DOW CHEMICAL COMPANY LIMITED
Modern Slavery Act Transparency Statement
Introduction:Dow Chemical Company Limited makes this statement pursuant to section 54(1) of the ModernSlavery Act 2015. It constitutes the slavery and human trafficking statement of Dow Chemical
Company Limited and its UK subsidiaries for the financial year ending 31 December 2018. Thisstatement delineates the actions Dow Chemical Company Limited has taken during the period toidentify potential modern slavery risks in its business operations and the steps implemented which
are aimed at ensuring there is no slavery or human trafficking in its supply chains. Respect forpeople is one of our core values. Our ultimate unlisted parent company (The Dow ChemicalCompany) is signatory to the United Nations Global Compact and we are committed to combatting
slavery and human trafficking in our own business and supply chains.
Dow Chemical Company Limited’s Organization:.
Dow Chemical Company Limited is a UK incorporated subsidiary of Dow Inc. (Dow) throughDow Inc.’s ownership of The Dow Chemical Company (TDCC), both being U.S incorporated
companies Dow Chemical Company Limited is the parent company of UK subsidiaries - Dow
Chemical Services UK Limited and Dow Services Trustees UK Limited.
Dow is a global leader in the chemical industry. Its market-driven, industry-leading portfolio ofadvanced materials, industrial intermediates, and plastics businesses deliver a broad range ofdifferentiated technology-based products and solutions for customers in high-growth markets suchas packaging, infrastructure, and consumer care. During 2018, Dow was a subsidiary of
DowDuPont Inc (NYSE: DWDP), a holding company comprising The Dow Chemical Companyand E.I. du Pont de Nemours & Company (DuPont). On 1 April 2019, DowDuPont Inc. completed
the previously announced separation of its materials science business by way of a share distributionof common stock in Dow Inc. Dow Inc. is now an independent, publicly traded company (NYSE:DOW). As a result of the separation, Dow Inc. became the direct parent company of The Dow
Chemical Company (TDCC).
Dow’s Supply Chains
Dow’s supply chain consists of more than 10,000 active suppliers around the world. This supply
chain is managed by our Group Procurement which operates as a single global function, structured
across all Business Lines. We develop and implement best-fit strategies for each category todeliver maximum value from the supply base in the areas of cost and risk management,sustainability, innovation, and growth.

Dow’s Relevant Policies:
Our commitment to ensuring that there is no modern slavery or human trafficking in our supply
chains or in any part of our business is embodied in the following Group Policies and Codes:••••

Group Human Rights PolicyGroup Code of Business Conduct
Group HR and Employment Policies
Group Procurement Policies includingo Supplier Code of Conducto Dow’s “Expectations of Suppliers” statement

Dow’s Due Diligence Processes for Slavery and Human Trafficking
Suppliers•••••

Our Supplier Code of Conduct (SCC) and “Expectations of Suppliers” statement
specifically address this aspect. The SCC is communicated to all current and new direct
suppliers and the majority of our purchase orders and contract templates have been updated
to include compliance as a contractual requirement.
Dow expects suppliers to implement systems and controls to promote compliance withapplicable laws and the principles set forth in this Code, including policies, training,monitoring and auditing mechanisms. Suppliers also should apply these or similar
principles to the subcontractors and suppliers they work with in providing goods andservices to Dow. Dow reserves the right to assess and monitor suppliers' compliance withthis Code. Suppliers who are not in compliance with this Code are expected to implement
corrective actions or may not be considered for future business.
We audit significant direct suppliers according to our business requirements. We havebegun to evaluate whether to require compliance certifications, self-assessments and/orcompliance audits
We have a helpline (phone and web-based available in multiple languages) which isavailable to employees and third parties which can be used to seek guidance on specificsituations, report violations of Dow's Code of Business Conduct including our HumanRights Policy and Supplier Code of Conduct or other unethical business practices. Calls
may be made anonymously in most countries and callers are protected from retaliation.
The outcomes of our programmes are generally communicated via our annual sustainability
report.

Employees
The principles of human rights are woven throughout our employee Code of Conduct. All
employees of Dow and its subsidiaries, including those with direct responsibility for supply chain
management, are expected to know and abide by this Code. Rigorous training on the content andapplication of the Code is mandatory for each and every employee, and each employee must

periodically acknowledge that they have read and agree to comply with the Code. Dow takes
seriously and fully investigates all potential legal or Code violations, in a respectful, confidential
and fair manner and takes action consistent with the severity of the violation.
This statement has been approved by the Managing Directors of Dow Chemical Company
Limited. It will be reviewed, updated and approved annually.

John Case
Chairman of the Board
Dow Chemical Company Limited
11 June 2019