Ethics and Compliance at Dow is an organized approach to making sure that ethical considerations are consistently integrated into how we conduct business everywhere. It is also a commitment by our senior management to ensure that employees are treated fairly and consistently, regardless of job level, business, function or geography. The Diamond Standard, Dow's Code of Business Conduct, summarizes many of the ethical principles and company policies. In 2011, Dow will launch a Supplier Code of Conduct that will give greater detail in this critical area of compliance for suppliers. Some general information appears below.

Separating the Source/Sell Relationship

Reciprocity is illegal in several countries. Any activity that involves an agreed-upon reciprocal source/sell relationship will not be tolerated at Dow and is grounds for termination of the contract with the supplier.

Dow Purchasing will always entertain proposals from existing and potential suppliers, including supply proposals by our customers.

Under normal circumstances, a customer will not be offered a supply position where it is not in Dow's best interest from a purchasing perspective.

Conflict of Interest

Dow employees live by the rule that they should avoid any activity, investment, or interest that might reflect unfavorably upon the integrity or good name of the company or of themselves. They are obligated to place Dow's interest in any business transaction ahead of any personal interest or personal gain to either themselves or to their spouse, family member, or other individual.

All Purchasing employees will specifically avoid any conflict of interest by discouraging suppliers from offering gifts and invitations to entertainment events.

A conflict of interest may also arise when an employee or family member has a direct or indirect personal or financial interest in any Dow supplier, partner, competitor, or customer, where such interest could influence Dow's dealings with such supplier, partner, competitor, or customer.

Questions or Concerns?

The Dow EthicsLine is a toll-free help line, available 24 hours a day, 7 days a week. The help line is available to those who wish to ask questions about Dow policy, seek guidance on specific situations, report violations of Dow's Code of Business Conduct or Supplier Code of Conduct, or other unethical business practices.