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)

Kelly Bysouth, 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, 2023.






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, 2023. 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 2023, 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 the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and/or Angola (collectively, “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. Nonetheless, 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 to cover 3TG. The Conflict Minerals Policy was expanded and renamed in 2019 to the Responsible Minerals Sourcing Policy (“Policy”) to include 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, cobalt and mica using the Organisation for Economic Cooperation and Development (OECD) 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 the United Nations Guiding Principles on 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 responsible sourcing policies including 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 500 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 (“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 2023. Members of 3M’s Responsible Minerals Steering Team participated in the RMI Due Diligence Practices Team and Plenary Team and attended the Responsible Business Alliance (“RBA”) and RMI Annual Conference to ensure alignment on programs and strategies in 2023. 3M also encouraged suppliers, smelters, and refiners to participate in RMI to expand common due diligence efforts. In addition, 3M and its Provider (as defined in Paragraph B.3 below) encouraged SORs identified in 3M’s supply chain, but non-conformant to RMAP, to enroll and participate in RMAP. In 2023, 3M contributed funding to an international development organization’s project on addressing the root causes of child labor in artisanal and small-scale mining for cobalt. Our support through the project’s adolescent apprenticeship program has contributed to reducing child labor in mining.

B. Description of RCOI:

1.RCOI Elements: The elements of 3M’s RCOI are identification and prioritization of in-scope 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 global Product Stewards (“PS”) were designated responsible for identifying in-scope products. The PS and 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 PS 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 and products that include these and other electrical or electronic components
Metallized films and tapes
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 several factors such as estimated content of 3TG, type of mineral, amount of spend, supplier location, and other corresponding supply chain information. 3M conducted outreach with suppliers for products that may contain Necessary 3TG, which represented over 80% of the in-scope Supplier Group (as defined in Paragraph B.3 below) in 2023.

3.     Data Collection: Once the relevant higher priority suppliers (collectively, “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, data collection, and validation. Accordingly, the CMRT was deployed to the Supplier Group through 3M’s Provider’s web portal. That system issued five automatic follow-up reminders to those in the Supplier Group who had not responded to the information requested. For those in the Supplier Group who had not responded after the follow-up reminders, two escalation emails were sent. 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 notifications 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.




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 each response to determine if further engagement with suppliers was warranted. Those responses were 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. 3M’s Provider worked with suppliers to resolve all responses with an incomplete status. The Provider’s web portal provided links to training resources and Conflict Minerals templates, practical tips, and best practices.

If there were discrepancies in expected mineral content for materials that contained Necessary 3TG on a supplier-submitted CMRT, additional information and follow-up was conducted with the supplier to clarify. Where appropriate, the Provider asked the supplier to submit a new CMRT and/or revised documentation.

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 each appliable supplier’s answer on its 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 from the suppliers’ submitted CMRTs to the SOR names and SOR country locations listed on the “smelter reference list” provided in the RMI CMRT template form.

The Provider validated whether any 3TG sourced from the Covered Countries was 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 hundreds 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 349 verified, unique SORs, including information regarding associated countries of origin. 3M and its Provider performed due diligence down to the product level on the SORs that were known or reasonably believed to have been 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 2023, 3M achieved an 90% response rate from suppliers, 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 2023.




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 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, 2023, 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/ Peter Gibbons
By: Peter GibbonsMay 31, 2024
Group President, Enterprise Supply Chain(Date)

Exhibit 1.01
CONFLICT MINERALS REPORT OF 3M COMPANY FOR THE YEAR ENDED DECEMBER 31, 2023
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, 2023.

“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, 2023 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, 2023 may have originated in the Democratic Republic of the Congo (“DRC”), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and/or Angola (collectively, “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, expanded and renamed to Responsible Minerals Sourcing Policy (“Policy”) in 2019, 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 and products that include these and other electrical or electronic components
Metallized films and tapes
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:

suppduediligencems.jpg








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 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 6.31 to conduct a survey of prioritized in-scope suppliers. During the supplier survey, 3M contacted suppliers via the Provider’s software-as-a-service (SaaS) platform, which enables 3M to track supplier communications and allows suppliers to upload completed CMRTs directly to the database for validation, assessment, and management. The database also provides functionality that meets the Organisation for Economic Co-operation and Development (OECD) process expectations by evaluating the quality of each supplier response and assigning a strength metric 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.

Through the Provider’s platform, 3M requested that all prioritized in-scope suppliers complete a CMRT. Training to guide suppliers on best practices to complete the CMRT was included. The Provider monitored progress and tracked all communications in the database to support reporting and transparency. 3M directly contacted suppliers that were unresponsive to the Provider’s requests and instructed these suppliers to complete and submit the CMRT to the Provider.

3M’s program includes 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 section 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 3M Tier 1 suppliers. The results of this data validation are shared with the suppliers to ensure they understand areas that require clarification or improvement and contribute to the program’s health assessment.

