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Supplier Responsibility Expectations

  • 3M values supplier partnerships where our core values align with empowering ethical growth, inspiring integrity through collaboration and compliance, as well as stewardship of our people, planet and practices. We encourage all suppliers to have a proactive approach in aligning with 3M's policies and programs to strengthen our supply chains and ensure conformance to regulations. By working together, we can achieve business success and uphold our strong, positive reputations.

    It is the responsibility of 3M Suppliers to stay current on applicable laws.

    ALERT for 3M China Suppliers:

    PDF Document 3M China Supplier Environmental Compliance Inquiry - English (218 KB)
    PDF Document 3M China Supplier Environmental Compliance Inquiry - Chinese (259 KB)


  • Supplier Responsibility Code

    Background: The 3M “Supply Chain Policies” were first established in 2006 to document our expectations for suppliers’ environmental, health, safety, labor and transportation performance. The Supplier Responsibility Code is the “next generation” of our expectations for supplier responsible practices.

    Why this, why now? Over the past decade, expectations for corporations to apply responsible sourcing practices to their supplier network have been expanding in scope and detail. Our foundational requirements for our suppliers must mature to meet these expectations. In addition, 3M became a signatory to the UN Global Compact in early 2014, and this updated set of expectations for our suppliers aligns with the UN Global Compact 10 principles.

    How was this new version developed?  A cross-functional team benchmarked the supplier requirements from many peer companies (multi-national manufacturers of diverse products).   We also consulted guidance from organizations like the OECD and the UN, and recent case studies from consulting firms and not-for-profit sustainability organizations.  Most significantly, we used as a basis for this draft the Electronics Industry Citizenship Coalition (EICC) Code of Conduct, tailoring it to include important aspects of 3M’s existing Supply Chain Policies.  The EICC Code is a well-established, comprehensive Code that is pervasive in the electronics industry, and is increasingly being emulated in other industries.

    What does it cover?  This 3M Supplier Responsibility Code consists of 5 main sections, with some of the more significant updates to our original Policies noted below:

    • Labor – includes more specific requirements and controls for the elimination of forced labor, and more details on appropriate working hours and time off.
    • Health & Safety – includes specific requirements for emergency exits, fire protection, and worker housing (when provided).
    • Environment – includes expectations on reducing environmental impacts, and protecting air, water, and land resources.
    • Ethics – this is a new section, mirroring 3M’s Code of Conduct positions on anti-bribery, conflicts of interest, protection of intellectual property, and related Business Conduct issues.
    • Management Systems – another new section, requiring strong policies and systems to control the aspects in the previous sections, and propagate the requirements up the supply chain.

    How will we implement?  New and renegotiated supply contracts and PO terms will reference the new code.  Existing contracts will not be re-negotiated solely for this change.  Our supplier assessment program is being updated to match the Code expectations.

    The 3M Supplier Responsibility Code is available in a number of different languages as provided on the 3M Supplier Responsibility Code page. This Supplier Responsibility Code Assessment introductory presentation (PDF, 1.2 MB) can be accessed and/or shared with suppliers to help them better understand 3M’s environmental and social compliance expectations.


  • Heavy Metals in Packaging

    3M is committed to compliance with all laws, including those relating to “Heavy Metals” in packaging. “Heavy Metals” are lead, mercury, cadmium and hexavalent chromium.

    Packaging suppliers are required to minimize heavy metals in packages and packaging materials under both the European Parliament and Council Directive 94/62/EC on Packaging and Packaging Waste (“Directive 94/62/EC”) and the United States laws enacted by various states under the Coalition of Northeastern Governor (“CONEG”) Model Toxics in Packaging legislation, including the California Toxics in Packaging Prevention Act, which requires suppliers to provide to their purchasers Certificates of Compliance with that law.

    Suppliers to 3M that deliver finished packaged products are also required to follow the Essential Requirements outlined in Annex II of Directive 94/62/EC.

