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)

File No. 1-3285	41-0417775	
(Commission File Number)	(IRS Employer Identification No.)	
 	 	
3M Center, St. Paul, Minnesota	55144-1000	
(Address of principal executive offices)	(Zip Code)	
 
Debora Fronczak, Senior 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, 2020.

 

 
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, 2020. References to 3M’s website are provided for convenience only, and its contents are not incorporated by reference into this Form SD or the attached 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 2020, 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 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 collaborates 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 400 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 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 2020. Members of 3M’s Responsible Minerals Steering Team participated in the RMI Due Diligence Practices Team and Plenary Team, as well as attended the Responsible Business Alliance (“RBA”) and RMI Annual Conference, which was virtual, to ensure alignment with program and strategies in 2020. 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 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 50 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 60% of the in-scope Supplier Group (as defined below) in 2020.
 
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 and 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 three 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 submit 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 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 331 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. In 2020, 3M achieved a response rate from suppliers that was greater than 90%, 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 2020.
 
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 attached Conflict Minerals Report and both reports are posted to 3M’s Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/).

 
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 from January 1 to December 31, 2020, 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, 2021	
 	 	 	
Group President, Enterprise Operations	 	(Date)	

Exhibit 1.01
 
CONFLICT MINERALS REPORT OF 3M COMPANY
FOR THE YEAR ENDED DECEMBER 31, 2020
 
INTRODUCTION
 
This Conflict Minerals Report (this “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, 2020.
 
“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 from January 1 to December 31, 2020 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 from January 1 to December 31, 2020 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 in 2011, renamed to Responsible Minerals Sourcing Policy in 2019, articulating the Conflict Minerals supply chain due diligence process and 3M’s commitments to reporting obligations regarding Conflict Minerals. The Policy (as defined below) 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 its database to assist with RCOI 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 6.01 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, which 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, who 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 on 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 3M’s Due Diligence Measures
 
3M’s 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 (the “UN Principles”).
 
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 Group President, Enterprise Operations. In addition, 3M has designated a cross-functional Responsible Minerals Steering Team (“Steering Team”), composed of representatives from Strategic Sourcing, Area Responsible Sourcing Leaders, Environment, Health & Safety and 3M Legal Affairs. The Steering Team has responsibility for developing and implementing 3M’s Policy and 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, Ethics and Compliance, 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 and 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, which was 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 foundational expectations as it relates to labor, ethics, environment, health and safety, as well as management systems. This code of conduct is based on industry and internationally-accepted principles, such as the UN Principles and the OECD Guidance. If a supplier does not meet 3M’s requirements, the situation is escalated and evaluated for disposition.
 
3M’s 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 and 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 below) 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 or 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 2020 3M conducted outreach with suppliers for products that may contain Necessary 3TG, which represented 60% of the in-scope Supplier Group.
 
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. 3M 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. 3M 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 SOR. 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 and 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 “SORs of Interest” in their CMRT responses, according to indicators defined in the OECD Guidance, 3M and its Provider requested additional information and/or Conflict Minerals due diligence standards and processes, conducting further due diligence about the “SORs of Interest.” 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 the provision, upon request, of 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 and its Provider sent letters to those SORs encouraging them to participate. 3M also encouraged its 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 as 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, environment, 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 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
 
3M has 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). 3M also has 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
 
3M has 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 three 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 submit 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 “SORs of Interest” 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 “SORs of Interest.” These factors include:
 
·                  Geographic proximity to the DRC and other 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.
 
3M verified SORs using RMI’s Conformant Smelters and Refiners list. 3M 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 interest were immediately given feedback instructing the supplier to take its own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that it supplies to 3M. Additional escalation may have been necessary to address any continued sourcing from these smelters of interest. Suppliers are given clear performance objectives within reasonable timeframes, with the ultimate goal of progressive elimination of these smelters of interest 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, 3M 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 2020, 3M found no instances where it was necessary to find replacement sources of supply or to suspend or terminate a supplier relationship. However, increased due diligence was applied and continues to be applied to those smelters of interest.
 
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 and Plenary Team, 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, 2020. 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 neither 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 25 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, 3M supports 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 2020, 3M received over 90% response rate from its suppliers as a result of outreach efforts and will continue to work with the remaining suppliers to obtain future alignment with requests.
 
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 interest 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 company-level data, or more data than can be directly linked to products sold by 3M; therefore, Annex II may contain countries from which 3M’s products are not sourced.
 
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, 3M relies 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. 3M verified 331 unique SOR names among these mentions, based on information listed on the RMI website. Of these unique SORs, 238 (72%) are validated as conformant to the RMAP process as of April 13, 2021, and 22 (7%) are reported as active by RMI, meaning they are engaged in the RMAP program but not yet conformant as of April 13, 2021. 3M’s Supplier Group identified 93% 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, 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.
 
