Exhibit 1.01

 

CONFLICT MINERALS REPORT OF 3M COMPANY

 

FOR THE YEAR ENDED DECEMBER 31, 2019

 

INTRODUCTION

 

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

 

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

 

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

 

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

 

REASONABLE COUNTRY OF ORIGIN INQUIRY

 

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

 

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

·              Products that include these and other electrical or electronic components

·              Metallized films and tapes

·              Some orthodontic products

·              Fall protection equipment

·              Fire safety equipment

 

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

 

 

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

 

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

 


 

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

 

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

 

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

 

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

 

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

 

DUE DILIGENCE MEASURES

 

A.        Design of Our Due Diligence Measures

 

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

 

B.        Due Diligence Performed

 

1.          Establish Strong Company Management Systems

 

Responsible Minerals (Conflict Minerals) Sourcing Policy

 

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

 

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

 

Internal Management System

 

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

 


 

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

 

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

 

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

 

Control System and Supply Chain Transparency

 

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

 

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

 

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

 

Supplier Engagement

 

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

 

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

 

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

 


 

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

 

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

 

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

 

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

 

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

 

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

 

Grievance Mechanism

 

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

 

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

 

Maintain Records

 

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

 

2.            Identify and Assess Risk in the Supply Chain

 

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

 


 

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

 

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

 

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

 

·                  Geographic proximity to the DRC and Covered Countries.

·                  Known mineral source country of origin.

·                  RMAP audit status.

·                  Credible evidence of unethical or conflict sourcing.

·                  Peer assessments conducted by credible third-party sources.

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 


 

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

 

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

 

5.            Report on Supply Chain Due Diligence

 

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

 

RESULTS OF DUE DILIGENCE

 

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

 

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

 

Supply Chain Outreach Results

 

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

 

Upstream Data Transparency

 

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

 

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

 

Countries of Origin

 

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

 

Information on Smelters or Refiners

 

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

 


 

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

 

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

 

 

Efforts to Determine the Country of Origin or Mine of Origin

 

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

 

Additional Due Diligence

 

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

 

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

 


 

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

 

STEPS TO IMPROVE DUE DILIGENCE

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

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

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

 


 

Cautionary Statement about Forward-Looking Statements

 

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

 


 

ANNEX I

 

As of April 27, 2020

 

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

 

Metal

 

Standard Smelter

 

Smelter
Facility

 

Smelter ID

Gold

 

8853 S.p.A.

 

ITALY

 

CID002763

Gold

 

Advanced Chemical Company

 

UNITED STATES OF AMERICA

 

CID000015

Gold

 

Aida Chemical Industries Co., Ltd.

 

JAPAN

 

CID000019

Gold

 

Al Etihad Gold Refinery DMCC

 

UNITED ARAB EMIRATES

 

CID002560

Gold

 

Allgemeine Gold-und Silberscheideanstalt A.G.

 

GERMANY

 

CID000035

Gold

 

Almalyk Mining and Metallurgical Complex (AMMC)

 

UZBEKISTAN

 

CID000041

Gold

 

AngloGold Ashanti Corrego do Sitio Mineracao

 

BRAZIL

 

CID000058

Gold

 

Argor-Heraeus S.A.

 

SWITZERLAND

 

CID000077

Gold

 

Asahi Pretec Corp.

 

JAPAN

 

CID000082

Gold

 

Asahi Refining Canada Ltd.

 

CANADA

 

CID000924

Gold

 

Asahi Refining USA Inc.

 

UNITED STATES OF AMERICA

 

CID000920

Gold

 

Asaka Riken Co., Ltd.

 

JAPAN

 

CID000090

Gold

 

AU Traders and Refiners

 

SOUTH AFRICA

 

CID002850

Gold

 

Aurubis AG

 

GERMANY

 

CID000113

Gold

 

Bangalore Refinery

 

INDIA

 

CID002863

Gold

 

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

 

PHILIPPINES

 

CID000128

Gold

 

Boliden AB

 

SWEDEN

 

CID000157

Gold

 

C. Hafner GmbH + Co. KG

 

GERMANY

 

CID000176

Gold

 

CCR Refinery - Glencore Canada Corporation

 

CANADA

 

CID000185

Gold

 

Cendres + Metaux S.A.

 

SWITZERLAND

 

CID000189

Gold

 

Chimet S.p.A.

