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At 3M, we set a high bar for our company regarding environmental and social governance, and we expect the same from our suppliers. 3M follows the Organization for Economic Cooperation and Development (OECD) Due Diligence framework for all of our responsible sourcing activities. The 3M Supplier Responsibility Code (SRC) is based on 3M’s corporate values for sustainable and responsible operations and aligns with the 10 Principles of the United Nations Global Compact, of which 3M is a participant. The SRC is also consistent with the Code of Conduct of the Responsible Business Alliance (RBA).
Our Due Diligence Management System consists of the following elements, which inform our continuous improvement efforts.
Strong policies aligned with our values.
The SRC outlines 3M’s foundational social and environmental expectations in the following areas: • Labor: Requirements align with the 3M Human Rights Policy and include important concepts like freely chosen employment (no forced, bonded, or trafficked labor), restrictions on working age (no child labor), and appropriate working hours and wages. Setting these expectations helps assure our suppliers’ actions will reflect 3M’s values on human rights as well as the values underlying the International Labour Organization (ILO) and laws, such as the California Transparency in Supply Chains Act, the United Kingdom Modern Slavery Act 2015, and the U.S. Federal Acquisition Regulation (FAR) on forced labor and human trafficking. To learn more about these topics, see the Human rights section • Environment, health, and safety (EHS): We expect our suppliers to care as much about the health and safety of their workers and their communities as 3M does and to implement proper procedures and controls to protect them as well as the environment in which we live • Ethics: Expectations align to the 3M Code of Conduct and hold our suppliers to the same high standards of honesty and integrity. Suppliers must prohibit any form of bribery and corruption and prevent conflicts of interest • Management systems: We expect our suppliers to establish processes to systematically conform to the 3M SRC as well as all legal requirements and to commit to continuous improvement.
The SRC establishes 3M’s expectations for new and existing suppliers anywhere in the world and for any supplied material or service. Our supplier vetting process includes a review of the SRC expectations and reinforcement that supplier programs and practices, as well as those of their subcontractors supplying products and/or services, conform to standards consistent with the SRC. Our global supplier contract agreements have incorporated SRC expectations.
We expect our suppliers to establish and implement their own relevant policies and programs in alignment with this SRC and to enforce these expectations with their own suppliers, thereby promoting our high Sustainability standards up our supply chains.
3M’s Vice President of Strategic Sourcing and Packaging Solutions (SS&PS) is accountable for 3M’s Responsible Sourcing program. The leader of our global responsible sourcing activities reports to the Vice President of SS&PS. Executive leaders including EHS, Ethics & Compliance, Corporate Auditing, Strategic Sourcing, Legal, Sustainability, and Human Resources are provided program updates at least twice a year, and Strategic Sourcing leadership is updated quarterly on the program’s status. Both groups have the opportunity to provide input on the various program activities. In 2019, 3M formed the Science, Technology & Sustainability (STS) Committee of the Board of Directors.
This committee reviews company Sustainability and EHS policies and programs for compliance with all applicable laws and regulations.
Supplier risk assessment and supply chain transparency.
As stated in our supplier contracts, in addition to full compliance with all applicable environmental laws, we expect our suppliers to integrate environmental responsibility into their operations. Suppliers should work to minimize adverse effects on the community, environment, and natural resources while safeguarding the health and safety of workers and the public. Additional information can be found at 3M Supplier Direct.
Our general supplier performance verification process begins with a self-assessment questionnaire (SAQ). The SAQ helps 3M understand supplier programs and determine whether they conform to 3M expectations. An on-site assessment may be conducted by 3M or a third party to assess the supplier’s level of conformance with 3M’s expectations. If deficiencies are identified, they will be addressed through an SRC Corrective Action Preventive Action (CAPA) process. Follow-up on the CAPA may include announced or unannounced assessments.
If the assessment identifies gaps or findings, and if a supplier is not able or willing to resolve them, the CAPA would escalate to a corporate Supplier Corrective Action Request (SCAR) that would involve sourcing, area manufacturing, and supply chain or business personnel engagement.
This assures appropriate resolution and conformance with 3M’s requirements. If a supplier is unwilling to work with 3M on the identified gaps or is unable to close the issues within a reasonable timeframe, alternative actions are determined with a cross-functional business team to elevate and resolve the situation.
