Conflict-Affected and High-Risk Areas, while avoiding de facto embargoes. This position is consistent with 3M’s Human Rights Policy Statement (http://multimedia.3m.com/mws/media/1029705O/human-rights- policy.pdf) and 3M’s respect for human rights within our own operations and our supply chains, as well as United Nations Guiding Principles for Business and Human Rights. 3M is a signatory to the United Nations Global Compact and is aligned with the ten principles. The 3M Policy forms the basis for 3M’s Responsible Minerals program, and its requirements are communicated to 3M’s suppliers through annual outreach and in relevant global contract templates and U.S. purchase order terms and conditions which require suppliers to comply with applicable laws and our policies on responsible minerals. The 3M Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/) contains training resources on various conflict minerals topics, including practical tips, best practices, and other relevant supplier information.

 

4.              3M’s Participation in Cross-Industry Efforts: As a downstream company that does not typically contract directly with 3TG SORs, 3M routinely collaborated with others in the industry through participation in RMI. RMI is a broad-based initiative that develops control systems regarding smelters and refiners through independently validated audits under RMI’s Responsible Minerals Assurance Process (“RMAP”). According to the RMI website, over 380 companies and associations across multiple industries participate in RMI. RMI also engages with a wide variety of organizations to discuss emerging issues, best practices and work on addressing shared

 

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challenges across the supply chain. In furtherance of our commitment to industry collaborative controls, and in particular the RMAP program, 3M was one of the early donors to the RMI Initial Audit Fund (the “Fund”) to provide financial assistance to smelters for their first-year audit. The Fund is intended to reduce barriers to smelter participation in the RMAP. 3M has been a member of RMI since 2011 and was an active member of RMI throughout 2019. Members of 3M’s Responsible Minerals Steering Team participated in the RMI Due Diligence Practices Team, Plenary Team, Smelter Engagement Team, and attended the Responsible Business Alliance (“RBA”) and RMI Annual Conference to ensure alignment with program and strategies in 2019. 3M also encouraged suppliers, smelters and refiners to participate in RMI to expand common due diligence efforts. In addition, 3M, as well as its provider (as defined below), encouraged SORs identified in 3M’s supply chain but non-conformant to RMAP to enroll and participate in RMAP.

 

B.            Description of RCOI:

 

1.              RCOI Elements: The elements of 3M’s RCOI are identification and prioritization of suppliers, supplier data collection, and an assessment of supplier data to determine whether further due diligence is required.

 

2.              Prioritized Supplier Inquiry: In view of 3M’s complex and extensive supply chains, 3M determined that a reasonably designed and good faith inquiry should focus on higher priority suppliers consistent with RMI’s Five Practical Steps to Support SEC Conflict Minerals Disclosure. 3M designated approximately 47 employees globally as “Responsible Minerals Advisors” (“RMAs”). The RMAs and many other knowledgeable 3M personnel identified products containing 3TG necessary to the functionality or production of those products (“Necessary 3TG”), including products from covered acquisitions. This process resulted in many product families and individual products being screened out from further inquiry, as not containing Necessary 3TG. Through the screening process, the RMAs and other 3M personnel determined to the best of their knowledge that the following product categories may contain Necessary 3TG:

 

·                  Electrical connectors, cables and cords, electronic chargers, controls, monitors and plated circuitry

·                  Products that include these and other electrical or electronic components

·                  Metallized films and tapes

·                  Some orthodontic products

·                  Fall protection equipment

·                  Fire safety equipment

 

3M then prioritized its review of these products that may contain Necessary 3TG and the corresponding supply chains taking into account various factors such as estimated content of 3TG, type of mineral, amount of spend, the nature of the supply chain, and supplier location. 3M conducted outreach with suppliers for products that may contain Necessary 3TG, which represented 92% of the in-scope supplier spend in 2019.

 

3.              Data Collection: Once the relevant higher priority suppliers (“Supplier Group”) were identified, 3M asked the Supplier Group to provide information about the Necessary 3TG in their products based on responses to the industry standard RMI Conflict Minerals Reporting Template (“CMRT”). 3M engaged a third-party service provider (“provider”) to assist with Supplier Group outreach as well as engagement with data collection and validation. Accordingly, the CMRT was deployed to the Supplier Group through 3M’s provider’s web portal. That system issued four automatic follow-up reminders to those in the Supplier Group who had not responded to the information requested. Additional direct mail reminders were sent to those in the Supplier Group who had not responded, and follow-up phone calls were made with prioritized suppliers. As part of these phone calls, 3M offered training to the supplier on topics including the importance of the information requested by 3M, the disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act conflict minerals legislation, and how to attach the CMRT into 3M’s provider’s web portal. In addition, follow-up reminders were sent as an escalation to those in the Supplier Group who had discrepancies in their CMRT. Outbound communications were conducted in native languages such as: English, German, simplified-Chinese, French, Italian, Spanish, Portuguese, and Japanese to best collaborate with suppliers to ensure expectations were understood.

 

4.              Data Validation: 3M and its provider conducted data validation on all submitted CMRTs and retained them for recordkeeping purposes. The goal of data validation is to increase the completeness and accuracy of the submissions and to identify any contradictory responses in the CMRT. 3M’s provider reviewed the responses to determine where further engagement with suppliers was warranted. Those responses were then escalated to 3M for additional due diligence and follow-up. We considered untimely or incomplete responses as well as inconsistencies with the data reported in the CMRT in making this determination. For any CMRT that was

 

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determined invalid based on this review, the provider’s web platform automatically sent the supplier an email outlining any validation issues with the CMRT question logic or missing fields. 3M’s provider proactively engaged suppliers to educate them on the validity requirements, how to enter CMRT data and/or 3M’s expectation on CMRT information, as appropriate. The provider’s web portal links to training resources and conflict minerals templates, practical tips, and best practices.

 

If there were discrepancies in expected mineral content for suppliers responding that materials contained Necessary 3TG, additional information and follow-up was conducted with the supplier to clear the discrepancy. Where appropriate, the provider asked the supplier to submit a new CMRT or revised documentation after such follow-up.

 

For those suppliers that indicated in their CMRTs that they did not have certain aspects of a conflict minerals program, such as a conflict minerals policy or implementation of due diligence measures for conflict-free sourcing, the CMRTs were still considered valid. However, the provider applied a “strength indicator” identifying if the supplier’s answer on their CMRT indicated a strong or weak conflict minerals program.

 

With respect to data validation on SOR-related information listed in the submitted CMRTs, the provider’s smelter team compared the SOR names and SOR country locations provided in the suppliers’ submitted CMRTs to the SOR names and SOR country locations that are listed on the “smelter reference list” provided in the RMI-CMRT template form.

 

The provider validated whether any 3TG sourced from the Covered Countries is conflict-free based on the information provided by our Supplier Group, by RMI and similar gold refining industry auditing programs (London Bullion Market Association and Responsible Jewellery Council), through RMI RCOI data and by other information available on RMI’s website.

