DOW’S GENERATIVE AI

ACCEPTABLE USE
POLICY
April 2024
DOW'S GENAI ACCEPTABLE USE POLICY WILL
HELP SET CLEAR STANDARDS OF BEHAVIOR
FOR USING INFORMATION TECHNOLOGY
RESOURCES, PROTECT DOW'S ASSETS AND
RESOURCES, AND ASSURE LEGAL AND
REGULATORY COMPLIANCE.
PLEASE READ THE INFORMATION PROVIDED
IN THE SLIDES CAREFULLY.
DOW’S GENERATIVE AI ACCEPTABLE USE POLICY

Purpose Agenda

 Provide guidelines and best practices Definitions​

for responsible use of Generative AI within Dow​ Scope​
 Promote efficient and ethical use of Generative AI​
Applicability of other Dow policies​
 Minimize risk of intentional or unintentional misuse​
Policy requirements​
 Prevent harm to individuals, Dow, or Dow's ambition​
Interpretations/exceptions​
 Increase awareness of new Dow GenAI
Acceptable Use Policy Enforcement​
Scope of applicability​
Issuing authority​
Effective date​
References

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DEFINITIONS

AI System or AI: machine-based artificial intelligence system that, for explicit or implicit objectives, infers, from the
input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can
influence physical or virtual environments. AI Systems vary in their levels of autonomy and adaptiveness after
deployment.

Generative AI: means a type of AI, which is focused on creating machine-learning models capable of generating
new and original content (e.g., text, images, video, speech, music, source code, product designs) in response to
user-inputted prompts. . Generative AI developers train algorithms to learn the patterns and structures of vast
training data, and to then use that knowledge to produce novel outputs that resemble the training data.. Generative
AI excels at both pattern recognition and pattern creation. Examples include large language model (“LLM”)
chatbots (e.g., OpenAI’s ChatGPT) and workplace productivity tools (e.g., Microsoft 365 CoPilot).

Traditional AI: means non-Generative AI, which primarily is used to analyze data, make predictions, and perform a
specific task intelligently, but which does not create anything new or original. Traditional AI excels at pattern
recognition. Examples include search engines (e.g., google.com), virtual assistants (e.g., Apple’s Siri),
autonomous vehicles (e.g., Tesla’s Autopilot), spelling/grammar checkers (e.g., in Microsoft Word), chess bots
(e.g., Google DeepMind’s AlphaZero), and machine translation tools (e.g., translate.google.com).

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EXAMPLES OF AI & GENAI
Artificial Intelligence Generative AI
 Image Recognition: Video monitoring of pellets loaded into  Patent Sieve: Allows Dow Scientists & Research the ability to connect
containers for defects. the database of patents to a LLM for prompting on specific attributes
 Supply Chain Optimization: Graph networking to determine best that help individuals find patents in the data much faster and allow
rates and routes to yield most optimal financial return for vehicle Dow to determine if can submit a patent claim or not.
logistics.  CSR Assistant: A Chatbot was created to help CSRs find documents
 Furnace Reliability: Monitoring sensors on our furnaces at the and work processes quicker faster by connecting training
plant to detect & predict the most optimal time to decoke, documentation to LLMs for CSRs to prompt on questions related to
improving unplanned events. how they can perform their work process or find other relevant
information for the customers.
 MarketMind: Semantic search capability to help marketers find
NEUROMORPHIC AUTONOMOUS relevant market insights through unstructured text & data mining by
COMPUTING SYSTEM

MACHINE LEARNING
web scraping and turning insights to sentiment of marketplace.
COGNITIVE CYBER
SECURITY

ROBOTIC PERSONAL DEEP LEARNING

ASSISTANTS

AUTONOMOUS NEURAL NETWORKS

SURGICAL ROBOTICS ARTIFICIAL
INTELLIGENCE PATTERN RECOGNITION
NEXT GEN CLOUD
ROBOTICS
Technology Landscape

NATURAL LANGUAGE
PROCESSING
THOUGHT CONTROLLED
GAMING

REAL TIME UNIVERSAL

TRANSLATION
CHATBOTS
Generative AI
VIRTUAL REAL TIME EMOTION
COMPANIONS ANALYTICS

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SCOPE

 Policy applies to individuals using

Generative AI for Dow work-related
tasks.
 Includes global Dow employees,
contractors, and other authorized users
 Covers any Generative AI use
case/emerging capability that involves
creation of content.
 Does not apply to use of Traditional AI
by Dow Users.

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APPLICABILITY OF OTHER DOW POLICIES

All Dow policies apply to the use of Generative AI and Traditional AI by Dow Users
 Code of Conduct
 Respect & Responsibility Policy
 Corporate Information Protection Policies
 Information Technology Security Policy
 Information Handling Policy
 Information Service Provider Policy
 Records Management Policy
 Information Protection Policy
 Data Privacy Policy

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 Throughout this training we will cover
prohibited use of GenAI, including some
examples of what is allowed to help
users interpret the policy.