The SRC outlines supplier expectations relating to grievance mechanisms. Anyone who has a concern involving 3M can use the 3MEthics.com site as an alternative way to report a concern.
Additional expectations for higher-risk value chains.
In addition to the global SRC expectations for all suppliers, certain areas warrant additional and specific formal expectations to drive more sustainable, responsible practices. This includes our use of certain minerals with the potential to be sourced from conflict-affected and high-risk areas, our use of timberbased products and other plant materials (pulp and paper), and all new suppliers in higher-risk countries, in areas such as Asia Pacific, Latin America, or parts of the Europe, Middle East, and Africa regions. See more on our risk identification in Responding to risks and transforming our supply chains.
Suppliers Our supply chain is an extension of our commitment to Sustainability.
3M supply chain Due Diligence Management System.
Report 15.
The SRC is currently available in languages.
Report on supply chain duediligence activities.
Verification.
Audit supply chain due diligence.
Values.
Establish strong policies and management systems.
Transformation.
Design and implement a strategy to respond to identified risks.
Transparency.
Identify and assess risks in the supply chain.
Suppliers How we work 176 177 3M 2020 Sustainability Report #improvinglives Suppliers
Focus: responsible minerals sourcing.
A prioritized area in our raw material supply network is the responsible sourcing of minerals. 3M deplores the violence and inhumane treatment that has occurred in the Democratic Republic of Congo, adjoining countries, and other conflict-affected and high-risk regions as defined by global regulatory bodies and is committed to supporting responsible sourcing of minerals that contain, but are not limited to, tin, tantalum, tungsten, gold, and cobalt, from all such regions. Additional information can be found in our Responsible Mineral Sourcing Policy and in Supplier Direct, Supplier Requirements.
Focus: pulp and paper 3M has prioritized pulp and paper products as an area that warrants additional formal expectations because of potential environmental risks, such as deforestation and habitat loss; potential human rights issues, such as infringement of indigenous peoples’ rights; and potential unsafe labor practices. As a global paper purchaser and Sustainability leader, 3M is well-positioned to positively influence practices throughout the forest products supply chain. We adopted our Pulp and Paper Sourcing Policy in 2015 to set standards of excellence for our suppliers through all tiers of supply from the forest. Our Pulp and Paper Sourcing Policy and guidance document is available in seven languages. Additional information can be found on the 3M Sustainable Forestry website.
Supplier diversity 3M is committed to diversity and inclusion, and we strongly encourage using diverse suppliers across our sourcing organization. This includes working with small businesses. We back up our commitment through initiatives that directly seek out diverse companies to support 3M’s business needs. Equally important, we recognize that diversity is a core value that helps strengthen our competitiveness and provides opportunities for new ideas and fresh perspectives.
3M has a long-standing commitment to sustainable business practices and to supporting the economic success of our communities, including working with both diverse and small-business suppliers. 3M considers a diverse supplier to be any supplier who qualifies for one or more of the following classifications: Minorityowned business, Women-owned business, and Small Business (including Small Disadvantaged, HUBZone, Woman, Veteran, or Service-Disabled Veteran).
3M proactively reaches out to various organizations, including the National Minority Supplier Development Council (NMSDC), Women’s Business Enterprise National Council (WBENC), Metropolitan Economic Development Association (MEDA), Small Business Administration (SBA), and others. We also have a supplier portal that allows businesses to provide a portfolio of their capabilities, which is distributed to 3M’s sourcing organization.
3M establishes goals and regularly tracks the dollar value of goods and services purchased from small businesses and diverse suppliers in concert with goals set annually with the U.S. federal government as part of our subcontracting plan for federal government contracting.
To achieve our goals, 3M has implemented a four-part strategy that aims to: • Increase our spending with current diverse suppliers by reviewing our existing diverse suppliers by diversity category • Identify additional diverse suppliers in our existing supply base by reviewing our top non-diverse suppliers by spending category • Find “new-to-3M” diverse suppliers • Further disrupt the status quo by working to move some of our Tier 2 spending to Tier 1 and focusing on diverse suppliers in our request for proposal (RFP) activity.
Our progress is routinely communicated to leadership across the organization.
We remain committed to supporting small businesses and diverse suppliers by continuing to reassess elements of our approach, working across the industry to assure best practices.
