Document Type: Procedure
Organization: Public Affairs / Legal Affairs
Subcategory: Government Affairs / Ethics & Compliance
Geographic Scope: Global

Operating Procedure for Complaints Procedure in the Event of Violationsof the German Supply Chain Act (Lieferkettensorgfaltspflichtengesetz, LkSG)
Applies to:

Introduction &;Background or
PurposeThis Procedure applies to all employees of 3M worldwide as well as to external parties, such as:- Third parties acting on behalf of 3M, e.g. temporary workers, employees of external service providers- Business partners, e.g. suppliers, customers or cooperation partners- Internal whistleblowers- other third parties
Acting responsibly, sustainably, ethically and lawfully is one of 3M's core cultural elements and principles andis firmly anchored in 3M's corporate strategy and Code of Conduct. This includes appropriate compliance withhuman rights and environmental due diligence obligations in accordance with the German Supply Chain Act(Lieferkettensorgfaltspflichtengesetz – LkSG).
3M wants to convince business partners with innovative products, competitive prices, good quality, service andcompetent advice. (Non-expert) Influencing business partners by e.g. Corruption, fraud or other violations of
3M's Code of Conduct are strictly prohibited.
We have put in place an effective complaints procedure to report human rights and environmental risks orviolations. The complaints procedure can be used to report all indications of possible violations of legal regulations, including human rights, or environmental risks or violations affecting one's own business area and along
the entire supply chain.

Requirements

The overall responsibility for compliance with the requirements of this procedural lies with Government Affairs Department and the Ethics & Compliance (E&C) Department of 3M Deutschland GmbH.

TABLE OF CONTENTS
1. PURPOSE AND SCOPE OF THIS PROCEDURAL INSTRUCTION ............................................................ 2
2. APPEAL PROCEEDINGS ...................................................................................................................... 2
3. SECRECY AND ANTI-RETALIATION ..................................................................................................... 2
4. REVIEW AND IMPROVEMENT ........................................................................................................... 3

1.

PURPOSE AND SCOPE OF THIS PROCEDURAL INSTRUCTION

The purpose of this Procedure is to transparently describe 3M’s complaints procedure within the meaning of §8 (2) LkSG (German Supply Chain Act) of 3M Deutschland GmbH and its affiliated companies within the meaningof § 15 AktG (German Stock Corporation Act). The complaint procedure is intended to enable persons to pointout human rights and environmental risks as well as violations of human rights-related or environmental due
diligence obligations under the LkSG or violations concerning their own business area as well as along the entire
supply chain that are caused by the economic activities of 3M Deutschland GmbH have arisen in their own
business area or through the actions of a supplier.

2.

APPEAL PROCEEDINGSAll whistleblowers can report their complaint (including anonymously - to the extent permitted by local law) in 24 languages and worldwide - through a web-based platform (operated by a third-party provider) to theparent company of 3M Deutschland GmbH, the 3M Company (hereinafter referred to as "3M") via the following link:
3MEthics.com
After selecting the appropriate country, a telephone number is provided, allowing submissions via telephone.
Contact persons are given as well.
Any concerns reported to 3M will be investigated. The individual concerns are tracked, monitored and closed(either as justified or unfounded).
It is ensured that anonymous reports remain anonymous. 3MEthics.com does not trace calls or identify callers, nor does it generate or maintain internal connection logs containing IP addresses.
Whistleblowers receive a "reporting key" and can use it to access their reports anonymously at any time. The
whistleblower will be contacted no later than 3 working days after the first report has been submitted. In thecase of anonymous reports, this is done via coded access (“reporting key”).
The result is communicated to the whistleblower or can be retrieved via the reporting key. The average processing time for a report is 90 days.
Note on the input mask:
Until further notice, whistleblowers can use the "HR, Diversity and Respectful Workplace" input field on LkSGrelevant topics in 3MEthics.com. After clicking on it, there are free fields for input.

3. SECRECY AND ANTI-RETALIATION
It is in the interest of the company to uncover and remedy grievances. 3M is fully committed to the confidential treatment of whistleblowers and to the protection of whistleblowers.
3M protects the anonymity of whistleblowers throughout the entire process of handling a complaint, provided that the reporter indicates that he or she wishes to remain anonymous. No measures are taken to determine their identity.
Whistleblowers who report possible compliance violations and provide information on human rights or environmental risks as well as violations of human rights or environmental due diligence obligations to the best of
their knowledge and in good faith do not have to fear any adverse actions by the company as a result of thecomplaint. In the event of apparent misuse of the 3M Whistleblowing Management System, 3M reserves theright to take legal action or disciplinary action against whistleblowers.
3M also protects the rights of the accused person. The presumption of innocence under the rule of law applies until proven otherwise.

4. REVIEW AND IMPROVEMENT
3M will carry out regular reviews and improvements to the complaints procedure on an ad hoc basis.
Linked Documents
Further Information
VersionVersion Effective Date
Language
Tags

GDPR EU Privacy Notice for Non-Employees
For further information, please contact the Government Affairs Department or the Ethics & Compliance Department of 3M Deutschland GmbH.
1.0
July 1st, 2023
English#German Supply Chain Act #LkSG #Complaints Procedure #SpeakUp #Human Rights #UEnvironmental Rights#Procedure #Supply Chain #Lieferkettensorgfaltspflichtengesetz #Whistleblower