Dow Authorization Process for U.S. Political Contributions
The Company’s Board of Directors reviews the Company’s involvement in government policy and disclosure on corporate political spending activities periodically, and makes recommendations to ensure the continued application of the Company’s high ethical standards and to maintain best practices for transparency on political spending.
Per the Authority and Responsibilities outlined in the Environment, Health, Safety & Technology (“EHS&T”) Committee Charter, the EHS&T Committee of the Company’s Board of Directors has oversight responsibility for the Company’s public policy and advocacy priorities. At least annually, the Committee reviews all Government Affairs activities, including corporate political spending activities and disclosures as well as compliance with the Company’s authorization process. The Committee approves disclosure of the Company’s political spending activities on www.dow.com.
Such disclosures include Dow Guidelines for U.S. Corporate Political Contributions, a report of U.S. candidates and organizations that receive corporate political contributions, a report of the portion of Dow’s dues or contributions to trade associations and civic organizations that are used for lobbying expenses and political expenditures and Dow’s Political Action Committee (DowPAC) guidelines for political contributions. The disclosures are updated on www.dow.com after EHS&T Committee approval.
All proposed political contributions are reviewed by a Dow Government Affairs work group which makes recommendations to the Vice President of Government Affairs for alignment with our Contributions Focus, and compliance with the Company’s Code of Business Conduct and federal and state law.
The Vice President of Government Affairs is responsible for approval of political contributions and management of the political contributions budget that is approved by the Corporate Vice President, Global Public Affairs and Government Affairs.
The Vice President of Government Affairs elevates political contributions for review and approval by the Corporate Vice President, Global Public Affairs and Government Affairs, and for further review and approval by the Chairman and Chief Executive Officer, and General Counsel, as appropriate.
Last Update: 05/10/2017