 

ITALY

 

CID000233

Gold

 

Chugai Mining

 

JAPAN

 

CID000264

Gold

 

DODUCO Contacts and Refining GmbH

 

GERMANY

 

CID000362

Gold

 

Dowa

 

JAPAN

 

CID000401

Gold

 

DS PRETECH Co., Ltd.

 

KOREA, REPUBLIC OF

 

CID003195

Gold

 

DSC (Do Sung Corporation)

 

KOREA, REPUBLIC OF

 

CID000359

Gold

 

Eco-System Recycling Co., Ltd. East Plant

 

JAPAN

 

CID000425

Gold

 

Eco-System Recycling Co., Ltd. North Plant

 

JAPAN

 

CID003424

Gold

 

Eco-System Recycling Co., Ltd. West Plant

 

JAPAN

 

CID003425

Gold

 

Emirates Gold DMCC

 

UNITED ARAB EMIRATES

 

CID002561

Gold

 

Geib Refining Corporation

 

UNITED STATES OF AMERICA

 

CID002459

Gold

 

Gold Refinery of Zijin Mining Group Co., Ltd.

 

CHINA

 

CID002243

Gold

 

Heimerle + Meule GmbH

 

GERMANY

 

CID000694

Gold

 

Heraeus Metals Hong Kong Ltd.

 

CHINA

 

CID000707

Gold

 

Heraeus Precious Metals GmbH & Co. KG

 

GERMANY

 

CID000711

Gold

 

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

 

CHINA

 

CID000801

Gold

 

Ishifuku Metal Industry Co., Ltd.

 

JAPAN

 

CID000807

Gold

 

Istanbul Gold Refinery

 

TURKEY

 

CID000814

Gold

 

Italpreziosi

 

ITALY

 

CID002765

Gold

 

Japan Mint

 

JAPAN

 

CID000823

Gold

 

Jiangxi Copper Co., Ltd.

 

CHINA

 

CID000855

Gold

 

JSC Uralelectromed

 

RUSSIAN FEDERATION

 

CID000929

Gold

 

JX Nippon Mining & Metals Co., Ltd.

 

JAPAN

 

CID000937

Gold

 

Kazzinc

 

KAZAKHSTAN

 

CID000957

Gold

 

Kennecott Utah Copper LLC

 

UNITED STATES OF AMERICA

 

CID000969

Gold

 

KGHM Polska Miedz Spolka Akcyjna

 

POLAND

 

CID002511

Gold

 

Kojima Chemicals Co., Ltd.

 

JAPAN

 

CID000981

Gold

 

Korea Zinc Co., Ltd.

 

KOREA, REPUBLIC OF

 

CID002605

Gold

 

Kyrgyzaltyn JSC

 

KYRGYZSTAN

 

CID001029

Gold

 

L’Orfebre S.A.

 

ANDORRA

 

CID002762

Gold

 

LS-NIKKO Copper Inc.

 

KOREA, REPUBLIC OF

 

CID001078

Gold

 

LT Metal Ltd.

 

KOREA, REPUBLIC OF

 

CID000689

Gold

 

Marsam Metals

 

BRAZIL

 

CID002606

Gold

 

Materion

 

UNITED STATES OF AMERICA

 

CID001113

Gold

 

Matsuda Sangyo Co., Ltd.

 

JAPAN

 

CID001119

Gold

 

Metalor Technologies (Hong Kong) Ltd.

 

CHINA

 

CID001149

Gold

 

Metalor Technologies (Singapore) Pte., Ltd.

 

SINGAPORE

 

CID001152

Gold

 

Metalor Technologies (Suzhou) Ltd.

 

CHINA

 

CID001147

Gold

 

Metalor Technologies S.A.

 

SWITZERLAND

 

CID001153

Gold

 

Metalor USA Refining Corporation

 

UNITED STATES OF AMERICA

 

CID001157

Gold

 

Metalurgica Met-Mex Penoles S.A. De C.V.

 

MEXICO

 

CID001161

Gold

 

Mitsubishi Materials Corporation

 

JAPAN

 

CID001188

Gold

 

Mitsui Mining and Smelting Co., Ltd.

 

JAPAN

 

CID001193

Gold

 

MMTC-PAMP India Pvt., Ltd.

