DOW EUROPE GMBH
Modern Slavery Act Transparency Statement
Introduction
Dow Europe GmbH makes this statement pursuant to section 54(1) of the Modern Slavery Act 2015. Itconstitutes the slavery and human trafficking statement of Dow Europe GmbH for the financial year
ending 31 December 2016. This statement delineates the actions Dow Europe GmbH has taken during
the period to identify 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 parent company (The Dow Chemical Company) issignatory to the United Nations Global Compact and we are committed to combatting slavery andhuman trafficking in its own business and supply chains.
Dow Europe GmbH’s Organization
Dow Europe GmbH is a Swiss incorporated subsidiary of The Dow Chemical Company, a U.S.
incorporated company (Dow) and has a consignment manufacturing agreement with its UK affiliatedcompany, Dow Chemical Company Limited. Dow is a leader in specialty chemicals, driving innovations
that extract value from material, polymer, chemical and biological science and supplying a variety ofdiverse applications including Agriculture, Automotive, Construction, Electronics, Energy,Infrastructure, Packaging and Product Safety. Dow has in excess of 6,000 product families which aremanufactured at 179 sites in 35 countries across the globe. On June 1, 2016, Dow became the 100
percent owner of Dow Corning Corporation’s silicones business, a global company with 25
manufacturing sites in 9 countries. The whole group comprises more than 49,000 employees worldwide.
Dow’s Supply Chains
Dow’s supply chain consists of more than 10,000 active suppliers around the world and more than
48,000 within the wider Dow Group. 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 to deliver maximum value from the supply base in the areas of costand 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 TraffickingSuppliers•••••

Our Supplier Code of Conduct and “Expectations of Suppliers” statement specifically address
this aspect. The SCC is communicated to all current and new direct suppliers and the majority ofour purchase orders and contract templates have been updated to include compliance as acontractual 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 thesubcontractors and suppliers they work with in providing goods and services to Dow. Dow
reserves the right to assess and monitor suppliers' compliance with this 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 have begun toevaluate whether to require compliance certifications, self-assessments and/or compliance audits.
We have a helpline (phone and web-based available in multiple languages) which is available toemployees and third parties which can be used to seek guidance on specific situations, reportviolations of Dow's Code of Business Conduct including our Human Rights Policy and Supplier
Code of Conduct or other unethical business practices. Calls may be made anonymously in mostcountries 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 ofDow and its subsidiaries, including those with direct responsibility for supply chain management, areexpected to know and abide by this Code. Rigorous training on the content and application of the Codeis 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 withthe severity of the violation.
This statement has been approved by the Managing Directors of Dow Europe GmbH. It will be
reviewed, updated and approved annually.

Heinz Haller
Chairman of the Managing Directors
Dow Europe GmbH
21 June 2017