Unilever

Code of Business Principles

and Code Policies
© Unilever 2024. Updated Edition 04.24A
Countering Respecting Safeguarding Engaging
Corruption People Information Externally 01
Contents
The Code and our Standard of Conduct Countering Corruption Respecting People

Our Framework 04 Avoiding Conflicts of Interest 16 Occupational Health & Safety 24

A message from Hein Schumacher 05 Anti-Bribery 17 Respect, Dignity & Fair Treatment 25

The Code of Business Principles 06 Gifts & Hospitality 18

Living the Code 08 Accurate Records, Reporting & Accounting 20

Legal Consultation 10 Protecting Unilever’s Physical & Financial 21

Responsible Risk Management 12

Assets & Intellectual Property

Responsible Innovation 13
Anti-Money Laundering and 22

Economic Sanctions
Product Safety & Product Quality 14

Safeguarding Information Engaging Externally Glossary

Protecting Unilever’s Information 28 Responsible Marketing 35 Glossary 44

Preventing Insider Trading 29 Responsible Sourcing & Business Partnering 36

Competitors’ Information 30 Fair Competition 37

Personal Data & Privacy 31
Contact with Government, Regulators & 39

Use of Information Technology 32 Non-governmental Organisations (NGOs)

Political Activities & Political Donations 41

External Communications – 42

The Media, Investors & Analysts

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The Code and
our Standard
of Conduct
Our Framework
A message from Hein Schumacher
The Code of Business Principles
Living the Code
Legal Consultation
Responsible Risk Management
Responsible Innovation
Product Safety & Product Quality

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Our Framework

Code of
Our Business Code
Values Principles Policies
Our Values of Integrity, Our Code of Business Our Code Policies define the
Respect, Responsibility and Principles is a simple ethical ethical behaviours that we all
Pioneering are the simplest statement of how we should need to demonstrate when
statement of who we are. operate. We publish this working for Unilever. They
They govern everything externally and expect all are mandatory. While these
we do. others who work with us are for internal use, we also
to set themselves equally high publish them externally in
principles. support of transparency.

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Foreword from Hein Schumacher
Welcome to the most important This document exists to protect our people,
document we have at Unilever our assets, our reputation, the communities
– our Code of Business Principles. in which we operate, our consumers,
customers and our partners right across our
Unilever’s high standards for how we do
value chain. It exists to make our company
business is one of my most enduring
stronger.
memories of working within the company at
the start of my career in the 1990s. Whether we have 25 years’ service or joined
only a matter of weeks ago, each of us
Whilst a lot has changed since then, our
must ensure we are familiar and fully up to
commitment to doing the right thing
date with our Code. Doing so ensures we
and treating people with respect and dignity
understand both our responsibilities and our
is reassuringly unchanged.
rights, and know when to speak up and

We have always been a purpose-driven raise concerns with confidence.

company and our success today,

Thank you for living and upholding our
tomorrow and into the future is built on our
Unilever Code of Business Principles today
shared commitment to always
and every day.
doing business with integrity.
Hein
This important document sets out the clear
standards of conduct we are all
required to uphold both individually and
collectively. It is there to ensure we make the
right choices as we go about our daily work
and it also provides clear guidelines
to help us prevent, detect and respond to
any concerns.

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 The Code of Business Principles (1 of 2)
Introduction Employees We will provide transparent, fair and Business Partners
Code of Business Principles and Code Policies

