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In July 2003, Dow updated its Code of Business Conduct (the "Code"). It was adopted by the Board of Directors, translated into 14 languages and published on the Internet. The Code not only explains Dow’s policies on complying with the law and what we expect of our employees, officers, and directors, but also now includes question-and-answer sections that use everyday scenarios to help further clarify the intent of the policies.

Dow’s Office of Global Ethics and Compliance and regional and subsidiary Ethics and Compliance Committees oversee the implementation of the Company’s ethics and compliance program. In 2003, Dow expanded its ethics training effort to ensure all employees globally understand their obligations under the Code. The training is available in 14 languages and will continue through 2004 until all employees have been trained.

Dow continues to encourage employees and others to report suspected violations of the Code and, in 2003, Dow enhanced and standardized its global internal process for reviewing and investigating such reports.

To make a report, employees or others can contact the Office of Global Ethics and Compliance or call the Dow EthicsLine, a globally accessible toll-free help line available 24 hours a day, seven days a week. The Dow EthicsLine is operated by an independent company and staffed by trained communications specialists whose only interest is listening to and reporting questions or concerns. Callers may contact the Dow EthicsLine, anonymously if they prefer, to ask questions and receive information, to seek guidance on a particular situation, or to report suspected violations of law or the Code.

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