 

Based on the responses received to the Company’s RCOI, which included thousands of alleged SOR names, and information on SOR names, locations and associated countries of origin from the RMI-RCOI data set (to which we have access as a member of RMI), 3M compiled a list of 297 verified, unique SORs, including information regarding associated countries of origin. 3M and its provider performed due diligence on the SORs that were known or reasonably believed to have sourced from the Covered Countries, or that had unknown sourcing as described in the attached Conflict Minerals Report.

 

C.            Results of RCOI

 

Downstream companies such as 3M are not likely to have direct information on the sources of minerals upstream of the SORs in their supply chains. Instead, downstream companies rely on available information regarding SORs identified through supplier inquiry. Accordingly, 3M and its provider reviewed supplier responses resulting from the inquiry described in Paragraphs B.3 and B.4 above as well as information from capacity-building interactions and efforts with suppliers to elicit responses and encourage development of conflict minerals programs. These supplier responses and the capacity-building efforts affirmed information on supply chain maturity gathered through participation in the RMI program and other industry associations. 3M has received substantially more SOR names from the Supplier Group in recent years as compared to the beginning of the program. 3M achieved a response rate from suppliers that was greater than 80%, which we believe is an indication of significant progress in the multi-tiered supply chains’ capacity to pass 3TG-related inquiries and information on SORs up and down those supply chains. As a downstream company typically several tiers from SORs, 3M relied on information from direct suppliers, many of them smaller and private companies. The information received on SOR names from direct suppliers suggested that these direct suppliers had made progress in building their conflict minerals programs and capacities to transmit conflict mineral information during 2019.

 

D.            Conclusion

 

Based on its RCOI 3M has reason to believe that a portion of its Necessary 3TG may have originated in the Covered Countries and has reason to believe that those Necessary 3TG minerals may not be from recycled or scrap sources. Accordingly, 3M and its provider conducted further due diligence on the source and chain of custody of Necessary 3TG contained in products supplied by the Supplier Group.

 

In accord with Rule 13p-1, 3M has filed this Form SD and the associated Conflict Minerals Report and both reports are posted to 3M’s Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/).

 

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Item 1.02         Exhibit

 

The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

 

Section 2          Exhibits

 

Item 2.01         Exhibits

 

Exhibit 1.01 — Conflict Minerals Report for the period January 1 to December 31, 2019, as required by Items 1.01 and 1.02 of this Form SD.

 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 

3M COMPANY
/s/ Eric Hammes
By: Eric Hammes		May 31, 2020
Executive Vice President, Enterprise Operations		(Date)

 

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Exhibit 1.01

 

CONFLICT MINERALS REPORT OF 3M COMPANY

 

FOR THE YEAR ENDED DECEMBER 31, 2019

 

INTRODUCTION

 

This Conflict Minerals Report for 3M Company (“3M”, “Company,” “we,” “our”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 for the reporting period from January 1 to December 31, 2019.

 

Conflict Minerals are defined by the Securities and Exchange Commission (“SEC”) as cassiterite, columbite-tantalite, wolframite and gold, and their derivatives, which are limited to tin, tantalum and tungsten (collectively “3TG”). As a result of the Company’s reasonable country of origin inquiry (“RCOI”) for the period January 1 to December 31, 2019 described in the attached Specialized Disclosure Report (“Form SD”), 3M has reason to believe that a portion of the 3TG necessary to the functionality or production of products (“Necessary 3TG”) that we manufactured or contracted to manufacture during the period between January 1, 2019 and December 31, 2019 may have originated in the Democratic Republic of Congo (“DRC”), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (together, the “Covered Countries”) and those Necessary 3TG may not be from recycled or scrap sources.

 

3M has actively engaged with its customers and suppliers for several years with respect to the use of conflict minerals. 3M adopted a conflict minerals policy articulating the conflict minerals supply chain due diligence process and 3M’s commitments to reporting obligations regarding conflict minerals. The policy is available on 3M’s Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/).

 

3M has contributed to industry efforts to address conflict minerals through serving as a member of the Responsible Business Alliance (“RBA”) and the Responsible Minerals Initiative (“RMI”). This engagement and the contributions made have helped develop standards, best practices, and tools that benefit all companies working to end the association between 3TG and conflict in the Covered Countries.

 

REASONABLE COUNTRY OF ORIGIN INQUIRY

 

Many essential products in the 3M businesses, such as electronics, personal safety or transportation, rely on 3TG. The following are examples of product families that often include 3TG:

 

·              Electrical connectors, cables and cords, electronic chargers, controls, monitors and plated circuitry

·              Products that include these and other electrical or electronic components

·              Metallized films and tapes

·              Some orthodontic products

·              Fall protection equipment

·              Fire safety equipment

 

3M therefore conducted due diligence on the source and chain of custody of Necessary 3TG as described below, using the following due diligence management system: To determine whether Necessary 3TG in products originated in Covered Countries, 3M retained a third-party service provider (“provider”) to assist us in reviewing the supply chain and identifying risks. 3M provided a list composed of suppliers and parts associated with the in-scope products to the provider for upload to their database to assist with reasonable country of origin of potential product families such as those noted above.

 

 

To collect data on the materials’ sources of origin procured by the supply chain, 3M utilized RMI’s Conflict Minerals Reporting Template (“CMRT”) version 5.12 to conduct a survey of all in-scope suppliers.

 

During the supplier survey, 3M contacted suppliers via the provider’s software-as-a-service (SaaS) platform that enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The database also provides functionality that meets the OECD Guidance (as defined

 

 

below) process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed are managed through this platform.

 

Via the database and provider, 3M requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. The provider monitored and tracked all communications in the database for future reporting and transparency. 3M directly contacted suppliers that were unresponsive to the provider’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to the provider.

 

3M’s program included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

 

All submitted forms were accepted and classified as valid or invalid so that data is retained. Examples of invalid submissions may include: incomplete, inaccurate, or inconsistent data. Further due diligence is implemented with suppliers providing invalid forms and are requested to submit a valid form. Suppliers were also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through the provider’s multilingual Supplier Experience team.

 

Based on the findings through the RCOI process, 3M was able to determine the countries of origin for a large portion of the 3TG in its products. As such, 3M continued to perform further due diligence on the source and chain of custody of the minerals in question.

 

DUE DILIGENCE MEASURES

 

A.        Design of Our Due Diligence Measures

 

Our Conflict Minerals due diligence management system has been designed to conform in all material respects with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”), as applicable for 3TG and downstream companies (as the term “downstream companies” is defined in the OECD Guidance).

 

B.        Due Diligence Performed

 

1.          Establish Strong Company Management Systems

 

Responsible Minerals (Conflict Minerals) Sourcing Policy

 

3M first adopted a Conflict Minerals Policy in 2011. The Conflict Minerals Policy was updated in 2019 and renamed to Responsible Minerals Sourcing Policy (“Policy”) to include 3TG and cobalt and is available on 3M’s Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/) along with other information on 3M’s Responsible Minerals program.

