At Dow, we believe that respect for the dignity, rights and aspirations of all people is a cornerstone of business excellence. This position extends to every Dow employee and to all people who work at any of Dow's facilities around the world. We also expect our business partners to commit to similar values and standards. This position is integral to Dow’s Values of Integrity, Respect for People and Protecting Our Planet, and Dow's Code of Conduct (“Code”), which guides behavior and set expectations for ethical conduct.
Global compliance with the Code is fundamental to our human rights position. The Code, approved by Dow’s Board of Directors, has been translated into 16 languages and describes our position on matters ranging from health and safety in the workplace, to conflicts of interest, bribery, corruption, sustainability and citizenship. All employees are required to complete annual training to ensure they understand how the Code applies to their jobs, where to obtain guidance for questions and concerns, and how to report violations.
Living the Values of Integrity and Respect for People is core to the way we do business and our commitment to the protection of human rights.
Dow lives its commitment to the protection of human rights globally in many ways:
Suppliers and Service Providers
We intentionally choose to do business with suppliers and service providers who share Dow’s Values and sense of global responsibility. All of our suppliers (new and existing) are expected to comply with our Code of Business Conduct for Suppliers, which specifies our standards around business and labor practices. We expect that all of Dow’s suppliers and service providers are compliant with the Code and all other applicable laws and regulations. We have a detailed work process to identify and manage sustainability risks across the supply chain and employ a distribution risk review process and trade compliance program to mitigate risks for Dow distributors.
We have an established process for due diligence and implementation phases of mergers, acquisitions and joint venture formations, which includes a review of human rights, environmental and labor risks prior to the completion of an acquisition or the formation of a new business venture.
Participation in Global Initiatives
Dow's Values and the Code are influenced by and reflect the fundamental principles described in the United Nations Universal Declaration of Human Rights. Dow committed in May 2007 to the UN Global Compact and its Ten Principles. Principles 1 and 2 speak directly to Human Rights concerns: that businesses should support and respect the protection of internationally proclaimed human rights; and make sure that they are not complicit in human rights abuses. Dow conveys our Communication on Progress for the UN Global Compact’s Ten Principles in our annual Environment, Social, and Governance (ESG) Report.
Further, we operate in full accordance with the UN Guiding Principles on Businesses and Human Rights. These Guiding Principles provide a framework for governments and companies that are committed to protecting human rights around the world. We respect the sovereignty of governments around the world and the responsibility of governments to protect the human rights of its citizens. Dow also has a significant role to play by ensuring compliance to local laws, regulations and customs in all aspects of its business operations.
Our position on human rights includes taking action 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 concerns regarding human rights conditions, we have several processes in place to report, investigate and resolve these matters.
Immediate response plans are in place to identify and respond to alleged abuse or violence against any individual at any Dow facility. Dow employs several hundred employees and contractors in its Emergency Services and Security department worldwide who fully comply with the Company’s training requirements, policies and procedures concerning human rights. This training is a condition of employment and is conducted on a regular basis.
Dow’s Regional Ethics and Compliance Committees (RECCs) are strategically situated to assist in the reporting, investigation and resolution of human rights violations. The RECCs operate regionally in all geographic areas where Dow conducts business and are comprised of the country or regional leader, along with senior finance, human resources and legal personnel. Each RECC is responsible for administration of the Code, with ultimate oversight from Dow’s General Counsel and the Audit Committee of the Board of Directors.
Employees and other interested parties are able to 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. The list of toll-free telephone numbers available by location is available at www.dowethicsline.com. Alternatively, individuals can contact the Office of Ethics and Compliance directly at firstname.lastname@example.org or +1-989-636-2544.
The Dow EthicsLine is also available in multiple languages at http://www.dowethicsline.com/for individuals who may be more comfortable reporting their concerns in writing. The same confidentiality safeguards that are in place for telephone reporting are in place for this option as well. Emails may be directed to email@example.com.