3M monitored and tracked SORs 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, 3M identified 59 (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 2020. 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 25 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 13, 2021, 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 2020 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 the SORs of interest 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.
 
3M will take additional mitigating action if credible sources provide information that identified SORs are potentially

 
financing armed groups in the Covered Countries. 3M requires suppliers to conduct additional due diligence to confirm the presence of any of the “SORs of Interest” 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 higher-risk minerals may benefit armed groups in the Covered Countries or by taking the following steps:
 
·                  Escalate those suppliers who did not provide a response to the outreach request to obtain future alignment with requests or disposition accordingly.
 
·                  Follow up with those in the Supplier Group that were unresponsive or did not provide sufficient information for the 2020 reporting year, thereby improving both supplier response rates and the quality of supply chain information available to 3M.
 
·                  Contact those in the Supplier Group that indicated in their response to the 2020 reporting year inquiry that did not have certain key aspects of a Conflict Minerals program in order to educate and obtain updated information from them.
 
·                  Continue supplier engagement and capacity-building efforts through 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, and Plenary Team.
 
·                  Encourage supplier and other company membership and participation in RMI, which will strengthen industry collaboration in order 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 the 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 CAHRAs.
 
·                  Retain partnership with a third-party service provider to streamline supplier outreach, feedback and due diligence efforts.
 
·                  Expand the 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 2020, 3M included cobalt in our outreach and will continue to expand this effort.
 
·                  Accelerate escalation of identified “SORs of Interest” that are not RMAP conformant and consistent with OECD Guidance to mitigate supply chain risk. As of April 13, 2021, 3M is continuing its due diligence efforts with one supplier to mitigate supply chain risk and align such supplier with 3M’s expectations.
 
·                  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,” “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 with no obligation on 3M’s part to update or revise any forward- looking statement, except as required by federal securities laws.

 
ANNEX I
 
As of April 13, 2021
 
The below list of SORs identified to 3M by the 3M Supplier Group is conformant with RMAP protocols as of April 13, 2021. 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 Name	 	Smelter Facility Location	 	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	 	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	 	Metal Concentrators SA (Pty) Ltd.	 	SOUTH AFRICA	 	CID003575	
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	 	Navoi Mining and Metallurgical Combinat	 	UZBEKISTAN	 	CID001236	
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	 	SAFINA A.S.	 	CZECH REPUBLIC	 	CID002290	
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 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	 	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 Fengming Metallurgy Chemical Plant	 	CHINA	 	CID002848	
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	 	HuiChang Hill Tin Industry Co., Ltd.	 	CHINA	 	CID002844	
Tin	 	Jiangxi New Nanshan Technology Ltd.	 	CHINA	 	CID001231	
Tin	 	Luna Smelter, Ltd.	 	RWANDA	 	CID003387	
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 Babel Inti Perkasa	 	INDONESIA	 	CID001402	
Tin	 	PT Babel Surya Alam Lestari	 	INDONESIA	 	CID001406	
Tin	 	PT Bangka Serumpun	 	INDONESIA	 	CID003205	
Tin	 	PT Menara Cipta Mulia	 	INDONESIA	 	CID002835	
Tin	 	PT Mitra Stania Prima	 	INDONESIA	 	CID001453	
Tin	 	PT Prima Timah Utama	 	INDONESIA	 	CID001458	
Tin	 	PT Rajawali Rimba Perkasa	 	INDONESIA	 	CID003381	
Tin	 	PT Rajehan Ariq	 	INDONESIA	 	CID002593	
Tin	 	PT Refined Bangka Tin	 	INDONESIA	 	CID001460	
Tin	 	PT Stanindo Inti Perkasa	 	INDONESIA	 	CID001468	
Tin	 	PT Timah Tbk Kundur	 	INDONESIA	 	CID001477	
Tin	 	PT Timah Tbk Mentok	 	INDONESIA	 	CID001482	
Tin	 	PT Tinindo Inter Nusa	 	INDONESIA	 	CID001490	
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	 	China Molybdenum Co., Ltd.	 	CHINA	 	CID002641	
Tungsten	 	Chongyi Zhangyuan Tungsten Co., Ltd.	 	CHINA	 	CID000258	
Tungsten	 	Fujian Ganmin RareMetal Co., Ltd.	 	CHINA	 	CID003401	
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 Chunchang Nonferrous Metals Co., Ltd.	 	CHINA	 	CID000769	
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	 	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	
 
ANNEX II
 
As of April 13, 2021
 
The below list of 3TG countries of origin identified to 3M by the 3M Supplier Group is conformant with RMAP protocols as of April 13, 2021. 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.
 
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; Democratic Republic of the Congo*; Ecuador; Egypt; 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 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; United States; Uzbekistan; Vietnam; Zambia*; Zimbabwe

* Covered Country