All submitted CMRTs were accepted and classified as either complete or invalid, to ensure data was retained. Examples of invalid submissions include incomplete, inaccurate, or inconsistent data. Further due diligence was conducted with suppliers who submitted invalid CMRTs. This included direct supplier engagement through the Provider’s multilingual Supplier Experience team who provided feedback on the CMRT submission, guidance on how to correct errors, and additional training and support as needed to successfully resubmit a valid CMRT.

Based on findings from the RCOI process, 3M was able to determine the countries of origin for a majority of those contacted under its outreach efforts of the 3TG in its products. As such, 3M continued to perform further due diligence on the source and chain of custody of these minerals.


DUE DILIGENCE MEASURES

A.     Design of 3M’s Due Diligence Measures

3M’s Conflict Minerals due diligence management system has been designed to conform with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“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 expanded and renamed in 2019 to Responsible Minerals Sourcing 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 respect for human rights in our own operations and our



supply chains as stated in the 3M Human Rights Policy (http://multimedia.3m.com/mws/media/1029705O/human-rights-policy.pdf) as well as with the OECD Guidance and United Nations Guiding Principles on Business and Human Rights (“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 Supply Chain, and a designated cross-functional Responsible Minerals Steering Team (“Steering Team”) composed of representatives from global Procurement, Responsible Sourcing, Environment, Health & Safety, Product Stewardship, Trade Compliance, and 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 Responsible Sourcing.

Senior leadership of Global Procurement, Enterprise Supply Chain, Legal Affairs, Corporate Audit, Ethics & Compliance, Environment, Health & Safety, Product Stewardship, Sustainability, 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 as well as an opportunity to provide input.

3M leveraged the Provider’s managed service team throughout the 2023 reporting year, which was made up of dedicated program specialists who supported 3M’s Conflict Minerals program. 3M communicated regularly with the Provider to receive updates on program status. Each member of the Provider’s team was trained in Conflict Minerals compliance and understood the intricacies of the CMRT and Conflict Minerals reporting requirements including Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). The Provider assisted with identifying and evaluating potential risks in the 3TG supply chain, as well as in development and implementation of additional due diligence steps that 3M will undertake with suppliers regarding Conflict Minerals.

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, product stewardship, and management systems. This code of conduct is based on industry and internationally accepted principles such as the UN Principles and the OECD Guidance and is aligned with the RBA framework. If a supplier is not able or willing to meet 3M’s requirements, a defined escalation process is followed 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 expects 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. 3M encourages suppliers to draw upon internationally recognized standards to advance social and environmental responsibility and business ethics.




All 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, and management systems. 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 may require.

3M determined that a reasonably designed inquiry for identifying and assessing supply chain risks should focus on higher priority suppliers, as is consistent with RMI’s Five Practical Steps to Support SEC Conflict Minerals Disclosure. 3M used numerous external indices, including the International Labour Organization, Global Slavery Index, and the Corruption Perception Index, among others, to assist in identification and prioritizing higher risk suppliers. The relevant higher priority suppliers (collectively, “Supplier Group”) were identified by 3M through its annual in-scope product review accounting for various factors such as estimated content of Necessary 3TG, type of mineral, amount of spend, supplier location and other corresponding supply chain information. In 2023, 3M conducted outreach with suppliers which represented over 80% of the in-scope Supplier Group for products that may contain Necessary 3TG.

3M created a process in coordination with the Provider to engage relevant suppliers to identify SORs contained in 3M’s supply chain. 3M communicated to these suppliers its requirements, which included expectations that they send a similar request to their direct suppliers to obtain information successively upstream to the SOR. The Provider’s web portal was utilized for the collection of CMRTs. Suppliers were guided to 3M’s Supplier Direct website (https://www.3m.com/3M/en_US/suppliers-direct/), which contains supplier responsibility expectations and links to additional supplier resources.

The Provider reviewed the Supplier Group CMRT responses to determine where further engagement with suppliers was warranted. In making such determination, 3M and the Provider considered untimely or incomplete responses, as well as inconsistencies with the data reported in the CMRT. For a 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. The Provider educated suppliers on the CMRT validity requirements, how to enter data, and 3M’s expectation to resolve all responses with an incomplete status. Suppliers had access to the Provider’s web portal which offers training resources, reporting templates, practical tips, and best practices.

For suppliers that identified “SORs of Interest” in their CMRT, according to indicators defined in the OECD Guidance as outlined below, 3M and its Provider requested additional information and provided resources on smelter risk mitigation.

3M’s Policy requires 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.

In partnership with the Provider, 3M has maintained 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 support with compliance specialists.

Grievance Mechanism

3M has a grievance mechanism whereby employees, suppliers, and other stakeholders 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.

