Dow Inc

Dow has put in place governance structures to ensure its policy engagement aligns with its climate strategy, with oversight by a dedicated Carbon Program Oversight Committee and a cross-functional Program Management Office reporting to a Climate Steering Team. As the company explains, "The oversight for action as it relates to reducing our carbon emissions lies with the Carbon Program Oversight Committee (POC), which reports to the CEO," and further notes that "Dow's Vice President of Government Affairs and Chief Sustainability Officer are directly involved in these actions and ensure alignment of government engagement across the entire PMO." Also, Dow discloses that "Dow is actively engaged in constructive advocacy to advance pragmatic policies to enable a successful path to zero," indicating a commitment to climate-related lobbying. However, the company does not disclose a formal framework for reviewing or exiting trade associations whose positions conflict with its climate goals, nor does it make available a dedicated climate-lobbying audit or board-level sign-off process for its advocacy plan. We found no evidence of specific procedures for aligning indirect lobbying activities, and the scope and frequency of monitoring climate-related lobbying beyond ETS participation is not clearly defined.