 

3M is committed to responsible sourcing of 3TG and cobalt using the OECD due diligence framework, so as not to support conflict or human rights abuses in the Covered Countries or Conflict-Affected and High-Risk Areas (“CAHRAs”), while avoiding de facto embargoes. This position is consistent with 3M’s Human Rights Policy (http://multimedia.3m.com/mws/media/1029705O/human-rights-policy.pdf) and 3M’s respect for human rights in our own operations and our supply chains, as well as with the OECD Guidance and United Nations Guiding Principles on Business and Human Rights.

 

Internal Management System

 

3M has established a management system to support the effective and efficient execution of our Responsible Minerals program. 3M’s management system includes an executive sponsor: 3M’s Senior Vice President, Enterprise Operations. In addition, 3M has designated a cross-functional Responsible Minerals Steering Team (“Steering Team”), composed of representatives from Strategic Sourcing, Regional Responsible Sourcing Leaders, and 3M Legal Affairs. The Steering Team has responsibility for developing and implementing 3M’s Policy, compliance strategy, as well as reviewing the progress, effectiveness and continual improvement of the program. The Steering Team is led by a Responsible Minerals Program Manager (“Program Manager”) from 3M Strategic Sourcing.

 

 

Senior leadership of Strategic Sourcing, Finance, Corporate Audit, Compliance and Business Conduct, and Human Resources is briefed bi-annually about the results of our due diligence efforts, including evaluation of risks and risk mitigation measures. These briefings also include an evaluation of the progress, effectiveness and execution of our Policy and Responsible Minerals program.

 

3M’s provider assisted with evaluating supply chain information regarding 3TG, identifying potential risks, and in the development and implementation of additional due diligence steps that 3M will undertake with suppliers with regard to conflict minerals.

 

3M leveraged the provider’s managed service team made up of dedicated program specialists who supported 3M’s conflict minerals program. 3M communicated regularly with the provider in order to receive updates on program status. Each member of the provider’s team is trained in conflict minerals compliance and understands the intricacies of the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”).

 

Control System and Supply Chain Transparency

 

3M’s Supplier Responsibility Code (“SRC”) (https://www.3m.com/3M/en_US/suppliers-direct/supplier-requirements/global-supplier-responsibility-code/) applies to all suppliers and outlines 3M’s expectations as it relates to labor, ethics, environmental health and safety as well as management systems. This code of conduct is based on industry and internationally-accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Guidance. If a supplier does not meet 3M’s requirements, the situation is escalated and evaluated for disposition.

 

3M global suppliers are expected to supply materials to 3M that are “Conflict-Free,” meaning minerals that are from recycled or scrap sources or that do not directly or indirectly finance armed groups through mining or mineral trading in the DRC, adjoining countries or any other CAHRAs as determined by regulatory bodies and as applied by RMI. This expectation is communicated in 3M contract agreement templates and U.S. purchase order terms & conditions. 3M relies on direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied, including sources of 3TG that are supplied to them from lower-tier suppliers.

 

3M is a member of RMI, which provides strong industry collaboration and greater visibility to supply chain risks. 3M gathered information on the use of 3TG by the Supplier Group (as defined in the Supplier Engagement section) using RMI’s CMRT. 3M engaged the provider to assist with Supplier Group outreach and engagement and with data collection and validation. 3M used the provider’s web portal to determine the chain of custody of the Necessary 3TG included in our products, with a focus on identifying smelters and refiners (“SORs”) in their respective supply chains.

 

Supplier Engagement

 

3M identified relevant suppliers that supply products that may contain Necessary 3TG. 3M has determined that a reasonably designed inquiry for identifying and assessing supply chain risks should focus on higher priority suppliers consistent with RMI’s Five Practical Steps to Support SEC Conflict Minerals Disclosure. 3M identified the relevant higher priority suppliers (“Supplier Group”) by prioritizing its review of products that may contain Necessary 3TG, and the corresponding supply chains, accounting for various factors such as estimated content of Necessary 3TG, type of mineral, amount of spend, the nature of the supply chain, and supplier location. In 2019 3M conducted outreach with suppliers for products that may contain Necessary 3TG, which represented 92% of the in-scope supplier spend.

 

3M’s provider reviewed the Supplier Group CMRT responses to determine where further engagement with suppliers was warranted. Those responses were then escalated to 3M for additional due diligence and follow-up. We considered untimely or incomplete responses as well as inconsistencies with the data reported in the CMRT in making this determination. For any CMRT that was determined invalid based on this review, the provider’s platform automatically sent the supplier an email outlining any validation issues with the CMRT question logic or missing fields. 3M’s provider proactively engaged suppliers to educate them on the validity requirements, how to enter CMRT data, and/or 3M’s expectation on CMRT information, as appropriate. Suppliers were educated on 3M’s provider’s supplier portal links, which provides training resources, reporting templates, practical tips, and best practices.

 

3M established controls and transparency by creating a process in coordination with the provider to engage relevant suppliers to identify SORs contained in 3M’s supply chain. We communicated expectations to these relevant suppliers in connection with our inquiry requesting they send a similar request to their direct suppliers to obtain the information successively upstream to the smelter or refiner. A provider web portal was utilized for the collection of CMRTs. Suppliers were provided a link to 3M’s Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/) where we communicate supplier responsibility expectations, have links to our Supplier Learning Academy, which includes links to training resources, practical tips, and best practices. 3M encourages all suppliers to have a proactive approach in aligning with 3M’s policies and programs to strengthen our supply chain to ensure conformance to regulations. Because 3M believes in developing strong and sustainable relationships, it is important our business partners understand 3M’s

 

 

commitment to doing business ethically and in compliance with the law.

 

For suppliers that identified “red-flagged” SORs in their CMRT responses, according to indicators defined in the OECD Guidance, 3M and its provider requested additional information on those suppliers’ conflict minerals due diligence standards and processes, including further due diligence about the “red-flag” SORs. In addition, these suppliers were provided a link to educational courses on smelter risk mitigation.

 

3M’s requirements related to responsible minerals in relevant global contract templates and U.S. purchase order terms and conditions require suppliers to comply with applicable laws and our policies on responsible minerals. This includes participation in a supply chain survey and related due diligence activities, and to provide upon request, information on SORs in relevant supply chains and other information 3M might require.

 

3M’s Policy expects suppliers to responsibly source 3TG and cobalt through SORs that comply with recognized assurance programs including RMI, the London Bullion Market Association (“LBMA”), and the Responsible Jewellery Council (“RJC”). For SORs identified by the Supplier Group not currently engaged in an assurance program, 3M sent letters to those SORs encouraging them to participate. 3M also encouraged our Supplier Group and in certain cases customers to reach out to those SORs and encourage their participation. In addition, communications were sent to those SORs in our supply chain who were conformant but had not been designated as progressing or having a re-audit in progress within three months of their conformance date.

 

3M also encourages suppliers to draw upon internationally recognized standards to advance social and environmental responsibility and business ethics. All existing and future suppliers are required to conform to 3M’s SRC, demonstrating their commitment to share 3M’s values on social and environmentally sustainable operations and practices, which include labor, ethics, environmental health and safety as well as management systems. The SRC is based upon the RBA framework. 3M uses several external indices, such as the International Labour Organization, Global Slavery Index, and the Corruption Perception Index, to assist with prioritization of higher risk suppliers.

