Dow Inc

Lobbying Transparency and Governance

Sign up to access all our data and the evidence and analysis underlying our overall scores. Once you've created an account, we'll get in touch with further details:

Direct Lobbying Transparency
Overall Assessment Comment Score
Strong Dow Inc provides a relatively detailed picture of its climate-policy advocacy. It identifies several concrete policy files it works on, including the passage of California Senate Bill 54 on plastic pollution, engagement with the European Commission’s End-of-Life Vehicles Directive, and support for finalising the Paris Agreement Rulebook and related global carbon-market provisions. In addition, the company publicly backs instruments such as “an economy wide market-based price on carbon” and “carbon border adjustment mechanisms,” and it publishes a list of its top public-policy priorities, all of which clarifies the scope of its lobbying activity. Dow also describes multiple, specific channels it uses to influence these measures: testimony by its Energy & Climate vice-president before the U.S. Senate Committee on Energy and Natural Resources, coalition and NGO work that “actively participated in the passage of California Senate Bill 54,” discussions with other heavy-industry players and governments “to start a voluntary emissions trading system,” and indirect engagement through bodies such as IETA and the American Chemistry Council. These examples name identifiable targets—the U.S. Senate, the California Legislature and Governor Newsom, and EU regulators—demonstrating clear disclosure of both mechanisms and audiences. Finally, the company sets out the changes it is seeking: completion of the Paris Rulebook to “create global carbon markets,” establishment of a voluntary ETS for hard-to-abate sectors with revenues channelled to low-carbon technology, mandatory climate-risk reporting based on TCFD and the GHG Protocol, and extended-producer-responsibility regimes that fund waste-management infrastructure and set science-based recycling targets. By pairing these specific desired outcomes with its stated mechanisms and policy references, Dow shows a strong level of transparency around its climate-related lobbying activities. 3
Lobbying Governance
Overall Assessment Comment Score
Moderate 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 Dows 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. 2