DOW CORNING CORPORATION CORPORATE CODE OF BUSINESS CONDUCT, 1977

A Matter of Integrity

Dow Corning believes in private enterprise. We will seek to establish an atmosphere of trust and respect between business and members of society, an atmosphere where business and the public understand, accept, and recognize the values and needs of each other.

To establish and promote this atmosphere of mutual trust and respect, Dow Corning accepts as our responsibility a recognition, evaluation and sensitivity to social needs. We will meet this responsibility by utilizing our technological and management skills to develop products and services that will further the development of society.

The watchword of Dow Corning worldwide activities is integrity. We recognize that due to local differences in custom and law, business practice differs throughout the world. We believe that business is best conducted and society best served within each country when business practice is based on the universal principles of honesty and integrity.

We recognize that our social responsibilities must be maintained at the high standards which lead to respect and trust by society. A clear definition of our social responsibilities should be an integral part of our corporate objectives and be clearly communicated to every employee.

Statement of General Conduct

We shall not tolerate payments in any illegal or questionable form, or non-standard commissions or other compensation, given or received, that may influence business decisions.

We shall not make any political contribution nor participate in partisan political activity as a company, recognizing however the rights of employees to participate in legal political processes as private citizens.

We shall be knowledgeable of local laws and customs and operate within them. On the other hand, when we are not being treated legally or ethically we will pursue whatever legitimate recourses are available to us.

Responsibilities to Our Employees

Relations with employees are based on the understanding that attracting and retaining talented and dedicated employees is vital to the accomplishment of financial and social objectives.

Our responsibilities to our employees are:

To manage our activities in such a way as to provide security and opportunities for our productive employees.

To hire, train, evaluate, and advance on the basis of individual ability, contribution, potential, interest and company needs without distinction as to nationality, sex, age, color or religion.

To compensate in accordance with local, national or industry practice.

To provide a safe and healthy work environment that at least meets the applicable governmental laws and regulations.

To provide a work environment that encourages individual self-fulfillment, open communication and free interchange of information and ideas.

Responsibilities to Host Countries In Which We Operate

Activities in host countries are based on the premise that we can and wish to contribute to the economic objectives of the host government while concurrently meeting our corporate objectives.

Our responsibilities to host countries are:

To preserve and, where possible, enhance the environment through elimination or control of pollution.

To conserve natural resources.

To design and modify facilities which meet or exceed current and anticipated environmental and safety laws and regulations.

To hire, train, and qualify host country nationals for positions of responsibility consistent with their demonstrated capabilities.

To pay our required share of taxes and duties but resist inequitable or double taxation between countries.

To resolve any government relations problems or conflicts among overlapping jurisdictions through prompt, direct and open discussions with responsible government officials.

To follow responsible monetary and credit practices and conduct foreign exchange operations not for speculative purposes, but in accordance with normal business requirements and to protect our exposure fluctuations.

To encourage the flow of our technology across borders to the extent needed and appropriate in our local operations and markets, and to receive adequate compensation and protection of this technology.