Applicability
This Code of Financial Ethics applies to the principal executive officers, principle financial officers, principal accounting officers or controllers, or persons performing similar functions (each, a “Covered Person”), and has been adopted by the Audit Committee of the Board of Directors of Dow Inc. (the “Company”), which is authorized to amend this Code.
Standards of Conduct
In performing his or her duties, each Covered Person shall:
- exhibit and promote honest and ethical behavior within the Company, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships as described in the Company’s Code of Conduct;
- promote full, fair, accurate, timely and understandable disclosure in reports and documents that the Company files with or submits to the Securities and Exchange Commission and in other public communications made by the Company;
- comply with applicable governmental laws, rules and regulations; and
- report promptly any violation of this Code of Financial Ethics to the Chair of the Audit Committee.
Accountability/Administration
Each Covered Person is expected to adhere to this Code of Financial Ethics. The Chair of the Audit Committee will assess compliance with this Code of Financial Ethics and report any material violations to the Audit Committee. The Audit Committee will consider such reports and shall recommend to the Board of Directors appropriate responsive actions.
Any request for a waiver under this Code of Financial Ethics shall be submitted in writing to the Chair of the Audit Committee who has the authority to grant or deny it. Any amendment to or waiver from this Code of Financial Ethics shall be promptly disclosed on the Company’s website or through a current report filed with the Securities and Exchange Commission.
Adopted April 1, 2019; Reaffirmed June 15, 2023