confidential procedures for employees

At Unilever we believe in growing Unilever is committed to a working and third parties to raise concerns. We will Unilever is committed to establishing
responsibly and sustainably. environment that promotes diversity, not retaliate against whistle-blowers or mutually beneficial relations with our
inclusion, life-long learning and equal employees that raise issues with us. suppliers, customers and business
Our Code of Business Principles defines the
opportunity, including for those with partners. In our business dealings
non- negotiables for all our employees. It
disabilities. We believe in a workplace we expect our partners to adhere to
codifies our values, making clear what is
where there is mutual trust, respect for Consumers business principles consistent with our
expected from our people.
human rights and no discrimination. Unilever is committed to providing own. This means compliance with our
Through living our Code, we will bring our We support the physical and mental purposeful branded products and services third party policies and a commitment
values and purpose to life, every day in wellbeing of our employees, ensuring which consistently offer value in terms of to working with us to address issues that
everything we do. safe working conditions. price and quality, and which are safe for negatively impact society and the
their intended use. Products and services planet. We will work with these partners
We will recruit, employ and promote
Standard of Conduct employees on the sole basis of the will be accurately and properly labelled, to raise standards so that their
advertised and communicated. employees are paid a living wage and
We conduct our operations with honesty, qualifications and abilities needed for the
are not subject to forced, compulsory,
integrity and openness, and with respect work to be performed.
trafficked or child labour.
for the human rights and interests of We will provide employees with a total Shareholders
our employees. remuneration package that meets or Unilever will conduct its operations in
We shall similarly respect the legitimate exceeds the legal minimum standards accordance with internationally accepted
interests of those with whom we have and in line with industry standards in principles of good corporate governance.
relationships. the markets in which we operate. We are We will provide timely, regular and
committed to giving employees a living reliable information on our activities,
We are committed to providing wage, ensuring that they can meet their structure, financial situation and
transparency across all our operations everyday needs. performance to all shareholders.
ensuring stakeholders trust what we do.
We will not use any form of forced,
compulsory, trafficked or child labour.
Obeying the Law We respect the dignity of the individual
Unilever companies and employees and the right of employees to freedom of
are required to comply with the laws association and collective bargaining.
and regulations of the countries in which We will maintain good communications
we operate. with employees through company-based
information and consultation procedures.

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 The Code of Business Principles (2 of 2)
Compliance – Monitoring – Community Involvement Public Activities Conflicts of Interests
Code of Business Principles and Code Policies

Reporting Unilever strives to be a trusted corporate Unilever companies are encouraged to All employees and others working for
citizen and, as an integral part of society, promote and defend their legitimate Unilever are expected to avoid personal
Compliance with these principles is an
to fulfil our responsibilities to the societies business interests. activities and financial interests which
essential element in our business success. and communities in which we operate. could conflict with their responsibilities to
The Unilever Board is responsible for Unilever will co-operate with governments the company.
ensuring these principles are applied and other organisations, both directly
throughout Unilever. Innovation and through bodies such as trade Employees must not seek gain for
In our scientific innovation to meet associations, in the development themselves or others through misuse of
The Chief Executive Officer is responsible
consumer needs we will respect the of proposed legislation and other their positions.
for implementing these principles and is
concerns of our consumers and of society. regulations which may affect legitimate
supported in this by the Global Code and
We will work on the basis of sound business interests.
Policy Committee which is chaired by the Data
science, applying rigorous standards
Chief Legal Officer. Unilever neither supports political Unilever is committed to the responsible,
of product safety.
parties nor contributes to the funds of ethical and fair use of data.
Day-to-day responsibility is delegated
groups whose activities are calculated to
to all senior management of the Competition promote party interests. We collect and use data in line with our
geographies, divisions, functions values, applicable laws and with respect
and operating companies. They are Unilever believes in vigorous yet fair
for privacy as a human right.
responsible for implementing these
competition and supports the development Bribery & Corruption
of appropriate competition laws. Unilever
principles, supported by local Business Unilever does not give or receive,
companies and employees will conduct Note
Integrity Committees. whether directly or indirectly, bribes or
their operations in accordance with the In this Code the expressions ‘Unilever’
Assurance of compliance is given and principles of fair competition and all other improper advantages for business and ‘Unilever companies’ are used for
monitored each year. Compliance is applicable regulations. or financial gain. No employee may offer, convenience and mean the Unilever
subject to review by the Board supported give or receive any gift or payment which Group of companies comprising Unilever
is, or may be construed as being, a bribe.
by the Corporate Responsibility The Planet PLC and its respective subsidiary
Committee and for financial and companies. The Board of Unilever means
Unilever is committed to making Any demand for, or offer of, a bribe must
accounting issues the Audit Committee. the Directors of Unilever PLC.
continuous improvements in the be rejected immediately and reported to
Any breaches of the Code must be management of our environmental impact management.
reported. The Board of Unilever will not and to the longer-term goal of developing Unilever accounting records and
criticise management for any loss of a sustainable business. supporting documents must accurately
business resulting from adherence to describe and reflect the nature of the
these principles and other mandatory Unilever will work in partnership with
others to promote environmental care, underlying transactions. No undisclosed
policies. Provision has been made or unrecorded account, fund or asset will
for employees to be able to report increase understanding of environmental
issues and disseminate good practice. be established or maintained.
in confidence and no employee will
suffer as a consequence of doing so.