    Please see 3M Corporate General Specification 180 on heavy metals in packaging, found on 3M.Com Partners and Suppliers / Packaging which includes additional background and 3M's requirements for its suppliers regarding the heavy metals content of packaging and packaging components.

    We are sure that your company, like 3M, is committed to compliance with all applicable laws.

    PDF Document Heavy Metals Certificate (75 KB) (form 35664)

    For additional information regarding Packaging Legislation, see links below:

    Toxics in Packaging Clearinghouse

    Summaries of the European Union Regulations

  • Conflict Minerals

    Background. Armed groups operating in the eastern Democratic Republic of the Congo (DRC) have controlled many of the region’s mines or transit routes and have engaged in armed conflict, as well as some of the world's worst human rights violations. Concern that proceeds from the mining of minerals have been used to fund extreme violence in that region led to a requirement in the U.S. Dodd-Frank Financial Reform Law of 2010, that U.S. publicly-traded companies must disclose any "conflict minerals" necessary to the functionality or production of products they manufacture or contract to manufacture. The conflict minerals are tin, tungsten, tantalum and gold (called the 3TG's). Companies using conflict minerals must also disclose their supply chain inquiries to verify whether these minerals originated in the DRC or adjoining countries.

    On August 22, 2012, the SEC approved the final rule on conflict minerals. All public companies must evaluate their product lines to determine whether they contain necessary conflict minerals and if so, file a Form SD by May 31 annually beginning in 2014, for products they manufacture or contract to manufacture in the year 2013. While the burden of compliance is on the public companies who manufacture those products, members of their supply chains for those products are also impacted.


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  • Counterfeit Goods

    Background
    3M is a worldwide leader in innovation and quality. To deliver best value, cutting edge products, 3M maintains a dynamic, worldwide supply chain. As with any global supply chain, there is risk that counterfeit materials, parts, components and assemblies may be introduced. The presence of counterfeit material could adversely impact 3M’s ability to meet customer expectations and expose 3M to penalties, fines, damages and other serious adverse consequences. Accordingly, 3M has established a Counterfeit Material Control Plan to ensure compliance with customer anti-counterfeit requirements, the evolving laws in this area and to ensure the overall quality, compliance and reputation of 3M’s diverse, innovative product lines.

    3M Expectations of Suppliers
    As part of 3M’s Counterfeit Material Control Plan, 3M has implemented a minimum set of risk-based counterfeit mitigation measures for all product lines, including measures relating to products and materials provided to 3M by suppliers. These measures are reflected in the Counterfeit Goods Provisions referenced below and are in addition to any other counterfeit goods requirements specified in a written agreement with 3M or provided to a supplier by 3M.

    Counterfeit Goods Provisions
    The following provisions apply to any purchase order for goods issued by 3M Company or its affiliates and to products provided to 3M or its affiliates pursuant to a written agreement:

    PDF Document Counterfeit Goods (146 KB)

  • Forced Labor / Human Trafficking

    3M abhors slavery and human trafficking in any form, and is committed to doing our part to eradicate these practices from the global supply chain. We have robust policies and systems in place to control these practices in our own operations and with our suppliers. 3M is a signatory to the United Nations Global Compact (UNGC), and is committed to operations and supply chains that embody the 10 Principles of the UNGC, six of which address human rights and labor practices. 3M issues disclosure statements in accordance with the California Transparency in Supply Chains Act (SB 657)(PDF, 84 KB), and the UK Modern Slavery Act 2015 (PDF, 169 KB). Our disclosure statements can also be found on www.3M.com, in the lower-right section entitled “Regulatory.”

    As 3M sets a high bar for itself regarding labor and employment, it expects the same from its suppliers. The 3M Supplier Responsibility Code specifies the Labor (including freely chosen employment and prohibition of child labor), Health and Safety, Environment, Ethics and Management Systems expectations we have for our suppliers. Conformance to this Code is required to become or remain a supplier to 3M, anywhere in the world, and for any supplied material or service. We expect suppliers as well as their suppliers to establish programs that are consistent with the 3M Supplier Responsibility Code, and this expectation is included in our global supply contracts. 3M evaluates Code conformance by existing and potential new suppliers through a self-assessment and/or onsite audit program.