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Policy requirements:
Prohibited
 Do not use any publicly available
Generative AI (e.g., ChatGPT,
Bard/Gemini, Anthropic, DeepMind).
 Do not use Generative AI in a way that
could result in, or fail to prevent, the death
or serious bodily injury of any person.
Allowed
• Use Dow’s approved (and licensed) enterprise
Generative AI tools only, such as M365 Copilot,
Sales Copilot
• If a user does not have a Copilot license, you
can securely use online Copilot at
Copilot.Microsoft.com. This is a Dow secured
experience, but you will not be able to access
your Dow data for use with online Copilot.
• As Dow progresses GenAI use, you can expect
more GenAI tools
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Policy requirements:
Prohibited
 Do not use Generative AI to evaluate or monitor the
performance or behavior of—or to make an employment
decision concerning—any Dow employee, contractor, other
person with whom Dow has a work-related contractual
relationship.
 Prohibited use includes:
o (i) managing work activities and personnel generally,
including appraisals, performance management,
promotions, staffing, training, career development;
o (ii) determining compensation, wages, stock options,
grants, bonuses;
o report. If the Leader otherwise follows the Policy in doing so—e.g., by
(iii) administering pension and benefits plans;
o (iv) conducting workforce analysis and planning, reporting
and data analytics, employee surveys;
o (v) managing disciplinary matters, grievances, terminations,
restructuring, layoffs, disparate impact analysis; and
o (vi) enabling Dow’s global human resources service
centers to provide services.
Allowed
 An example of acceptable use would be a Leader using
Copilot to summarize performance feedback received from
several different Dow employees about one of the
Leader’s direct reports (e.g., by cut/pasting the feedback
into Word and prompting CoPilot to summarize the direct
report’s strengths and weaknesses as described in the
feedback).
 This use case would not constitute using CoPilot to “evaluate or
monitor the performance of behavior of—or to make an employment
decision concerning”—the direct report. Rather, the Leader would be
using CoPilot merely to summarize and distill the feedback text and
help draft a potential insert for the Leader’s written review of the direct
ensuring that the CoPilot-generated output is accurate, appropriate,
and suitable for use in the written review—then the use case is
allowed.
The Leader is accountable for the final performance review
and content.
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Policy requirements:
Prohibited
 Do not use Generative AI in the candidate
recruitment and selection process.
Prohibited use includes advertising
vacancies; screening, filtering, selecting, or
rejecting applications; evaluating, scoring, or
comparing candidate data, profiles, or
resumes; evaluating candidates during
interviews or tests; and otherwise assisting
in any way with the decision-making
responsibilities of our hiring teams.
Allowed
• Assisting with the development of content
for job posting
• Assisting in the development of potential
interview questions
The hiring manager and panel are accountable
for the final decision of candidate selection and
the justification for the selection.
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Policy requirements:
Prohibited
 Do not use Generative AI to review or analyze
(or train AI models) using Dow’s historical
human resources data relating to past
employment decisions made concerning: (i)
Dow employees, contractors, or other
personnel; and/or (ii) external candidates for
employment.
 Do not use Generative AI to “profile”—i.e., to
evaluate, analyze, or predict personal aspects
relating to any individual, such as the
individual’s performance at work, economic
situation, health, preferences, interests,
reliability, behavior, location, or movements.
 Do not use Generative AI to identify, verify, or
infer any protected classification
characteristic about any individual without that
individual’s explicit consent—e.g., race,
color, ancestry, national origin, citizenship,
religion or creed, marital status, medical
condition, physical/mental disability, sex
(including gender, gender identity/expression,
pregnancy/childbirth/related medical
conditions), sexual orientation, veteran or
military status, genetic information (including
family medical history).
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 Policy requirements:
Prohibited
 Do not use Generative AI to process, identify,
verify, infer, or reveal any individual’s
sensitive personal data without that
individual’s explicit consent—e.g., (i) racial
or ethnic origin, political opinions, religious or
philosophical beliefs, trade union membership,
genetic data, biometric data, health data, sex
life/orientation data; (ii) precise geolocation; (iii)
financial account, debit card, or credit card
number in combination with any required
security or access code, password, or log-in
credentials allowing access to an account.
 Do not use Generative AI to process any individual’s
biometric data—i.e., personal data resulting from
specific technical processing relating to the physical,
physiological, or behavioral characteristics of a natural
person, which allow or confirm the unique identification
of that person. The term biometric data includes but is
not limited to a retina or iris scan, fingerprint,
voiceprint, scan of hand or face geometry, facial image
processed with facial recognition technology, and gait
pattern processed with gait recognition technology. The
term biometric data also includes any information,
regardless of how it is captured, converted, stored, or
shared, based on an individual’s biometric data used to
identify an individual (e.g., a unique mathematical
representation of a fingerprint).
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Policy requirements:
Prohibited
 Do not use Generative AI to attempt to monitor,
assess, or infer any individual’s emotional state
from their facial expressions or facial
movements.
 Do not use Generative AI for ongoing
surveillance or real-time or near real-time
identification or persistent tracking of any
individual without that individual’s valid consent.
 Do not use Generative AI to deploy subliminal
techniques beyond a person’s consciousness
to materially distort, influence, direct, or control
a person’s behavior or choices in a manner that
causes or is likely to cause that person or
another person physical or psychological harm.
Allowed
• You may use GenAI in connection with machine vision use
cases (e.g., where a camera combined with AI are used to
detect whether a spotter is in the right place, whether a
person is wearing the required PPE, or whether a "man
down" safety incident has occurred).
 This use case is allowed, assuming (1) that the camera/AI doesn’t
track or log the specific identity of persons appearing on camera (e.g.,
via facial recognition); (2) that the camera/AI is used for coaching and
safety purposes only (i.e., to ensure proper spotter placement and PPE
use and to provide real-time coaching/corrections; and not to track, log,
or prove the number of infractions by a particular employee in order to
evaluate the employee’s performance at work or take an adverse
employment action); (3) that use of the camera/AI is focused on a
specific area in the workplace/plant where spotter positions, PPE, and
safe behaviors are critical; and (4) that in-scope employees are notified
about Dow’s use of the camera/AI for coaching and safety purposes
(e.g., via a sign posted on a wall near the specific area in the
workplace/plant, or via an email notification to in-scope employees).
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Policy requirements:

