Code Of Business Principles And Code Policies

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UnileverCode of Business Principlesand Code ardingInformationEngagingExternally01

ContentsThe Code and our Standard of ConductCountering CorruptionOur Framework04Avoiding Conflicts of Interest16Occupational Health & Safety24A message from Alan Jope05Anti-Bribery17Respect, Dignity & Fair Treatment25The Code of Business Principles06Gifts & Hospitality19Living the Code08Accurate Records, Reporting & Accounting20Legal Consultation10Responsible Risk Management12Responsible Innovation13Product Safety & Product Quality14Safeguarding InformationRespecting PeopleProtecting Unilever’s Physical & FinancialAssets & Intellectual PropertyAnti-money Laundering2122Engaging ExternallyGlossaryProtecting Unilever’s Information28Responsible Marketing35Preventing Insider Trading29Responsible Sourcing & Business Partnering36Competitors’ Information30Fair Competition37Personal Data & Privacy31Contact with Government, Regulators &39Use of Information Technology32Non-governmental Organisations (NGOs)Political Activities & Political Donations41External Communications –42Glossary44The Media, Investors & AnalystsThe Codeof ngExternallyExternallyGlossary0202

The Code andour Standardof ConductOur FrameworkA message from Alan JopeThe Code of Business PrinciplesLiving the CodeLegal ConsultationResponsible Risk ManagementResponsible InnovationProduct Safety & Product QualityThe Codeof ngExternallyExternallyGlossary0303

Our FrameworkOurValuesOur Values of Integrity,Respect, Responsibility andPioneering are the simpleststatement of who we are.They govern everythingwe do.The Codeof BusinessPrinciplesCode ofBusinessPrinciplesCodePoliciesOur Code of BusinessPrinciples is a simple ethicalstatement of how we shouldoperate. We publish thisexternally and expect allothers who work with usto set themselves equally highprinciples.Our Code Policies define theethical behaviours that we allneed to demonstrate whenworking for Unilever. Theyare mandatory. While theseare for internal use, we alsopublish them externally insupport of ernallyExternallyGlossary0404

Foreword from Alan JopeWelcome to the most importantdocument we have at Unilever– our Code of Business Principles.up’ in this connected, social media worldhas become more complicated than ever.What’s more, the accelerating pace ofchange, and the greater speed with whichWhen I think of my time at Unilever, andwe must operate, often intensifies theseconsider why I have stayed for over 30challenges.years, I put it down to two core reasons: ourgeographical diversity and the values of thebusiness. Values that give us the instinct todo the right thing and to treat each otherwith respect.The Code of Business Principles is ourguidebook for putting our values intopractice. It sets out a clear standard ofconduct to ensure that we always makethe right choice, providing a frameworkHaving a strong set of values that respectof simple “musts” and “must nots”. It’s apeople, society, and the planet has alwaysdocument which not only protects Unilever,been at the heart of Unilever, and willand each and every one of us, but will helpcontinue to be critical to building ourus to have a meaningful impact on the livespurpose-led, future-fit company. Our licenceof millions of people across our value chain.to operate and our ability to competesuccessfully, are dependent on each andevery one of us living these values, day inand day out.Much of Unilever’s strength lies in the sharedvalues of our people. Behaving with integrityis part of who we are. Thank you for yourdiligence and for helping to create a fairerYet we know that in this volatile andand more principled world as we workunpredictable world, we face numeroustowards delivering our vision of being thechallenges in doing so. Challenges, but notglobal leader in sustainable business.excuses. Many of the countries in which weoperate rank poorly in global corruptionindices. The digital world increasinglypresents us with new considerations formanaging cyber and data security, andhow our company and our brands ‘showThe Codeof BusinessPrinciplesRead and re-read our Code.It matters.Thank lyExternallyGlossary0505

The Code of Business Principles (1 of 2)Code of Business Principles and Code PoliciesIntroductionEmployeesAt Unilever we believe in growingresponsibly and sustainably.Unilever is committed to a workingenvironment that promotes diversity,inclusion, life-long learning and equalopportunity, including for those withdisabilities. We believe in a workplacewhere there is mutual trust, respect forhuman rights and no discrimination.We support the physical and mentalwellbeing of our employees, ensuringsafe working conditions.Our Code of Business Principles defines thenon- negotiables for all our employees. Itcodifies our values, making clear what isexpected from our people.Through living our Code, we will bring ourvalues and purpose to life, every day ineverything we do.Standard of ConductWe conduct our operations with honesty,integrity and openness, and with respectfor the human rights and interests ofour employees.We shall similarly respect the legitimateinterests of those with whom we haverelationships.We are committed to providingtransparency across all our operationsensuring stakeholders trust what we do.Obeying the LawUnilever companies and employeesare required to comply with the lawsand regulations of the countries in whichwe operate.The Codeof BusinessPrinciplesWe will recruit, employ and promoteemployees on the sole basis of thequalifications and abilities needed for thework to be performed.We will provide employees with a totalremuneration package that meets orexceeds the legal minimum standardsand in line with industry standards inthe markets in which we operate. We arecommitted to giving employees a livingwage, ensuring that they can meet theireveryday needs.We will provide transparent, fair andconfidential procedures for employeesand third parties to raise concerns. We willnot retaliate against whistle-blowers oremployees that raise issues with us.ConsumersUnilever is committed to providingpurposeful branded products and serviceswhich consistently offer value in terms ofprice and quality, and which are safe fortheir intended use. Products and serviceswill be accurately and properly labelled,advertised and communicated.ShareholdersBusiness PartnersUnilever is committed to establishingmutually beneficial relations with oursuppliers, customers and businesspartners. In our business dealingswe expect our partners to adhere tobusiness principles consistent with ourown. This means compliance with ourthird party policies and a commitmentto working with us to address issues thatnegatively impact society and the planet.We will work with these partners to raisestandards so that their employees arepaid a living wage and are not subjectto forced, compulsory, trafficked orchild labour.Unilever will conduct its operations inaccordance with internationally acceptedprinciples of good corporate governance.We will provide timely, regular andreliable information on our activities,structure, financial situation andperformance to all shareholders.We will not use any form of forced,compulsory, trafficked or child labour.We respect the dignity of the individualand the right of employees to freedom ofassociation and collective bargaining.We will maintain good communicationswith employees through company-basedinformation and consultation nallyExternallyGlossary0606