    3M’s Business Conduct Policies clearly state the commitment of all 3M employees to compliance with all applicable laws, regulations and 3M policies in the conduct of our business activities. This extends to laws regarding slavery or human trafficking in the countries in which we do business. All employees are required to review and agree to our Code of Conduct on an annual basis, and completion of various business conduct trainings is mandatory each year.

    3M has adopted strong employment, labor, and worker protection principles in its Human Rights Policy (PDF, 57 KB) that applies to 3M employees worldwide. We prohibit the use of forced or bonded labor, and the employment of children under 16 years of age (or the minimum age established by local law if older). 3M has a formal Employee Relations assessment process, whereby we evaluate our individual operations’ conformance to these labor, employment, and human rights policies and expectations.

    More information about all of these policies and programs can be found in 3M’s annual Sustainability Report.

  • Pulp and Paper Sourcing & Legal Harvesting Laws

    Why Forests and Responsible Supply Chains are Important

    Forests are used by people around the world for recreation, cultural significance, health and livelihood. They are home to many species of plants and animals, their trees capture and store atmospheric carbon, and they support vital services like clean water. These complex ecosystems are valuable resources that should be responsibly managed and preserved for future generations. 3M does not support natural forest degradation or conversion to non-forest use. We support the protection of indigenous peoples’ rights to offer Free and Prior Informed Consent (FPIC) to harvesting operations on their land, and of workers’ safety and other basic rights.

    At 3M, we are guided by our values; they are woven into the very fabric of our company culture. We act with uncompromising integrity. We respect our social and physical environments around the world. We share our sustainability values with our customers and stakeholders. 3M wants to work with the best suppliers who share these commitments to sustainable forests and responsibility in all stages of the forest products supply chain.

    The 3M Pulp and Paper Sourcing Policy

    The PDF Document 3M Pulp and Paper Sourcing Policy (254 KB) formalizes our and our supply chain’s responsibilities to comply with global regulations, and further the causes of sustainable forestry and transparent, responsible supply chains.

    We expect our pulp and paper suppliers to read, understand and implement the expectations in our Policy. The companion PDF Document Policy Conformance Guidance Document (206.57 KB) contains definitions and additional explanation of many of the important concepts in the Policy. 3M will also provide our suppliers additional information and opportunities for education and engagement.

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    Please refer to 3M's web page on Sustainable Forestry for more information, including links to our semi-annual Policy Progress Reports.

    3M’s Expectations for Suppliers

    Legality: 3M expects that all pulp, paper and packaging supplied to us contains wood or plant-based fiber that is legally harvested, sourced, transported and exported from its country of origin. Please see the Legal Harvesting Laws on this page for more information on these expectations.

    Traceable to Forest Source: 3M expects suppliers to know their own supply chains, and respond to our requests for material traceability information in a complete and timely manner. Understanding our forest products supply chain, including paper and pulp mills and forest sources, is fundamental to ensuring Policy conformance. We depend on our direct suppliers to understand and disclose their supply chains to us, so that together we can ensure Policy conformance and drive responsible sourcing and sustainable forestry.

    Due Diligence Management System: 3M expects our suppliers to adopt company policies and a due diligence management system approach to address responsible forest products sourcing and sustainable forestry. We also expect our suppliers to work with their suppliers to adopt similar policies and management systems. 3M has created a Word Document due diligence management system template outline (60 KB) for our suppliers' use if they choose, and which can be shared with their suppliers.

