exo-is/governance-reporting-on-listed-companies huggingface dataset:
Keyword: governance
Corporate Governance
DOW   |   2023 Progress Report   |   67
DRIVING ACCOUNTABILITY AND BEST-IN-CLASS PERFORMANCE
Engaging With Stakeholders
Dow’s Board members and leaders conduct outreach throughout the year 
to ensure they understand and consider the issues of importance to our 
stakeholders, including shareholders, governments, customers, suppliers and 
employees. 
Dow continually evaluates enhancements to our environmental, social, 
governance and executive compensation practices, and appreciates 
engaging key stakeholders, including our shareholders, in the evaluation of 
these enhancements. In 2023, the following actions were taken: 
•	Maintained our focus on our low-cost-to-serve model and cash flow 
generation by delivering $1 billion of targeted cost
Keyword: governance
Corporate Governance
DOW   |   2023 Progress Report   |   68
DRIVING ACCOUNTABILITY AND BEST-IN-CLASS PERFORMANCE
Enterprise Risk Management Approach and Process
To operate responsibly as a company for the long term, we must balance opportunity and appropriate risk. Enterprise risk management is considered a 
strategic priority within the Company and responsibility for managing risk rests with management, while the Board and its committees provide oversight. 
Dow has a robust enterprise risk management process in place, conducted by our strategic planning and analysis function, to identify, assess and monitor 
risks. Risks are assessed using a broad range of inputs, including external and internal to Dow. The results are reviewed by a diverse, cross-functional
Keyword: governance
Corporate Governance
DOW   |   2023 Progress Report   |   69
DRIVING ACCOUNTABILITY AND BEST-IN-CLASS PERFORMANCE
Supporting Our Company Priorities Through Our 
Compensation Practices
Our pay-for-performance programs and offerings – including base pay, the 
annual Performance Award and long-term incentives – are designed to be fair 
and equitable while rewarding employees for achieving Dow’s most critical 
financial and operational goals as well as those aligned to our Company 
ambition.  
Set by the Board’s Compensation and Leadership Development Committee, 
the objectives of our compensation program are to: 
•	Support the achievement of Dow’s vision and strategy 
•	Motivate and reward executives when they deliver desired business results 
and shareholder val
Keyword: governance
Corporate Governance
1 The Inclusion & Diversity metric is included in the Performance Award targets for approximately 3,000 people leaders and senior leadership, which includes named executive officers.
2	 Non-GAAP measure. For definitions and reconciliation to the most directly comparable U.S. GAAP measure, see page 204 in the Non-GAAP Financial Measures in Reporting & Disclosures.
DOW   |   2023 Progress Report   |   70
DRIVING ACCOUNTABILITY AND BEST-IN-CLASS PERFORMANCE
Ensuring a Culture of Integrity
Integrity is essential for sustainable, long-term business growth and success. We design our ethics and compliance 
programs to create a culture of integrity, where ethical and lawful behavior is supported and rewarded, and people are 
empowered to do what i
Keyword: governance
Our governance structure for ethics and compliance is designed to advance accountability, consistency, transparency 
and integrity everywhere we do business. Our Dow Office of Ethics and Compliance (OEC), Global Ethics and 
Compliance Committee, and four regional Ethics and Compliance Committees help the Company manage risk and 
maintain a positive reputation through: 
Training and awareness. The Code 
of Conduct applies to all Directors, 
officers, and full- and part-time 
employees of Dow. All employees 
and officers are required to complete 
training annually to ensure they 
understand how the code applies to 
their jobs, where to obtain guidance 
for questions and concerns, and how 
to report violations. All Directors, 
officers and employees must ce
Keyword: governance
Corporate Governance
DOW   |   2023 Progress Report   |   71
DRIVING ACCOUNTABILITY AND BEST-IN-CLASS PERFORMANCE
Reporting & Disclosures
GRI Disclosure Report
GRI Disclosure Report - GRI Content Index
Universal Standards
GRI 1: Foundation 2021
GRI 2: General Disclosure 2021
3-3 Management Approach
Transparency & Reporting
Key Impacts
• Following the purpose of the Global Reporting Initiative (GRI), Dow’s sustainability 
reporting objective is to provide transparency on how it contributes to, or aims to 
contribute to, sustainable development. (positive)
• Dow delivers comprehensive, high-quality and consistent environmental, social and 
governance reporting, providing clarity and details about Dow’s material 
sustainability topics for its customers, sharehold
Keyword: governance
Social and Governance (ESG) disclosures referenced or included in the GRI Content 
Index as of, and for the year ended on December 31, 2023, are presented in 
accordance with the 2021 GRI Sustainability Reporting Standards. Additionally, 
management of Dow asserts that the ESG disclosures referenced or included in the 
GHG Protocol disclosure report for the year ended on December 31, 2023, are 
presented in accordance with GHG Protocol: A Corporate Accounting and Reporting 
Standard (Revised Edition), published by the WRI/WBCSD.
