{"url_path":"/sec/cik-0000100790/10-k/2026/item-1c","section_key":"item-1c","section_title":"Item 1C CYBERSECURITY","topic":"sec","document":{"doc_type":"10-K","doc_date":"2026-02-03","source_url":"https://www.sec.gov/Archives/edgar/data/100790/0000029915-26-000004-index.html","accession_number":"0000029915-26-000004","cik":"0000100790","ticker":null,"issuer_name":"UNION CARBIDE CORP /NEW/","edgar_url":"https://www.sec.gov/Archives/edgar/data/100790/0000029915-26-000004-index.html","primary_entity_key":"0000100790","primary_entity_name":"UNION CARBIDE CORP /NEW/"},"word_count":1131,"has_tables":true,"body_markdown":"ITEM 1C. CYBERSECURITY\n\nRisk Management and Strategy\n\nDow has processes in place to identify, assess and monitor material risks from cybersecurity threats, including the material risks of the Corporation. These processes are part of Dow’s overall enterprise risk management process and have been embedded in its operating procedures, internal controls and information systems.\n\nDow's comprehensive cybersecurity and information security framework includes risk assessment and mitigation through a threat intelligence-driven approach, application controls, and enhanced security with ransomware defense. The framework leverages International Organization for Standardizations 27001/27002 standards for general information technology controls, International Society of Automation/International Electrotechnical Commission standards for industrial automation, the National Institute of Standards and Technology Cyber Security Framework (\"NIST CSF\") for measuring overall readiness to respond to cybersecurity threats, and Sarbanes-Oxley for assessment of internal controls. In addition, Dow maintains business continuity and disaster recovery plans as well as a cybersecurity insurance policy.\n\nDow has comprehensive processes to manage cybersecurity risks when engaging with third-party service providers, including reviewing questionnaires and independent quantitative scores of the vendor’s cybersecurity hygiene, maintaining robust controls to address and mitigate significant risks that may arise, and performing ongoing assessments and reviews throughout the duration of the engagement.\n\nDow has established cybersecurity and information security awareness training programs. Formal training on topics relating to Dow’s cybersecurity, data privacy and information security policies and procedures is mandatory at least annually for all employees, contractors and third parties with access to Dow’s network. Training is administered and tracked through online learning modules. Training topics include how to escalate suspicious activities including phishing, viruses, spams, deep fakes, insider threats, suspect human behaviors or safety issues. Based on role and location, some employees receive additional in-depth training to provide more comprehensive knowledge on potential risks related to their individual job responsibilities. Training is supplemented through regular Dow company-wide communications with frequent updates to educate on the latest adversary trends and social engineering techniques.\n\nAdditionally, Dow engages in cybersecurity crisis response simulations to assess Dow’s ability to adapt to information and operational technology threats. Improper or illegitimate use of Dow’s information system resources or violation of Dow’s information security policies and procedures is subject to disciplinary action. Dow’s security posture is supported by a comprehensive defense-in-depth strategy that relies on layers of technology including, but not limited to, Multi-Factor Authentication and Zero Trust principles to ensure that access to information and communication is vetted and secure.\n\nDow also utilizes internal and external audits and assessments, vulnerability testing, governance processes over outsourced service providers, active risk management and benchmarking against peers in the industry to validate Dow’s security posture. Dow also engages external firms to measure Dow’s NIST CSF maturity level.\n\n13\n\n[Table of Contents](#i2aef629ae28d4ab08017402fb32766d6_7)\n\nAs of the date of this report, no risks from cybersecurity threats, including those resulting from any previous cybersecurity incidents, have materially affected, or are reasonably likely to materially affect, the Corporation, including its business strategy, results of operations or financial condition. Although the Corporation has mature processes in place to identify and mitigate potential risks from cybersecurity threats, such risks cannot be completely eliminated. More information on the risks of cybersecurity threats and potential impact to the Corporation can be found in Item 1A. Risk Factors.\n\nGovernance\n\nRole of Management\n\nDow’s information systems organization is led by Dow’s chief information & digital officer, who reports to Dow's chief operating officer, and is responsible for administration of the cybersecurity and information security framework and risk management, including that of the Corporation, with oversight by the Dow Inc. Audit Committee.\n\nDow’s chief information & digital officer has formal education in information technology and more than 30 years of experience in information systems and technology, including as the vice president of Global Information Technology at Cargill, Incorporated, prior to joining Dow. The chief information & digital officer receives regular updates on cybersecurity matters, results of mitigation efforts and cybersecurity incident response and remediation.\n\nDow management responsible for developing and executing its cybersecurity policies is comprised of individuals with either formal education and degrees in information technology or cybersecurity, or with experience working in information technology and cybersecurity, including relevant experience in security related industries. Additionally, leaders in Dow’s information technology function receive periodic training and education on cybersecurity related topics. Certain leaders also obtain industry certifications, such as Certified Information Systems Security Professional or Certified Information Security Manager.\n\nDow’s Cyber Security Operations Center (“CSOC”) serves as the central point for all cybersecurity incidents and reporting, including incidents that directly target employees or Dow internal information systems and incidents originating from third parties. The CSOC provides end-to-end operations for purposes of monitoring, detecting, alerting and responding to cybersecurity incidents. The CSOC evaluates each incident in terms of its impact on Dow’s and the Corporation's operations, ability to conduct business with customers and suppliers, brand reputation and health, safety or the environment, and the speed and degree to which the incident has been contained. The CSOC is also responsible for activating the containment and resolution efforts and third-party service providers are engaged where appropriate to support Dow through the resolution of the incident.\n\nThe CSOC reports all cybersecurity incidents to Dow’s Materiality Assessment Team, which includes senior representatives from information technology, finance, legal and other relevant business functions. If the Materiality Assessment Team initially assesses that a cybersecurity incident may be material, the CSOC immediately notifies Dow's Cybersecurity Executive Steering Team for final determination of materiality. Dow's Cybersecurity Executive Steering Team consists of Dow's chief operating officer; chief financial officer; chief information & digital officer; chief information security officer; senior vice president, operations, manufacturing & engineering; chief technology & sustainability officer; vice president of government affairs; and general counsel. The CSOC escalates incidents with significant impact and pervasiveness to Dow’s Corporate Crisis Management Team for further action. After initial identification, the CSOC monitors all cybersecurity incidents for changes in degree of impact or pervasiveness to ensure timely escalation and response. Decisions of Dow's Cybersecurity Executive Steering Team are communicated through established governance channels, including reporting to Dow's Audit Committee. This process is integrated into Dow’s overall incident response and risk management framework, ensuring alignment between operational response and strategic oversight.\n\nRole of the Corporation's Board\n\nThe Corporation's Board of Directors (\"Board\") recognizes the importance of cybersecurity in safeguarding the Corporation’s sensitive data. The Board is responsible for overseeing overall risk management for the Corporation, including review and approval of the enterprise risk management approach and processes implemented by management to identify, assess, manage and mitigate risk.\n\nThe Corporation’s Board receives information and updates periodically with respect to the effectiveness of Dow’s cybersecurity and information security framework, data privacy and risk management, which includes that of the Corporation. The Board also receives updates on material incidents relating to information systems security, including cybersecurity incidents.\n\n14\n\n[Table of Contents](#i2aef629ae28d4ab08017402fb32766d6_7)"}