    Certification: 3M expects our suppliers to know the forest certification status of the material they purchase and of the entities in their supply chain, and to disclose certification information to us upon request. 3M’s policy expectations and guidelines are consistent with many forest certification standards, but our Policy does not require certification. Certification in and of itself is not the objective of our Policy, but it is one useful tool to help verify what is happening on the ground. Please refer to this PDF Document forestry certification overview (513 KB) for more on how we believe our Policy compares to the major global forestry certification schemes.

    Collaboration: 3M expects our suppliers to work together with us and their suppliers to ensure Policy conformance and promote responsible and transparent supply chains. We recognize the integral role that our suppliers play to source and produce the materials required for 3M products, and we know that collaboration and transparency depend on a foundation of mutual trust. Through our Pulp & Paper Sourcing Policy, we wish to harness the power of our supply chain to achieve real, positive change for the world's forests.

    Conformance: 3M expects our suppliers to be forthcoming in their opportunities for performance improvements for themselves or their suppliers, and in cases where conformance cannot immediately be demonstrated, we will support suppliers that are working on timely and reasonable progress towards conformance. If a supplier won’t work with us or change their practices to conform, 3M will seek alternative sources of supply.

    Refer to this PDF Document presentation (2.3 MB) for additional information on the 3M Pulp and Paper Sourcing Policy.

    How Policy Conformance Benefits 3M Suppliers

    The business climate is continually changing and evolving. Not only are more customers interested in understanding where their products come from, but governments around the world, through laws and regulations, are requiring product producers to know more about the sources of their raw materials. Products that can be traced to responsible sources will help your business comply with regulations and protect your reputation, and can be a differentiation factor in retaining existing business and earning opportunities for new business.

    Together, we can support sustainable forestry and responsible, transparent supply chains.

    Additional Guidance

    United Nations Supply Chain Sustainability
    A Guide to Traceability: A Practical Approach to Advance Sustainability in Global Supply Chains


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    Legal Harvesting Laws

    Products and product packaging supplied to 3M Company must comply with laws related to product content, including laws that prohibit use of illegally harvested timber or plant materials. Laws regarding timber and timber products, such as the United States Lacey Act, the European Union Timber Regulation, and the Australia Illegal Logging Prohibition Act, restrict the sales and imports of illegally harvested timber or products derived from such timber (including paper or paper pulp). These laws also may include "due care" or "due diligence" requirements.

    Additional Details on U.S. Lacey Act Requirements

    The U.S. Lacey Act was amended in 2008 to prohibit the purchase or sale of products or product packaging in the United States made from wood, paper, wood fiber or other plant materials, with certain limited exceptions, if the plant material was illegally harvested in its country of origin. The Lacey Act has import declaration requirements that are currently in effect for a limited number of wood products. However, the prohibition on purchase or sale of products containing illegally harvested plant materials applies to all products containing plant material.

    3M has developed a corporate U.S. Lacey Act Specification. The Specification has additional background on this law, and sets out 3M's expectations for suppliers providing materials to 3M that contain plant material subject to the Lacey Act. See U.S. Lacey Act Specification.

    3M's Sourcing Contract Provisions and Supply Chain Policies on Legal Harvesting

    3M includes prohibitions on illegally harvested plant materials in new and renewed sourcing contracts. Under 3M's Supplier Responsibility Code and previously 3M's Supply Chain Policies: EHS, Transportation, Labor/Human Resources and Supplied Materials, suppliers are expected to supply 3M materials containing plant materials or their derivatives that are legally sourced, harvested and exported from their country of origin. Suppliers are also expected to adopt policies and management systems with respect to the United States Lacey Act, the European Union Timber Regulation and similar laws (such as the Australia Illegal Logging Prohibition Act), and to require their suppliers to adopt similar policies and systems.

    As a supplier to 3M, please become aware of these requirements and take the following steps:


    1. Determine which of the products you supply to 3M contain timber or plant materials within the scope of the U.S. Lacey Act, the EU Timber Regulation, Australia Illegal Logging Act and similar laws.
    2. Work with your suppliers to make sure all plant materials are legally harvested, sourced and exported from their country of origin, or validate the origin as recycled.
    3. Adopt company policies and management systems with respect to the U.S. Lacey Act, EU Timber Regulation, Australia Illegal Logging Act and similar laws, and require your suppliers to adopt similar policies and systems. This will assist in pushing these requirements upstream and in obtaining information on legality of harvest that is passed downstream.