The overarching report includes all policies, commitments, actions and their 
effectiveness and stakeholders. Accordingly, please see associated details under each 
relative disclosure. 
___       ---------______________________________
Keyword: governance
Limited assurance has been provided by Deloitte & Touche LLP. The Company’s highest governance body and senior executives are responsible for its assertion. See Independent 
Assurance Statement for additional information.
3-3 Management Approach
Governance & Accountability
Key Impacts
• Dow’s governance practices reflect its commitment to serve all stakeholders, cultivate 
a culture of trust and accountability, and create a business environment that ensures 
the long-term viability and vitality of its business. (positive)
For a full explanation of Dow’s governance and accountability material topics, see 
Corporate Governance on pages 17-32 of the 2024 Proxy Statement↗. Also see the 
Corporate Governance chapter on page 64.
Policies
• Dow Code of Conduct Policy | Public Policy | Dow Corporate↗ see GRI 2-16 
Communications of critical
Keyword: governance
• Dow Corporate Governance Guidelines | Dow Investor Relations↗. The Board 
readopted corporate governance guidelines designed to assist Dow and the Board in 
implementing effective corporate governance practices.
2023 Actions Taken
Board Responsibilities and Management
• Enhanced Director qualifications disclosure with focus on self-identified skills, 
professional experience and diversity of backgrounds. 
• Expanded disclosure of Dow’s enterprise risk management approach and process; 
continued emphasis on Board oversight and responsibility for environmental, social 
and governance performance.
• Improved leadership succession planning disclosure regarding Dow’s assessment 
and development of senior leadership talent and the succession plans of all key 
management
Keyword: governance
For additional 2023 actions to manage governance and accountability, see A Message 
from Dow’s Independent Lead Director on page xii of the 2024 Proxy Statement↗.
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DOW  I  2023 PROGRESS REPORT  I  75
2-6 Activities, value chain and other business relationships
Dow is a global company that operates within the chemical sector and conducts its worldwide operations through six global businesses organized into the following operating 
segments: Packaging & Specialty Plastics, Industrial Intermediates & Infrastructure and Performance Materials & Coatings. 
Dow’s portfolio of plastics, industrial intermediates, coatings and sili
Keyword: governance
2-9 Governance structure and composition
The Board is responsible for broad corporate policy and overall performance of the Company, including the economic, environment and people strategic objectives and performance 
goals of the Company, through oversight of management and stewardship of the Company. The Board has four standing Committees (individually a “Committee” and collectively the 
“Committees”) with well-defined responsibilities for the Company’s impacts on economy, environment and people as stated in the Bylaws and in their respective Committee Charters. 
For additional information, see the Board Committees section starting on page 19 of the 2024 Proxy Statement↗ and the Committee Charters posted on the Company’s website at 
Corporate Governanc
Keyword: governance
The responsibilities of the Board and its Committees are aligned with leadership accountability across environmental, social and governance priorities, which are summarized in the 
Driving Performance with Strong Oversight Responsibilities and Leadership Engagement section of this report, page 67.
The composition of the Board, including independence, tenure, Committee assignments, service on other public company boards, gender, ethnicity and qualifications, is summarized 
on pages 33-48 of the 2024 Proxy Statement↗.
2-10 Nomination and selection of the highest governance body
The Corporate Governance Committee has responsibility for reviewing and recommending Director nominees for membership on the Board. This Committee also recommends 
guidelines to evaluate candidates for Board membership to provide for a diverse and highly qualified Board that reflects a broad range of view
Keyword: governance
The Corporate Governance Committee requires the inclusion of diverse candidates in its initial Director search list based on self-identified factors such as age, race, gender or 
sexual identity, ethnicity, culture and nationality. Minimum qualifications for any Director candidates include strong values and discipline, high ethical standards, a commitment to full 
participation on the Board and its Committees, relevant career experience and a commitment to inclusion and diversity. Candidates should possess individual skills, experience and 
demonstrated abilities that help meet the current needs of the Board, such as experience or expertise in some of the following areas: the specific industries in which the Company 
operates; issues affecting global businesses, s
Keyword: governance
cience and technology; finance and/or economics; corporate governance; public policy; government affairs and prior government 
service; environmental and/or social impact experience; and experience as a chief executive officer, chief operating officer, chief financial officer or other senior leader of a major 
company. Other factors that are considered include: independence of thought; willingness to comply with Director stock ownership guidelines; meeting applicable Director 
independence standards (where independence is desired); and absence of conflicts of interest. The slate of Director nominees submitted for stockholder vote at the Annual Meeting 
of Stockholders and to fill any vacancies on the Board is determined in accordance with the Company’s bylaws.
The Corporate Governance Committee reviews the a
Keyword: governance
Governance Committee assessed best practices regarding retirement age, which led to adoption of a mandatory retirement age of 75 (previously 72) in February 2024.
2-11 Chair of the highest governance body
Currently, the roles of the Board chair and CEO are combined, with Jim Fitterling serving as Chair and CEO and Richard K. Davis serving as the independent Lead Director. Mr. 
