Center for the Study of Ethics in the Professions at IIT

Our Standards of Business Conduct

Fair, legal and ethical business practice has been the cornerstone of Dow Corning's operating philosophy since the company was founded in 1943. We believe that business is best conducted and society best served when business practice is based on the principles of honesty and integrity.
The Code of Business Conduct provides guidelines, but can not cover every situation you may encounter. Should you become aware of -or involved in -a questionable practice, bring it to the attention of your supervisor or a member of the Business Conduct Committee at any time.

Dow Corning's Responsibilities to Employees:

All relations with employees will be guided by our belief that the dignity of the individual is primary.
Opportunity without bias will be afforded each employee in relation to demonstrated ability, initiative and potential.
Business decisions will be consistent with our intent to provide long-term stability and opportunity to all productive employees.
Qualified citizens of countries where we do business will be hired and trained for available positions consistent with their capabilities.
The work environment will encourage individual self-fulfillment, the maximization of skills and talents, open communication and the free exchange of information and ideas.
A safe, clean and pleasant work environment that at minimum meets all applicable laws and regulations will be provided.
The privacy of an individual's personal records will be respected; employees may participate in a review of their personnel records upon request.

Employee's Responsibilities to Dow Corning:

Employees will regard proprietary information as a valuable corporate asset and will avoid the unauthorized disclosure of Dow Corning's business activities, future plans, technology or other proprietary information. We will respect proprietary information belonging to others.
Employees must be free of conflicting interests which could inhibit or detract from their on-the-job performance or with Dow Corning's business interests.
Employees will not engage in bribery, price fixing, kickbacks, collusion, or any practice, which might give the appearance of being illegal or unethical.
Employees will avoid discussions with competitors that could be construed as unfair competition or the restriction of free trade. Relations with our competitors will be limited to buyer/seller agreements, licensing agreements or matters of general concern to the industry or society. All such discussions will be documented.

Relations with Customers, Distributors, Suppliers:

Dow Corning will provide on time products and services that meet the requirements of our customers. We will provide information and support necessary to maximize the use and effectiveness of our products.
Dow Corning expects and encourages its agents, representatives and distributors to conduct business in a legal and ethical manner.
The purchase of supplies, materials and services will be based on quality, price, service, ability to supply and the vendor's adherence to legal and ethical business practices. Fees paid for business services must be reasonable and in line with customary local rates.

Conservation, Environmental and Product Stewardship Practices:

Dow Corning will be responsible for the impact of its technology upon the environment. We will protect the natural environment by continually seeking reasonable ways to eliminate or minimize discharges of potentially harmful waste materials.
All waste will be recycled when possible and economical. Non-recyclable waste will be disposed of in accordance with applicable standards.
New facilities will be designed to optimize the efficient use of natural resources and to conserve energy. Existing facilities will be modified to meet current and anticipated environmental laws and regulations.
We will continually strive to assure that our products and services are safe, efficacious and accurately represented in our literature, advertising and package identification.
Product characteristics, including toxicity and potential hazards, will be made known to those who produce, package, transport, use and dispose of Dow Corning products.

International Business Guidelines:

Dow Corning endeavors to be a productive and cooperative corporate citizen wherever we do business. We recognize, however, that laws, business practices and customs differ from country to country and may occasionally inhibit rather than foster open competition. Such practices could include boycotts, information requests, tax systems, duty classification procedures, labor standards and property protection, among others. If there is a conflict with U.S. law or a Dow Corning standard of business conduct, we will seek reasonable ways to resolve the difference. Failing resolution, Dow Corning will remove itself from the particular business situation.
Dow Corning personnel will not authorize or give payments or gifts to government employees or their beneficiaries in order to obtain or retain business. We will strongly discourage facilitating payments to expedite the performance of routine services. Where the practice is common and there is no reasonable alternative, a minimum payment may be considered. Such payments will be accurately documented and recorded.
No payment, contribution or service will be offered by Dow Corning to a political party or a candidate, even in countries where such payments are legal.
While encouraging the transborder transfer of technology necessary to support its subsidiaries and joint ventures, Dow Corning expects to receive fair compensation for, and protection of, its technology.
Dow Corning will strive to establish inter-company prices at a level that would prevail in arm's length transactions. The intent of this approach to pricing is to assure each country a fair valuation of goods and services transferred.

Financial Responsibilities:

Dow Corning funds will be used only for purposes that are legal and ethical. All transactions will be properly and accurately recorded.
Dow Corning will maintain a system of internal accounting controls and assure that all involved employees are fully apprised of that system.
Dow Corning encourages the free flow of funds for investment, borrowing, dividending and the return of capital throughout the world.

To Dow Corning Employees:

At the top of the list of our corporate objectives is this statement: "Dow Corning's actions shall be guided by its Corporate Code of Business Conduct." Dow Corning places a exceedingly high value on corporate integrity. A sense of fair play, honesty and ethical business practice has always been the foundation of Dow Corning's operating philosophy.
Since 1976 we have extended our efforts to formalize Dow Corning's approach to business conduct. The Code itself is regularly reviewed and updated; a top level Corporate Committee monitors and audits our worldwide compliance with Code principles; we report on business conduct practices annually to the Audit and Social Responsibility Committee of the Board of Directors.
Our intent goes beyond compliance with the law, although that is quite fundamental. Throughout the organization we are developing a sense, or attitude, of personal integrity among our employees. Each employee plays a part in maintaining the integrity of the organization in all its business activities.
I assure you the management of Dow Corning places top priority on fair, legal and ethical business conduct. As an employee of Dow Corning, I ask that you continue to share this key commitment.

Sincerely
John S. Ludington
Chairman and Chief Executive Officer
1984 Dow Corning Corporation