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relationships by developing differentiated, practical and ingenious solutions to their sustainability challenges.
▪ Environmental Protection: Provide practical and effective solutions and products to address environmental challenges for ourselves and our customers.
▪ Social Responsibility: Engage key stakeholders in dialogue and take action to improve 3M's sustainability performance.
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2010 Dodd-Frank Financial Reform Act*
▪ Trade in Tin, Tantalum, Tungsten and Gold financing extreme violence in African Congo region
▪ Publicly held companies (“issuers”) must disclose conflict mineral sources in annual financial reports
▪ Under proposed Securities & Exchange Commission regulations:
● Use of these minerals far upstream in manufacturing may be in scope, e.g., catalysts
● Even non-publicly held companies who are suppliers may need to provide such information to issuers, e.g., trace back to smelter or even mine
*H.R. 4173 §1502*H.R. 4173 §1502
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Suppliers a key stakeholder
▪ As part of our Sourcing Sustainability Standard, expectations are set for suppliers through 3M’s Supply Chain Policies: EHS, Transportation, Labor/Human Resources and Supplied Materials.
● Selection and retention of suppliers worldwide● Selective review of supplier performance to these policies● Corrective action process● Business relationship termination if warranted
▪ Conflict Minerals Policy added June 2011
Working with SuppliersWorking with Suppliers
New Goal: Review at least 80% of Supplier Spend in certain countries to Drive Conformance with 3M’s Standard by 2015
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Supplier inquiries▪ Driven by regulations, customer demands and internal
goals▪ Corporate template “information forms” for businesses to
query new/existing suppliers for EHS information● 100% composition● Presence/use of specific chemicals, e.g., regulated lists● Regulatory classifications, compliance statements…
▪ Challenges● Non-electronic● Incompletely filled out forms or no response● Management of change● Data freshness● Multiple businesses contacting same supplier● Non-product EHS topics, e.g., conflict minerals, Lacey Act
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“Campaign” approach for conflict minerals
▪ Conflict minerals requires auditable due diligence and reporting
▪ Initiating supplier contact at a Corporate Sourcing level using 3M's “Single Face”
▪ Developing single electronic solution for supplier contact, follow-up and data collection
● Allows for one way and two way communication● Better integration into Sourcing Supplier Escalation Process
▪ Interface planned to ultimate system of record for purchased material and product conflict mineral status, smelter name, etc.
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The customer side
▪ Major customers (if issuers) have their own conflict minerals SEC reporting obligations
▪ Different industries may demand suppliers to provide status information on their prescribed form
● Caution with exact language – what liabilities are incurred?● Can raw data be downloaded into these different formats?
▪ 3M’s businesses have taken self-service approaches for customer EHS communication on 3M.com