Fitterling’s 40-year tenure and multiple roles with the Company and in the industry make him uniquely suited to facilitate the Board’s governance oversight of strategy and safe and 
effective business operations. Mr. Fitterling’s familiarity with and knowledge of Dow’s business are unmatched. Furthermore, he has a long history of leadership in reporting 
transparency and sustai
Keyword: governance
Company’s independent Lead Director, has significant experience in corporate governance and public company management as a current and former Director on other public 
company boards and a former CEO of a large public company.
The Board recognizes that the leadership structure and combination or separation of the CEO and Board chair roles are driven by the needs of the Company. As a result, no policy 
exists requiring combination or separation of leadership roles. This determination is made on an annual basis by the Board, which allows the flexibility to make changes to Board 
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DOW  I  2023 PROGRESS REPORT  I  78
leadership that are in the best interests of th
Keyword: governance
The Board believes that its independence and effective oversight of management is enabled through the Company’s strong corporate governance practices and safeguards currently 
in place, including the election of a separate independent Lead Director with significant responsibilities; the use of executive sessions; the Board’s robust Committee structure with 
each Committee composed of independent Directors and chaired by an independent Lead Director; and annual review of the leadership structure.
For more information, see the Board Leadership Structure section starting on page 18 of the 2024 Proxy Statement↗. 
2-12 Role of the highest governance body in overseeing the management of impacts
The Board is responsible for overseeing the Company’s impacts to the economy, environment and people, including the Company’s mission and values; operational and financial 
performance; susta
Keyword: governance
The Company regularly engages stakeholders and establishes collaborative partnerships to continue progress on Dow’s environmental, social and governance priorities and build a 
clearer understanding of the complex global challenges and local conditions in the countries where the Company does business. Stakeholders include customers, suppliers, current 
and prospective employees, community advisory panels, societal organizations, regulators, shareholders and investors. The Company also brings in diverse perspectives and 
guidance through the Sustainability External Advisory Committee (SEAC) and Science and Technology Advisory Council. This feedback, as well as stockholder support at the last 
annual meeting, is carefully considered when reviewing business, financial, operational, governance and compensation profiles and practices.
2-13 Delegation of responsibility for managing impacts
The B
Keyword: governance
business plans, progress on environmental, social and governance priorities and enterprise risk management.
2-14 Role of the highest governance body in sustainability reporting
The Board and each of its Committees reviewed this report and approved, as applicable, topics in their respective areas of responsibility as set forth in the Committee charters 
(Board Committees | Dow Investor Relations↗). The Dow Inc. Audit Committee, with management, has oversight over the limited assurances provided on the assertion that the 
disclosures in this report are presented in accordance with the applicable reporting frameworks.
For additional information, see GRI 3-3 Management approach – Transparency & Reporting.
2-15 Conflicts of interest
The Board adopted the Code of Conduct (the “Code”), which guides workforce b
Keyword: governance
The Corporate Governance Committee reviews the relationships between the Company, Directors and management at least annually and recommends to the Board whether each 
Director qualifies as “independent” under the applicable rules of the NYSE and the Company’s Corporate Governance Guidelines.
The Company discloses Director independence, other public company board memberships, material supplier/purchaser relationships and related person transactions in relevant 
SEC filings, including the 2024 Proxy Statement↗ and the Company’s Annual Report on Forms 10-K~ and Quarterly Reports on Forms 10-Q~, as appropriate.
For additional information, see GRI 2-26 Mechanisms for seeking advice and raising concerns.
2-16 Communication of critical concerns
Throughout the year and at
Keyword: governance
management’s execution of the corporate and business plans, progress on environmental, social and governance priorities, and enterprise risk management. 
At least quarterly and more frequently as needed, the Dow Inc. Audit Committee and the full Board receive updates regarding critical concerns including but not limited to principal 
risks that may negatively impact the future results of the Company (a detailed discussion of which is included in the section titled Risk Factors in the Company’s Annual Report on 
Form 10-K~ and subsequent Quarterly Reports on Form 10-Q~); the effectiveness of the Company’s ethics and compliance programs; the ethical handling of conflicts of interest and 
reported concerns about potential misconduct; the effectiveness of the Company’s cybersecurity and information security framework; and material incidents relating
Keyword: governance
2-17 Collective knowledge of the highest governance body
All new Directors participate in a robust orientation to become familiarized with the Company’s strategic priorities, corporate and business plans; significant financial, accounting and 
risk management issues; and governance policies and compliance processes, including the Dow Code of Conduct↗ and sustainability initiatives. On an ongoing basis, Directors 
receive materials or briefing sessions regarding the operations of the Company, strategic priorities, and environmental, social and governance matters and risks including sustainable 
development. 
For additional information, see the Director Orientation and Education section on pages 29-30 of the 2024 Proxy Statement↗.
___       ---------___________________________________________
Keyword: governance
2-18 Evaluation of the performance of the highest governance body
As provided in the Corporate Governance Guidelines, Board Committee charters and the NYSE listing standards, the Board and each of its Committees are required to conduct an 
annual self-evaluation of its performance with a particular focus on overall effectiveness and oversight of the economic, environment and people strategic objectives and 
performance goals of the Company.