RMI has a Grievance and Complaints Mechanism (“RMI Mechanism”) as part of its continuous improvement and risk management process. The RMI Mechanism allows stakeholders to raise concerns about its initiative, audit program, protocols, audit quality and auditor competencies, mineral supply chains and upstream/downstream initiatives. Stakeholders can also report concerns on 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. Our 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 to identify and assess 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. The portal issued five automated follow-up reminders to those in the Supplier Group who had not responded with the information requested. For those in the Supplier Group who had not responded after the follow-up reminders, two escalation emails were sent. Outbound communications were conducted in native languages, such as English, German, simplified Chinese, French, Italian, Spanish, Portuguese, and Japanese, 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 a Responsible Minerals Assurance Process (“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 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 used numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying “SORs of Interest” including:

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 were also evaluated on the strength of their own program, which assists 3M in making key risk mitigation decisions. 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 worked with the Provider throughout each phase of the process and provided periodic updates to the Steering Team and its executive sponsor.

The Provider’s risk mitigation activities were 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 were given clear performance objectives within reasonable timeframes, with the ultimate goal of progressive elimination of smelters of interest from the supply chain. In addition, suppliers were guided to the educational materials, located on the Provider’s website, on mitigating the risks identified through the data collection process.

If additional escalation was required, the Program Manager worked with the Steering Team and its executive sponsor or other relevant executives to determine appropriate follow-up actions and risk mitigation. Follow-up actions based on the variety of supplier risk levels may include additional due diligence by the Steering Team. 3M and its Provider may communicate directly with suppliers that have not yet been determined to be conformant with RMAP in order to request additional information and encourage their involvement in 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 2023 reporting year, 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 suppliers with 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 participated in RMI’s Due Diligence Practices Team and Plenary Team to keep 3M informed of new auditing standards, emerging risks, and risk assessment methods.

Annually, during the supplier outreach, the Provider directly contacts SORs that are not 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.

5. Report on Supply Chain Due Diligence

3M has published the Form SD and Conflict Minerals Report for the year ended December 31, 2023. 3M’s Forms SD and Conflict Minerals 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 the 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 response evaluations, 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. 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, of the 77 SORs identified as sourcing from those Covered Countries, 56 have been validated as conformant and/or active with RMAP protocols. The SORs which are not yet conformant/active have received direct communication from 3M detailing our Policy requirements and encouraging their participation in RMAP.

As outlined in the OECD Guidance, the internationally-recognized standard on which 3M’s system is based, 3M supports RMI’s RMAP audit of 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

As stated above, supply chain outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten, and gold. Following the industry standard process, 3M sent CMRTs to its in-scope Tier 1 suppliers, who were expected to follow this process until the SOR sources were identified. In 2023, 3M achieved an 90% response rate from its suppliers as a result of outreach efforts and will continue to work with the remaining suppliers to obtain alignment with future 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 common 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, many companies providing the CMRTs have the practice of listing all SORs they may purchase from within the reporting period. Therefore, the SORs (as sources) listed in Annex I are 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 these smelters could be connected to 3M’s products. 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 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 that the Supplier Group and its suppliers provide 3M with information on the SORs supplying 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. 3M verified 349 unique SOR names based on information listed on the RMI website. Of these unique SORs, 225 (65%) were validated as conformant to RMAP protocols as of April 29, 2024, and 5 (1%) were reported as active by RMI, meaning they were engaged in the RMAP program but not yet conformant as of April 29, 2024. 3M’s Supplier Group identified 100% 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 protocols 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 initiated participation in an independent third-party assurance process. During the 2023 reporting year, 3M identified 90 (26%) SOR facilities that were not participating in an independent third-party assurance process. These facilities are in the process of receiving letters from 3M strongly encouraging their participation.



rmchart2023.jpg

Efforts to Determine the Country of Origin or Mine of Origin

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 or countries of origin for Necessary 3TG used in 3M products manufactured during 2023. 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 include the countries listed in Annex II below.






Additional Due Diligence

3M compared the overall set of SORs identified by the Supplier Group against RMI’s RCOI list dated April 29, 2024, to identify all names and mineral sourcing for SORs that were conformant with the RMAP protocols and had been validated by a third-party auditor. The RCOI list also identified SORs participating in other assurance programs where the mineral sourcing of SORs was not disclosed.

For the 119 SORs identified to 3M by the Supplier Group in 2023 that are not yet engaged in the RMAP as active or validated as conformant to RMAP protocols or by any other independent third-party programs, 3M conducted further due diligence to understand whether the SORs of interest processed Necessary 3TG used in products provided to 3M. 3M also conducted additional due diligence, using a variety of information available from RMI and other reputable sources, to search 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 were reviewed, and specified factors were applied to determine risk levels.

3M will take additional mitigating action if credible sources provide information that identified SORs were 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 RMAP and similar programs, which will increase overall transparency and accessibility to information on geographic location of SOR mines of origin.

3M 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 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 2023 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 2023 reporting year inquiry that did not have certain key aspects of a Conflict Minerals program 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, 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 suppliers, customers, and other companies to become active members of 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.

·Continue to 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 with RMAP protocols.

·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.




·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 2019 and 2022, respectively, 3M broadened our scope to include cobalt and mica in our annual outreach, demonstrating 3M’s commitment to expanding our efforts.