Prohibited Allowed
 Do not use Generative AI to generate and act on • You may use GenAI to generate draft positions or
individualized advice that in the ordinary course of idea statements that can be validated by the
business would be provided by a licensed licensed professional
professional—e.g., financial, legal, or medical
advice. Nothing in this paragraph prohibits
appropriate use of Generative AI by a licensed The human is responsible for decision making, not
Dow accountant, attorney, or medical professional GenAI. GenAI can assist you with information to
that complies with this policy. make a decision but should not be used to take/make
 Do not use Generative AI to generate code the decision.
designed to disrupt, damage, or gain
unauthorized access to a computer system
(e.g., malware).
 Do not use Generative AI to make automated
decisions about any individual without human
involvement and oversight.
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Policy requirements:
Prohibited
 Do not use Generative AI to modify, use, or distribute
the output in a manner that is likely to infringe or
misappropriate any third-party copyright or intellectual
property right. Prohibited use includes disabling,
evading, disrupting, or interfering with any content
filters, prompt restrictions, or other safety systems that
are part of the Generative AI tool.
 Do not use Generative AI in a way prohibited by
applicable laws, including applicable copyright,
intellectual property, data privacy/protection, and AI-
specific laws.
 Do not use Generative AI in a way that violates this
policy or other Dow policies.
 Do not use Generative AI provided through Microsoft’s
Azure OpenAI Service (e.g., DowGPT) in a way that
violates Microsoft’s
Code of Conduct for Azure Open AI Service.
Allowed
• Users must be aware of what are authorized GenAI
tools in Dow’s environment and only use these tools
as they have infringement and copyright protection
built in.
• Developers of and or teams bringing GenAI
capability into Dow need to ensure the tool/capability
provides copyright and infringement protection for
Dow.
• Microsoft 365 Copilot has copyright protection built
in, therefore imagery and other content generated by
this tool will not violate these laws.
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Policy requirements:

Prohibited
 Do not use Generative AI to engage in fraudulent, defamatory, or deceptive activities, including
scams, coordinated inauthentic behavior, false online engagement, plagiarism, disinformation, or
spam. Prohibited use includes manipulating public debate, discussion, or engagement relating to Dow
or its business, products, technology, interests, history, environmental impact, sustainability, industry,
competitors, investors, risks, liabilities, financial performance, stock price, or material non-public
information.

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POLICY REQUIREMENTS: APPROPRIATE USE
Assist with Dow work-related tasks
 Data analysis
 Content creation
 Decision-making
 Communications
 Search for information
 Summarize information

The key is that GenAI can assist users, not

replace and not make decisions.