 

INDIA

 

CID002509

Gold

 

Moscow Special Alloys Processing Plant

 

RUSSIAN FEDERATION

 

CID001204

Gold

 

Nadir Metal Rafineri San. Ve Tic. A.S.

 

TURKEY

 

CID001220

 


 

Gold

 

Nihon Material Co., Ltd.

 

JAPAN

 

CID001259

Gold

 

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

 

AUSTRIA

 

CID002779

Gold

 

Ohura Precious Metal Industry Co., Ltd.

 

JAPAN

 

CID001325

Gold

 

OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)

 

RUSSIAN FEDERATION

 

CID001326

Gold

 

OJSC Novosibirsk Refinery

 

RUSSIAN FEDERATION

 

CID000493

Gold

 

PAMP S.A.

 

SWITZERLAND

 

CID001352

Gold

 

Planta Recuperadora de Metales SpA

 

CHILE

 

CID002919

Gold

 

Prioksky Plant of Non-Ferrous Metals

 

RUSSIAN FEDERATION

 

CID001386

Gold

 

PT Aneka Tambang (Persero) Tbk

 

INDONESIA

 

CID001397

Gold

 

PX Precinox S.A.

 

SWITZERLAND

 

CID001498

Gold

 

Rand Refinery (Pty) Ltd.

 

SOUTH AFRICA

 

CID001512

Gold

 

REMONDIS PMR B.V.

 

NETHERLANDS

 

CID002582

Gold

 

Royal Canadian Mint

 

CANADA

 

CID001534

Gold

 

SAAMP

 

FRANCE

 

CID002761

Gold

 

Safimet S.p.A

 

ITALY

 

CID002973

Gold

 

Samduck Precious Metals

 

KOREA, REPUBLIC OF

 

CID001555

Gold

 

SAXONIA Edelmetalle GmbH

 

GERMANY

 

CID002777

Gold

 

SEMPSA Joyeria Plateria S.A.

 

SPAIN

 

CID001585

Gold

 

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

 

CHINA

 

CID001622

Gold

 

Sichuan Tianze Precious Metals Co., Ltd.

 

CHINA

 

CID001736

Gold

 

Singway Technology Co., Ltd.

 

TAIWAN, PROVINCE OF CHINA

 

CID002516

Gold

 

SOE Shyolkovsky Factory of Secondary Precious Metals

 

RUSSIAN FEDERATION

 

CID001756

Gold

 

Solar Applied Materials Technology Corp.

 

TAIWAN, PROVINCE OF CHINA

 

CID001761

Gold

 

Sumitomo Metal Mining Co., Ltd.

 

JAPAN

 

CID001798

Gold

 

SungEel HiMetal Co., Ltd.

 

KOREA, REPUBLIC OF

 

CID002918

Gold

 

T.C.A S.p.A

 

ITALY

 

CID002580

Gold

 

Tanaka Kikinzoku Kogyo K.K.

 

JAPAN

 

CID001875

Gold

 

The Refinery of Shandong Gold Mining Co., Ltd.

 

CHINA

 

CID001916

Gold

 

Tokuriki Honten Co., Ltd.

 

JAPAN

 

CID001938

Gold

 

TOO Tau-Ken-Altyn

 

KAZAKHSTAN

 

CID002615

Gold

 

Torecom

 

KOREA, REPUBLIC OF

 

CID001955

Gold

 

Umicore Brasil Ltda.

 

BRAZIL

 

CID001977

Gold

 

Umicore Precious Metals Thailand

 

THAILAND

 

CID002314

Gold

 

Umicore S.A. Business Unit Precious Metals Refining

 

BELGIUM

 

CID001980

Gold

 

United Precious Metal Refining, Inc.

 

UNITED STATES OF AMERICA

 

CID001993

Gold

 

Valcambi S.A.

 

SWITZERLAND

 

CID002003

Gold

 

Western Australian Mint (T/a The Perth Mint)

 

AUSTRALIA

 

CID002030

Gold

 

WIELAND Edelmetalle GmbH

 

GERMANY

 

CID002778

Gold

 

Yamakin Co., Ltd.

 

JAPAN

 

CID002100

Gold

 

Yokohama Metal Co., Ltd.

 

JAPAN

 

CID002129

Gold

 

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

 

CHINA

 

CID002224

Tantalum

 

Asaka Riken Co., Ltd.