·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 29, 2024, 3M is continuing its due diligence efforts with the identified suppliers to mitigate supply chain risk and align such supplier with 3M’s expectations.

·Support organizations working within communities and across partners to mitigate environmental and social impacts.

·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 29, 2024

The below list includes SORs identified to 3M by the 3M Supplier Group as of April 29, 2024. 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 supplied to 3M because they 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 3M products.

MetalSmelter NameSmelter Facility Location Smelter ID
Tantalum5D Production OUEstoniaCID003926
Gold8853 S.p.A.ItalyCID002763
TungstenA.L.M.T. Corp.JapanCID000004
GoldABC Refinery Pty Ltd.AustraliaCID002920
GoldAbington Reldan Metals, LLCUnited States Of AmericaCID002708
TungstenACL Metais EireliBrazilCID002833
GoldAdvanced Chemical CompanyUnited States Of AmericaCID000015
GoldAfrican Gold RefineryUgandaCID003185
GoldAgosi AGGermanyCID000035
GoldAida Chemical Industries Co., Ltd.JapanCID000019
GoldAl Etihad Gold Refinery DMCCUnited Arab EmiratesCID002560
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BrazilCID003427
GoldAlbino Mountinho Lda.PortugalCID002760
GoldAlexy MetalsUnited States Of AmericaCID003500
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UzbekistanCID000041
TinAlphaUnited States Of AmericaCID000292
TantalumAMG BrasilBrazilCID001076
TinAn Vinh Joint Stock Mineral Processing CompanyViet NamCID002703
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazilCID000058
GoldArgor-Heraeus S.A.SwitzerlandCID000077
TungstenArtek LLCRussian FederationCID003553
GoldAsahi Pretec Corp.JapanCID000082
GoldAsahi Refining Canada Ltd.CanadaCID000924
GoldAsahi Refining USA Inc.United States Of AmericaCID000920
GoldAsaka Riken Co., Ltd.JapanCID000090
TungstenAsia Tungsten Products Vietnam Ltd.Viet NamCID002502
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TurkeyCID000103
GoldAU Traders and RefinersSouth AfricaCID002850
GoldAugmont Enterprises Private LimitedIndiaCID003461
GoldAurubis AGGermanyCID000113
TinAurubis BeerseBelgiumCID002773
TinAurubis BerangoSpainCID002774
GoldBangalore RefineryIndiaCID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PhilippinesCID000128
GoldBoliden ABSwedenCID000157
GoldC. Hafner GmbH + Co. KGGermanyCID000176
GoldCaridadMexicoCID000180
GoldCCR Refinery - Glencore Canada CorporationCanadaCID000185
GoldCendres + Metaux S.A.SwitzerlandCID000189
GoldCGR Metalloys Pvt Ltd.IndiaCID003382
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaCID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaCID003190
GoldChimet S.p.A.ItalyCID000233
TungstenChina Molybdenum Tungsten Co., Ltd.ChinaCID002641
TinChina Tin Group Co., Ltd.ChinaCID001070
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaCID000258
GoldChugai MiningJapanCID000264
TungstenCNMC (Guangxi) PGMA Co., Ltd.ChinaCID000281