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POLICY REQUIREMENTS: REQUIRED APPROVAL
 Enterprise Generative AI licensed to Dow
by a third party must be approved prior to
deployment, this includes conducting an
IT Security Risk, Data Privacy and Legal
assessment(s)
 Deployment includes full or partial
implementation and any pilot or proof-of-
concept project
 Dow Users may not use Generative AI
without approval in accordance with
Dow’s Information Service Provider Policy

DOW CONFIDENTIAL - Do not share without permission August 2019 19

POLICY REQUIREMENTS: NOT A SUBSTITUTE FOR HUMAN INTELLIGENCE

 Generative AI is not a substitute for the skill, judgment, intelligence,

or ability of Dow Users.
 Dow Users may use Generative AI to assist their work only.
 In a court of law, GenAI will not be held accountable, we will be.

DOW CONFIDENTIAL - Do not share without permission August 2019 20

POLICY REQUIREMENTS: ACCURACY AND APPROPRIATENESS
 Carefully consider and craft the prompt before inputting it
 Be sure to apply sensitive data training based on your role. Especially when your role has access to: Crown
Jewels, People/PII, Commercial Agreements/Contracts. Just because GenAI can, doesn’t mean you should.
 Exercise due diligence and critical thinking when reviewing the output
 Verify the accuracy of the output by cross-checking with reliable sources
 Verify the appropriateness of the output for the intended use or action
 Carefully select and edit the output to render it accurate and appropriate

DOW CONFIDENTIAL - Do not share without permission August 2019 21

Policy requirements: Potential AI hallucinations and
bias
• Automation bias: tendency of humans to favor suggestions from automated decision-making
systems
• AI hallucinations: false, inaccurate, misleading, nonsensical, and/or irrelevant response or
output from Generative AI. GenAI uses data patterns to form responses, if there is a large
data set that is inaccurate, GenAI will assume it to be accurate data based on the frequency of
the data pattern.
• Training data: may be from biased sources and/or include incorrect, incomplete, or
unrepresentative information
• Reinforcement learning with human feedback: if human feedback lacks impartiality or is
inconsistent, misleading, or incorrect, then the Generative AI outputs may become biased
• Stochastic parrot: LLM chatbot does not understand what it is saying, it produces the most
statistically likely words in longer packages

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POLICY REQUIREMENTS: TRANSPARENCY AND ACCOUNTABILITY

 Transparency in the use of Generative AI

 Dow Users must:
a) Be transparent about their use of
Generative AI;
b) Disclose to end users when they are
interacting with Generative AI

 Maintenance of AI system logs

 Dow administrators are required to maintain
AI system logs to the extent such logs are in
our control, which will be determined during
the risk assessments.

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ENFORCEMENT
 Violation of this policy can subject the
person responsible and/or the company
he or she represents to disciplinary or
legal action.
 Potential consequences include removal
of access, coaching, training,
verbal/written warning, PA and/or LTI
impact, mandatory unpaid leave, last
chance letter, termination with or without
cause, and/or legal action.

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 POLICY REQUIREMENTS: REPORTING MISUSE
 Report any actual or suspected misuse of Generative AI or violation of this
policy
 Report to supervisor, any Dow leader, Human Resources, Dow Legal, the
Office of Ethics and Compliance, and/or the Dow Ethics Line
 Reports can be made anonymously via the Dow Ethics Line

DOW CONFIDENTIAL - Do not share without permission August 2019 25

INTERPRETATIONS/EXCEPTIONS
 Questions on policy interpretation
must be referred to Dow Legal
 Requests for exceptions subject
to review and approval of Dow
Legal
 Exceptions must comply with
Dow's Code of Conduct and legal
obligations

DOW CONFIDENTIAL - Do not share without permission August 2019 26

SCOPE OF APPLICABILITY

Affiliate Type Applicability of this Policy  Dow refers to The Dow Chemical
Company and its Affiliates
Wholly Owned If TDCC owns 100% of an Affiliate, the  Affiliate means an entity that is under
Affiliates Affiliate will adopt and follow this policy.
common control or ownership with
TDCC
If TDCC owns more than 50% but less
than 100% of an Affiliate, or if TDCC  Control is defined as the power to
Majority-Owned/
exercises management control over the direct or cause the direction of the
Controlled
operations of an Affiliate, the Affiliate is
Affiliates
encouraged to adopt this policy but may management and policies of an entity
implement its own.
 This policy applies for TDCC Affiliates

If TDCC owns 50% or less of an

Affiliate, or if TDCC does not exercise
Minority-Owned/
management control over the Affiliate,
Controlled
the existence of a Generative AI policy
Subsidiaries
is a good business practice that may be
considered by the Affiliate.

DOW CONFIDENTIAL - Do not share without permission August 2019 27

POLICY REQUIREMENTS: TRAINING AND AWARENESS
 Complete this required Generative AI
training and confirm that you have read
the GenAI Acceptable Use Policy.
 Please click here to return to Diamond
Learning and receive credit for the
course.

DOW CONFIDENTIAL - Do not share without permission August 2019 28

 Thank you

DOW CONFIDENTIAL - Do not share without permission August 2019 29