 

JAPAN

 

CID000092

Tantalum

 

Changsha South Tantalum Niobium Co., Ltd.

 

CHINA

 

CID000211

Tantalum

 

CP Metals Inc.

 

UNITED STATES OF AMERICA

 

CID003402

Tantalum

 

D Block Metals, LLC

 

UNITED STATES OF AMERICA

 

CID002504

Tantalum

 

Exotech Inc.

 

UNITED STATES OF AMERICA

 

CID000456

Tantalum

 

F&X Electro-Materials Ltd.

 

CHINA

 

CID000460

Tantalum

 

FIR Metals & Resource Ltd.

 

CHINA

 

CID002505

Tantalum

 

Global Advanced Metals Aizu

 

JAPAN

 

CID002558

Tantalum

 

Global Advanced Metals Boyertown

 

UNITED STATES OF AMERICA

 

CID002557

Tantalum

 

Guangdong Zhiyuan New Material Co., Ltd.

 

CHINA

 

CID000616

Tantalum

 

H.C. Starck Co., Ltd.

 

THAILAND

 

CID002544

Tantalum

 

H.C. Starck Hermsdorf GmbH

 

GERMANY

 

CID002547

Tantalum

 

H.C. Starck Inc.

 

UNITED STATES OF AMERICA

 

CID002548

Tantalum

 

H.C. Starck Ltd.

 

JAPAN

 

CID002549

Tantalum

 

H.C. Starck Smelting GmbH & Co. KG

 

GERMANY

 

CID002550

Tantalum

 

H.C. Starck Tantalum and Niobium GmbH

 

GERMANY

 

CID002545

Tantalum

 

Hengyang King Xing Lifeng New Materials Co., Ltd.

 

CHINA

 

CID002492

Tantalum

 

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

 

CHINA

 

CID002512

Tantalum

 

Jiangxi Tuohong New Raw Material

 

CHINA

 

CID002842

Tantalum

 

JiuJiang JinXin Nonferrous Metals Co., Ltd.

 

CHINA

 

CID000914

Tantalum

 

Jiujiang Tanbre Co., Ltd.

 

CHINA

 

CID000917

Tantalum

 

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

 

CHINA

 

CID002506

Tantalum

 

KEMET Blue Metals

 

MEXICO

 

CID002539

Tantalum

 

LSM Brasil S.A.

 

BRAZIL

 

CID001076

Tantalum

 

Metallurgical Products India Pvt., Ltd.

 

INDIA

 

CID001163

Tantalum

 

Mineracao Taboca S.A.

 

BRAZIL

 

CID001175

Tantalum

 

Mitsui Mining and Smelting Co., Ltd.

 

JAPAN

 

CID001192

Tantalum

 

Ningxia Orient Tantalum Industry Co., Ltd.

 

CHINA

 

CID001277

Tantalum

 

NPM Silmet AS

 

ESTONIA

 

CID001200

Tantalum

 

PRG Dooel

 

NORTH MACEDONIA, REPUBLIC OF

 

CID002847

Tantalum

 

QuantumClean

 

UNITED STATES OF AMERICA

 

CID001508

Tantalum

 

Resind Industria e Comercio Ltda.

 

BRAZIL

 

CID002707

Tantalum

 

Solikamsk Magnesium Works OAO

 

RUSSIAN FEDERATION

 

CID001769

Tantalum

 

Taki Chemical Co., Ltd.

 

JAPAN

 

CID001869

Tantalum

 

Telex Metals

 

UNITED STATES OF AMERICA

 

CID001891

Tantalum

 

Ulba Metallurgical Plant JSC

 

KAZAKHSTAN

 

CID001969

Tantalum

 

XinXing HaoRong Electronic Material Co., Ltd.

 

CHINA

 

CID002508

Tantalum

 

Yanling Jincheng Tantalum & Niobium Co., Ltd.

 

CHINA

 

CID001522

Tin

 

Alpha

 

UNITED STATES OF AMERICA

 

CID000292

Tin

 

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

 

CHINA

 

CID000228

Tin

 

Chifeng Dajingzi Tin Industry Co., Ltd.

 

CHINA

 

CID003190

Tin

 

China Tin Group Co., Ltd.