MetalSmelter NameSmelter Facility Location Smelter ID
GoldCoimpa Industrial LTDABrazilCID004010
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos
Do Brasil Ltda
BrazilCID003486
TinCRM SynergiesSpainCID003524
TungstenCronimet Brasil LtdaBrazilCID003468
TinCV Ayi JayaIndonesiaCID002570
TinCV Venus Inti PerkasaIndonesiaCID002455
TantalumD Block Metals, LLCUnited States Of AmericaCID002504
GoldDaye Non-Ferrous Metals Mining Ltd.ChinaCID000343
GoldDegussa Sonne / Mond Goldhandel GmbHGermanyCID002867
GoldDijllah Gold Refinery FZCUnited Arab EmiratesCID003348
TinDongguan CiEXPO Environmental Engineering Co., Ltd.ChinaCID003356
TungstenDONGKUK INDUSTRIES CO., LTD.Korea, Republic OfCID004060
GoldDongwu Gold GroupChinaCID003663
TinDowaJapanCID000402
GoldDowaJapanCID000401
TinDS MyanmarMyanmarCID003831
GoldDSC (Do Sung Corporation)Korea, Republic OfCID000359
GoldEco-System Recycling Co., Ltd. East PlantJapanCID000425
GoldEco-System Recycling Co., Ltd. North PlantJapanCID003424
GoldEco-System Recycling Co., Ltd. West PlantJapanCID003425
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy
Joint Stock Company
Viet NamCID002572
TinEM VintoBolivia (Plurinational State Of)CID000438
GoldEmerald Jewel Industry India Limited (Unit 1)IndiaCID003487
GoldEmerald Jewel Industry India Limited (Unit 2)IndiaCID003488
GoldEmerald Jewel Industry India Limited (Unit 3)IndiaCID003489
GoldEmerald Jewel Industry India Limited (Unit 4)IndiaCID003490
GoldEmirates Gold DMCCUnited Arab EmiratesCID002561
TinEstanho de Rondonia S.A.BrazilCID000448
TantalumF&X Electro-Materials Ltd.ChinaCID000460
TinFabrica Auricchio Industria e Comercio Ltda.BrazilCID003582
TinFenix MetalsPolandCID000468
GoldFidelity Printers and Refiners Ltd.ZimbabweCID002515
TantalumFIR Metals & Resource Ltd.ChinaCID002505
GoldFujairah Gold FZCUnited Arab EmiratesCID002584
TungstenFujian Xinlu Tungsten Co., Ltd.ChinaCID003609
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.ChinaCID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaCID002494
TinGejiu City Fuxiang Industry and Trade Co., Ltd.ChinaCID003410
TinGejiu Kai Meng Industry and Trade LLCChinaCID000942
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaCID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.ChinaCID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaCID000555
GoldGG Refinery Ltd.Tanzania, United Republic OfCID004506
GoldGGC Gujrat Gold Centre Pvt. Ltd.IndiaCID002852
TantalumGlobal Advanced Metals AizuJapanCID002558
TantalumGlobal Advanced Metals BoyertownUnited States Of AmericaCID002557
TungstenGlobal Tungsten & Powders LLCUnited States Of AmericaCID000568
GoldGold by Gold ColombiaColombiaCID003641
GoldGold Coast RefineryGhanaCID003186
GoldGold Refinery of Zijin Mining Group Co., Ltd.ChinaCID002243
GoldGreat Wall Precious Metals Co., Ltd. of CBPMChinaCID001909
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaCID003116
GoldGuangdong Jinding Gold LimitedChinaCID002312
TantalumGuangdong Rising Rare Metals-EO Materials Ltd.ChinaCID000291
TungstenGuangdong Xianglu Tungsten Co., Ltd.ChinaCID000218
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.ChinaCID000651
TungstenH.C. Starck Tungsten GmbHGermanyCID002541
GoldHangzhou Fuchunjiang Smelting Co., Ltd.ChinaCID000671



MetalSmelter NameSmelter Facility Location Smelter ID
TungstenHANNAE FOR T Co., Ltd.Korea, Republic OfCID003978
GoldHeimerle + Meule GmbHGermanyCID000694
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaCID002492
GoldHeraeus Germany GmbH Co. KGGermanyCID000711
GoldHeraeus Metals Hong Kong Ltd.ChinaCID000707
TungstenHubei Green Tungsten Co., Ltd.ChinaCID003417
TinHuiChang Hill Tin Industry Co., Ltd.ChinaCID002844
TungstenHunan Chenzhou Mining Co., Ltd.ChinaCID000766
GoldHunan Chenzhou Mining Co., Ltd.ChinaCID000767
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.ChinaCID000773
TungstenHunan Jintai New Material Co., Ltd.ChinaCID000769
TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou
Tungsten Products Branch
ChinaCID002513
GoldHwaSeong CJ CO., LTD.Korea, Republic OfCID000778
TungstenHydrometallurg, JSCRussian FederationCID002649
GoldIndustrial Refining CompanyBelgiumCID002587
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.ChinaCID000801
GoldInternational Precious Metal RefinersUnited Arab EmiratesCID002562
GoldIshifuku Metal Industry Co., Ltd.JapanCID000807
GoldIstanbul Gold RefineryTurkeyCID000814
GoldItalpreziosiItalyCID002765
GoldJALAN & CompanyIndiaCID002893
GoldJapan MintJapanCID000823
TungstenJapan New Metals Co., Ltd.JapanCID000825
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.ChinaCID002551
GoldJiangxi Copper Co., Ltd.ChinaCID000855
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.ChinaCID002512
TungstenJiangxi Gan Bei Tungsten Co., Ltd.ChinaCID002321
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.ChinaCID002313
TinJiangxi New Nanshan Technology Ltd.ChinaCID001231
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.ChinaCID002318
TantalumJiangxi Tuohong New Raw MaterialChinaCID002842
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.ChinaCID002317
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaCID002316
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaCID000914
TantalumJiujiang Tanbre Co., Ltd.ChinaCID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaCID002506
TungstenJSC "Kirovgrad Hard Alloys Plant"Russian FederationCID003408
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRussian FederationCID000927
GoldJSC Novosibirsk RefineryRussian FederationCID000493
GoldJSC UralelectromedRussian FederationCID000929
GoldJX Nippon Mining & Metals Co., Ltd.JapanCID000937
GoldK.A. RasmussenNorwayCID003497
GoldKaloti Precious MetalsUnited Arab EmiratesCID002563
GoldKazakhmys Smelting LLCKazakhstanCID000956
GoldKazzincKazakhstanCID000957
TantalumKEMET de MexicoMexicoCID002539
TungstenKennametal FallonUnited States Of AmericaCID000966
TungstenKennametal HuntsvilleUnited States Of AmericaCID000105
GoldKennecott Utah Copper LLCUnited States Of AmericaCID000969
GoldKGHM Polska Miedz Spolka AkcyjnaPolandCID002511
GoldKojima Chemicals Co., Ltd.JapanCID000981
GoldKorea Zinc Co., Ltd.Korea, Republic OfCID002605
GoldKundan Care Products Ltd.IndiaCID003463
GoldKyrgyzaltyn JSCKyrgyzstanCID001029
GoldKyshtym Copper-Electrolytic Plant ZAORussian FederationCID002865
GoldL'azurde Company For JewelrySaudi ArabiaCID001032
TungstenLianyou Metals Co., Ltd.Taiwan, Province Of ChinaCID003407
TungstenLianyou Resources Co., Ltd.Taiwan, Province Of ChinaCID004397
GoldLingbao Gold Co., Ltd.ChinaCID001056