For additional information on the evaluation process and an example of action taken in response to the evaluations, see the Board and Committee Evaluation Process section on 
page 31 of the 2024 Proxy Statement↗.
2-19 Remuneration policies
A detailed review of Dow’s independent Director remuneration policies can be found in the Director Compensation section start
Keyword: governance
Corporate Governance Committee and is regularly benchmarked utilizing the compensation peer group.
The Compensation and Leadership Development Committee annually reviews and evaluates the compensation program metrics. The Committee reviews the following factors, 
among others:
• Competitive analysis: Median levels of compensation for similar jobs and job levels in the market, taking into account revenue relative to the compensation peer group.
• Company performance: Measured against financial metrics and operational targets approved by the Committee, along with relative Total Shareholder Return (TSR) against the 
relative TSR peer group.
• Market landscape: Business climate, economic conditions and other factors.
• Individual roles and performance: Each execut
Keyword: governance
for the advisory vote on executive compensation, as well as engagement with stakeholders throughout the year, when reviewing the business, corporate governance and executive 
compensation profiles and practices. For example, as a result of stakeholder engagement, the Board made the decision to continue to include quantifiable metrics regarding the 
Company’s ambition in its short-term and long-term incentive awards.
For additional information, see The Compensation Process section on page 78 of the 2024 Proxy Statement↗.
2-21 Annual total compensation ratio
Based upon the calculation of compensation for both the CEO and the median employee, the ratio of CEO pay to median employee pay for 2023 was approximately 220:1. The 
median employee was selected from the Dow population worldwide, excluding the CEO, as of November 30, 2023, using base salary and Performance Award, at target, as the 
consistent
Keyword: governance
governance topics. (positive)  
• New/changing laws can fundamentally impact Dow’s operations or markets in which it does business; therefore, advocacy efforts and policymaking are critical to long-term 
Company success. (positive/negative)
Contribution information is a matter of public record in the United States and is readily available to interested parties through the Federal Election Commission, Internal Revenue 
Service (IRS) and Secretaries of State.
Commitments
• Dow is committed to the highest standard of ethical conduct in its involvement in the political process. 
• All financial contributions strictly adhere to U.S. federal and state laws regarding contribution limits on amount, source, criteria and reporting requirements.  
Policies
•  A
Keyword: governance
• Labor Relations must communicate and manage stakeholders as outlined in regional governance.
• Dow treats employees and employee representation with respect, aligned with its core values within the Code.
Processes for management of employee grievances are outlined in site or local handbook/policy documents. Site or local handbook/policies are available to employees either in 
print, electronically or via both channels. Any violation of the Code can be reported and addressed through the company EthicsLine (see 2-26 Mechanisms for seeking advice and 
raising concerns for more information).
GRI 3: Material topics 2021
3-1 Process to determine material topics
Dow’s determination of material topics involves conducting a comprehensive assessment every two to three years combined with annual reviews to assess the need for any 
updates.
Keyword: governance
In 2022, Dow engaged a large public accounting firm to assist in completing a comprehensive update of its sustainability/environmental, social and governance materiality 
assessment to determine the sustainability priorities of Dow and its stakeholders to inform their sustainability disclosures and strategy. The process was holistic and started by 
assessing the overall landscape using benchmarking across the industry to identify the most relevant topics, which were then assessed by approximately 70 stakeholders 
representing both internal and external viewpoints. Through meaningful stakeholder engagement, Dow prioritized the impacts that it has or can have from two perspectives: 1) The 
impact the material topic has on Dow’s business objectives, goals and strategies, and 2) The external impact of Dow through the topic of people, planet, economy and human rights 
(double materiality view). Exam
Keyword: governance
• Governance & Accountability 
Moderate <----------------------------------------------------------------------------------------------------------------------------------------> Very High
Impact on Dow – Goals, Business Objectives, Strategy
Importance
Very High
High
Moderate
See also the United Nations Sustainable Development Goals (SDGs) to understand how each of the material topics align.
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DOW  I  2023 PROGRESS REPORT  I  92
GRI 200 Economic standards
GRI 204: Procurement Practices 2016
204-1 Proportion of spending on local suppliers
Dow recognizes the importance of supporting local
Keyword: governance
reflects those same principles and can be found here: Corporate Taxation Policy | Dow↗. To understand more about the Company's tax governance, see GRI 207-2 Tax governance, 
control, and risk management.
Dow’s obligations to shareholders, employees and the communities in which it operates are critical to its success and therefore Dow is guided by the following principles:
• Economic Substance: Dow’s customers and market demands determine where it operates and consequently where it pays taxes. Dow undertakes transactions for commercial 
and business purposes only. Dow does not use so-called tax havens, nor does it transfer value to low-tax jurisdictions for tax avoidance purposes. Dow transfer pricing policies 
reflect the economic substance of its global footprint and the activities being performed in each jurisdiction. Dow engages outside consultants to assist with benchmarking to 
determine appropriate int
Keyword: governance
207-2 Tax governance, control, and risk management
Dow’s tax policy, emerging risks and controversy items are reviewed at least annually by the Board of Directors with oversight of the Dow Inc. Audit Committee. 