More on our supplier diversity program can be found on the Supplier Diversity website.
We understand that our Sustainability impacts extend beyond our own operations. By purchasing raw materials and services from small and large companies all over the world, we participate in a global, complex supply chain. And it doesn’t stop there. Our suppliers have their own suppliers, extending back to the original source of each material we use.
3M is committed to diversity and inclusion, and we strongly encourage using diverse suppliers across our sourcing organization.
“As a key business partner to 3M, we are proud to say that we have modeled our own Social Responsibility, Code of Conduct, and Paper Sourcing Policies to ensure that the key concepts regarding human rights, labor, ethics, and environmental risks outlined in 3M’s Supplier Responsibility Code and Pulp & Paper Policy are part of our own core standard beliefs and behaviors.
3M was instrumental in positively challenging Loparex to make sure our policies had all the requisite elements. Today, we have policies in place that we are proud to hold ourselves and our suppliers accountable to, and this would not have been possible without the help of 3M.” - Loparex 26.7%
In 2019, 3M spending with small businesses represented of which 6.71% went to diverse suppliers.
Goal: Drive supply chain Sustainability through targeted raw material traceability and supplier performance assurance by 2025.
Science for Circular.
Suppliers How we work 178 179 3M 2020 Sustainability Report #improvinglives Suppliers
Our actions 3M works with a broad, complex supply chain, consisting of over 63,900 suppliers in over 270 subcategories in.
In 2019, the SRC Steering Team provided refresher training for more than 300 assessors and sourcing professionals globally to assure a detailed understanding of 3M’s SRC expectations, processes, and supporting tools.
Employees received access to online training materials that covered each of the elements of the SRC, including labor and human rights, EHS, ethics, and management systems requirements. 3M’s business partners website also provided training materials for suppliers to expand their knowledge on topics such as global bribery and corruption awareness, eliminating forced labor, slavery, and human trafficking from the global supply chain, and preventing corruption and mitigating compliance risk for distributors and business partners.
Beyond risk, we aim to utilize our supply chains in our overarching goals for Sustainability. 3M recognizes that many of the world’s greatest challenges can be solved through collaboration. We are currently exploring supply chain integration opportunities with some of our key suppliers in effort to advance circularity. And, in 2019, we asked suppliers to partner with us to help advance our aspirational Sustainability goals in 3M’s Circular Economy Supplier Letter.
Verifying our supplier performance.
Although applicable to all suppliers, our supply chain risk assessment process focuses on prioritized suppliers, each of which must complete an SAQ and/ or be subject to an on-site assessment as specified in our SRC. In the past nine years, we have conducted over 6,900 self-assessments or on-site audits of suppliers in prioritized countries. Along the way, our assessment process has become more evolved and more comprehensive.
which included the comprehensive RBA framework and expanded from 18 to 31 countries, covering every region of the world.
Forced labor and human trafficking 3M’s efforts to eradicate forced labor and human trafficking from its direct supply chains are discussed in more detail in our transparency in supply chains and modern slavery disclosures. These disclosures communicate our commitment to legal and ethical practices as exhibited by our membership in the United Nations Global Compact, the implementation of 3M’s Code of Conduct, and cooperative efforts working with others to abolish human rights atrocities, especially in regard to human trafficking, forced labor, modern slavery, and other related crimes. 3M is committed to doing our part to eradicate human trafficking in any form 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 sets a high bar for our company regarding labor and employment, and we expect the same from our suppliers as articulated in the SRC.
5 10 15 20 25 30 35 40 45 50 55 0 2017 2016 2018 2019 2015.
Asia Pacific.
Latin America United States.
Canada Europe, Middle East, Africa 2,000 5,000 6,000 7,000 1,000 3,000 4,000 2017 2016 2018 2019 2015 0 109 countries around the world.
Supplier locations Supplier spend by region 2019 percentage.
Cumulative supplier assessments, since 2008.
Total number 550.
In 2019, 3M completed over assessments.
Responding to risks and transforming our supply chains.
We are constantly managing changes in supply markets, both where there is an opportunity to extract value, and defensively, where necessary to mitigate risk and secure supply. As described earlier, we focus efforts on the salient issues in categories where human rights and environmental risks are the greatest. More broadly, we conduct robust risk prioritization to determine other suppliers we will engage via an assessment against our SRC, which includes policy and contract conformance.
