Exhibit 1.01

 

CONFLICT MINERALS REPORT OF 3M COMPANY

FOR THE YEAR ENDED DECEMBER 31, 2014

 

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 (“Rule 13p-1”) for the reporting period from January 1 to December 31, 2014.

 

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 for the period January 1 to December 31, 2014 described in the attached 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, 2014 and December 31, 2014 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 has reason to believe that those Necessary 3TG may not be from recycled or scrap sources.

 

The Company therefore conducted due diligence on the source and chain of custody of Necessary 3TG as described below.

 

DUE DILIGENCE MEASURES

 

A.            Design of Our Due Diligence Measures

 

Our CMR Conflict Minerals due diligence process has been designed to conform in all material respects with the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (2013) (the “OECD Guidance”), as applicable for 3TG and downstream companies (as the term ‘downstream companies’ is defined in the OECD Guidance).  Our due diligence measures included:

 

1.               Establish strong Company management systems;

2.               Identify and assess risks in the supply chain;

3.               Design and implement a strategy to respond to identified risks;

4.               Carry out independent third-party audit of the supply chain due diligence at identified points in the supply chain;  and

5.               Report on supply chain due diligence.

 

 

B.            Due Diligence Performed

 

1.              Establish Strong Company Management Systems

 

Conflict Minerals Policy

 

3M adopted a Conflict Minerals Policy, which is posted on our website.

 

Internal Management System

 

3M’s management system for conflict minerals includes an executive sponsor who is 3M’s Senior Vice President, Supply Chain.  In addition, the Company designated a Conflict Minerals Steering Team, comprised of representatives from Sourcing Operations, Medical Department Regulatory Services, EHS and Sustainability Operations, and 3M Legal Affairs.  The Conflict Minerals Steering Team has responsibility for developing and implementing 3M’s conflict minerals compliance strategy, as well as for reviewing the progress and effectiveness of the program going forward.  The Steering Team is led by a Conflict Minerals Program Manager from 3M Sourcing Operations.  Senior Sourcing, Finance and Audit management were briefed about the results of our due diligence efforts.

 

Control System and Supply Chain Transparency

 

3M gathers information using the Conflict Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Template (CMRT) sent to the Supplier Group via our web-enabled Supplier Regulatory eEnablement (SREE) system to determine the chain of custody of the Necessary 3TG included in our products.

 

Supplier Engagement

 

After our supplier inquiry for the 2013 reporting year, 3M e-mailed those in the Supplier Group that were unresponsive using 3M’s Supplier Corrective Action and Response (SCAR) process.  3M also e-mailed those in the Supplier Group that indicated they did not have key aspects of a conflict minerals program by sending an educational bulletin.

 

3M distributed its expectations for suppliers in connection with our inquiry for the 2014 reporting year in the SREE e-mail that included the CMRT.  The SREE e-mail included links to 3M’s Conflict Minerals website, which includes our Conflict Minerals Policy and 3M training on how to respond to the CMRT.  This website also directs suppliers to training resources available through the CFSI.  3M also sent educational bulletins where supplier responses indicated a need for additional information.

 

3M’s U.S. Sourcing contract templates and purchase order terms & conditions require suppliers to provide upon request, information on the smelters and refiners in relevant supply chains, and other information 3M might require.

 

3M’s Conflict Minerals website states that 3M encourages our suppliers to responsibly source 3TG from the Covered Countries through SORs validated as DRC Conflict Free.

 

 

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.  We have procedures in place for follow-up in the event any conflict minerals issues are raised through our grievance mechanism.

 

Maintain Records

 

We have a record retention policy applicable to conflict minerals-related documentation that provides for retention for a minimum of ten years.

 

2.              Identify and Assess Risk in the Supply Chain

 

In 2014 3M used a web-based system to distribute the Conflict Minerals Reporting Template (CMRT) to the Supplier Group in order to identify Smelters or Refiners (“SORs”) and gather information on our supply chain.

