Dow (“Dow” or the “Company”) is committed to maintaining the highest ethical standards and complying with all applicable sanctions laws and regulations, including those of the United States, European Union, United Kingdom, Switzerland, and Canada. Our Sanctions Compliance Policy applies to all Dow officers, directors, and employees, and may impose broader requirements than the relevant legal standards to mitigate risk. We prohibit engaging in business with sanctioned countries and individuals and emphasize the importance of seeking advice and reporting potential violations. Violations of this policy can result in disciplinary actions, including termination and legal penalties.
Dow’s Compliance and Reporting Process
Our position includes acting to promptly report any conduct inconsistent with the Code, our Values or the law. All reports of misconduct are taken seriously and are treated confidentially, consistent with a full and fair inquiry. In the event an employee or other interested party has any concerns, we have several processes in place to report, investigate, and resolve these matters.
Any reports of inappropriate conduct under Dow’s Sanctions Compliance Policy will be taken seriously, promptly reviewed, and appropriately investigated consistent with the global investigation process and the requirements of any applicable laws, directives, and regulations.
Employees and other interested parties can seek advice and report potential violations by telephone or in writing via the internet. The Dow EthicsLine is a toll-free help line, available 24 hours a day, 7 days a week that is also available in multiple languages. The list of toll-free telephone numbers available by location is available at www.dowethicsline.com. Translation services are available if you prefer to speak in your native language. The communications specialists who answer your call are employed by an independent company and are trained to handle your call confidentially. In some countries, you may call the Dow EthicsLine anonymously if you prefer.
The Dow EthicsLine is also available in multiple languages on the web for individuals who may be more comfortable reporting their concerns in writing. The same confidentiality safeguards that are in place for telephone reporting are also applicable for written reports. Alternatively, you can call the Office of Ethics and Compliance directly at +1-989-636-2544. Emails may be directed to Ethics@Dow.com. Dow employees can also report to a Dow Attorney.