Corporate Environmental Disclosure and Reporting at Dow Chemical Company
Dow Chemical (DOW) is a manufacturer and supplier of products used primarily as raw
materials in the manufacture of customer products and services in industries such as appliance,
automotive, agricultural, building and construction, chemical processing, electronics, furniture,
housewares, oil and gas, packaging, paints, coatings and adhesives, personal care,
pharmaceutical, processed foods, pulp and paper, textile and carpet, utilities, and water
1.1. Comment on DOW’s environmental disclosure in the most recent 10-K report filed with the
SEC. More specifically, comment on the discussions required by items 101, 103, 303, and
503 of Regulation S-K, as directed by the SEC’s Interpretive Guidance of 2010.
1.2. Comment on DOW’s voluntary sustainability disclosures, with special focus on the most
recent annual sustainability report published by the company. More specifically, discuss the
application of the GRI guidelines, including general standard disclosures and performance
GHG Reporting at Dow Chemical Company (NYS:DOW)
Discuss the application of the GHG Protocol by Dow Chemical regarding the determination of
organizational and operational boundaries and calculation of GHG emissions. Base your
discussion on the company’s disclosures on processes used to determine the report content. Are
these disclosures comprehensive?
Contingent Environmental Liabilities at Dow Chemical Company (NYS:DOW) and at
Axiall Corporation (NYS:AXLL)
3.1. Does Dow Chemical recognize or disclose contingent environmental liabilities in the most
recent annual 10-K report? Discuss the company’s disclosure in light of FASB
3.2. Does Axiall Corporation recognize or disclose contingent environmental liabilities in the
most recent annual 10-K report? Discuss the company’s disclosure in light of FASB
Please find below a list of points that should be mentioned for problems 1, 2 and 3 (in general).
Item 101 of S-K – Business Description
In Dow’s report, Item 1 – Business
Pg 20 – “The Company is subject to extensive federal, state, local and foreign laws, regulations, rules and ordinances relating to pollution, protection of the environment, greenhouse gas emissions, and the generation, storage, handling, transportation, treatment, disposal and remediation of hazardous substances and waste materials.”
Item 103 of S-K – Legal Proceedings
In Dow’s report – Item 3 – Legal Proceedings
Pg 25 – Environmental Matters – Includes discussion of EPA inspections, settlements and penalties paid to EPA, discussion of violations and pending legal proceedings by a Netherlands-based wholly owned subsidiary, and an Administrative Complaint from the Texas Council of Environmental Quality alleging violations of various environmental requirements regulating air emissions
Item 303 of S-K – Management Discussion and Analysis
In Dow’s report, Part II, Item 7
Pg 62. Environmental Matters
Pg 62. Environmental Policies – “To meet the Company’s public commitments, as well as the stringent laws and government regulations related to environmental protection and remediation to which its global operations are subject, Dow has well-defined policies, requirements and management systems.”
“Detailed information on Dow’s performance regarding environmental matters and goals can be found online on Dow’s Sustainability webpage atwww.dow.com. The Company’s website and its content are not deemed incorporated by reference into this report.”
Pg 62. Chemical Security
Pg 63. Climate Change – Regulatory matters (cap and trade systems and carbon taxes); Physical Climate Parameters – “Through corporate energy efficiency programs and focused GHG management efforts, the Company has and is continuing to reduce its GHG emissions footprint.”
Pg 64. Environmental remediation liabilities, superfund sites, and other remediation sites,…
Item 503 of SEC Regulation S-K – Risk factors
In Dow’s report, Item 1A
Pg 20. “Environmental Compliance: The costs of complying with evolving regulatory requirements could negatively impact the Company’s financial results. Actual or alleged violations of environmental laws or permit requirements could result in restrictions or prohibitions on plant operations, substantial civil or criminal sanctions, as well as the assessment of strict liability and/or joint and several liability.”
2012 Sustainability Report
GRI A+ rating
On page 116, a GRI Index links GRI’s general disclosure requirements and indicators to different sections on the report. The company fully reported for most indicators, and partially reported for some (for example EN7, EN10, EN11, EN17, EN21 and DN27).
The report contains many graphs, charts and figures that illustrate performance, achievement, and goals. However, in several sections both quantitative information and discussion of the companie’s actions to mitigate these issues are not comprehensive (for example, concerning waste water).
Even though still follows the GRI G3.1 framework, Dow uses terminology that was introduced in G4 (for example, the major sections titles are economic, environmental, and sub-categories for social proposed in G4)
2012 Sustainability Report
Boundaries explained in 3.6 Boundary of the report, pg 28. Approach used is financial control approach, but not much detail is given. Also include “and operations in leased facilities that are Dow managed”.
Report on Scopes 1 and 2, and provides a few numbers for scope 3 (EN16 and EN17, pg 69)
There is no break down by scope, individual GHGs, business divisions, or source of emissions.
ASU450: Companies must recognize “probable” loss contingencies and disclose “reasonably possible” (more than remote) contingencies in the notes to their financial statements. Disclosures should be “more extensive as additional information about a potential unfavorable outcome becomes available”.
Risk factors, Pg 20 – “At December 31, 2013, the Company had accrued obligations of $722 million ($754 million at December 31, 2012) for probable environmental remediation and restoration costs, including $73 million ($69 million at December 31, 2012) for the remediation of Superfund sites. This is management’s best estimate of the costs for remediation and restoration with respect to environmental matters for which the Company has accrued liabilities, although it is reasonably possible that the ultimate cost with respect to these particular matters could range up to approximately two and a half times that amount.”
Management discussion and analysis, Pg 64 – Environmental remediation – provides information about superfund sites and related liabilities
Note 14, Pg 101 – Repeats same information and adds “Consequently, it is reasonably possible that environmental remediation and restoration costs in excess of amounts accrued could have a material impact on the Company’s results of operations, financial condition and cash flows. It is the opinion of the Company’s management, however, that the possibility is remote that costs in excess of the range disclosed will have a material impact on the Company’s results of operations, financial condition or cash flows. Inherent uncertainties exist in these estimates primarily due to unknown conditions, changing governmental regulations and legal standards regarding liability, and emerging remediation technologies for handling site remediation and restoration.”
State that accrues “when it is probable that a liability has been incurred and the amount of the liability can be reasonably estimated based on current law and existing technologies”
Also summarizes values in a table and provides detailed information regarding some of the sites and dispute resolutions.
accrued and therefore recognized $64m for environmental contingencies
“amounts recorded in the accompanying consolidated financial statements related to these contingencies are based on the best estimates and judgments available to us, the actual outcomes could differ from our estimates”
“reasonably possible loss contingencies related to environmental matters in the range of $60 million to $100 million”
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