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Important Notice

Use of EthicsPoint

Use of this EthicsPoint reporting tool is entirely voluntary. You are encouraged to identify yourself when reporting a concern; however, anonymous reporting is also available. Be advised that under 3M's Employee Obligations and Reporting Principle, 3M prohibits retaliation against anyone who raises a business conduct concern in good faith or cooperates in a company investigation. The company will not permit any sanction against you for raising a good-faith concern regardless of whether the underlying facts prove to be correct or result in any disciplinary action.

In addition to EthicsPoint, you may also report to your management, your assigned legal counsel, or the Compliance and Business Conduct Department.

3M Compliance and Business Conduct Department
3M Center, 220-11-W-09
3M Company
Saint Paul, MN 55144-1000

If you are raising a concern under the Respectful Workplace Principle, you also can go to your local Human Resources Manager or someone higher in the 3M Human Resources organization.

If you are raising a concern regarding accounting, financial reporting, internal accounting controls or auditing matters, you may also report to:

General Auditor
3M Corporate Auditing Department
224-06-N-11, 3M Center Saint Paul, MN 55144-1000

Due to the local laws of your country, you may make a report using this EthicsPoint system concerning only serious acts or crimes related to:

• Financial Issues – including falsification of a financial document or report, making false financial claims, inaccurate financial disclosures, insider trading, or questionable practices relating to internal financial controls;
• Auditing and Accounting – including accounting, auditing or internal financial controls such as tax evasion, misstatement of revenues, expenses, assets, or wrongful transactions;
• Banking – including unethical or questionable banking practices such as money laundering, bank fraud, embezzlement, fabricating, falsifying or forging any banking documents or records;
• Anti-Bribery – including influencing the official or political action of another by corrupt inducements, giving items that could be interpreted as an effort to improperly influence a business relationship or decision.

What Happens to Your Report when you submit it through EthicsPoint

Once you submit your report through EthicsPoint, EthicsPoint will notify 3M. Your report will be reviewed by a 3M Compliance and Business Conduct employee in the United States to ensure that the nature and content of your report may be processed through this EthicsPoint System based on applicable law.

If your report is one that cannot legally be processed through EthicsPoint, you will be contacted and informed of other methods for addressing your concern and your report will be deleted from this system to the extent required by applicable law.

If applicable law allows, your EthicsPoint report will be processed through this EthicsPoint system and will be forwarded to a 3M Compliance and Business Conduct employee in the United States. 3M will, if appropriate, conduct an investigation.

You are able to monitor progress on your report by contacting the 3M Business Conduct Helpline or by clicking the Follow Up on Report link on the EthicsPoint website.

Confidential Handling of Your Report

Information you submit will be treated confidentially by those handling your report and those administering this system.

All the information you submit will be stored on the EthicsPoint database hosted by EthicsPoint in the United States. EthicsPoint follows the Safe Harbor Principles for data protection, which establishes a legal standard of data protection equivalent to the European Union. In addition, 3M's agreement with EthicsPoint requires EthicsPoint to adequately secure your information and use it only for authorized purposes.

Unless required by law or litigation, the information in the database will only be reviewed and used by those individuals who need to know the information in order to investigate your report, manage the investigation results, and administer the system. These individuals may include 3M employees in Compliance and Business Conduct, Legal Affairs, Human Resources, IT Security and Integrity, Corporate Security, Corporate Auditing or other management functions, as well as trusted service providers under agreement with 3M. These individuals may be located in the United States or other locations as needed to review and investigate your report.

Under EU data protection laws, all individuals whose personal information is processed through this system have a right to request access to that information. They also have the right to have this information corrected if the information is inaccurate.

Content of Your Report

Please be aware that the information you supply about yourself, your colleagues, or any aspect of 3M's operations may result in decisions that affect others. We ask you to provide only information that, to the best of your knowledge, is correct. You will not be sanctioned for submitting information in good faith, even if it turns out to be inaccurate. However, if you knowingly provide false or misleading information, it may result in disciplinary action.

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