Through the Corporate Taxation Policy↗, Code of Conduct↗ and Code of Financial Ethics↗, Dow’s control framework establishes high ethical standards for all its employees. 
Employees can raise concerns about the Company's business conduct through the ethics reporting processes described in GRI 2-26 Mechanisms for seeking advice and raising 
concerns. For additional information of Dow’s control framework, see GRI 3-3 Management approach – Ethics & Compliance.
Dow has strong internal controls and procedures that govern its tax processes and lower its risk
Keyword: governance
Dow is driving governance practices to create long-term value for shareholders, 
strengthen accountability and build an agile company that can adapt and respond to 
changing conditions. Resilience crosses many areas of management within Dow, with 
primary operational oversight handled by Dow’s Executive Sustainability Team. The 
Executive Sustainability Team provides both sponsorship as well as acts as a point of 
escalation for Dow's operational and climate resilience activities. There are several key 
teams involved in Dow's risk management to effectively remediate or mitigate climate, 
operational events and security risks. These teams work both proactively and reactively 
across the globe to manage operational and climate challenges.
• The Climate Steering Team
Keyword: governance
• The Sustainability Governance Process Team for Operations (SGPTO) is 
responsible for driving accountability throughout Operations with a focus on 
environmental, health and safety performance, work process, standard and policy
direction and oversight; environmental permit and regulatory; compliance and reviews 
of corporate environmental, health and safety audit results. The team’s scope includes 
all operational facilities and contract manufacturing arrangements. SGPTO also 
manage the Priority Facility process, which uses a data-based analysis to identify 
facilities with higher levels of risk within the Company. Then it formally reviews and 
validates that strong risk mitigation plans are in place.
• The Supply Chain Sustainability Governance Team (SCSGT) is respon
Keyword: governance
very closely with the SGPTO and the Product Sustainability Governance Team in 
support of end-to-end resilience risk management.
• The Product Sustainability Governance Team (PSGT) is responsible for reviewing 
product regulatory and sustainability risks and associated risk management plans. This 
team reviews proposed product stewardship initiatives; provides oversight to Dow’s 
corporate environment, health and safety policies, standards and requirements; 
reviews business risk reviews; reviews results of internal product stewardship audits 
and conducts an annual management system review to determine the effectiveness of 
the processes and team. The team also helps drive collaboration and alignment 
between businesses and functions to effectively manage environment, health and 
safety organization risks r
Keyword: governance
Safer Materials; and Sustainable Procurement. Also see the detailed description of Dow’s Enterprise Risk Management approach within the TCFD Governance section named 
Describe the Board’s oversight of climate-related risks and opportunities.
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DOW  I  2023 PROGRESS REPORT  I  99
3-3 Management Approach
Circular Economy
Key Impacts
• As one of the world's largest materials producers, Dow manufactures products that provide foundational societal benefits; however, many regions have a lack of waste 
management infrastructure to bring back end-of-life products, including plastics, into a circular economy. This can contribute to environmental pollution and leakage into the 
environment. (negative) 
• Moving toward a more circular
Keyword: governance
Governance (ESG) performance and included in Dow’s Code of Conduct for 
Suppliers↗. Refer to GRI 3-3 Sustainable Procurement Management Approach for 
details. 
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DOW  I  2023 PROGRESS REPORT  I  107
2023 Actions Taken
 
Water Conservation
Reduce freshwater intake intensity by 
implementing water conservation projects.
• All high-capital investments are required 
to account for any impacts on water as 
part of the capital approval process. 
• The list of projects to achieve Dow’s 
2025 WLO freshwater intake intensity 
goal is reviewed quarterly by the WLO 
leadership team. For example,
Keyword: governance
governance (ESG) performance and included in Dow’s Code of Conduct for 
Suppliers↗. Refer to GRI 3-3 Sustainable Procurement Management Approach for 
details.  
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DOW  I  2023 PROGRESS REPORT  I  114
Biodiversity
2023 Actions Taken
Strategy Development
Building on the work of Dow’s Valuing Nature Goal, a 
multi-functional internal and external team created Dow’s 
new 2050 Nature Ambition that reflects the need to 
conserve and restore critical habitat, enable equitable 
access to nature and its benefits, and minimize Dow’s 
footprint on nature from raw material supply to product end 
u
Keyword: governance
governance structure internally.
Stakeholders Engaged
• The Nature Conservancy (TNC)
• SEAC
• Internal and external stakeholders
• EHS&T Committee of the Board
Product and Project Screening
Projects are screened to identify opportunities to utilize 
engineered natural technology such as wetlands. 
Additionally:
• Screening across the research and development 
portfolio for product benefits and impacts to nature 
delivered more than 60% of this year’s nature goal 
achievements. 