MetalSmelter NameSmelter Facility Location Smelter ID
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.ChinaCID001058
TungstenLLC VostokRussian FederationCID003643
GoldL'Orfebre S.A.AndorraCID002762
GoldLS-NIKKO Copper Inc.Korea, Republic OfCID001078
GoldLT Metal Ltd.Korea, Republic OfCID000689
TinLuna Smelter, Ltd.RwandaCID003387
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.ChinaCID001093
TinMa'anshan Weitai Tin Co., Ltd.ChinaCID003379
TinMagnu's Minerais Metais e Ligas Ltda.BrazilCID002468
TinMalaysia Smelting Corporation (MSC)MalaysiaCID001105
TinMalaysia Smelting Corporation Berhad (Port Klang)MalaysiaCID004434
TungstenMalipo Haiyu Tungsten Co., Ltd.ChinaCID002319
GoldMarsam MetalsBrazilCID002606
TungstenMasan High-Tech MaterialsViet NamCID002543
GoldMaterionUnited States Of AmericaCID001113
TantalumMaterion Newton Inc.United States Of AmericaCID002548
GoldMatsuda Sangyo Co., Ltd.JapanCID001119
GoldMD OverseasIndiaCID003548
TinMelt Metais e Ligas S.A.BrazilCID002500
GoldMetal Concentrators SA (Pty) Ltd.South AfricaCID003575
TinMetallic Resources, Inc.United States Of AmericaCID001142
GoldMetallix Refining Inc.United States Of AmericaCID003557
TantalumMetallurgical Products India Pvt., Ltd.IndiaCID001163
GoldMetalor Technologies (Hong Kong) Ltd.ChinaCID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeCID001152
GoldMetalor Technologies (Suzhou) Ltd.ChinaCID001147
GoldMetalor Technologies S.A.SwitzerlandCID001153
GoldMetalor USA Refining CorporationUnited States Of AmericaCID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MexicoCID001161
TinMineracao Taboca S.A.BrazilCID001173
TantalumMineracao Taboca S.A.BrazilCID001175
TinMining Minerals Resources SARLCongo, Democratic Republic Of TheCID004065
TinMinsurPeruCID001182
GoldMitsubishi Materials CorporationJapanCID001188
TinMitsubishi Materials CorporationJapanCID001191
GoldMitsui Mining and Smelting Co., Ltd.JapanCID001193
TantalumMitsui Mining and Smelting Co., Ltd.JapanCID001192
GoldMKS PAMP SASwitzerlandCID001352
GoldMMTC-PAMP India Pvt., Ltd.IndiaCID002509
GoldModeltech Sdn BhdMalaysiaCID002857
TinModeltech Sdn BhdMalaysiaCID002858
TungstenMoliren Ltd.Russian FederationCID002845
GoldMorris and WatsonNew ZealandCID002282
GoldMoscow Special Alloys Processing PlantRussian FederationCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.S.TurkeyCID001220
TungstenNam Viet Cromit Joint Stock CompanyViet NamCID004034
GoldNavoi Mining and Metallurgical CombinatUzbekistanCID001236
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyViet NamCID002573
GoldNH Recytech CompanyKorea, Republic OfCID003189
TungstenNiagara Refining LLCUnited States Of AmericaCID002589
GoldNihon Material Co., Ltd.JapanCID001259
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaCID001277
TinNovosibirsk Tin CombineRussian FederationCID001305
TantalumNPM Silmet ASEstoniaCID001200
TungstenNPP Tyazhmetprom LLCRussian FederationCID003416
TinO.M. Manufacturing (Thailand) Co., Ltd.ThailandCID001314
TinO.M. Manufacturing Philippines, Inc.PhilippinesCID002517
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustriaCID002779
GoldOhura Precious Metal Industry Co., Ltd.JapanCID001325



