Dow Inc

## Government Relations

3-3 Management approach

**Key Impacts**

- The political process significantly impacts Dow through government policies, legislation and judicial and regulatory
decisions. (positive/negative)

- Dow actively participates in the political process through legally authorized advocacy, grassroots efforts and
financial contributions which can inform environmental, social and 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)

Dow is committed to the highest standard of ethical conduct in its involvement in the political process. All financial
contributions strictly adhere to federal and state laws regarding contribution limits on amount, source, criteria and
reporting requirements. 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.

Dow receives information from trade and business associations as well as civic leagues and social welfare
organizations in the United States regarding the portion of its dues or contributions that are used for lobbying
expenses and political expenditures. Dow includes this information in the aggregate in its quarterly lobbying activity
reports filed with the U.S. Congress, as required by the Lobbying Disclosure Act (LDA), which can be viewed under the
link named "Dow's LDA filings" within the Trade Associations policy linked below.

**Policies**

- Dow provides lists of candidates who receive corporate political contributions for the previous five years online at:

[Corporate Political Contributions | U.S. Public Policy | Dow Corporate.](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/contribution-recipients)

- Dow provides a list of trade association memberships and discloses expenses above $25,000 per year, for the
[previous five years, at: Trade Associations | U.S. Public Policy | Dow Corporate.](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/trade-and-civic-associations)

GRI Disclosure Report – GRI Content Index\n\nGovernment Relations\n\n3-3 Management approach\n\n**Key Impacts**\n\n- The political process significantly impacts Dow through government policies, legislation and judicial and regulatory decisions. (positive/negative)\n\n- Dow actively participates in the political process through legally authorized advocacy, grassroots efforts and financial contributions which can inform environmental, social and governance topics. (positive)\n\n- 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)\n\nDow is committed to the highest standard of ethical conduct in its involvement in the political process. All financial contributions strictly adhere to federal and state laws regarding contribution limits on amount, source, criteria and reporting requirements. 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.\n\nDow receives information from trade and business associations as well as civic leagues and social welfare organizations in the United States regarding the portion of its dues or contributions that are used for lobbying expenses and political expenditures. Dow includes this information in the aggregate in its quarterly lobbying activity reports filed with the U.S. Congress, as required by the Lobbying Disclosure Act (LDA), which can be viewed under the link named "Dow's LDA filings" within the Trade Associations policy linked below.\n\n**Policies**\n\n- Dow provides lists of candidates who receive corporate political contributions for the previous five years online at:\n\n[Corporate Political Contributions | U.S. Public Policy | Dow Corporate.](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/contribution-recipients)\n\n- Dow provides a list of trade association memberships and discloses expenses above $25,000 per year, for the\n[previous five years, at: Trade Associations | U.S. Public Policy | Dow Corporate.](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/trade-and-civic-associations)"
"**Direct Political Contributions**

The political process significantly impacts Dow through government policies, legislation and judicial and regulatory decisions. Dow actively participates in the political process through legally authorized advocacy, grassroots efforts and financial contributions.

Dow is committed to the highest standard of ethical conduct in its involvement in the political process. All financial contributions strictly adhere to federal and state laws regarding contribution limits on amount and source, criteria and reporting requirements. 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.

[• More information on Dow's direct political contribution policy can be found here: Contributions | U.S. Public Policy | Dow Corporate](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/political-contribution)

[• Dow's authorization process for political contributions is available at: Authorization for Political Contributions | U.S. Public Policy | Dow Corporate](https://corporate.dow.com/en-us/about/legal/conduct/us-public-policy/authorization-for-contributions)

[• Dow provides lists of candidates who receive corporate political contributions for the previous five years online at: Corporate Political Contributions | U.S. Public Policy | Dow](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/contribution-recipients)
[Corporate](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/contribution-recipients)

[• A link to Dow's Lobbying Disclosure Act (LDA) (U.S. Congressional Lobbying Disclosure Filings) can be found here: Trade Associations | U.S. Public Policy | Dow Corporate](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/trade-and-civic-associations)

**Indirect Political Contributions**

Dow participates in many trade and business associations. Engagement with trade and business associations, whose purpose is to promote common business interests, assists the Company in managing priorities relevant to Dow and the chemical industry and disclosures. Contributions related to trade association expenditures represent Dow's indirect political contributions.