 

The SREE system issued three automatic follow-up reminders to those in the Supplier Group who had not responded to the information request.  Additional e-mail reminders were sent to those in the Supplier Group who did not respond, and follow-up phone calls were made with some suppliers.  Supplier responses were reviewed by 3M Sourcing Operations and some responses were also reviewed by employees identified as Conflict Minerals Advisors.  If supplier responses indicated that Necessary 3TG contained in products provided to 3M may have originated from the Covered Countries, then such responses were sent to the Conflict Minerals Steering Team for further review and determination of follow-up steps.

 

3.              Design and Implement a Strategy to Respond to Risks

 

3M designed a strategy to respond to risks.  The Conflict Minerals Program Manager will report to the Company’s Conflict Minerals Steering Team and its executive sponsor and provide periodic updates 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 the Covered Countries. The 3M Conflict Minerals Steering Team and executive sponsor or other relevant executives will determine appropriate follow-up actions, if any, to mitigate risks.   Follow-up actions may include the Company’s Supplier Corrective Action and Response (SCAR) process.  As part of the SCAR process the Company may decide to find alternate sources of supply or terminate existing supplier relationships, as appropriate.  For the year 2014, 3M found no instances where it was necessary to find replacement sources of supply 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 relies on the CFSI’s Conflict-Free Smelter (CFS) Program and similar gold refining industry auditing programs to perform third-party audits of SORs.  We will validate whether any 3TG sourced from the Covered Countries is conflict-free based on the information provided by our Supplier Group and on the information available on the CFSI’s website.

 

 

5.              Report on Supply Chain Due Diligence

 

This Report and our Form SD will be filed with the SEC and be publicly available at http://investors.3m.com/financials/sec-filings/default.aspx and listed under the filing type “SD.”  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 Reasonable Country of Origin Inquiry (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.  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 may not be from recycled or scrap sources.

 

As outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the internationally recognized standard on which our company’s system is based, we support an industry initiative that audits smelters’ and refiners’ due diligence activities. That industry initiative is the EICC and GeSI’s Conflict-Free Sourcing Initiative. The data on which we relied for certain statements in this declaration was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report for member “mmco”.

 

Following our Year 2014 inquiry and identification of SORs, we contacted SORs within our supply chain not yet validated as DRC Conflict Free and not actively pursuing validation, and encouraged them to join the CFS Program and become validated as DRC Conflict Free.

 

Information on Smelters or Refiners

 

The CMRT requested that the Supplier Group provide 3M with information on the SORs that the Supplier Group and its suppliers use to supply 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 responses from the Supplier Group indicated that they were unable to provide SOR information at this time.  Other 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 with products provided to 3M.  The CMRT responses provided to us by the Supplier Group resulted in the collective identification of 592 SORs.  Based on smelter identification numbers set forth in the Supplier Group responses or provided on the CFSI website, we verified 176 unique SORs from among those SORs identified to us by the Supplier Group that may have been used to process Necessary 3TG in 3M products, and these unique SORs are listed in Annex I below.  Of these unique SORs, 106 were validated conflict-free under the CFS program or a similar program for gold refiners.

 

Efforts to Determine the Country of Origin or Mine of Origin

 

In order to determine country or mine of origin, 3M must: (a) seek information about 3TG SORs in our supply chains through use of the CMRT questions; and (b) rely on the CFS Program and its independent audits of SORs, as well as information from that effort made available by CFSI to its members.  3M’s Supplier Group did not provide information on mines of origin for Necessary 3TG used in 3M products manufactured during 2014.  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 CFSI 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 on Annex II are Covered Countries, the SORs identified as sourcing from those Covered Countries have all been validated as using conflict free sourcing practices under the Conflict Free Smelter program.

 

STEPS TO IMPROVE DUE DILIGENCE

 

3M will be alert for facts and circumstances that may require SOR-related risk mitigation.  In addition, 3M also expects that more SORs will become validated as “DRC Conflict Free” through the CFS Program and similar programs which will increase overall transparency and accessibility to information on geographic location of SOR mines of origin.

 

3M expects to improve its due diligence to further mitigate the risk that Necessary 3TG benefit armed groups in the DRC or any of its adjoining countries by taking the following steps:

 

·                  Follow-up with those in the Supplier Group that were unresponsive or did not provide sufficient information in 2014, thereby improving both supplier response rates and the quality of supply chain information available to 3M.