• Screening takes place across capital projects for 
manufacturing impacts on the ecosystem and evaluation 
positive contributions that can be made with nature-
based solutions. Projects must demonstrate a significant 
improvement in one or more of the following areas, 
withou
Keyword: governance
and suppliers to uphold the highest standards of environmental sustainability, social responsibility and corporate governance. (positive)
• Dow continues to expand its sustainable procurement program through enhanced supplier assessments, sustainability metrics, internal and supplier education, and collaborative 
partnerships with industry groups, influential forums, third-party programs and non-government organization NGOs. (positive) 
• Dow’s ability to influence supplier sustainability performance and drive continuous improvement across the supply chain aligns to Dow’s corporate ambition. Dow’s shared 
responsibility, collaboration and transparency with suppliers supports the achievement of Dow’s business objectives while having a positive environmental and social impact. 
(positive/negative)
Dow’s global footprint extends to over 30,000 suppliers across 92 co
Keyword: governance
ESG and Strategic Planning & Governance teams ensure the inclusion of sustainability throughout all purchasing activities.
Commitments
• Dow is committed to active engagement with suppliers to proactively reduce risks, build capacity and track progress on shared goals, focusing on key topics like climate change, 
water, nature, labor and human rights, and inclusion and diversity.
• Dow is committed to compiling robust data on key environmental and social issues, ensuring accessibility to drive strategic planning and decision-making across Dow. 
• Dow is committed to expanding knowledge of environmental and social sustainability within its procurement team and supplier network via training sessions, direct engagement 
and joint educational programs with industry leaders. 
Policie
Keyword: governance
• Corporate governance: Dow expects its suppliers to conduct their businesses ethically and in compliance with the law. Any potential violations can be reported without fear of 
retaliation through Dow’s Ethics Line.  
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DOW  I  2023 PROGRESS REPORT  I  131
2023 Actions Taken
Supplier Assessments
Routine monitoring of supplier environmental, social and 
governance (ESG) performance enhances Dow’s 
procurement decision-making processes and supplier 
relationship management discussions. 
• Dow conducted a high-level risk screening across its 
supply chain to assess potential ESG risks based on a 
su
Keyword: governance
Dow continues to enhance its assessment of environmental and social issues in its supply chain. In 2023, Dow conducted a screening of environmental, social and governance risks 
for 21,851 of its 30,811 suppliers based on their country, sector, and product or service. Using the risk profiles, as well as factors like spend and Scope 3 greenhouse gas emissions, 
2,463 suppliers (48% of spend) were assessed with Ecovadis and/or CDP in 2023. 
• Dow collected Ecovadis ratings on 2,278 suppliers in collaboration with TfS members, providing a rich data set on supplier performance around environment, ethics, labor and 
human rights, and procurement.
• Suppliers with high emissions relative to Dow’s Scope 3 were requested to disclose detailed greenhouse gas emissions and climate strategy data via CDP. Dow collected 329 
CDP climate disclosures in 2023, along with 19 forest and 16 water CDP disclosures from suppliers
Keyword: governance
Established Governance
Dow continues to utilize the Global Learning Council 
(GLC) as a key enabler for corporate priorities to 
guarantee cross-functional alignment and consistency 
across learning and development efforts.
The Modernizing Workforce Capabilities (MWC) program 
defined a framework with six enterprise competency 
categories and approximately 3,500 skills that align to Dow 
roles. This delivers the foundation and framework for 
Dow’s skill-based culture to be leveraged within the talent 
ecosystem.
Dow continued implementing work process improvements 
on learning content governance, tools and capabilities. 
The Company also initiated a global learning solutions 
model redesign to serve stakeholders through a digital, 
strategic and agile experience
Keyword: governance
tracked through self-assessments, independent internal audits and corporate audit governance process, safety-related behavior-based observations, incident investigations, 
inspections (mechanical integrity) and management system reviews.
403-2 Hazard identification, risk assessment and incident investigation
Processes to assess work-related hazards and assess risks include:
• Initial and routine hazard analyses, which are completed by a team of toxicologists, industrial hygienists and physicians who apply their expertise and knowledge of the scientific 
and medical literature and work processes to monitor trends and regulations in worker health assessment.
• Results of medical surveillance exams, which are reviewed as a source of feedback and continuous improvement. 
• Risk reviews for new or modified Dow products, including quali
Keyword: governance
and supports a more engaged, agile and future-ready workforce. This includes a global governance framework sponsored by the Global Learning Council (GLC), with ongoing 
learning experience efforts creating a more innovative approach to development, and enabled by a global skills framework.  
