Chemical Management Policy and Procedure

This document applies to all 3M operations worldwide. Environmental policy chemical management, Chemical management policy, or Chemical management procedure.

Introduction and Background or Purpose.

A Company team strongly desires to reduce potential environmental and human health risks around chemicals of concern and prepare to move beyond regulatory requirements. We are working to establish programs that reduce or eliminate such chemicals of concern.

During the transition to an Eco-friendly journey, XYZ  Limited recognizes that hazardous chemicals may be used in order to produce quality products unless alternatives are commercially explored and viability is established with the support of our vendors and customers support, we also understand that these must be used with knowledge of the risk they present to human health and the environment. It is expected with the continual growth of available hazard data due to regulations such as REACH / ZDHC that the number of chemicals identified as requiring legislative restrictions will increase. The tracking of such factors within XYZ Limited means that the increase in harmful chemicals can be eliminated and/or managed effectively and maintained at a practicable level.

The hazardous chemicals management policy is driven by four principle ideas that we believe help to ensure that the products we produce or use minimize adverse effects to human health and the environment.

Product substitution and process improvements

Hazard assessment and communication

Supply chain management

Sustainable chemistry with special emphasis on recycles and reuse

Requirements or Expectations

The overall responsibility for compliance with this document is assigned to 3M Sustainability & Product Stewardship organizations.

Chemicals Management Policy

To continually improve the EHS attributes of our products, 3M must identify specific chemicals whose use in products and manufacturing processes will be subject to approval by the Corporate Environmental, Health, and Safety (EHS) Committee or its designee. The list of specific chemicals is maintained by the Corporate EHS Committee or its designee.

Innovation is at the heart of 3M. While recognizing increasing requests from 3M's customers and stakeholders for transparency with respect to ingredient disclosure, nevertheless all information relating to 3M's proprietary manufacturing processes and product formulations must be maintained as 3M Restricted or 3M Confidential according to 3M's Information Classification and Handling Standard.

Additional Elements

➤ This policy replaces existing policies and standards that ban or restrict the use of the following specific chemistries:

➤ Polychlorinated Biphenyls (PCBs) Standard, originally adopted by 3M in 1980 to prohibit the use of and manage the handling of PCBs.

➤ Ozone-Depleting Substances Standard, originally adopted by 3M in 1988 to protect the stratospheric ozone layer.

➤ Asbestos Standard ("Products" section only), originally adopted by 3M in 1990 to establish expectations for the use, management, and disposal of asbestos in 3M products and facilities.

➤ Persistent Chemicals Policy, originally adopted by 3M in 2001 to minimize the likelihood that the manufacture, use, and disposal of 3M products will result in the accumulation of persistent chemicals in increasing levels in living organisms, and to assess and manage the potential for distribution of persistent chemicals in the environment.

For chemistries not specifically identified in the Chemicals Management Policy as REACH / ZDHC or other 3M policies and standards, 3M will continue its practice of selecting lower-hazard materials when possible in alignment with our code of conduct and corporate values.

BANTI SINGH

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