3M Deutschland GmbHGerman Supply Chain Due Diligence Act(Lieferkettensorgfaltspflichtengesetz)
Self-Declaration and Policy Statement
Executive summary:
At 3M Company (3M), we share our customers' commitment to legal and ethical businesspractices around the world.
3M is a global leader that helps support a safe, sustainable, healthy and bright world, foreveryone. Our Purpose drives our culture, which in turn drives our innovation model leading tostrong performance and growth.
3M has been named the World's Most Ethical Company® by the Ethisphere Institute for nineconsecutive years. This award reflects our ongoing commitment to maintaining the highest
ethical and compliance standards in our business practices. 3M has also been a participant in
the United Nations Global Compact since 2014. 3M publishes its Code of Conduct Ethics &Compliance | 3M United States in 22 languages and invests extensive resources in programs
designed to help our employees understand and follow our Code of Conduct. One of 3M's core
principles of business conduct is compliance with applicable laws wherever 3M does business.
3M also has a 3M Supplier Responsibility Code, which outlines 3M's foundational expectationsof its suppliers in the areas of labour, environment, health and safety, ethics and management
systems. Conformance with this Code is required to become or remain a supplier to 3M
anywhere in the world and for any supplied materials or services.
The following Self-Declaration and Policy Statement describes the basic principles of 3M
Deutschland GmbH with regard to their fulfilment of obligations according to the Supply Chain
Due Diligence Act (Lieferkettensorgfaltspflichtengesetz, “SCDDA”).
Introduction
Responsible, sustainable, ethical and lawful action is one of the key 3M cultural elements andprinciples and is firmly anchored in the 3M corporate strategy and the 3M Code of Conduct.
This includes appropriate compliance with human rights and environmental due diligencerequirements in accordance with the Supply Chain Due Diligence Act.
Just as sustainability is embedded in our promise to improve lives by helping solve the world’sgreatest challenges, sustainable thinking is embedded into the core of 3M and in the strategicplanning process we use for every business it is part of the corporate culture and tradition. Asa concept with ecological, social and economic importance, sustainable action and corporate
responsibility have been continuously developed within 3M for decades.
The 3M Environmental Policy, created in 1975, established the framework for environmental
management and conservation of resources, emphasizing prevention of pollution at thesource. We work to identify potential risks to the environment as well as to the health andsafety of our employees and communities, and we take steps to modify processes, productdesign, and standards to address these risks. We leverage information and technology toassess the risks and drive compliance through data systems and technical analysis. Since
1988, 3M has defined global, quantitative targets for reducing emissions to water, air and soil,
which are updated on an ongoing basis. Programs for the more efficient use of raw materials
and energy complement this strategy. The successes are measurable: In the last twenty years,
for example, Scope 1 and Scope 2 location-based CO₂ emissions have been reduced by morethan 75 percent. 3M has supported the Paris Agreement since its inception and incorporated
the 2018 findings of the Special Report on Global Warming of 1.5°C by the Intergovernmental
Panel on Climate Change (IPCC) into our goals, operations, and actions.
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3M's activities are not limited to environmental stewardship in the traditional sense. For thecompany, sustainability is only ever conceivable as a holistic approach. That is why 3M
combines environmental, social, and governance programs, initiatives and activities with thestandard to act responsibly beyond legal requirements. In the process, the environment,economy and society are equally important elements. 3M has always been a purpose-drivencompany. We unlock the power of people, ideas and science to reimagine what’s possible.
The power comes from connecting purpose to our performance
1. Ethical action as a basic principle
Our success is based on long-term trust - business partners, customers, and suppliers havetrusted 3M for decades. Maintaining and expanding this trust is a fundamental principle of thecompany. It is based on more than just innovative products - namely on a clear basic approachon the part of 3M, which provides for ethical business conduct at all times. This philosophy isexpressed in the corporate culture, which is based on respect and trust, as well as in the 3M
Code of Conduct, which applies to 95,000 employees in over 70 countries and stands for a
corporate culture characterised by ethical behaviour. 3M also ensures that its suppliers shareits commitment to maintaining compliant, responsible, and sustainable operations andpractices through adherence with the 3M Supplier Responsibility Code. We expect oursuppliers to enforce these expectations with their own suppliers, thereby promoting our highsustainability standards through our supply chains.
The 3M Sustainability Reporting, related Policies, Standards, Our Code of Conduct, andSupplier Responsibility Code can be found using the following link:
https://www.3M.com/3M/en_US/sustainability-us/annual-report/