In 2023, Dow delivered LEAD – a three-day summit covering all people leaders and influential leaders (~3,500) – with topics focused on purpose, performance and people, including 
key priorities and leader expectations. People Leader Essentials and People Leader Foundations programs were provided to upskill more than 330 new leaders at Dow. In addition, 
117 individuals participated in the McKinsey Accelerate Development Program that provides leadership development for underrepresented talent, and 206 leaders graduated from 
executive educational c
Keyword: governance
405-1 Diversity of governance bodies and employees
Percentage of individuals within the organization’s governance bodies by gender, age group and race/ethnicity – Dow’s Board of Directors:
Percent of Directors by Gender
As of June 2024
As of June 2023
As of June 2022
Men
 66.7 %
 66.7 %
 66.7 %
Women
 33.3 %
 33.3 %
 33.3 %
Percent of Directors by Age
< 30
0%
0%
0%
30-50
0%
0%
 8.3 %
50+
 100.0 %
 100.0 %
 91.7 %
Percent of Directors by U.S Ethnic Minority
U.S. Non-Minority
 66.7 %
 66.7 %
 66.7 %
U.S. Ethnic Minority Total
 33.3 %
 33.3 %
 33.3 %
Black or African American
 25.0 %
 25.0 %
 25.0 %
Hispanic or Latino
 8.3 %
 8.3 %
 8.3 %
Number and percentage of employees per employee category by gender, age group and race/ethnicity:
Total Number of Employees by Gender^
Keyword: governance
• Governance: An emerging and growing number of human rights expectations will require enhanced internal coordination across the various businesses, functions and 
geographies. (negative)
Emerging human rights frameworks seek ways to prevent or mitigate adverse human rights impacts that are directly linked to business operations, products or services. As new 
issues emerge, governments are continuing to update specific requirements, including expectations of business to comply with human rights requirements and legislation. As a 
result, each of Dow’s businesses, functions and geographies is impacted by human rights. Human rights are embedded in Dow’s long-term commitment to the United Nations (U.N.) 
Sustainability Development Goals (SDGs) via its mul
Keyword: governance
reflected in its ongoing commitments and actions related to environmental, social and governance (ESG).
The Environmental Justice (EJ) Steering Team acts as the governance structure for issues and opportunities related to EJ. The Social Justice Council monitors inequality matters 
and advises Dow on its response. Most recently, Dow established an ESG Supply Chain Due Diligence Team to implement a comprehensive response aligned with supply chain 
management (including purchasing), business strategy, communications and sustainability reporting to address emerging regulatory requirements. 
Commitments 
• Living the values of Integrity and Respect for People is core to the way Dow conducts business and its commitment to the protection of human rights. Dow’s values and the Dow 
Code of Conduct Policy | Public Policy | Dow Corporate↗ are in
Keyword: governance
Governance Structure 
• Updated Supplier Code of Conduct and associated webpages because of new human 
rights expectations and requirements like the German Supply Chain Due Diligence Act 
and other expected legislation at the European Union level.
• Shared human rights-related expectations with suppliers and other business partners 
to drive a commitment toward implementing the appropriate processes to respect 
human rights and comply with country legislation.
• Defined and implemented a structured risk assessment framework to better analyze, 
document and understand risks to Dow’s business activities and our supply chain 
originating in Germany. The framework will serve as a guidepost for enhancements to 
a global risk assessment framework.
 Stakeho
Keyword: governance
governance processes over outsourced service 
providers, active risk management and benchmarking 
against peers in the industry were undertaken. This 
includes regular assessments by external auditors to 
measure Dow’s NIST CSF maturity level. Dow leverages 
multiple external cybersecurity performance rating 
agencies (e.g., Security Scorecard, BitSight) to validate 
Dow’s security posture and continually ranks in a 
leadership position compared with industry peers.
In 2023, Dow was assessed and awarded the ISO/IEC 
27001:2022 certification for its centralized services which 
enable the protection of Dow’s cyber infrastructure, data 
privacy, protection and assurance of information, and the 
operations that protect and defend information and 
informa
Keyword: governance
Category Governance: Disclose the organization’s governance around climate-related risks and opportunities
Describe the board’s oversight of climate-related risks and opportunities
Enterprise risk management (ERM) is a strategic priority within the Company and responsibility for managing risk rests with management while the Committees and the Board 
provide oversight. The Board oversees, reviews and approves at least annually the enterprise risk management process implemented by management to identify, assess, manage 
and mitigate risk. Each Committee maintains additional responsibility for oversight of specific risk areas relevant to their respective charters.
The Board is also responsible for overseeing the Company’s strategy development and planning process, including annual review of the corpor
Keyword: governance
environmental, social and governance priorities of the Company, such as climate-related risks and opportunities and its path to net zero, ensuring transparency and accountability. 
Each Committee is responsible for oversight of specific strategic and environmental, social and governance areas relevant to their respective charters.
Enterprise Risk Management Process
The enterprise risk management process is a company-wide, cross-functional assessment that identifies, assesses, manages and mitigates risks on an annual basis. The enterprise 
risk management approach and process are conducted by Dow’s strategic planning and business analysis function. This function is structurally independent of business lines. This 
function is led by the senior vice president of Corporate Devel
Keyword: governance
Corporate Governance | Dow Investor Relations↗.