MetalSmelter NameSmelter Facility Location Smelter ID
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant"
(OJSC Krastsvetmet)
Russian FederationCID001326
TungstenOOO “Technolom” 1Russian FederationCID003614
TungstenOOO “Technolom” 2Russian FederationCID003612
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)CID001337
GoldPease & CurrenUnited States Of AmericaCID002872
GoldPenglai Penggang Gold Industry Co., Ltd.ChinaCID001362
TungstenPhilippine Chuangxin Industrial Co., Inc.PhilippinesCID002827
GoldPlanta Recuperadora de Metales SpAChileCID002919
TinPongpipat Company LimitedMyanmarCID003208
TantalumPowerX Ltd.RwandaCID004054
TinPrecious Minerals and Smelting LimitedIndiaCID003409
GoldPrioksky Plant of Non-Ferrous MetalsRussian FederationCID001386
GoldPT Aneka Tambang (Persero) TbkIndonesiaCID001397
TinPT Aries Kencana SejahteraIndonesiaCID000309
TinPT Artha Cipta LanggengIndonesiaCID001399
TinPT ATD Makmur Mandiri JayaIndonesiaCID002503
TinPT Babel Inti PerkasaIndonesiaCID001402
TinPT Babel Surya Alam LestariIndonesiaCID001406
TinPT Bangka Prima TinIndonesiaCID002776
TinPT Bangka SerumpunIndonesiaCID003205
TinPT Bangka Tin IndustryIndonesiaCID001419
TinPT Belitung Industri SejahteraIndonesiaCID001421
TinPT Bukit TimahIndonesiaCID001428
TinPT Cipta Persada MuliaIndonesiaCID002696
TinPT Menara Cipta MuliaIndonesiaCID002835
TinPT Mitra Stania PrimaIndonesiaCID001453
TinPT Mitra Sukses GlobalindoIndonesiaCID003449
TinPT Panca Mega PersadaIndonesiaCID001457
TinPT Premium Tin IndonesiaIndonesiaCID000313
TinPT Prima Timah UtamaIndonesiaCID001458
TinPT Putera Sarana Shakti (PT PSS)IndonesiaCID003868
TinPT Rajawali Rimba PerkasaIndonesiaCID003381
TinPT Rajehan AriqIndonesiaCID002593
TinPT Refined Bangka TinIndonesiaCID001460
TinPT Sariwiguna BinasentosaIndonesiaCID001463
TinPT Stanindo Inti PerkasaIndonesiaCID001468
TinPT Sukses Inti MakmurIndonesiaCID002816
TinPT Timah NusantaraIndonesiaCID001486
TinPT Timah Tbk KundurIndonesiaCID001477
TinPT Timah Tbk MentokIndonesiaCID001482
TinPT Tinindo Inter NusaIndonesiaCID001490
TinPT Tirus Putra MandiriIndonesiaCID002478
TinPT Tommy UtamaIndonesiaCID001493
GoldPX Precinox S.A.SwitzerlandCID001498
GoldQG Refining, LLCUnited States Of AmericaCID003324
TantalumQuantumCleanUnited States Of AmericaCID001508
GoldRand Refinery (Pty) Ltd.South AfricaCID001512
GoldRefinery of Seemine Gold Co., Ltd.ChinaCID000522
GoldREMONDIS PMR B.V.NetherlandsCID002582
TinResind Industria e Comercio Ltda.BrazilCID002706
TantalumResind Industria e Comercio Ltda.BrazilCID002707
TantalumRFH Yancheng Jinye New Material Technology Co., Ltd.ChinaCID003583
GoldRoyal Canadian MintCanadaCID001534
TinRui Da HungTaiwan, Province Of ChinaCID001539
GoldSAAMPFranceCID002761
GoldSabin Metal Corp.United States Of AmericaCID001546
GoldSafimet S.p.AItalyCID002973
GoldSAFINA A.S.CzechiaCID002290
GoldSai RefineryIndiaCID002853