The following declaration in accordance with the SCDDA refers to the German branches of 3M
Deutschland GmbH and describes the human rights strategy with regard to the SCDDA risks.
This Policy Statement is published.
2. Obligations according to the Supply Chain Due Diligence Act
The duty of care in the supply chain and SCDDA risks (SCDDA risks) are subject to a large
number of German legal requirements and regulations1. This Self-Declaration and Policy
Statement describes the subject-specific requirements for 3M Deutschland GmbH; it does notrepresent any obligation of 3M Deutschland GmbH towards its customers or business partners
or suppliers or employees that goes beyond the interface regulation; 3M Deutschland GmbHdoes not assume any additional responsibility, liability, indemnification obligations or the liketowards them. Incidentally, this Self-Declaration is not a contract, in particular not a contract infavour of third parties and also not a contract with a protective effect in favour of third parties.
Until further notice, this Self-Declaration also applies as a Policy Statement in accordance withsection 6 (2) SCDDA; however, the Policy Statement will be updated shortly and created as
an independent document, since the findings and developments from the date of validity of theSCDDA will be incorporated.
The German activities of 3M Deutschland GmbH fall within the scope of the German Supply
Chain Due Diligence Act (SCDDA), which prescribes due diligence with focus on the following
human rights and environmental risks ("SCDDA risks").
M1 Prohibition of child labour
M2 Prohibition of forced labour and all forms of slavery
M3 Failure to comply with occupational health and safety and work-related health hazards
M4 Failure to respect freedom to form a coalition - freedom of association and the right to collective bargaining

1 Supply Chain Due Diligence Act (LkSG) [Link German version] | Supply Chain Due Diligence Act (SCDDA) [Linkto English version]
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M5 Prohibition of unequal treatment in employment
M6 Prohibition on withholding adequate wages
M7 Destruction of the natural livelihood through environmental pollution
M8 Unlawful violation of land rights
M9 Prohibition on hiring or using private/public security forces that could lead to impairments due to a lack of
instruction or control
M10 The prohibition of an action going beyond the above or an omission of a breach of duty, which is directly
capable in a particularly serious way to impair a protected legal position (resulting from the human rights agreements
as defined in section 2 (1)) and whose illegality is obvious after a reasonable assessment of all relevant
circumstances
U1 Prohibited manufacture, use and/or disposal of mercury (Minamata Convention)
U2 Prohibited production and/or use of substances within the scope of the Stockholm Convention (POP) and nonenvironmentally sound handling of waste containing POPs
U3 Prohibited import/export of hazardous waste as defined in the Basel Convention