 

In partnership with 3M’s service provider, 3M has put a strong emphasis on supplier education and training. This includes guiding suppliers to online resources, including access to interactive training courses, informational and best practice documents and real time chat with compliance specialists.

 

Grievance Mechanism

 

We have a grievance mechanism whereby employees and suppliers can report concerns regarding 3M’s business conduct and other matters, at 3M-ethics.com (https://secure.ethicspoint.com/domain/media/en/gui/8897/index.html). We have procedures in place for follow-up in the event any responsible minerals issues are raised through our grievance mechanism.

 

SORs and other external stakeholders also may use RMI’s Grievance and Complaints Mechanism (“RMI Mechanism”). The RMI Mechanism allows stakeholders to raise concerns about the RMI Responsible Minerals Assurance Process (“RMAP”) audit process, protocols, and SOR operations that fall within the scope of the RMAP, audit quality, and auditor competencies, mineral supply chains and upstream/downstream initiatives, as well as mineral sourcing activities and due diligence of RMI member companies.

 

Maintain Records

 

We have a record retention policy applicable to conflict minerals-related documentation that provides for retention for a minimum of ten years. 3M’s provider’s document retention policy includes 3M conflict minerals related documents, including supplier responses to CMRTs as well as the sources identified within each reporting period.

 

2.            Identify and Assess Risk in the Supply Chain

 

As part of the process of identifying and assessing risks in the supply chain, 3M asked the Supplier Group to share information about the Necessary 3TG in their products provided to 3M based on responses to the industry standard RMI CMRT. 3M deployed the CMRT to the Supplier Group through the provider’s supplier’s web portal. That system issued four automatic follow-up reminders to those in the Supplier Group who had not responded to the information requested. Additional direct mail reminders were sent to those in the Supplier Group who had not responded, and follow-up phone calls were made with prioritized suppliers. As part of these phone calls, 3M offered training to the supplier on topics including the importance of the information requested by 3M, the disclosure requirements of the Dodd-Frank Act conflict minerals legislation, and how to attach the CMRT into 3M’s provider’s web portal. In addition, follow-up reminders were sent as an escalation to those in the Supplier Group who had discrepancies in their CMRTs. Outbound communications were conducted in native languages such as: English, German, simplified Chinese, French, Italian, Spanish, Portuguese, and Japanese to best collaborate with suppliers to ensure expectations were understood. If supplier responses indicated

 

 

that Necessary 3TG contained in products provided to 3M may have originated from the Covered Countries, had unknown sourcing or may have been processed by SORs that have not been validated as using DRC conflict free sourcing practices, then such responses were escalated to the Steering Team for further review and determination of follow-up steps.

 

3M does not have a direct relationship with SORs and does not perform direct audits of these entities within the supply chain. Smelters that have completed an RMAP audit are considered to be DRC conflict free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, follow-ups are made to suppliers reporting those facilities. Smelters are then assessed for the potential for sourcing risk.

 

Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. The provider uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

 

·                  Geographic proximity to the DRC and Covered Countries.

·                  Known mineral source country of origin.

·                  RMAP audit status.

·                  Credible evidence of unethical or conflict sourcing.

·                  Peer assessments conducted by credible third-party sources.

 

Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.

 

We verified SORs using RMI’s Conformant Smelters and Refiners list. We also referred to other sources of information, including publications of the LBMA and the RJC, to validate and assess potential risks.

 

3.            Design and Implement a Strategy to Respond to Identified Risks

 

3M has designed and implemented a strategy to respond to risks. The Program Manager works with the Steering Team and its executive sponsor, providing periodic updates or escalating issues to relevant executives of any findings where a supplier in the Supplier Group identifies a SOR processing Necessary 3TG for 3M products that sources from or may source from the Covered Countries.

 

The provider’s risk mitigation activities are initiated whenever a supplier’s CMRT reported facilities of concern. Through the provider, suppliers with submissions that included any smelters of concern were immediately given feedback instructing the supplier to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to 3M. Additional escalation may have been necessary to address any continued sourcing from these smelters of concern. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters of concern from the supply chain. In addition, suppliers are guided to the educational materials, located on the provider’s website, on mitigating the risks identified through the data collection process.

 

If additional escalation is required, the Program Manager works with the Steering Team and its executive sponsor, or other relevant executives, to determine appropriate follow-up actions, if any, to mitigate risks. Follow-up actions based upon the variety of supplier risk levels may include additional due diligence by the Steering Team. 3M and its provider may communicate directly with its suppliers that have not yet been determined to be conformant with RMAP in order to request sourcing information and encourage their involvement with the RMI Program. As part of the due diligence activities we may decide to find alternate sources of supply and/or suspend or terminate existing supplier relationships after failed attempts at mitigation or remediation. For the year 2019, 3M found no instances where it was necessary to find replacement sources of supply, or to suspend or terminate a supplier relationship.

 

4.            Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

 

3M utilized information provided by the independent third-party audits of SORs through RMAP, LBMA and the RJC to determine whether any Necessary 3TG sourced from the Covered Countries is validated as “Conflict-Free” using RMI’s RCOI data. In addition, members of the Steering Team participate in RMI’s Due Diligence Practices Team, Plenary Team, Smelter Engagement Team and Risk Readiness User Group, which keeps 3M informed of new auditing standards, emerging risks, and risk assessment methods.

 

3M’s provider directly contacted SORs that are not currently enrolled in the RMAP to encourage their participation and

 

 

gather information regarding each facility’s sourcing practices on behalf of its compliance partners. 3M is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance.

 

Through 3M’s membership with the RMI, SORs have been encouraged to participate in the RMAP. Any SORs that were reported by suppliers who were not part of the RMAP were also contacted directly by 3M’s provider to encourage them to participate in the RMAP.

 

5.            Report on Supply Chain Due Diligence

 

3M has published the Form SD and Conflict Minerals Report for the year ended December 31, 2019. These reports are publicly available within the Responsible Minerals section of 3M’s Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/). The reference to 3M’s website is provided for convenience only, and its contents are not incorporated by reference into this Report and Form SD nor deemed filed with the SEC.

 

RESULTS OF DUE DILIGENCE

 

Based on our RCOI described in our Form SD and the other aspects of our due diligence program described above, 3M evaluated the Supplier Group responses to the CMRT based supplier inquiry. As a result of the RCOI activity, 3M has reason to believe that a portion of its Necessary 3TG may have originated in the Covered Countries and those Necessary 3TG may not be from recycled or scrap sources. However, after conducting further due diligence, 3M determined that based on SOR information provided by the Supplier Group and information available to 3M as a member of RMI, the 13 SORs identified as sourcing from those Covered Countries have been validated as conformant to RMAP protocols.

 

As outlined in the OECD Guidance, the internationally-recognized standard on which 3M’s system is based, we support RMI’s RMAP process that audits SORs’ due diligence activities. The source of information for certain statements in this declaration was obtained through our membership in RMI, using the RCOI report for member “mmmco.”

