Dow’s Position on Human Rights

The Dow Chemical Company believes 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 The Diamond Standard, Dow's Code of Business Conduct (“Code”), which guide 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 24 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 training to assure 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 recognizes and respects applicable labor and employment laws — including those addressing freedom of association, privacy and equal employment opportunity — wherever we operate. We believe that working positively and directly with employees best serves their interests. In addition, we strive to work cooperatively with duly chosen employee representatives in the common pursuit of the interests of the employees and the Company’s mission.
  • Dow adheres to the United Nations (UN) Global Compact principles.
  • Dow endeavors to positively impact the reduction of unlawful labor and child exploitation through compliance with child labor laws. Dow understands that children may legitimately perform tasks which do not interfere with their education, do not negatively affect their health, safety, and development, and are in compliance with applicable local, state, national, provincial, and international laws and regulations.
  • Dow holds our business partners through Dow’s Supplier Code of Conduct and active engagement.
  • Because respect for people and care for our communities are part of Dow’s culture, we abide by and respect the property and resource rights held by others.

Dow’s Global Commitment

Dow lives its commitment to the protection of human rights globally in many ways:

  • Business Partners

We intentionally choose to do business with partners 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 business partners 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 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 risks prior to the completion of an acquisition or the formation of a new business venture.

  • Employee Programs

Dow has specific sourcing relationships with organizations that specialize in recruiting people with disabilities including the National Technical Institute for the Deaf (NTID), and DiversAbility, LLC. Dow’s Disability Employee Network (DEN) focuses on improving perceptions about people with disabilities and raising awareness about the contributions they make — both at work and outside of work. In addition, DEN fosters the professional and personal success of people with disabilities through a variety of training resources, aimed at people with disabilities and leaders managing people with disabilities.

  • 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 Sustainability 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.

  • Recognition

In 2016, Dow was awarded a Gold Recognition Level in sustainability and corporate social responsibility (CSR) in a performance assessment conducted by EcoVadis. EcoVadis is a collaborative platform enabling companies to monitor the sustainable performance of their suppliers. This marks Dow’s second year in a row to have achieved this recognition. Dow ranks in the top 2% of suppliers assessed by EcoVadis.

Dow’s Compliance and Reporting Process

Our position on human rights includes taking action to promptly report any conduct inconsistent with the Code, our Values or the law — even if the facts of the situation are not entirely clear. All reports of misconduct are taken seriously and will be 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 ethics@dow.com or +1-989-636-2544.

The Dow EthicsLine is also available in multiple languages on the web at 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 ethics@dow.com.