DOW CHEMICAL COMPANY LIMITED
Modern Slavery Act Transparency Statement
Introduction:
Dow Chemical Company Limited makes this statement pursuant to section 54(1) of the Modern Slavery 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 2023. This statement 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 isno slavery or human trafficking in its supply chains. Respect for people is one of our core values. Our parent company (The Dow
Chemical Company) is signatory to the United Nations Global Compact and we are committed to combatting slavery and humantrafficking 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) through Dow Inc.’s ownership of The
Dow Chemical Company (TDCC), both being U.S incorporated companies. Dow Chemical Company Limited is the parentcompany 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 of advanced materials, industrial
intermediates, and plastics businesses deliver a broad range of differentiated technology-based products and solutions forcustomers in high-growth markets such as 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 majority managed byPurchasing 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 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 ourbusiness is embodied in the following Dow Inc. group policies and codes:•••••

Human Rights Policy
Dow Inc. Code of Conduct (Code)
Conflict Minerals Policy
HR and Employment Policies
Procurement Policies includingo Dow Code of Business Conduct for Suppliers (“SCC”)
o Dow’s “Expectations of Suppliers” statement

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

Our Code of Business Conduct for Suppliers 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 with applicable laws and theprinciples 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 and services toDow. Dow reserves the right to assess and monitor suppliers' compliance with the SCC. Suppliers who are not incompliance 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 make evaluations whether to requirecompliance certifications, self-assessments and/or compliance audits.
Third parties acting on Dow’s behalf are subject to periodic intensive assessments to monitor further their compliancewith the SCC.
Dow has a robust global risk-based due diligence process established to conduct due diligence on third parties based onrisk-profile. All employees serving as relationship managers to third parties intermediaries are required to fully andtimely comply with this due diligence process, which is a mandatory process and must be completed prior toestablishing or renewing business arrangements. The results are used by Dow to determine the next steps, frommitigation plans up to the non-start or non-continuity of the business relationship.
We have a helpline (phone and web-based available in multiple languages) which is available to employees and thirdparties which can be used to seek guidance on specific situations, report violations of the Code including our HumanRights Policy and the SCC or other unethical business practices. Calls may be made anonymously in most countriesand reporters are protected from retaliation.
The outcomes of our programmes are generally communicated via our annual Environmental, Social and Governance(ESG) Report.

Employees
The principles of human rights are woven throughout the Code. All employees of Dow and its subsidiaries, including those withdirect responsibility for supply chain management, are expected to know and abide by this Code. Annual training on the contentand application of the Code is mandatory for each and every employee, and each employee must also periodically acknowledge
that they have read and agree to comply with the Code. Dow takes seriously and fully investigates all potential legal or Codeviolations, in a respectful, confidential and fair manner and takes action consistent with the severity of the violation.

This statement has been approved by the Directors of Dow Chemical Company Limited. It will be reviewed, updated andapproved annually.

John Case
Chairman of the Board
Dow Chemical Company Limited 24th June 2024

Form No. 903-359-01-0624 DOW