DOW INC.

The Board maintains a Code of Conduct (the “Code”) to guide workforce behavior and set expectations for ethical conduct, covering areas such as health and safety, conflicts of interest, bribery, corruption, sustainability, and citizenship. The Board also adopted a separate Code of Financial Ethics that applies to key financial officers. These codes, as well as the Company’s public position on human rights, respect and responsibility, anti-bribery and anti-corruption, responsible sourcing, and political engagement, are available on the Company’s website athttps://corporate.dow.com/en-us/about/legal/conduct.html. Any waivers or amendments to the Code requiring disclosure will be disclosed on the website.

The Dow Office of Ethics and Compliance (the “OEC”), led by the Chief Compliance Officer who reports to the General Counsel, administers the Code and related compliance programs with oversight by the Audit and Corporate Governance Committees. The Code applies to all Directors, officers, full- and part-time employees of Dow and its wholly owned subsidiaries, and certain joint ventures that adopt the Code. Annual training is required for all officers and employees to ensure understanding and compliance. All Directors, officers and employees must certify each year that they will comply with the Code.

The Code is regularly reviewed by the OEC, and the Audit and Corporate Governance Committees who recommend updates as needed for Board approval. Throughout the year and at least annually, the Board receives information and updates from management and actively engages with senior leaders with respect to the effectiveness of the Company’s ethics and compliance programs. In addition, the Audit Committee receives periodic reports summarizing Dow’s compliance program, containing questions and concerns received and investigated, training and certification status, and other OEC initiatives, and actively engages with the Chief Compliance Officer.

The OEC operates the Dow EthicsLine, a confidential, multilingual, 24/7 resource for questions, guidance, or reporting Code violations, allowing anonymous reports where legal. Retaliation against those participating in an investigation in good faith is strictly prohibited. More information about the Dow EthicsLine can be found atwww.dowethicsline.com.

Dow also has a Code of Business Conduct for Suppliers that outlines expectations and mandatory requirements for suppliers based on the principles of the United Nations Global Compact. Dow may take action, including termination of current and future business relationships, if these principles are not followed. The Code is integrated into requests for proposals, tenders, contracts, purchase orders and supplier relationship management strategies. The Code of Business Conduct for Suppliers is available on the Company’s website athttps://corporate.dow.com/en-us/about/legal/conduct.html.