Defendant Name: The Dow Chemical Company

Defendant Type: Subsidiary of Public Company
Public Company Parent: DowDuPont Inc.
SIC Code: 2821
CUSIP: 26078J10

Initial Case Details

Legal Case Name In the Matter of The Dow Chemical Company
First Document Date 02-Jul-2018
Initial Filing Format Administrative Action
File Number 3-18570
Allegation Type Issuer Reporting and Disclosure
AAER 3947

Violations Alleged

Exchange Act
• Rule 12b-20
• Sec 13(a)
• Rule 13a-1
• Sec 14(a)
• Rule 14a-9

Resolutions

First Resolution Date 02-Jul-2018
Headline Total Penalty and Disgorgement $1,750,000

Related Documents:

34-83581 02-Jul-2018 Administrative Proceeding
Order Instituting Cease-and-Desist Proceedings Pursuant To Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease- and-Desist Order
On July 2, 2018, the SEC issued an order against The Dow Chemical Company, stating: "From 2011 through 2015, and in proxy statements reporting on those years, Dow did not ensure that approximately $3 million in executive perquisites were adequately evaluated and disclosed as "other compensation" in the Compensation Discussion & Analysis ("CD&A") section of the annual proxy statements. These authorised but undisclosed perquisites included personal use of the Dow aircraft and other expenses."
34-83581-s 02-Jul-2018 Administrative Summary
Dow Chemical Agrees to $1.75 Million Penalty and Independent Consultant for Failing to Disclose Perquisites
On July 2, 2018, the SEC issued a press release regarding SEC charges against The Dow Chemical Company, stating: "The SEC's order finds that from 2011-2015, Dow failed to ensure that approximately $3 million in perquisites provided to its chief executive officer ("CEO") were adequately identified and disclosed as other compensation in Dow's 2013-2016 proxy statements. These authorised but undisclosed perquisites included the CEO's personal use of Dow aircraft and other expenses."