 

CHINA

 

CID001070

Tin

 

Dowa

 

JAPAN

 

CID000402

Tin

 

EM Vinto

 

BOLIVIA (PLURINATIONAL STATE OF)

 

CID000438

 


 

Tin

 

Fenix Metals

 

POLAND

 

CID000468

Tin

 

Gejiu Kai Meng Industry and Trade LLC

 

CHINA

 

CID000942

Tin

 

Gejiu Non-Ferrous Metal Processing Co., Ltd.

 

CHINA

 

CID000538

Tin

 

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

 

CHINA

 

CID001908

Tin

 

Gejiu Zili Mining And Metallurgy Co., Ltd.

 

CHINA

 

CID000555

Tin

 

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

 

CHINA

 

CID003116

Tin

 

Guanyang Guida Nonferrous Metal Smelting Plant

 

CHINA

 

CID002849

Tin

 

HuiChang Hill Tin Industry Co., Ltd.

 

CHINA

 

CID002844

Tin

 

Huichang Jinshunda Tin Co., Ltd.

 

CHINA

 

CID000760

Tin

 

Jiangxi New Nanshan Technology Ltd.

 

CHINA

 

CID001231

Tin

 

Ma’anshan Weitai Tin Co., Ltd.

 

CHINA

 

CID003379

Tin

 

Magnu’s Minerais Metais e Ligas Ltda.

 

BRAZIL

 

CID002468

Tin

 

Malaysia Smelting Corporation (MSC)

 

MALAYSIA

 

CID001105

Tin

 

Melt Metais e Ligas S.A.

 

BRAZIL

 

CID002500

Tin

 

Metallic Resources, Inc.

 

UNITED STATES OF AMERICA

 

CID001142

Tin

 

Metallo Belgium N.V.

 

BELGIUM

 

CID002773

Tin

 

Metallo Spain S.L.U.

 

SPAIN

 

CID002774

Tin

 

Mineracao Taboca S.A.

 

BRAZIL

 

CID001173

Tin

 

Minsur

 

PERU

 

CID001182

Tin

 

Mitsubishi Materials Corporation

 

JAPAN

 

CID001191

Tin

 

O.M. Manufacturing (Thailand) Co., Ltd.

 

THAILAND

 

CID001314

Tin

 

O.M. Manufacturing Philippines, Inc.

 

PHILIPPINES

 

CID002517

Tin

 

Operaciones Metalurgicas S.A.

 

BOLIVIA (PLURINATIONAL STATE OF)

 

CID001337

Tin

 

PT Artha Cipta Langgeng

 

INDONESIA

 

CID001399

Tin

 

PT ATD Makmur Mandiri Jaya

 

INDONESIA

 

CID002503

Tin

 

PT Menara Cipta Mulia

 

INDONESIA

 

CID002835

Tin

 

PT Mitra Stania Prima

 

INDONESIA

 

CID001453

Tin

 

PT Refined Bangka Tin

 

INDONESIA

 

CID001460

Tin

 

PT Timah Tbk Kundur

 

INDONESIA

 

CID001477

Tin

 

PT Timah Tbk Mentok

 

INDONESIA

 

CID001482

Tin

 

Resind Industria e Comercio Ltda.

 

BRAZIL

 

CID002706

Tin

 

Rui Da Hung

 

TAIWAN, PROVINCE OF CHINA

 

CID001539

Tin

 

Soft Metais Ltda.

 

BRAZIL

 

CID001758

Tin

 

Thai Nguyen Mining and Metallurgy Co., Ltd.

 

VIET NAM

 

CID002834

Tin

 

Thaisarco

 

THAILAND

 

CID001898

Tin

 

Tin Technology & Refining

 

UNITED STATES OF AMERICA

 

CID003325

Tin

 

White Solder Metalurgia e Mineracao Ltda.

 

BRAZIL

 

CID002036

Tin

 

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

 

CHINA

 

CID002158

Tin

 

Yunnan Tin Company Limited

 

CHINA

 

CID002180

Tin

 

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

 

CHINA

 

CID003397

Tungsten

 

A.L.M.T. Corp.

 

JAPAN

 

CID000004

Tungsten

 

ACL Metais Eireli

 

BRAZIL

 

CID002833

Tungsten

 

Asia Tungsten Products Vietnam Ltd.