 

·                  Follow-up with those in the Supplier Group that indicated in their response to our 2014 inquiry that they did not have certain key aspects of a conflict minerals program, to obtain updated information.

 

·                  Continue our supplier engagement and capacity building efforts through our supplier inquiry and by directing suppliers to training resources available through industry associations and the CFSI, in order to improve response rates and information quality.

 

·                  Continue our company membership in CFSI.

 

·                  Encourage supplier and other company membership and participation in CFSI, which will strengthen industry collaboration to increase leverage on smelters and refiners to join the CFS program and thereby become validated as DRC Conflict Free.

 

·                  Contact smelters and/or refiners to join the CFS program and become validated as DRC Conflict Free.

 

·                 Encourage responsible sourcing by suppliers of 3TG in the Covered Countries through smelters or refiners validated as DRC Conflict Free.

 

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

 

Mineral		Smelter or Refiner Name		Country Location of Smelter or Refiner
Gold		Aida Chemical Industries Co. Ltd.		JAPAN
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		GERMANY
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		UZBEKISTAN
Gold		AngloGold Ashanti Córrego do Sítio Minerção		BRAZIL
Gold		Argor-Heraeus SA		SWITZERLAND
Gold		Asahi Pretec Corporation		JAPAN
Gold		Asaka Riken Co Ltd		JAPAN
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		TURKEY
Gold		Aurubis AG		GERMANY
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		PHILIPPINES
Gold		Bauer Walser AG		GERMANY
Gold		Boliden AB		SWEDEN
Gold		C. Hafner GmbH + Co. KG		GERMANY
Gold		Caridad		MEXICO
Gold		CCR Refinery — Glencore Canada Corporation		CANADA
Gold		Cendres & Métaux SA		SWITZERLAND
Gold		Chimet S.p.A.		ITALY
Gold		Chugai Mining		JAPAN
Gold		Daejin Indus Co. Ltd		KOREA, REPUBLIC OF
Gold		Do Sung Corporation		KOREA, REPUBLIC OF
Gold		Dowa		JAPAN
Gold		Eco-System Recycling Co., Ltd.		JAPAN
Gold		FSE Novosibirsk Refinery		RUSSIAN FEDERATION
Gold		Heimerle + Meule GmbH		GERMANY
Gold		Heraeus Ltd. Hong Kong		HONG KONG
Gold		Heraeus Precious Metals GmbH & Co. KG		GERMANY
Gold		Hwasung CJ Co. Ltd		KOREA, REPUBLIC OF
Gold		Ishifuku Metal Industry Co., Ltd.		JAPAN
Gold		Istanbul Gold Refinery		TURKEY
Gold		Japan Mint		JAPAN
Gold		Jiangxi Copper Company Limited		CHINA
Gold		Johnson Matthey Inc		UNITED STATES
Gold		Johnson Matthey Ltd		CANADA
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		RUSSIAN FEDERATION
Gold		JSC Uralectromed		RUSSIAN FEDERATION

 

 

