For more information on the Dow Corning Code of Conduct, contact: SENEFFE (Area Headquarters) Dow Corning Europe SA Ethics and Compliance Office Parc Industriel - Zone C rue Jules Bordet 7180 Seneffe Belgium TEL: +32 64 88 80 00 FAX: +32 64 88 89 30 WEB: dowcorning.com http://intranet/codeofconduct MIDLAND, MICHIGAN, USA (World Headquarters) Dow Corning Corporate Center Ethics and Compliance Office 2200 W. Salzburg Road P.O. Box 994 Midland, Michigan 48686-0994 USA TEL: +1 989 496 4000 FAX: +1 989 496 6731 WEB: dowcorning.com Vision Disclosure Competition TOKYO (Area Headquarters) Dow Corning Toray Co., Ltd. Ethics and Compliance Office 23F Otemachi First Square Bldg. East Tower, 1-5-1 Otemachi Chiyoda-ku, Tokyo, 100-0004 Japan TEL: +03 3287 1011 FAX: +03 3287 1201 WEB: dowcorning.co.jp Conduct Finance Safety Confidentiality Sustainability Health n Area Headquarters l Manufacturing Sites Key Customer Service Centers u Key Science & Technology Centers s Warehousing Sites Effective June 1, 2011 Dow Corning is a registered trademark of Dow Corning Corporation. We help you invent the future is a trademark of Dow Corning Corporation. “Responsible Care®” is a registered service mark of the American Chemistry Council. ©2011, 2007 Dow Corning Corporation. All rights reserved. Printed in USA Vision, Values, and the Code of Conduct

TABLE OF CONTENTS 2 Vision 4 Values 5 Letter from CEO All Dow Corning employees should be guided by our Values in DOW CORNING COMMITMENT TO INTEGRITY 6 Company Reputation 6 Laws and Regulations 6 Policies and Procedures 6 Use of Company Resources order to realize the Dow Corning Vision. The Code of Conduct describes how the behavior that is expected of each of us is shaped by these Values. DOW CORNING RESPONSIBILITIES TO EMPLOYEES 7 Mutual Respect 7 Privacy 7 Non-Discrimination 7 Freedom from Harassment 7 Safe Work Environment 8 EMPLOYEE RESPONSIBILITIES TO DOW CORNING GIFTS AND ENTERTAINMENT...

Dear Colleagues: At Dow Corning, doing business with integrity has been our commitment since the company was founded in 1943. Sound, fair, and ethical business behavior is the foundation of Dow Corning’s reputation and success. We show our integrity by our ethical behavior and our respect for society’s values. Our employees are the source of our ideas, actions, and performance. Employees can best achieve their full potential in an environment of fairness and respect, self-fulfillment, teamwork, and dedication to excellence. We work with our customers in the spirit of long-term relationships based...

Dow Corning Commitment to Integrity Dow Corning Responsibilities to Employees According to our Values, employees can best achieve their full potential in an environment of excellence, teamwork, and mutual respect. Dow Corning Integrity means consistently doing the is committed to treating employees fairly and with dignity. right thing at the right time according MUTUAL RESPECT Our commitment to honesty and mutual respect is the basis for our encouragement of open communications, teamwork, and personal development. SAFE WORK ENVIRONMENT We adhere to policies and practices that respect the privacy...

Each Dow Corning employee is expected to act with integrity in accordance with our Vision, Values, and Code of Conduct. Employee Responsibilities to Dow Corning RESPONSIBILITIES Employees are expected to: Follow Dow Corning Values, the Code of Conduct, relevant laws and legislation, and all company policies in working with Dow Corning employees, customers, suppliers, and all other business contacts. Treat colleagues with mutual respect and without discrimination. Use Dow Corning resources only for company business purposes. Avoid any activities that harm or conflict with Dow Corning’s interests....

Acting with integrity requires that we avoid conflicts – or the Customers, Channel Partners, and Suppliers appearance of conflicts – between the company’s interests Dow Corning is committed to acting with integrity in our dealings with customers, channel partners, suppliers, and competitors. Integrity is the key ingredient to successful business relationships. Avoiding Conflicts of Interest When making decisions and acting for Dow Corning, employees are expected to do so fairly, objectively, and free of outside influences. A conflict of interest can arise when actions or decisions do not meet...

Financial Integrity INTEGRITY Ensuring the accuracy and integrity of our financial records is required by many laws and regulations, as well as by our Dow Corning Values. FINANCIAL RECORDS We will maintain honest, accurate, timely, and sufficient records of our assets, liabilities, and operations. Such records may be as simple as time cards or as complex as filings of comprehensive financial statements. We will maintain a comprehensive system of internal controls. We will ensure that no unlawful, improper, or questionable payments are made to third parties. All employees are expected to show...

Sustainability The Dow Corning Value of Sustainability commits People safety, manufacturing process the company to act responsibly to create economic safety, and product safety are critical growth and value, improve the quality of life and our aspects of the well-being of employees, environmental performance. the broader community, customers, and our business operations. Likewise, the Dow Corning will: Use the following Guiding Principles of Sustainability: security of our people, places, products, Reduce the environmental impact and improve the health and safety aspects of our current and future...

Preserving the ethical culture of our company is everyone’s responsibility. Dow Corning management believes cases, questions, or concerns about potential violations of this Code can and should be reported promptly by any employee without fear of penalty or retaliation. Raising Concerns and Reporting Misconduct re unsure if an action is 1A legal or ethical, or Suspect that misconduct 2 may have occurred, or Have observed misconduct, 3 You are required to report it. Use the reporting channels mentioned to the right. To make the reporting process as easy and comfortable as possible for everyone,...