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. It constitutes the slavery and human trafficking statement of Dow Europe GmbH for thefinancial year ending 31 December 2020. This statement delineates the actions Dow Europe GmbHhas taken during the period to identify potential modern slavery risks in its business operations andthe steps implemented which are aimed at ensuring there is no slavery or human trafficking 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 arecommitted 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 indirect subsidiary of The Dow Chemical Company(TDCC) and TDCC is a direct wholly owned subsidiary of Dow Inc. (“Dow”) . Both TDCC andDow are US incorporated companies. Dow Europe GmbH has a consignment manufacturingagreement with its UK affiliated company, 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 suchas packaging, infrastructure, and consumer care.
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 Dow Inc. group Policies andcodes:

Human Rights Policy
Dow Inc. Code of Business Conduct (Code)HR and Employment Policies
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 the SCC, 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 with
the SCC. Suppliers who are not in compliance with the SCC 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 the Code including our Human Rights Policy and the SCC
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 Code. 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 and application of the Code is
mandatory for each and every employee, and each employee must periodically acknowledge thatthey 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 be
reviewed, updated and approved annually.

Neil Carr
Chairman of the Managing Directors
Dow Europe GmbH
June 21, 2021
Form No. 066-00363-01-0621 DOW