 

Supply Chain Outreach Results

 

Supply chain outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten and gold. Following the industry standard process, CMRTs were sent to and requested from Tier 1 suppliers, who are expected to follow this process until the SOR sources are identified. In 2019, 3M received 80% response rate from its suppliers as a result of outreach efforts.

 

Upstream Data Transparency

 

All SORs listed by suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are attached in Annex I. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing the SORs have the practice to list all SORs they may purchase from within the reporting period. Therefore, the SORs (as sources) listed in Annex I are likely to be more comprehensive than the list of SORs which actually processed the 3TG contained in 3M’s products.

 

Suppliers that identified these specific smelters of concern on their CMRT were contacted in accordance with the OECD Guidance to inform them of the potential for risk, and to evaluate whether or not these smelters could be connected to 3M’s products. The suppliers were asked to complete a user-defined or product-level CMRT specific to the materials, products or piece parts purchased by 3M, rather than a company-level CMRT, to better identify the connection to products that they supply to 3M. Other suppliers were evaluated internally to determine if they were in fact still active suppliers. If not, they were removed from the scope of data collection.

 

Countries of Origin

 

Annex II includes an aggregated list of countries of origin from which the reported facilities collectively source 3TG, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. As mentioned in the above section, it is understood that many responses may provide more data than can be directly linked to products sold by3M, therefore, Annex II may contain more countries than those that 3M’s products are being sourced from.

 

Information on Smelters or Refiners

 

The CMRT requested the Supplier Group and its suppliers provide 3M with information on the SORs providing Necessary 3TG to 3M. Because 3M typically does not have a direct relationship with the facilities used to process 3TG, we must rely on information provided by the Supplier Group. Some suppliers in the Supplier Group provided information on all SORs

 

 

used by the supplier but could not provide information linking specific SORs used to process Necessary 3TG in products supplied to 3M. We verified 297 unique SOR names among these mentions, based on information listed on the RMI website. Of these unique SORs, 234 (79%) are validated as conformant to the RMAP process as of April 27, 2020, and 4 (2%) are reported as active by RMI, meaning they are engaged in the RMAP program but not yet conformant as of April 27, 2020. 3M’s Supplier Group identified 94% of the total number of conformant SORs listed on RMI’s website in their supply chains. Based on our involvement in the RMI Due Diligence Practices Team and the RMI Smelter Engagement Team as well as resources available to us through our membership in RMI, 3M believes the number of SORs conformant to RMAP process is attributable in part to industry collaborative efforts through RMI and other third-party validation programs.

 

We monitored and tracked SORs that we identified as not having received a “Conflict-Free” designation or not having begun participating in an independent third-party assurance process. During this reporting year, we identified 52 (18%) SOR facilities that were not participating in an independent third-party assurance process. These facilities received letters from 3M encouraging their participation.

 

 

Efforts to Determine the Country of Origin or Mine of Origin

 

In order to determine country or mine of origin, 3M: (a) seeks information about 3TG SORs in our supply chain through use of the CMRT questions; and (b) utilizes information from the RMAP and its independent audits of SORs, as well as information from that effort made available by RMI publicly and to its members. 3M’s Supplier Group did not provide information on mines of origin for Necessary 3TG used in 3M products manufactured during 2019. 3M does not have sufficient information to conclusively determine the mines or the countries of origin of the Necessary 3TG in its products or whether the Necessary 3TG are from recycled or scrap sources. However, based on SOR information provided by the Supplier Group through the CMRT responses, as well as RMI information available to its members, the countries of origin of 3TG associated with SORs identified to 3M by the Supplier Group are believed to include the countries listed in Annex II below. While some countries listed in Annex II are Covered Countries, 3M validated that 24 SORs identified as sourcing from those Covered Countries are conformant to RMAP.

 

Additional Due Diligence

 

3M compared the overall set of SORs identified by the Supplier Group against RMI’s RCOI list dated April 27, 2020, to identify all names and mineral sourcing for SORs that are conformant with the RMAP protocols and have been validated by a third-party auditor. The RCOI list also identified SORs participating in other assurance programs where the mineral sourcing of SORs is not disclosed.

 

For the 59 SORs identified to 3M by the Supplier Group in 2019 that are not yet engaged in the RMAP as active or validated as conformant to RMAP or by any other independent third-party programs, 3M conducted further due diligence to confirm whether those SORs processed Necessary 3TG used in products provided to 3M. In addition, 3M conducted due diligence through other means using a variety of information sources from RMI and others searching for evidence of SORs sourcing from the Covered Countries or potentially contributing to conflict in the Covered Countries. Such additional sources of information included news articles, reports published by NGOs, and/or industry association information that may indicate locations from which a SOR sources. For SORs not independently verified, geographic location and mining production by country are reviewed, and specified factors are applied to determine risk levels. As noted above, 3M and industry efforts persuaded one SOR to participate in RMAP and become conformant.

 

 

3M will take additional mitigating action if we learn of credible information that identified SORs are potentially financing armed groups in the Covered Countries. We require our suppliers to conduct additional due diligence to confirm the presence of any of these red-flagged SORs in the chain of custody for Necessary 3TG in products supplied to 3M.

 

STEPS TO IMPROVE DUE DILIGENCE

 

3M is alert for facts and circumstances that may require SOR-related risk mitigation. 3M also expects that more SORs will become validated as “RMAP-conformant” through the RMAP process and similar programs which will increase overall transparency and accessibility to information on geographic location of SOR mines of origin.

 

3M, working with its provider, will continue to expand its due diligence to further mitigate the risk that Necessary 3TG, cobalt, and other high-risk minerals that may benefit armed groups in the Covered Countries or by taking the following steps:

 

·                  Follow-up with those in the Supplier Group that were unresponsive or did not provide sufficient information in 2019, thereby improving both supplier response rates and the quality of supply chain information available to 3M.

 

·                  Verify with those in the Supplier Group that indicated in their response to our 2019 inquiry that they did not have certain key aspects of a conflict minerals program, to educate and obtain updated information.

 

·                  Continue our supplier engagement and capacity-building efforts through our supplier inquiry and outreach by directing suppliers to training resources available on the 3M Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/) and through industry associations and RMI, in order to improve response rates and information quality.

 

·                  Stay actively involved with and continue our company membership in RMI, which provides independent third-party audits of SORs due diligence practices including engagement in the RBA and RMI Annual Conference, Due Diligence Practices Team, Plenary Team and Smelter Engagement Team.

 

·                  Encourage supplier and other company membership and participation in RMI, which will strengthen industry collaboration to increase leverage on SORs to participate in independent third-party audits and become conformant to RMAP, LBMA, or RJC protocols.

 

·                  Contact SORs directly to undergo an audit of their due diligence practices with the goal of becoming compliant to the RMAP, LBMA, or RJC protocols.

 

·                  Expect responsible sourcing by suppliers of 3TG in the Covered Countries through use of SORs validated as conformant to RMAP process.

 

·                  Continue our Responsible Minerals program and process to support compliance to the European Union regulation on supply chain due diligence by importers of minerals and metals originating in conflict-affected and high-risk areas.

