REPORTING & DISCLOSURE TRACKING OUR PROGRESS DOW | REPORTING & DISCLOSURE | 95 Dow Disclosures – GRI Content Index 102-16 Values, principles, standards and norms of behavior See Code of Conduct (Page 39) in the 2022 Proxy Statement filed with the SEC on March 4, 2022. Dow Code of Conduct – Dow Code of Conduct Policy | Public Policy | Dow Corporate Accountability and transparency are core components of Dow’s overall ethics and compliance program. The Office of Ethics and Compliance (OEC) regularly monitors Dow’s compliance programs and uses these statistics to assess and continuously improve its processes and programs. In addition, the OEC regularly reviews its own performance on matters such as substantiation rates, cycle times, trainings and certifications and employee engagement and trust. The OEC holds itself to high standards of responsiveness and adherence to compliance policies. Relevant statistics are disclosed on a quarterly basis to the Global and Regional Ethics and Compliance Committees and the Audit Committee of Dow’s Board. 102-17 Mechanisms for advice and concerns about ethics Our employees are expected to behave in a way that protects our business interests, our reputation and each other. This includes taking action to promptly report any conduct inconsistent with our Code of Conduct, our values or the law. The OEC is responsible for communicating to all stakeholders the mechanisms in place to seek advice and report potential misconduct. Employees and other interested parties who have a question or desire to make a report regarding any ethics and compliance matters can use the following confidential options: • EthicsLine (third party-managed service) – a safe, reliable and convenient method to report ethical concerns (by calling or via online form). It is available globally, with multilingual capabilities, 24 hours a day, seven days a week. • Make a report via telephone. • Make a report via online submission. • Make a report of a concern to their supervisors or other leaders, Dow attorneys, human resources personnel, Global or Regional Ethics & Compliance Committee members or directly to the OEC. We respect and protect any reporter and whistleblower who raises concerns about potential misconduct, and we do not tolerate retaliation against anyone who reports a potential violation in good faith. Reports about alleged violations of the Code or the law are provided at least quarterly to the Audit Committee of the Dow Board. To summarize 2021: • 395 matters were reported to the OEC, of which 316 warranted an investigation. • 344 matters were closed (31% substantiated; 14% unsubstantiated but other issues were uncovered, and 55% unsubstantiated or not related to policy violations). Types of issues: Conflicts of interest, Environmental Health & Safety, Human Resources, Misuse of Assets and Others. All issues that require corrective action are appropriately addressed.
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