Statement of Principles of the Dow-companies in Germany on the German Supply Chain Due Diligence Act

Dow in Germany

We at Dow are a materials science leader leveraging our deep experience and understanding of chemistry, engineering and physics together to create solutions for the world's toughest challenges. We have six businesses that align our integrated materials portfolio to three attractive market verticals where we have unique competitive advantages: packaging, infrastructure, consumer care and mobility. Dow's scale of $50 billion in annual sales and global reach enables us to achieve our purpose of delivering a sustainable future for the world through our expertise in materials science and in collaboration with our partners.

Germany is one of the most important markets and production locations worldwide for Dow. The first sales office was opened in Frankfurt am Main in April 1960, and today Dow has 13 locations with around 3.500 employees in various legal entities in Germany. Research and development, production facilities, but also sales and administrative functions are located in Germany and contribute to the company's success.

The following statement clarifies the fundamental commitments of German affiliates, in accordance with the SCDDA, to respecting human rights principles, already reflected in other below mentioned Dow corporate policies. In addition, we also expect our suppliers and other business partners to commit to complying with these principles and to implement appropriate processes to respect human rights. This also includes that they provide information on how the principles mentioned are complied with, if requested to do so.

Sustainability, Ethics and Compliance at Dow

Launched in 2015, Dow’s 2025 Sustainability Goals are our third generation of sustainability goals and important drivers of integrating sustainable practices into our day-to-day business practices. Aligned to the United Nations Sustainable Development Goals, our 2025 Goals set the foundation for Dow to take leadership roles in our industry around our priorities of Climate Protection, Circular Economy and Safer Materials.

We believe that ethics and compliance are essential components of sustainable business success and growth. That’s why we strive to maintain a culture of integrity and ground our decision making in our values. Our Code of Conduct guides our behavior and sets expectations for ethical conduct on matters ranging from health and safety in the workplace, to conflicts of interest, bribery, corruption, sustainability and citizenship. The full text of this code as well as our position on human rights and our commitment to responsible sourcing, can be found here.

We comply with applicable national law. In cases where international human rights are restricted by local laws, we strive to promote the principles behind the international standards without conflicting with local laws. Where local laws exceed international standards, we will follow them.

Human Rights

We consider the protection of human rights to be a central element of our corporate responsibility. We are committed to respecting internationally recognized human rights principles, to respecting them in our business activities and along our value chains. This includes, in particular, the prohibition of child and forced labor, the prohibition of all forms of slavery and discrimination, and the strengthening of freedom of association. We are also committed to respecting occupational health and safety, paying decent wages, and prohibiting environmental pollution, forced evictions, and the use of security forces if their use entails a risk of disregarding or restricting human rights.

Dow's Values of Respect for People, Integrity and Protecting the Planet and the Code of Business Conduct for Suppliers are influenced by and reflect the fundamental principles described in the United Nations Universal Declaration of Human Rights. Dow committed in May 2007 to the UN Global Compact and its Ten Principles. Principles 1 and 2 speak directly to Human Rights concerns: that businesses should support and respect the protection of internationally proclaimed human rights; and make sure that they are not complicit in human rights abuses.

Further, we operate in full accordance with the UN Guiding Principles on Businesses and Human Rights. These Guiding Principles provide a framework for governments and companies that are committed to protecting human rights around the world. We respect the sovereignty of governments around the world and the responsibility of governments to protect the human rights of its citizens.

Environmental, Health and Safety

The safety and well-being of our people – whether employees or contractors – is our first and highest priority, and our goal is for everyone to return home unharmed each day. We believe that a safer company is a more reliable company – and a more reliable company will better meet our stakeholders’ needs, including those of our customers and the communities where we operate. To ensure worker safety, Dow uses a comprehensive, integrated operating discipline management system that includes policies, requirements, processes, best practices and procedures that drive implementation and execution of our Environment, Health & Safety (EH&S) standards, Quality and Operations standards, and related external standards. Through this system, we lay the foundational expectations of hazard assessment and risk mitigation aligned to Responsible Care®. We also are strengthening operating discipline by utilizing digital and technology solutions in our manufacturing operations to further increase safety and security. Dow’s programs also include a robust occupational health (OH) system that supports employees at company sites, functions and businesses around the world with information, resources and consultation on health-related opportunities and issues related to work or impacting work, including acute public health situations, such as pandemic response.

Sustainable Procurement

Recognizing that Sustainability in chemical supply chain management is a collaborative topic, Dow expanded its audit program for suppliers associated with potential sustainability risks.

Dow’s Code of Business Conduct for Suppliers stipulates requirements related to social responsibility. The Code is integrated into the ordering process, including requests for proposals, tenders, contracts, purchase orders and supplier relationship management strategies, putting sustainability at the forefront of all purchasing activities.

The Code of Business Conduct for Suppliers also requires suppliers to track and improve their environmental performance, identify key issues and develop strategies for continuous improvement. Suppliers must proactively manage environmental risks and ensure their products and operations meet applicable standards.

Dow expects suppliers to adopt environmentally friendly technologies and systems and participate in collaborations to develop innovative technology. Dow favors suppliers that set targets to achieve carbon neutrality and circularity and publicly disclose their sustainability metrics and goals. Suppliers with additional environmental risks, such as suppliers of bio-based materials, may need to submit additional documentation to Dow.

Implementation of the German Supply Chain Due Diligence Act (SCDDA)

We strive to progressively and regularly analyze, document and better understand our risks and their concrete connection to our company through structured risk assessments in our own business activities, the supply chain and related to our products and services.

We will incorporate the results of our risk analyses into relevant business processes, in particular into our supplier management system. Where risks exist, we implement appropriate preventive measures.

The following measures are part of Dow’s risk management system:

The health and safety of our employees is our top priority. By implementing uniformly high standards at all our sites, we work continuously to create a safe and healthy working environment. Our employees take part in regular training to promote safety-conscious behavior.
As part of our product stewardship program, we continuously review the safety of our products in terms of health and environmental risks.
Dow conducts due diligence on third parties based on risk profile when selecting and evaluating suppliers, commits them on selected/specified sustainability, human rights and environmental criteria and implements appropriate control measures.
Dow has appointed a Human Rights Officer for German legal entities as part of our governance structure.
Dow globally trains all full- and part-time employees on the content of Dow Code of Conduct every year and provides supplemental training for targeted full- and part-time employees on Dow’s policies, including the German Supply Chain Due Diligence Act (SCDDA), according to their job profiles and responsibilities.
Specific Dow Rules of Procedure under Section 8 (2) of the SCDDA have been published on the Dow Germany website.
Potential compliance violations or human rights abuses can be reported through various channels. A confidential help line and website for those who wish to report risks to or violations of SCDDA has been opened. Dow investigates all reported potential misconduct and violations of the SCDDA.
Dow strictly forbids and does not tolerate retaliatory treatment of any kind against a whistleblower who, in good faith, exercises his/her/their right to report potential misconduct, or who makes a complaint or cooperates in an investigation, even if the allegation cannot be substantiated. If a retaliation complaint is substantiated, disciplinary measures will be taken.

In case of SCDDA related risks or violations we will implement effective remedial actions.