 

·                  Retain our partnership with a provider to streamline supplier outreach, feedback and due diligence efforts.

 

·                  Expand our responsible minerals assessment and due diligence efforts to include other high-risk minerals and areas of the world as determined by regulatory bodies and applied by RMI. In 2019 3M included cobalt in our outreach.

 

·                  Accelerate escalation of identified “red-flagged” SORs/SORs that are not RMAP conformant and consistent with OECD Guidance to mitigate supply chain risk. As of April 27, 2020, 3M is continuing its due diligence efforts to mitigate supply chain risk with the remaining 6 suppliers that have reported to 3M that one or more of these SORs are in their respective supply chains.

 

·                  Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include:

 

·                  Using a comprehensive SOR library with detailed status and notes for each listing.

·                  Scanning for credible media on each SOR to flag risk issues.

·                  Comparing the list of SORs against government watch and denied parties lists.

 

 

Cautionary Statement about Forward-Looking Statements

 

Certain statements in this report may be “forward-looking” within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “expects,” “intends,” “plans,” “projects,” “believes,” and “estimates,” “targets,” “anticipates,” and similar expressions are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward- looking statement, except as required by federal securities laws.

 

 

ANNEX I

 

As of April 27, 2020

 

The below list of SORs identified to 3M by the 3M Supplier Group is conformant with RMAP protocols as of April 27, 2020. 3M is typically many tiers in the supply chain removed from SORs, and our direct suppliers have not traced materials supplied to 3M back to individual SORs. Many of our suppliers provided information to 3M on all SORs identified to them by their suppliers, and have not been able to confirm that Necessary 3TG processed by these SORs is contained in the products they have supplied to us because some of the suppliers did not provide their CMRT at the product level. Therefore, it is possible that the list contains SORs not used to process Necessary 3TG contained in our products.

 

Metal		Standard Smelter		Smelter Facility		Smelter ID
Gold		8853 S.p.A.		ITALY		CID002763
Gold		Advanced Chemical Company		UNITED STATES OF AMERICA		CID000015
Gold		Aida Chemical Industries Co., Ltd.		JAPAN		CID000019
Gold		Al Etihad Gold Refinery DMCC		UNITED ARAB EMIRATES		CID002560
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		GERMANY		CID000035
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		UZBEKISTAN		CID000041
Gold		AngloGold Ashanti Corrego do Sitio Mineracao		BRAZIL		CID000058
Gold		Argor-Heraeus S.A.		SWITZERLAND		CID000077
Gold		Asahi Pretec Corp.		JAPAN		CID000082
Gold		Asahi Refining Canada Ltd.		CANADA		CID000924
Gold		Asahi Refining USA Inc.		UNITED STATES OF AMERICA		CID000920
Gold		Asaka Riken Co., Ltd.		JAPAN		CID000090
Gold		AU Traders and Refiners		SOUTH AFRICA		CID002850
Gold		Aurubis AG		GERMANY		CID000113
Gold		Bangalore Refinery		INDIA		CID002863
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		PHILIPPINES		CID000128
Gold		Boliden AB		SWEDEN		CID000157
Gold		C. Hafner GmbH + Co. KG		GERMANY		CID000176
Gold		CCR Refinery - Glencore Canada Corporation		CANADA		CID000185
Gold		Cendres + Metaux S.A.		SWITZERLAND		CID000189
Gold		Chimet S.p.A.		ITALY		CID000233
Gold		Chugai Mining		JAPAN		CID000264
Gold		DODUCO Contacts and Refining GmbH		GERMANY		CID000362
Gold		Dowa		JAPAN		CID000401
Gold		DS PRETECH Co., Ltd.		KOREA, REPUBLIC OF		CID003195
Gold		DSC (Do Sung Corporation)		KOREA, REPUBLIC OF		CID000359
Gold		Eco-System Recycling Co., Ltd. East Plant		JAPAN		CID000425
Gold		Eco-System Recycling Co., Ltd. North Plant		JAPAN		CID003424
Gold		Eco-System Recycling Co., Ltd. West Plant		JAPAN		CID003425
Gold		Emirates Gold DMCC		UNITED ARAB EMIRATES		CID002561
Gold		Geib Refining Corporation		UNITED STATES OF AMERICA		CID002459
Gold		Gold Refinery of Zijin Mining Group Co., Ltd.		CHINA		CID002243
Gold		Heimerle + Meule GmbH		GERMANY		CID000694
Gold		Heraeus Metals Hong Kong Ltd.		CHINA		CID000707
Gold		Heraeus Precious Metals GmbH & Co. KG		GERMANY		CID000711
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.		CHINA		CID000801
Gold		Ishifuku Metal Industry Co., Ltd.		JAPAN		CID000807
Gold		Istanbul Gold Refinery		TURKEY		CID000814
Gold		Italpreziosi		ITALY		CID002765
Gold		Japan Mint		JAPAN		CID000823
Gold		Jiangxi Copper Co., Ltd.		CHINA		CID000855
Gold		JSC Uralelectromed		RUSSIAN FEDERATION		CID000929
Gold		JX Nippon Mining & Metals Co., Ltd.		JAPAN		CID000937
Gold		Kazzinc		KAZAKHSTAN		CID000957
Gold		Kennecott Utah Copper LLC		UNITED STATES OF AMERICA		CID000969
Gold		KGHM Polska Miedz Spolka Akcyjna		POLAND		CID002511
Gold		Kojima Chemicals Co., Ltd.		JAPAN		CID000981
Gold		Korea Zinc Co., Ltd.		KOREA, REPUBLIC OF		CID002605
Gold		Kyrgyzaltyn JSC		KYRGYZSTAN		CID001029
Gold		L’Orfebre S.A.		ANDORRA		CID002762
Gold		LS-NIKKO Copper Inc.		KOREA, REPUBLIC OF		CID001078
Gold		LT Metal Ltd.		KOREA, REPUBLIC OF		CID000689
Gold		Marsam Metals		BRAZIL		CID002606
Gold		Materion		UNITED STATES OF AMERICA		CID001113
Gold		Matsuda Sangyo Co., Ltd.		JAPAN		CID001119
Gold		Metalor Technologies (Hong Kong) Ltd.		CHINA		CID001149
Gold		Metalor Technologies (Singapore) Pte., Ltd.		SINGAPORE		CID001152
Gold		Metalor Technologies (Suzhou) Ltd.		CHINA		CID001147
Gold		Metalor Technologies S.A.		SWITZERLAND		CID001153
Gold		Metalor USA Refining Corporation		UNITED STATES OF AMERICA		CID001157
Gold		Metalurgica Met-Mex Penoles S.A. De C.V.		MEXICO		CID001161
Gold		Mitsubishi Materials Corporation		JAPAN		CID001188
Gold		Mitsui Mining and Smelting Co., Ltd.		JAPAN		CID001193
Gold		MMTC-PAMP India Pvt., Ltd.		INDIA		CID002509
Gold		Moscow Special Alloys Processing Plant		RUSSIAN FEDERATION		CID001204
Gold		Nadir Metal Rafineri San. Ve Tic. A.S.		TURKEY		CID001220