MetalSmelter NameSmelter Facility Location Smelter ID
GoldSam Precious MetalsUnited Arab EmiratesCID003666
GoldSamduck Precious MetalsKorea, Republic OfCID001555
GoldSamwon Metals Corp.Korea, Republic OfCID001562
GoldSEMPSA Joyeria Plateria S.A.SpainCID001585
GoldShandong Gold Smelting Co., Ltd.ChinaCID001916
GoldShandong Humon Smelting Co., Ltd.ChinaCID002525
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.ChinaCID001619
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaCID001622
GoldShenzhen CuiLu Gold Co., Ltd.ChinaCID002750
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.ChinaCID002527
TungstenShinwon Tungsten (Fujian Shanghang) Co., Ltd.ChinaCID004430
GoldShirpur Gold Refinery Ltd.IndiaCID002588
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaCID001736
GoldSingway Technology Co., Ltd.Taiwan, Province Of ChinaCID002516
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRussian FederationCID001756
GoldSolar Applied Materials Technology Corp.Taiwan, Province Of ChinaCID001761
TantalumSolikamsk Magnesium Works OAORussian FederationCID001769
GoldSovereign MetalsIndiaCID003383
GoldState Research Institute Center for Physical Sciences
and Technology
LithuaniaCID003153
GoldSudan Gold RefinerySudanCID002567
GoldSumitomo Metal Mining Co., Ltd.JapanCID001798
GoldSungEel HiMetal Co., Ltd.Korea, Republic OfCID002918
GoldSuper Dragon Technology Co., Ltd.Taiwan, Province Of ChinaCID001810
TinSuper LigasBrazilCID002756
GoldT.C.A S.p.AItalyCID002580
TantalumTaki Chemical Co., Ltd.JapanCID001869
GoldTanaka Kikinzoku Kogyo K.K.JapanCID001875
TantalumTANIOBIS Co., Ltd.ThailandCID002544
TantalumTANIOBIS GmbHGermanyCID002545
TantalumTANIOBIS Japan Co., Ltd.JapanCID002549
TungstenTANIOBIS Smelting GmbH & Co. KGGermanyCID002542
TantalumTANIOBIS Smelting GmbH & Co. KGGermanyCID002550
TantalumTelex MetalsUnited States Of AmericaCID001891
TinThaisarcoThailandCID001898
TinTin Smelting Branch of Yunnan Tin Co., Ltd.ChinaCID002180
TinTin Technology & RefiningUnited States Of AmericaCID003325
GoldTokuriki Honten Co., Ltd.JapanCID001938
GoldTongling Nonferrous Metals Group Co., Ltd.ChinaCID001947
GoldTOO Tau-Ken-AltynKazakhstanCID002615
GoldTorecomKorea, Republic OfCID001955
TungstenTungsten Vietnam Joint Stock CompanyViet NamCID003993
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyViet NamCID002574
TantalumUlba Metallurgical Plant JSCKazakhstanCID001969
GoldUmicore Precious Metals ThailandThailandCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgiumCID001980
TungstenUnecha Refractory metals plantRussian FederationCID002724
GoldUnited Precious Metal Refining, Inc.United States Of AmericaCID001993
GoldValcambi S.A.SwitzerlandCID002003
TinVQB Mineral and Trading Group JSCViet NamCID002015
GoldWEEEREFININGFranceCID003615
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaCID002030
TinWhite Solder Metalurgia e Mineracao Ltda.BrazilCID002036
GoldWIELAND Edelmetalle GmbHGermanyCID002778
TungstenWolfram Bergbau und Hutten AGAustriaCID002044
TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaCID002320
TungstenXiamen Tungsten Co., Ltd.ChinaCID002082
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDChinaCID000616
TantalumXinXing HaoRong Electronic Material Co., Ltd.ChinaCID002508
GoldYamakin Co., Ltd.JapanCID002100



MetalSmelter NameSmelter Facility Location Smelter ID
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaCID001522
GoldYokohama Metal Co., Ltd.JapanCID002129
TungstenYUDU ANSHENG TUNGSTEN CO., LTD.ChinaCID003662
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaCID002158
GoldYunnan Copper Industry Co., Ltd.ChinaCID000197
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.ChinaCID003397
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaCID002224








ANNEX II

As of
April 29, 2024


The below list includes 3TG countries of origin identified to 3M by the 3M Supplier Group as of April 29, 2024. 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 supplied to 3M 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 3M products.



Albania; Andorra; Angola*; Argentina; Armenia; Australia; Austria; Azerbaijan; Belarus; Belgium; Benin; Bermuda; Bolivia (Plurinational State of); Botswana; Brazil; Bulgaria; Burkina Faso; Burundi*; Cambodia; Canada; Central African Republic*; Chile; China; Colombia; Congo (Republic of the); Cyprus; Democratic Republic of the Congo*; Djibouti; Dominica; Dominican Republic; Ecuador; Egypt; El Savador; Eritrea; Estonia; Ethiopia; Fiji; Finland; France; Georgia; Germany; Ghana; Guam; Guatemala; Guinea; Guyana; Honduras; Hong Kong; Hungary; India; Indonesia; Ireland; Israel; Italy; Ivory Coast; Japan; Jersey; Kazakhstan; Kenya; Korea (Republic of); Kyrgyzstan; Liberia; Liechtenstein; Lithuania; Luxembourg; Madagascar; Malaysia; Mali; Mauritania; Mexico; Mongolia; Morocco; Mozambique; Myanmar; Namibia; Netherlands; New Zealand; Nicaragua; Niger; Nigeria; Norway; Oman; Panama; Papua New Guinea; Peru; Philippines; Poland; Portugal; Russian Federation; Rwanda*; Saudi Arabia; Senegal; Serbia; Sierra Leone; Singapore; Slovakia; South Africa; South Sudan*; Spain; Sudan; Suriname; Sweden; Switzerland; Taiwan; Tajikistan; Tanzania*; Thailand; Togo; Turkey; Uganda*; United Arab Emirates; United Kingdom; United States; Uruguay; Uzbekistan; VietNam; Zambia*



* Covered Country



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