The Code of Business Principles (2 of 2)Code of Business Principles and Code PoliciesCompliance – Monitoring –ReportingCompliance with these principles is anessential element in our business success.The Unilever Board is responsible forensuring these principles are appliedthroughout Unilever.The Chief Executive Officer is responsiblefor implementing these principles and issupported in this by the Global Code andPolicy Committee which is chaired by theChief Legal Officer.Day-to-day responsibility is delegatedto all senior management of thegeographies, divisions, functionsand operating companies. They areresponsible for implementing theseprinciples, supported by local BusinessIntegrity Committees.Assurance of compliance is given andmonitored each year. Compliance issubject to review by the Board supportedby the Corporate ResponsibilityCommittee and for financial andaccounting issues the Audit Committee.Any breaches of the Code must bereported. The Board of Unilever will notcriticise management for any loss ofbusiness resulting from adherence tothese principles and other mandatorypolicies. Provision has been madefor employees to be able to reportin confidence and no employee willsuffer as a consequence of doing so.The Codeof BusinessPrinciplesCommunity InvolvementPublic ActivitiesConflicts of InterestsUnilever strives to be a trusted corporatecitizen and, as an integral part of society,to fulfil our responsibilities to the societiesand communities in which we operate.Unilever companies are encouraged topromote and defend their legitimatebusiness interests.All employees and others working forUnilever are expected to avoid personalactivities and financial interests whichcould conflict with their responsibilities tothe company.InnovationIn our scientific innovation to meetconsumer needs we will respect theconcerns of our consumers and of society.We will work on the basis of soundscience, applying rigorous standardsof product safety.CompetitionUnilever believes in vigorous yet faircompetition and supports the developmentof appropriate competition laws. Unilevercompanies and employees will conducttheir operations in accordance with theprinciples of fair competition and allapplicable regulations.The PlanetUnilever is committed to makingcontinuous improvements in themanagement of our environmental impactand to the longer-term goal of developinga sustainable business.Unilever will work in partnership withothers to promote environmental care,increase understanding of environmentalissues and disseminate good nilever will co-operate with governmentsand other organisations, both directlyand through bodies such as tradeassociations, in the developmentof proposed legislation and otherregulations which may affect legitimatebusiness interests.Unilever neither supports politicalparties nor contributes to the funds ofgroups whose activities are calculated topromote party interests.Bribery & CorruptionUnilever does not give or receive,whether directly or indirectly, bribes orother improper advantages for businessor financial gain. No employee may offer,give or receive any gift or payment whichis, or may be construed as being, a bribe.Any demand for, or offer of, a bribe mustbe rejected immediately and reported tomanagement.Employees must not seek gain forthemselves or others through misuse oftheir positions.DataUnilever is committed to the responsible,ethical and fair use of data.We collect and use data in line with ourvalues, applicable laws and with respectfor privacy as a human right.NoteIn this Code the expressions ‘Unilever’and ‘Unilever companies’ are used forconvenience and mean the Unilever Groupof companies comprising Unilever N.V.,Unilever PLC and their respective subsidiarycompanies. The Board of Unilever means theDirectors of Unilever N.V. and Unilever PLC.Unilever accounting records andsupporting documents must accuratelydescribe and reflect the nature of theunderlying transactions. No undisclosedor unrecorded account, fund or asset willbe established or agingExternallyExternallyGlossary0707

Living the Code (1 of 2)Code of Business Principles and Code PoliciesAs a purpose-led company, ourvalues are the foundation of oursuccess and essential to achievingour ambition of making sustainableliving commonplace.Living the Code means to put ourvalues into practice and reiterateour commitment to doing good;this helps us to deliver valuewith values. Our consumers andcustomers trust us for doingbusiness with integrity. This is oneof our greatest assets, and tomaintain our reputation, requiresthe highest standards of behaviour.Unilever’s Code of BusinessPrinciples (the Code), and thepolicies that support it (CodePolicies), set out the standardsrequired from all our employees.Unilever also requires its thirdparty business partners and theiremployees to adhere to businessprinciples consistent with our own.These expectations are set out inUnilever’s Responsible Sourcing andBusiness Partnering Policy that underpinour third-party compliance programme.The Codeof BusinessPrinciplesBreaching the Code or Code Policiescould have very serious consequencesfor Unilever and for individuals involved.Where illegal conduct is involved, thesecould include significant fines for Unilever,imprisonment for individuals andsignificant damage to our reputation.This Code Policy explains how to ensure theCode and all Code Policies are understoodand followed by all our employees andothers working for Unilever. It confirmseveryone’s responsibility to speak up andreport suspected or actual breaches, andoutlines how such situations must bem

Much of Unilever’s strength lies in the shared values of our people. Behaving with integrity is part of who we are. Thank you for your diligence and for helping to create a fairer and more principled world as we work towards delivering our vision of being the global leader in sustainable business. Read and re-read our Code. It matters. Thank you, Alan