    Click here for more information on the U.S. Lacey Act: USDA Animal and Plant Health Inspection Service.

    Click here for more information on the EU Timber Regulation.

    Click here for more information on the Australia Illegal Logging Prohibition Act.

  • Rigid Plastic Packaging Container (RPPC)

    California's Rigid Plastic Packaging Container (RPPC) law was enacted in 1991 as part of an effort to reduce the amount of plastic waste disposed in California landfills and to increase the use of recycled postconsumer plastic. The law mandates that product manufacturers that sell products held in RPPCs meet one of the compliance options identified in the regulation.

    3M is committed to compliance with all laws, including those relating to Rigid Plastic Packaging Container (RPPC). RPPC generally means a packaging container that:

    • is made entirely of plastic (except for incidental portions of the packaging),
    • has a relatively inflexible shape or form,
    • has a minimum capacity or volume of eight (8) ounces up to a maximum capacity or volume of five (5) gallons,
    • is capable of at least one closure (including closure during the manufacturing process).

    RPPCs can range in shape, color, size, and form. RPPCs can include, but are not limited to:

    • Buckets
    • Tubs
    • Pails
    • Tubes
    • Cartridges
    • Jugs
    • Bottles (wide mouth and/or narrow neck)
    • Clamshells (heat-sealed and/or reclosable)
    • Plastic Folding Cartons

    RPPC legislation requires Packaging component suppliers to provide Certificates of Compliance with California law as required by Title 14 of the California Code of Regulations. We are requesting that as a supplier to 3M you provide all Container Manufacturer Certification Information as required under Section 17945.4 of Title 14, California Code of Regulations (CCR) for the package component numbers provided.

    We are sure that your company, like 3M, is committed to compliance with all applicable laws.

    For additional information regarding RPPC Packaging Legislation, see links below:

    California's Department of Resources Recycling and Recovery (CalRecycle)

    Regulations: Title 14, California Code of Regulations (CCR) Chapter 4, Article 3,

    Section 17942-17946

    Statutes: California Public Resources Code (PRC)

    Section 42300-42301

    Section 42320-42327

    Section 42330

    Section 42340-42345

  • RoHS Specification

    3M Company has developed a corporate EU RoHS Specification which sets forth 3M's expectations for suppliers providing materials to 3M that may be subject to the requirements of the European Union's Directive 2002/95/EC, Restriction of the use of certain Hazardous Substances in Electrical and Electronic Equipment, as amended, and/or the substance restrictions of the recast RoHS Directive 2011/65/EU, Annex II, jointly known as "EU RoHS."

    Directive 2002/95/EC as amended is repealed on January 3, 2013. Directive 2011/65/EU is in effect as of that date.

    Under EU RoHS, electrical and electronic equipment placed on the European Union market may not contain more than certain levels of:

    • Lead
    • Mercury
    • Cadmium
    • Hexavalent Chromium
    • Polybrominated biphenyls (PBBs) (flame retardant)
    • Polybrominated diphenyl ethers (PBDEs) (flame retardant)

    Other countries around the world are considering and/or have implemented regulations that are similar to EU RoHS.

    The 3M EU RoHS Specification applies to all materials, parts, components and/or products (whether finished or semi-finished) that include restrictions on the EU RoHS substances listed above or that have this specification cited on or in their 3M part number drawing, part or product specifications, sourcing agreements, purchase contracts, purchase orders or other purchasing documentation.

    Here is the PDF Document3M Corporate EU RoHS Specification (32 KB)

    For more information on the EU RoHS Directive, please see the following link: http://ec.europa.eu/environment/waste/rohs_eee/index_en.htm


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