 

 

Gold		Nihon Material Co., Ltd.		JAPAN		CID001259
Gold		Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH		AUSTRIA		CID002779
Gold		Ohura Precious Metal Industry Co., Ltd.		JAPAN		CID001325
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)		RUSSIAN FEDERATION		CID001326
Gold		OJSC Novosibirsk Refinery		RUSSIAN FEDERATION		CID000493
Gold		PAMP S.A.		SWITZERLAND		CID001352
Gold		Planta Recuperadora de Metales SpA		CHILE		CID002919
Gold		Prioksky Plant of Non-Ferrous Metals		RUSSIAN FEDERATION		CID001386
Gold		PT Aneka Tambang (Persero) Tbk		INDONESIA		CID001397
Gold		PX Precinox S.A.		SWITZERLAND		CID001498
Gold		Rand Refinery (Pty) Ltd.		SOUTH AFRICA		CID001512
Gold		REMONDIS PMR B.V.		NETHERLANDS		CID002582
Gold		Royal Canadian Mint		CANADA		CID001534
Gold		SAAMP		FRANCE		CID002761
Gold		Safimet S.p.A		ITALY		CID002973
Gold		Samduck Precious Metals		KOREA, REPUBLIC OF		CID001555
Gold		SAXONIA Edelmetalle GmbH		GERMANY		CID002777
Gold		SEMPSA Joyeria Plateria S.A.		SPAIN		CID001585
Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.		CHINA		CID001622
Gold		Sichuan Tianze Precious Metals Co., Ltd.		CHINA		CID001736
Gold		Singway Technology Co., Ltd.		TAIWAN, PROVINCE OF CHINA		CID002516
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		RUSSIAN FEDERATION		CID001756
Gold		Solar Applied Materials Technology Corp.		TAIWAN, PROVINCE OF CHINA		CID001761
Gold		Sumitomo Metal Mining Co., Ltd.		JAPAN		CID001798
Gold		SungEel HiMetal Co., Ltd.		KOREA, REPUBLIC OF		CID002918
Gold		T.C.A S.p.A		ITALY		CID002580
Gold		Tanaka Kikinzoku Kogyo K.K.		JAPAN		CID001875
Gold		The Refinery of Shandong Gold Mining Co., Ltd.		CHINA		CID001916
Gold		Tokuriki Honten Co., Ltd.		JAPAN		CID001938
Gold		TOO Tau-Ken-Altyn		KAZAKHSTAN		CID002615
Gold		Torecom		KOREA, REPUBLIC OF		CID001955
Gold		Umicore Brasil Ltda.		BRAZIL		CID001977
Gold		Umicore Precious Metals Thailand		THAILAND		CID002314
Gold		Umicore S.A. Business Unit Precious Metals Refining		BELGIUM		CID001980
Gold		United Precious Metal Refining, Inc.		UNITED STATES OF AMERICA		CID001993
Gold		Valcambi S.A.		SWITZERLAND		CID002003
Gold		Western Australian Mint (T/a The Perth Mint)		AUSTRALIA		CID002030
Gold		WIELAND Edelmetalle GmbH		GERMANY		CID002778
Gold		Yamakin Co., Ltd.		JAPAN		CID002100
Gold		Yokohama Metal Co., Ltd.		JAPAN		CID002129
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		CHINA		CID002224
Tantalum		Asaka Riken Co., Ltd.		JAPAN		CID000092
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		CHINA		CID000211
Tantalum		CP Metals Inc.		UNITED STATES OF AMERICA		CID003402
Tantalum		D Block Metals, LLC		UNITED STATES OF AMERICA		CID002504
Tantalum		Exotech Inc.		UNITED STATES OF AMERICA		CID000456
Tantalum		F&X Electro-Materials Ltd.		CHINA		CID000460
Tantalum		FIR Metals & Resource Ltd.		CHINA		CID002505
Tantalum		Global Advanced Metals Aizu		JAPAN		CID002558
Tantalum		Global Advanced Metals Boyertown		UNITED STATES OF AMERICA		CID002557
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		CHINA		CID000616
Tantalum		H.C. Starck Co., Ltd.		THAILAND		CID002544
Tantalum		H.C. Starck Hermsdorf GmbH		GERMANY		CID002547
Tantalum		H.C. Starck Inc.		UNITED STATES OF AMERICA		CID002548
Tantalum		H.C. Starck Ltd.		JAPAN		CID002549
Tantalum		H.C. Starck Smelting GmbH & Co. KG		GERMANY		CID002550
Tantalum		H.C. Starck Tantalum and Niobium GmbH		GERMANY		CID002545
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		CHINA		CID002492
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		CHINA		CID002512
Tantalum		Jiangxi Tuohong New Raw Material		CHINA		CID002842
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		CHINA		CID000914
Tantalum		Jiujiang Tanbre Co., Ltd.		CHINA		CID000917
Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		CHINA		CID002506
Tantalum		KEMET Blue Metals		MEXICO		CID002539
Tantalum		LSM Brasil S.A.		BRAZIL		CID001076
Tantalum		Metallurgical Products India Pvt., Ltd.		INDIA		CID001163
Tantalum		Mineracao Taboca S.A.		BRAZIL		CID001175
Tantalum		Mitsui Mining and Smelting Co., Ltd.		JAPAN		CID001192
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		CHINA		CID001277
Tantalum		NPM Silmet AS		ESTONIA		CID001200
Tantalum		PRG Dooel		NORTH MACEDONIA, REPUBLIC OF		CID002847
Tantalum		QuantumClean		UNITED STATES OF AMERICA		CID001508
Tantalum		Resind Industria e Comercio Ltda.		BRAZIL		CID002707
Tantalum		Solikamsk Magnesium Works OAO		RUSSIAN FEDERATION		CID001769
Tantalum		Taki Chemical Co., Ltd.		JAPAN		CID001869
Tantalum		Telex Metals		UNITED STATES OF AMERICA		CID001891
Tantalum		Ulba Metallurgical Plant JSC		KAZAKHSTAN		CID001969
Tantalum		XinXing HaoRong Electronic Material Co., Ltd.		CHINA		CID002508
Tantalum		Yanling Jincheng Tantalum & Niobium Co., Ltd.		CHINA		CID001522
Tin		Alpha		UNITED STATES OF AMERICA		CID000292
Tin		Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.		CHINA		CID000228
Tin		Chifeng Dajingzi Tin Industry Co., Ltd.		CHINA		CID003190
Tin		China Tin Group Co., Ltd.		CHINA		CID001070
Tin		Dowa		JAPAN		CID000402
Tin		EM Vinto		BOLIVIA (PLURINATIONAL STATE OF)		CID000438

 

 