3M uses industry indices to identify higher-risk supply chains in conjunction with Lean Six Sigma (LSS) tools to optimize and strengthen its risk management processes. The criteria matrix helps rank global suppliers using multiple factors such as geographic, category, and businesscritical elements to determine where assessments should be performed.
In 2018, we updated our assessment progress and increased the scope of each assessment.
How we work 180 181 3M 2020 Sustainability Report #improvinglives Suppliers
Responsible minerals actions.
Forging ahead with continuous improvement 3M’s Responsible Minerals Sourcing program, now in its seventh year, has gone through continuous improvements, based on insights from past campaigns as well as external benchmarking that provided ways to optimize and increase the effectiveness of program activities.
In 2019, as part of our responsible sourcing expectations, 3M expanded its responsible minerals sourcing to include how cobalt is sourced in order to support industry expectations and 3M’s Values and Human Rights policies. 3M expects our suppliers to adopt a similar policy and due-diligence management system, and we require the same of their suppliers in order to proliferate responsible sourcing practices throughout the supply chain.
In addition, 3M is an active member of the Responsible Minerals Initiative (RMI), which develops tools and provides guidance for companies regarding conflict minerals. Our membership in RMI and various sub-teams, such as the Smelter Engagement Team (SET), Due Diligence Practice Team, and Plenary Team, enable 3M to be involved in activities supporting RMI’s Code of Conduct and due-diligence practices. The teams provide useful venues for 3M to offer their ideas and learn from other member companies as we all work together on this important journey of transforming our supply chains.
In October 2019, 3M attended the RMI Annual Conference to discuss strategies and best practices regarding the expansion of a market-driven responsible sourcing supply chain.
3M’s membership in RMI provides insights into emerging risk and assessments in raw materials supply chains utilizing the Risk Readiness Assessment (RRA) tool. RRA is the basis for corporate assessments of material risks in 3TG (tantalum, tin, tungsten, and gold) supply chains, specifically related to social and environmental risks.
With the evolution of conflict minerals programs, 3M partnered with a third party to manage our 2019 program outreach and data collection. The third-party platform automates the collection, validation, and centralization of data to support 3M’s Responsible Minerals Sourcing program. Suppliers entering the portal are linked to training resources with access to topics and webinars such as “Smelter Validation in 2019: Hot Topics,” “The Evolving Regulatory Landscape: Top 10 Trends for 2020,” and “Responsible Minerals Compliance: Leveraging the OECD Due Diligence Guidance.”
Additional information can be found in the 3M Conflict Minerals Securities and Exchange Commission filings found on 3M Supplier Direct, Supplier Requirements, Responsible Minerals.
Pulp and paper actions.
Pulp and paper policy implementation on the ground.
Throughout our policy implementation, we have seen several examples of marked improvements in responsible pulp and paper sourcing practices as a result of our engagement with suppliers. These include: • Meeting with suppliers’ senior corporate executives about the importance of assuring responsible and sustainable supply chains, and agreeing to collaborate on that goal • Suppliers establishing new positions within their companies • Significant increases in supply chain traceability and transparency • Increased engagement by our suppliers with their upstream supply chain • Suppliers adopting pulp and paper policies for the first time • Suppliers enhancing existing policies to meet the requirements of 3M’s policies • Supplier invitation to sourcing area for our pulp and paper products to understand challenges around responsible sourcing and to create a path forward (see November 2019 3M Pulp and Paper Sourcing Policy Progress Report for more information on this topic)
Through an online survey, 3M suppliers can provide complete supply chain information all the way to the forest sources, or they can easily forward parts of the online survey to their suppliers (paper or pulp mills, for example) for completion.
Conflict mineral supply chain traceability 2019 percentage.
RMAP conformant 78.4%
RMAP active 1.7%
RMAP not enrolled 17.5%
Based on Responsible Minerals Assurance Process (RMAP)
Pulp and paper supply chain traceability 2019 percentage.
Traceable to forest source or 100% recycled 56%
Traceable to pulp mill 22%
Traceable to paper mill 8%
Not yet engaged or traceable 14%
We aim to work with suppliers and peer companies to document as much of our global paper supply chain as possible, amplify our efforts to mitigate risks, improve efficiencies, and drive sustainable practices throughout the supply chain.