Describe management’s role in assessing and managing climate-related risks and opportunities
To manage the implementation of Dow’s Climate Strategy, Dow has established the Climate Steering Team (CST), which sets strategy and oversees the activities related to 
assessing and managing climate-related risks and opportunities. The CST consists of executive business and functional leaders who report to either the CEO or CFO. The CST is 
facilitated by the global Climate Transition Director. The CST supervises the Carbon Program Management Office (PMO) and the Water & Nature Program Management Office 
(PMO), which are tasked to develop and execute actions aligned with Dow’s Scope 1, 2 and 3 greenhouse gas (GHG) mitiga
Keyword: governance
across various goals, frameworks and governance structures aimed at codifying this impact.
Dow recognizes that there are potential social impacts associated with its climate strategy and transition. Consistent with the Paris Agreement on climate change, Dow is committed 
to ensuring a just transition of the workforce and the creation of decent work and quality jobs as part of this transition. 
Dow believes that its technology transition and innovations will create quality jobs consistent with the recent announcement of Dow’s net-zero greenhouse gas emissions integrated 
ethylene cracker and derivatives site in Alberta, Canada, which will triple the site’s capacity. In alignment with the principles of just transition, Dow references its actions throughout 
this report. The following prin
Keyword: governance
Diversity of governance bodies and employees
GRI 405-2
Ratio of basic salary and remuneration of women to men
Environmental & Climate Justice
Dow recognizes the environmental justice (EJ) movement as an opportunity to ensure the Company is appropriately including its communities in Dow’s progress toward becoming 
the most inclusive materials science company in the world. EJ is already embedded into everything Dow does, from the Company’s sustainability goals to its core values. 
Reference 
Disclosure
GRI 2-12
Role of the highest governance body overseeing the management of impacts
GRI 2-24
Embedding policy commitments
GRI 2-25
Processes to remediate negative impacts
GRI 2-27
Compliance with laws and regulations
GRI 2-29
Approach to stakeholder engagement
GRI 305-
Keyword: governance
For more information, see Enterprise Risk Management Process within the TCFD Governance Describe the board’s oversight of climate-related risks and opportunities section.
For information about Dow’s use of scenario analysis, see TCFD Strategy Describe the resilience of the organization’s strategy, taking into consideration different climate-related 
scenarios, including a 2°C or lower scenario.
Describe the organization’s processes for managing climate-related risks
Management of climate risk is assigned to Dow’s Climate Steering Team (CST), which is accountable for developing and implementing plans to mitigate risk and for tracking actions 
and progress against those plans. With oversight and accountability by the CST, specific carbon-related risks are managed by Dow’s Carbon Program Management Office (PMO). 
Water and natur
Keyword: governance
For additional detail of the teams involved in climate risk management, see TCFD Governance Management’s role in climate risk management.
___       ---------_____________________________________________________________Reporting & Disclosures
__   
    hi DRIVING ACCOUNTABILITY AND BEST-IN-CLASS PERFORMANCE
DOW  I  2023 PROGRESS REPORT  I  184
Category Metrics: Disclose the metrics and targets used to assess and manage relevant climate-related risks and opportunities
Dow employs multiple metrics to monitor its performance and progress toward managing climate and sustainability risks and opportunities. These metrics involve disclosing Scope 1, 
2 and 3 GHG emissions, along with supplementary metrics related to energy intensity, renewable power and energy, freshwater intake intensity and the alignment of Dow’s 
innovation and produc
Keyword: governance
See disclosure GRI 2-12 Role of the highest governance body in overseeing the management of impacts and sections TCFD Category Strategy and TCFD Category Risk 
Management.
Operational Safety, Emergency Preparedness & Response
RT-CH-540a.1. Process Safety Incidents Count (PSIC), Process Safety Total Incident Rate (PSTIR) and Process Safety Incident Severity Rate (PSISR)
Process Safety Containment Tier 1 Events 
Description
2023
2022
2021
Number of Process Safety Incidents
9
11
Process Safety Total Incident Rate
0.016
0.019
Process Safety Incident Severity Rate
0.062
0.018
Process Safety Containment Events (PSCEs) 
As an industry leader in sustainability performance, Dow has been heavily involved in the development of the Process Safety Containment Event (PSCE) metric. The PSCE metric is 
derive
Keyword: governance
Pillar 1 – Governance: Core Metrics & Disclosures
Governing Purpose
Setting purpose
See GRI 2-12 Role of the highest governance body in overseeing the management of impacts and 2-22 Statement of sustainable development strategy.
Quality of Governing Body
Governance body composition
See GRI 2-9 Governance structure and composition and GRI 405-1 Diversity of governance bodies and employees.
Stakeholder Engagement
Material issues impacting stakeholders
See GRI 2-19 Remuneration policies, GRI 2-29 Approach to stakeholder engagement, GRI 3-1 Process to determine material topics 
and GRI 3-2 List of material topics.
Ethical Behavior
Anti-corruption
See GRI 205-2 Communication and training about anti-corruption policies and procedures and GRI 205-3 Confirmed incidents