Tin		Fenix Metals		POLAND		CID000468
Tin		Gejiu Kai Meng Industry and Trade LLC		CHINA		CID000942
Tin		Gejiu Non-Ferrous Metal Processing Co., Ltd.		CHINA		CID000538
Tin		Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.		CHINA		CID001908
Tin		Gejiu Zili Mining And Metallurgy Co., Ltd.		CHINA		CID000555
Tin		Guangdong Hanhe Non-Ferrous Metal Co., Ltd.		CHINA		CID003116
Tin		Guanyang Guida Nonferrous Metal Smelting Plant		CHINA		CID002849
Tin		HuiChang Hill Tin Industry Co., Ltd.		CHINA		CID002844
Tin		Huichang Jinshunda Tin Co., Ltd.		CHINA		CID000760
Tin		Jiangxi New Nanshan Technology Ltd.		CHINA		CID001231
Tin		Ma’anshan Weitai Tin Co., Ltd.		CHINA		CID003379
Tin		Magnu’s Minerais Metais e Ligas Ltda.		BRAZIL		CID002468
Tin		Malaysia Smelting Corporation (MSC)		MALAYSIA		CID001105
Tin		Melt Metais e Ligas S.A.		BRAZIL		CID002500
Tin		Metallic Resources, Inc.		UNITED STATES OF AMERICA		CID001142
Tin		Metallo Belgium N.V.		BELGIUM		CID002773
Tin		Metallo Spain S.L.U.		SPAIN		CID002774
Tin		Mineracao Taboca S.A.		BRAZIL		CID001173
Tin		Minsur		PERU		CID001182
Tin		Mitsubishi Materials Corporation		JAPAN		CID001191
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		THAILAND		CID001314
Tin		O.M. Manufacturing Philippines, Inc.		PHILIPPINES		CID002517
Tin		Operaciones Metalurgicas S.A.		BOLIVIA (PLURINATIONAL STATE OF)		CID001337
Tin		PT Artha Cipta Langgeng		INDONESIA		CID001399
Tin		PT ATD Makmur Mandiri Jaya		INDONESIA		CID002503
Tin		PT Menara Cipta Mulia		INDONESIA		CID002835
Tin		PT Mitra Stania Prima		INDONESIA		CID001453
Tin		PT Refined Bangka Tin		INDONESIA		CID001460
Tin		PT Timah Tbk Kundur		INDONESIA		CID001477
Tin		PT Timah Tbk Mentok		INDONESIA		CID001482
Tin		Resind Industria e Comercio Ltda.		BRAZIL		CID002706
Tin		Rui Da Hung		TAIWAN, PROVINCE OF CHINA		CID001539
Tin		Soft Metais Ltda.		BRAZIL		CID001758
Tin		Thai Nguyen Mining and Metallurgy Co., Ltd.		VIET NAM		CID002834
Tin		Thaisarco		THAILAND		CID001898
Tin		Tin Technology & Refining		UNITED STATES OF AMERICA		CID003325
Tin		White Solder Metalurgia e Mineracao Ltda.		BRAZIL		CID002036
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		CHINA		CID002158
Tin		Yunnan Tin Company Limited		CHINA		CID002180
Tin		Yunnan Yunfan Non-ferrous Metals Co., Ltd.		CHINA		CID003397
Tungsten		A.L.M.T. Corp.		JAPAN		CID000004
Tungsten		ACL Metais Eireli		BRAZIL		CID002833
Tungsten		Asia Tungsten Products Vietnam Ltd.		VIET NAM		CID002502
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		CHINA		CID002513
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		CHINA		CID000258
Tungsten		Fujian Ganmin RareMetal Co., Ltd.		CHINA		CID003401
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		CHINA		CID000499
Tungsten		Ganzhou Haichuang Tungsten Co., Ltd.		CHINA		CID002645
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		CHINA		CID000875
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		CHINA		CID002315
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		CHINA		CID002494
Tungsten		Global Tungsten & Powders Corp.		UNITED STATES OF AMERICA		CID000568
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		CHINA		CID000218
Tungsten		H.C. Starck Smelting GmbH & Co. KG		GERMANY		CID002542
Tungsten		H.C. Starck Tungsten GmbH		GERMANY		CID002541
Tungsten		Hunan Chenzhou Mining Co., Ltd.		CHINA		CID000766
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		CHINA		CID002579
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		CHINA		CID000769
Tungsten		Hunan Litian Tungsten Industry Co., Ltd.		CHINA		CID003182
Tungsten		Hydrometallurg, JSC		RUSSIAN FEDERATION		CID002649
Tungsten		Japan New Metals Co., Ltd.		JAPAN		CID000825
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		CHINA		CID002551
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		CHINA		CID002321
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		CHINA		CID002318
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		CHINA		CID002317
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		CHINA		CID002316
Tungsten		Kennametal Fallon		UNITED STATES OF AMERICA		CID000966
Tungsten		Kennametal Huntsville		UNITED STATES OF AMERICA		CID000105
Tungsten		KGETS Co., Ltd.		KOREA, REPUBLIC OF		CID003388
Tungsten		Lianyou Metals Co., Ltd.		TAIWAN, PROVINCE OF CHINA		CID003407
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		CHINA		CID002319
Tungsten		Masan Tungsten Chemical LLC (MTC)		VIET NAM		CID002543
Tungsten		Moliren Ltd.		RUSSIAN FEDERATION		CID002845
Tungsten		Niagara Refining LLC		UNITED STATES OF AMERICA		CID002589
Tungsten		Philippine Chuangxin Industrial Co., Inc.		PHILIPPINES		CID002827
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		VIET NAM		CID001889
Tungsten		Unecha Refractory metals plant		RUSSIAN FEDERATION		CID002724
Tungsten		Wolfram Bergbau und Hutten AG		AUSTRIA		CID002044
Tungsten		Woltech Korea Co., Ltd.		KOREA, REPUBLIC OF		CID002843
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		CHINA		CID002320
Tungsten		Xiamen Tungsten Co., Ltd.		CHINA		CID002082
Tungsten		Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.		CHINA		CID002830
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		CHINA		CID002095

 

 

ANNEX II

 

As of April 27, 2020

 

The below list of 3TG countries of origin identified to 3M by the 3M Supplier Group is conformant with RMAP protocols as of April 27, 2020. 3M is typically many tiers in the supply chain removed from SORs, and our direct suppliers have not traced materials supplied to 3M back to individual countries of origin. Many of our suppliers provided information to 3M on all SORs identified to them by their suppliers, and have not been able to confirm that the countries of origin for all 3TG processed by these SORs have been used in the products they have supplied to us because they did not provide their CMRT at the product level. Therefore, it is possible that the list contains countries of origin of 3TG not contained in our products.

 

3M validated that SORs identified as sourcing from the Covered Countries are conformant to RMAP.

 

Afghanistan, Albania, Angola*, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Bulgaria, Burundi*, Cambodia, Canada, Central African Republic*, Chile, China, Colombia, Czech Republic, Djibouti, Dominican Republic, DRC or an adjoining country (Covered Countries)*, Ecuador, Egypt, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic*, Republic Of Korea, Russia, Rwanda*, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan*, Suri, Suriname, Sweden, Switzerland, Tanzania*, Thailand, Turkey, Uganda*, United Arab Emirates, United Kingdom, USA, Uzbekistan, Viet Nam, Zambia*, Zimbabwe

 

* Covered Country