Gold		JX Nippon Mining & Metals Co., Ltd.		JAPAN
Gold		Kazzinc Ltd		KAZAKHSTAN
Gold		Kennecott Utah Copper LLC		UNITED STATES
Gold		Kojima Chemicals Co., Ltd		JAPAN
Gold		Korea Metal Co. Ltd		KOREA, REPUBLIC OF
Gold		Kyrgyzaltyn JSC		KYRGYZSTAN
Gold		L’ azurde Company For Jewelry		SAUDI ARABIA
Gold		LS-NIKKO Copper Inc.		KOREA, REPUBLIC OF
Gold		Materion		UNITED STATES
Gold		Matsuda Sangyo Co., Ltd.		JAPAN
Gold		Metalor Technologies (Hong Kong) Ltd		HONG KONG
Gold		Metalor Technologies (Singapore) Pte. Ltd.		SINGAPORE
Gold		Metalor Technologies SA		SWITZERLAND
Gold		Metalor USA Refining Corporation		UNITED STATES
Gold		Met-Mex Peñoles, S.A.		MEXICO
Gold		Mitsubishi Materials Corporation		JAPAN
Gold		Mitsui Mining and Smelting Co., Ltd.		JAPAN
Gold		Moscow Special Alloys Processing Plant		RUSSIAN FEDERATION
Gold		Nadir Metal Rafineri San. Ve Tic. A.Ş.		TURKEY
Gold		Navoi Mining and Metallurgical Combinat		UZBEKISTAN
Gold		Nihon Material Co. LTD		JAPAN
Gold		Ohio Precious Metals, LLC		UNITED STATES
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)		RUSSIAN FEDERATION
Gold		OJSC Kolyma Refinery		RUSSIAN FEDERATION
Gold		PAMP SA		SWITZERLAND
Gold		Prioksky Plant of Non-Ferrous Metals		RUSSIAN FEDERATION
Gold		PT Aneka Tambang (Persero) Tbk		INDONESIA
Gold		PX Précinox SA		SWITZERLAND
Gold		Rand Refinery (Pty) Ltd		SOUTH AFRICA
Gold		Royal Canadian Mint		CANADA
Gold		Sabin Metal Corp.		UNITED STATES
Gold		SAMWON METALS Corp.		KOREA, REPUBLIC OF
Gold		Schone Edelmetaal		NETHERLANDS
Gold		SEMPSA Joyería Platería SA		SPAIN
Gold		Shandong Zhaojin Gold & Silver Refinery Co. Ltd		CHINA
Gold		So Accurate Group, Inc.		UNITED STATES
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		RUSSIAN FEDERATION

 

 

Gold		Solar Applied Materials Technology Corp.		TAIWAN
Gold		Sumitomo Metal Mining Co., Ltd.		JAPAN
Gold		Tanaka Kikinzoku Kogyo K.K.		JAPAN
Gold		The Great Wall Gold and Silver Refinery of China		CHINA
Gold		The Refinery of Shandong Gold Mining Co. Ltd		CHINA
Gold		Tokuriki Honten Co., Ltd		JAPAN
Gold		Torecom		KOREA, REPUBLIC OF
Gold		Umicore Brasil Ltda		BRAZIL
Gold		Umicore SA Business Unit Precious Metals Refining		BELGIUM
Gold		United Precious Metal Refining, Inc.		UNITED STATES
Gold		Valcambi SA		SWITZERLAND
Gold		Western Australian Mint trading as The Perth Mint		AUSTRALIA
Gold		YAMAMOTO PRECIOUS METAL CO., LTD.		JAPAN
Gold		Yokohama Metal Co Ltd		JAPAN
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		CHINA
Gold		Zijin Mining Group Co. Ltd		CHINA
Tantalum		Conghua Tantalum and Niobium Smeltry		CHINA
Tantalum		F&X Electro-Materials Ltd.		CHINA
Tantalum		Global Advanced Metals Boyertown		UNITED STATES
Tantalum		H.C. Starck GmbH Goslar		GERMANY
Tantalum		H.C. Starck Smelting GmbH & Co.KG		GERMANY
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		CHINA
Tantalum		Kemet Blue Powder		UNITED STATES
Tantalum		LSM Brasil S.A.		BRAZIL
Tantalum		Mineração Taboca S.A.		BRAZIL
Tantalum		Mitsui Mining & Smelting		JAPAN
Tantalum		Molycorp Silmet A.S.		ESTONIA
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		CHINA
Tantalum		Taki Chemicals		JAPAN
Tantalum		Ulba		KAZAKHSTAN

 

 