[• More information on Dow's trade association policy can be found here: Trade Associations | U.S. Public Policy | Dow Corporate.](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/trade-and-civic-associations)

Dow receives information from trade and business associations as well as civic leagues and social welfare organizations in the United States regarding the portion of its dues or contributions that are used for lobbying expenses and political expenditures. Dow includes this information in the aggregate in its quarterly lobbying activity reports filed with the U.S. Congress, as required by the LDA, which can be viewed under the link named "Dow's LDA filings" within the Trade Associations link above.

[In addition, Dow provides a list of trade association membership and discloses expenses above $25,000 per year, for the previous five years, at: Trade Associations | U.S. Public Policy | Dow Corporate.](https://corporate.dow.com/content/corp/en-us/about/legal/conduct/us-public-policy/trade-and-civic-associations)

The CEO is a member of the Leadership Team, which oversees the efforts of Dow's Climate Steering Team and Program Management Office (Climate PMO) and associated sub-teams. The Leadership Team oversees all of Dow's efforts related to GHG emissions reduction and climate management, including but not limited to setting targets and goals, developing strategy, reporting, advocacy, evaluation of climate risks and opportunities, technology investments, and capital planning. [...] Examples of climate-related topics discussed at EHS&T Committee meetings include but are not limited to: monitoring environmental performance and progress against Dow's Sustainability Goals; overseeing risk associated with EH&S policies and operations, emerging regulatory developments, reporting and compliance; and reviewing the Company's sustainability commitments and progress, including efforts to protect the climate, reduce GHG emissions, eliminate plastic waste and deliver circular economy solutions.

Dow's Government Affairs team monitors the political landscape across all of the areas of the world where Dow operates to understand the status of emerging regulation as it relates to emissions trading schemes (ETS) or carbon taxes in order to understand any potential impact to our business. [...] 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. The POC includes Senior Leaders responsible for our participation in ETS, as well as Dow's Vice President of Government Affairs and Chief Sustainability Officer. [...] Dow's current strategy to achieve our objectives around carbon and climate change include: implementing energy efficiency projects, sourcing cost-advantaged renewable power to support our operations, and evaluating low carbon technology options for the maximum affordable footprint reduction.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Dow's overall strategy as it relates both to systems we are currently regulated by, as well as areas of the world where we foresee the potential for future regulation, is to actively reduce GHG emissions in the most cost-efficient way, while engaging with policy makers worldwide to offer insight into opportunities to accelerate carbon reduction at manufacturers similar to Dow. The oversight for action as it relates to reducing our carbon emissions lies with Dow's cross-business, cross functional "Program Management Office† (PMO), which reports to a Climate Steering Team led by a variety of senior leaders with direct alignment to the CEO. 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.

Attach commitment or position statement(s)[…]Page 123 of the Dow-2021-ESG-Report.pdf indicates:
"Dow supports the Paris Agreement and its goal to keep global temperature rise to well below 2°C and to pursue efforts to limit the increase to 1.5°C. Consistent with this commitment, we have set an ambitious target of being carbon neutral by 2050 (Scope 1+2+3 plus product benefits). We have also set a medium-term goal to reduce our net annual carbon emissions by 5 million metric tons by 2030 versus our 2020 baseline (15% reduction). This builds upon an already achieved 15% emissions reduction since 2005 (~30% total reduction by 2030 vs. 2005). Our emissions reduction targets are scientifically-based and in alignment with, and ahead of, the International Energy Agency's 2050 Net Zero Emissions Scenario for the chemical industry. Our ability to meet these commitments, while enabling business growth, will require effective management of our energy consumption and the implementation of new technologies. In addition, we will need the appropriate infrastructure and policy developments to support emissions reductions; Dow is actively engaged in constructive advocacy to advance pragmatic policies to enable a successful path to zero.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Dow's overall strategy as it relates both to systems we are currently regulated by, as well as areas of the world where we foresee the potential for future regulation, is to actively reduce GHG emissions in the most cost-efficient way, while engaging with policy makers worldwide to offer insight into opportunities to accelerate carbon reduction with manufacturers similar to Dow. The oversight for action as it relates to reducing our GHG emissions lies with Dow's cross-business, cross functional "Program Management Office" (PMO), which reports to a Climate Steering Team led by a variety of senior leaders with direct alignment to the CEO. 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.