Defendant Name: The Dow Chemical Company

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

Document Reference: 34-83581

Document Details

Legal Case Name In the Matter of The Dow Chemical Company
Document Name 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
Document Date 02-Jul-2018
Document Format Administrative Proceeding
File Number 3-18570
AAER 3947
Allegation Type Issuer Reporting and Disclosure
Document Summary 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."

Disgorgement & Penalty Information

Resolutions
Cease and Desist Order
Compliance Related Independent Consultant
Monetary Penalties:

Civil Penalty

Individual:     $1,750,000.00 Shared:    

Related Documents:

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."