Tantalum		Zhuzhou Cement Carbide		CHINA
Tin		Alpha		UNITED STATES
Tin		China Rare Metal Materials Company		CHINA
Tin		China Tin Group Co., Ltd.		CHINA
Tin		CNMC (Guangxi) PGMA Co. Ltd.		CHINA
Tin		Cookson		UNITED STATES
Tin		Cooper Santa		BRAZIL
Tin		CV JusTindo		INDONESIA
Tin		CV Makmur Jaya		INDONESIA
Tin		CV Nurjanah		INDONESIA
Tin		CV Serumpun Sebalai		INDONESIA
Tin		CV United Smelting		INDONESIA
Tin		EM Vinto		BOLIVIA
Tin		Estanho de Rondônia S.A.		BRAZIL
Tin		Fenix Metals		POLAND
Tin		Gejiu Non-Ferrous Metal Processing Co. Ltd.		CHINA
Tin		Gejiu Zi-Li		CHINA
Tin		Huichang Jinshunda Tin Co. Ltd		CHINA
Tin		Jiangxi Nanshan		CHINA
Tin		Kai Unita Trade Limited Liability Company		CHINA
Tin		Linwu Xianggui Smelter Co		CHINA
Tin		Magnu’s Minerais Metais e Ligas LTDA		BRAZIL
Tin		Malaysia Smelting Corporation (MSC)		MALAYSIA
Tin		Melt Metais e Ligas S/A		BRAZIL
Tin		Metallo Chimique		BELGIUM
Tin		Mineração Taboca S.A.		BRAZIL
Tin		Minsur		PERU
Tin		Mitsubishi Materials Corporation		JAPAN
Tin		Novosibirsk Integrated Tin Works		RUSSIAN FEDERATION
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		THAILAND
Tin		OMSA		BOLIVIA
Tin		PT Alam Lestari Kencana		INDONESIA
Tin		PT Artha Cipta Langgeng		INDONESIA
Tin		PT Babel Inti Perkasa		INDONESIA
Tin		PT Babel Surya Alam Lestari		INDONESIA
Tin		PT Bangka Kudai Tin		INDONESIA
Tin		PT Bangka Putra Karya		INDONESIA
Tin		PT Bangka Timah Utama Sejahtera		INDONESIA
Tin		PT Bangka Tin Industry		INDONESIA

 

 

Tin		PT Belitung Industri Sejahtera		INDONESIA
Tin		PT BilliTin Makmur Lestari		INDONESIA
Tin		PT Bukit Timah		INDONESIA
Tin		PT DS Jaya Abadi		INDONESIA
Tin		PT Eunindo Usaha Mandiri		INDONESIA
Tin		PT Fang Di MulTindo		INDONESIA
Tin		PT HP Metals Indonesia		INDONESIA
Tin		PT Karimun Mining		INDONESIA
Tin		PT Koba Tin		INDONESIA
Tin		PT Mitra Stania Prima		INDONESIA
Tin		PT Pelat Timah Nusantara Tbk		INDONESIA
Tin		PT Prima Timah Utama		INDONESIA
Tin		PT Refined Banka Tin		INDONESIA
Tin		PT Sariwiguna Binasentosa		INDONESIA
Tin		PT Stanindo Inti Perkasa		INDONESIA
Tin		PT Tambang Timah		INDONESIA
Tin		PT Timah (Persero), Tbk		INDONESIA
Tin		PT Timah Nusantara		INDONESIA
Tin		PT Tinindo Inter Nusa		INDONESIA
Tin		PT Yinchendo Mining Industry		INDONESIA
Tin		Rui Da Hung		TAIWAN
Tin		Soft Metais, Ltda.		BRAZIL
Tin		Thaisarco		THAILAND
Tin		White Solder Metalurgia e Mineração Ltda.		BRAZIL
Tin		Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.		CHINA
Tin		Yunnan Tin Company, Ltd.		CHINA
Tungsten		A.L.M.T. Corp.		JAPAN
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		CHINA
Tungsten		Global Tungsten & Powders Corp.		UNITED STATES
Tungsten		H.C. Starck GmbH		GERMANY
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		CHINA
Tungsten		Kennametal Fallon		UNITED STATES
Tungsten		Kennametal Huntsville		UNITED STATES
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		CHINA
Tungsten		Xiamen Tungsten Co., Ltd.		CHINA

 

 

ANNEX II

 

*Smelters identified as sourcing from these countries have all been validated as using conflict free sourcing practices under the Conflict Free Smelter Program.