DOW INC

No material developments regarding this matter occurred in the first three months of 2025. For a current status of this matter, see Note 10 to the Consolidated Financial Statements.

Environmental Proceedings

On May 17, 2021, the Company received a civil complaint from the State of Texas ("State") on behalf of the Texas Commission on Environmental Quality, filed in the 250th District Court of Travis County, Texas ("Travis County District Court"). The suit alleges environmental violations at the Company's Freeport, Texas, site involving several air emissions events, which allegedly occurred at the site between 2016 and 2021. The State is seeking monetary and injunctive relief to prevent recurrence. On February 28, 2025, notice was published in the Texas Register of a proposed resolution in the form of an Agreed Final Judgment. On April 2, 2025, the Agreed Final Judgment was approved by the Travis County District Court and became effective. Pursuant to the Agreed Final Judgment, the Company must pay a $2 million civil penalty and $50,000 in attorneys’ fees, with no injunctive relief.

In October 2023, Region 6 of the U.S. Environmental Protection Agency ("EPA") conducted an inspection of the Company’s Louisiana Operations under the EPA’s Risk Management Program ("RMP"). The inspection was initiated due to an incident at the Company's Glycol-2 unit in Plaquemine, Louisiana, on July 14, 2023, as previously disclosed by the Company. The EPA published its inspection report on January 26, 2024. On January 3, 2025, the Company received a Notice Letter from the EPA’s enforcement branch, which formally alleged 21 violations of RMP and Clean Air Act requirements and offered the Company an opportunity to confer with the EPA. Discussions between the Company and EPA are ongoing.