3. Expectations
3M Deutschland GmbH expects its employees and its suppliers in the supply chain within themeaning of the SCDDA to support 3M's commitment to ethical business conduct and integrityin order to identify the human rights and environmental risks and violations described in theSCDDA and to guard against them in an appropriate manner (or prevent them) and, if
necessary, to stop or minimise them.
This applies in particular to the priority areas of human rights and environmental risks. It is
expected that the employees of 3M Deutschland GmbH and their suppliers in the supply chain
support 3M in risk management, risk analysis, preventive and remedial measures and thecomplaints procedure within the meaning of the SCDDA; this applies to 3M DeutschlandGmbH's own business area and its supply chain within the meaning of the SCDDA and isexpressed in this regard, for example, in the 3M Code of Conduct and the 3M Supplier
Responsibility Code.
4. Procedure
3M Deutschland GmbH has a proven management system. This consists of specifications forthe management of the organisational units, regulation management, risk management, aninternal control system and a compliance management system. In addition, relevantinstructions are in place.
The requirements of the Supply Chain Due Diligence Act, in particular risk management, arewoven into it in terms of personnel, processes and documentation. Annual and event-relatedrisk analyses are carried out in our own business area and in the supply chain in accordancewith the instructions and regulations of the SCDDA.
The results are appropriately weighted and prioritised. Preventive and remedial measuresaccording to the SCDDA are assigned to the prioritised risks. Their effectiveness is checked
annually and as required and updated if necessary. In accordance with the legal requirements,
3M Deutschland GmbH also includes indirect suppliers in the analyses and measures
mentioned. This applies in particular if 3M Deutschland GmbH has actual indications that aviolation of a human rights-related or environmental obligation appears possible at an indirect
supplier (substantiated knowledge). 3M and thus also 3M Deutschland GmbH maintain alegally compliant complaints procedure.
3M Deutschland GmbH will check the fulfilment of the duty of care in accordance with the law,
update and document and report if necessary. 3M Deutschland GmbH with all of its businesspremises adheres to the obligations arising from the SCDDA in relation to SCDDA risks.
4.1.

Risk analysis in accordance with the SCDDA
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3M Deutschland GmbH carries out a risk analysis in accordance with SCDDA. Here, customers
and contractors are informed on a need-to-know basis in accordance with the 3M interface
rules (see below).
4.2.

Priority risks

3M Deutschland GmbH carries out the risk analysis continuously and ad hoc in accordancewith the legal requirements, in particular with regard to appropriate weighting and prioritisation.
This Statement will be reviewed and updated accordingly.
4.3.

Preventive and remedial measures according to SCDDA

3M Deutschland GmbH has preventive and remedial measures in accordance with theSCDDA. These are applied in particular in our own business areas and in relation to our direct
suppliers.
4.4.

Treatment of indirect suppliers according to SCDDA

3M Deutschland GmbH treats indirect suppliers in accordance with the SCDDA. Customers
and contractors are informed on a "need-to-know" basis in accordance with the 3M interface
rules (see below).
4.5.

Complaints procedure in accordance with the SCDDA

3M Deutschland GmbH has a complaints procedure in place in accordance with the SCDDA.
4.6.

3M interface rules

3M Deutschland GmbH will comply with the human rights and environmental expectations
required by the SCDDA and address them appropriately within its supply chain. 3M
Deutschland GmbH will also support the customer in its risk management, risk analysis,
prevention, remedy and complaints procedures in its own business area and in relation to its
direct and indirect suppliers to the extent required (in particular to the extent required by law,
the appropriateness and effort targets).
3M Deutschland GmbH will answer the legitimate questions of the customer as best as
possible; in the process, business secrets of 3M are protected and are not to be disclosed. 3Mshall determine, at its sole discretion, what is a trade secret (this applies in particular tointellectual property, know-how, designs, processes and methods, recipes, contents,materials, calculation components, countries of origin, regions, suppliers, customers, names,addresses, telephone numbers). 3M Deutschland GmbH shall inform the customer about its
own business area and the supply chain of 3M on a need-to-know basis with consideration ofappropriateness and legal obligation. In justified cases, the customer is given the opportunity
to be audited, whereby the subject, intensity, duration and frequency must be agreed with 3M.
According to this stipulation, 3M Deutschland GmbH can also only allow such audits in justified
cases and generally only to third parties who are obliged to neutrality and confidentiality. 3M
Deutschland GmbH decides at its sole discretion which certifications it seeks, maintains andawards.
4.7.

Reporting obligation

3M Deutschland GmbH will continuously document the fulfilment of the stated obligations, inparticular the duty of care according to the SCDDA and report on it in accordance with theSCDDA.
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February, 2023
contact:
3M Deutschland GmbHemail: innovation.de@mmm.com

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