DOW EUROPE GMBH
Modern Slavery Act Transparency Statement 2019
Introduction
Dow Europe GmbH makes this statement pursuant to section 54(1) of the Modern Slavery Act
2015. It constitutes the slavery and human trafficking statement of Dow Europe GmbH for thefinancial year ending 31 December 2018. This statement delineates the actions Dow EuropeGmbH 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 humantrafficking in its supply chains. Respect for people is one of our core values. Our ultimate
unlisted parent company (The Dow Chemical Company) is signatory to the United Nations
Global Compact and we are committed to combatting slavery and human trafficking in its own
business and supply chains.

Dow Europe GmbH’s Organization
Dow Europe GmbH is a Swiss incorporated subsidiary of Dow Inc. (Dow) through Dow Inc’sownership of The Dow Chemical Company (TDCC), both being U.S. incorporated companies
Dow Europe GmbH has a consignment manufacturing agreement with its UK affiliatedcompany, Dow Chemical Company 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
such as packaging, infrastructure, and consumer care.
During 2018, TDCC was a subsidiary of DowDuPont Inc (NYSE: DWDP), which was a holding
company comprising The Dow Chemical Company and E.I. du Pont de Nemours & Company(DuPont). On 1 April 2019, DowDuPont Inc. completed the previously announced separation ofits materials science business by way of a share distribution of common stock in Dow Inc. Dow
Inc. is now an independent, publicly traded company (NYSE: DOW). As a result of theseparation, 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 eachcategory to deliver 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 Policy•Group Code of Business Conduct•

Group HR and Employment Policies•

Group Procurement Policies including
oSupplier Code of Conduct

oDow’s “Expectations of Suppliers” statement

Dow’s Due Diligence Processes for Slavery and Human TraffickingSuppliers•

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 thecontent and application of the Code is mandatory for each and every employee, and eachemployee 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 Europe GmbH. It will bereviewed, updated and approved annually.

Neil Carr
Chairman of the Managing Directors
Dow Europe GmbH
17 June 2019