 

VIET NAM

 

CID002502

Tungsten

 

Chenzhou Diamond Tungsten Products Co., Ltd.

 

CHINA

 

CID002513

Tungsten

 

Chongyi Zhangyuan Tungsten Co., Ltd.

 

CHINA

 

CID000258

Tungsten

 

Fujian Ganmin RareMetal Co., Ltd.

 

CHINA

 

CID003401

Tungsten

 

Fujian Jinxin Tungsten Co., Ltd.

 

CHINA

 

CID000499

Tungsten

 

Ganzhou Haichuang Tungsten Co., Ltd.

 

CHINA

 

CID002645

Tungsten

 

Ganzhou Huaxing Tungsten Products Co., Ltd.

 

CHINA

 

CID000875

Tungsten

 

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

 

CHINA

 

CID002315

Tungsten

 

Ganzhou Seadragon W & Mo Co., Ltd.

 

CHINA

 

CID002494

Tungsten

 

Global Tungsten & Powders Corp.

 

UNITED STATES OF AMERICA

 

CID000568

Tungsten

 

Guangdong Xianglu Tungsten Co., Ltd.

 

CHINA

 

CID000218

Tungsten

 

H.C. Starck Smelting GmbH & Co. KG

 

GERMANY

 

CID002542

Tungsten

 

H.C. Starck Tungsten GmbH

 

GERMANY

 

CID002541

Tungsten

 

Hunan Chenzhou Mining Co., Ltd.

 

CHINA

 

CID000766

Tungsten

 

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

 

CHINA

 

CID002579

Tungsten

 

Hunan Chunchang Nonferrous Metals Co., Ltd.

 

CHINA

 

CID000769

Tungsten

 

Hunan Litian Tungsten Industry Co., Ltd.

 

CHINA

 

CID003182

Tungsten

 

Hydrometallurg, JSC

 

RUSSIAN FEDERATION

 

CID002649

Tungsten

 

Japan New Metals Co., Ltd.

 

JAPAN

 

CID000825

Tungsten

 

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

 

CHINA

 

CID002551

Tungsten

 

Jiangxi Gan Bei Tungsten Co., Ltd.

 

CHINA

 

CID002321

Tungsten

 

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

 

CHINA

 

CID002318

Tungsten

 

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

 

CHINA

 

CID002317

Tungsten

 

Jiangxi Yaosheng Tungsten Co., Ltd.

 

CHINA

 

CID002316

Tungsten

 

Kennametal Fallon

 

UNITED STATES OF AMERICA

 

CID000966

Tungsten

 

Kennametal Huntsville

 

UNITED STATES OF AMERICA

 

CID000105

Tungsten

 

KGETS Co., Ltd.

 

KOREA, REPUBLIC OF

 

CID003388

Tungsten

 

Lianyou Metals Co., Ltd.

 

TAIWAN, PROVINCE OF CHINA

 

CID003407

Tungsten

 

Malipo Haiyu Tungsten Co., Ltd.

 

CHINA

 

CID002319

Tungsten

 

Masan Tungsten Chemical LLC (MTC)

 

VIET NAM

 

CID002543

Tungsten

 

Moliren Ltd.

 

RUSSIAN FEDERATION

 

CID002845

Tungsten

 

Niagara Refining LLC

 

UNITED STATES OF AMERICA

 

CID002589

Tungsten

 

Philippine Chuangxin Industrial Co., Inc.

 

PHILIPPINES

 

CID002827

Tungsten

 

Tejing (Vietnam) Tungsten Co., Ltd.

 

VIET NAM

 

CID001889

Tungsten

 

Unecha Refractory metals plant

 

RUSSIAN FEDERATION

 

CID002724

Tungsten

 

Wolfram Bergbau und Hutten AG

 

AUSTRIA

 

CID002044

Tungsten

 

Woltech Korea Co., Ltd.

 

KOREA, REPUBLIC OF

 

CID002843

Tungsten

 

Xiamen Tungsten (H.C.) Co., Ltd.

 

CHINA

 

CID002320

Tungsten

 

Xiamen Tungsten Co., Ltd.

 

CHINA

 

CID002082

Tungsten

 

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

 

CHINA

 

CID002830

Tungsten

 

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

 

CHINA

 

CID002095

 


 

ANNEX II

 

As of April 27, 2020

 

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

 

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

 

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

 


* Covered Country