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 Living the Code (1 of 2)
As a purpose-led company, our Breaching the Code or Code Policies Living the Code is a team effort. The Code
Code of Business Principles and Code Policies

values are the foundation of our could have very serious consequences for and Code Policies cannot cover every
Unilever and for individuals involved. eventuality, particularly as laws differ
success and essential to achieving
Where illegal conduct is involved, between countries. If specific situations
our ambition of making sustainable these could include significant fines for are not expressly covered, the spirit of the
living commonplace. Unilever, imprisonment for individuals and Code and Code Policies must be upheld
significant damage to our reputation. by exercising common sense and good
Living the Code means to put our judgement, always in compliance with
values into practice and reiterate This Code Policy explains how to ensure the applicable laws.
our commitment to doing good; Code and all Code Policies are understood
and followed by all our employees and
this helps us to deliver value Musts
others working for Unilever. It confirms
with values. Our consumers and everyone’s responsibility to speak up and
customers trust us for doing All employees must:
report suspected or actual breaches, and
business with integrity. This is one outlines how such situations must be • Ensure they know and understand
of our greatest assets, and to managed. Any failure to comply with the the requirements of our Code and
maintain our reputation, requires Code and any of the Code Policies is taken Code Policies
very seriously by Unilever and may result in
the highest standards of behaviour. disciplinary action, including dismissal and • Undertake relevant training (including
legal action. the completion of the annual Code
Unilever’s Code of Business declaration) as required by their Line
Principles (the Code), and the References in the Code and Code Policies Manager or Business Integrity Officer
policies that support it (Code to ‘employees’ include the following:
Policies), set out the standards • Follow the Code and Code Policies: if they
• Unilever employees, whether full time, are unsure of how to interpret these or
required from all our employees. have any doubts about whether specific
part time, fixed term, permanent or
Unilever also requires its third- trainees behaviours meet the standards required
party business partners and their they must seek the advice of their Line
employees to adhere to business • Persons with statutory director roles Manager or Business Integrity Officer
principles consistent with our own. or equivalent responsibilities
• Immediately report actual or potential
• Unilever employees of joint ventures breaches of the Code or Code Policies,
These expectations are set out in
whether relating to them, colleagues
Unilever’s Responsible Sourcing and
• Employees of new acquisitions, from the or people acting on Unilever’s behalf
Business Partnering Policy that underpin
date that the company is acquired and whether accidental or deliberate.
our third-party compliance programme.
This includes instances where business
partners’ behaviour may not meet the
same standards

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 Living the Code (2 of 2)
Musts In addition, those at Manager level and • Ensure that anyone who raises Must nots
Code of Business Principles and Code Policies

above must: concerns, or highlights potential or

Their Line Manager is usually the right actual breaches, receives support and Employees must not:
person to report potential or actual • Lead by example, setting a strong tone respect and that there is no retaliation
breaches. If this is not appropriate, they from the top, showing they are familiar against them • Ignore or fail to report situations where
must talk to one of the following: with the Code and Code Policies and they believe there is or may be a breach
taking steps to embed a culture of • Ensure that concerns raised are taken of the Code or Code Policies
– Their Business Integrity Officer integrity across all operations seriously and addressed promptly,
treating related information with • Attempt to prevent a colleague from
– A member of the Business Integrity • Ensure that all their team members, discretion and discussing them with reporting a potential or actual breach or
Committee in the country where including new joiners: their Business Integrity Officer as ask them to ignore an issue
concerns occur soon as possible to determine the
– Have read the Code and Code Policies appropriate course of action including • Retaliate against any person who
– Unilever’s confidential Code Support whom else to inform reports a potential or actual breach
Line (where allowed by local law), – Have completed any related
by telephone or web using the mandatory training • Collaborate further and complete any • Discuss any potential or actual breach
telephone number or web address documentation (e.g. case information under investigation with other persons,
communicated locally – Understand how to raise concerns and lessons learnt) as may be unless this has been cleared with the
and / or report actual or suspected required of them by their Business investigation team
• If asked not to report a potential breach breaches Integrity Officer
by their Line Manager or another
employee, they must immediately • Deliver training that the Business • Insofar as a breach may have occurred
report it to their Business Integrity Integrity Committee or their Line within their operations, consider what
Officer and / or the Code Support Line Manager has asked of them, e.g. additional communications, training
Business Integrity Moments, face-to- or changes to business controls and
face briefings and team discussions procedures are necessary to reduce the
likelihood of similar breaches occurring
• Offer guidance and support about the
Code and Code Policies to their team
where needed and escalate unresolved
questions to their Business Integrity
Officer

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 Legal Consultation (1 of 2)
Employees must at all times comply
Code of Business Principles and Code Policies

with laws and regulations that apply

to the countries in which Unilever
operates. Ignorance of the law is no
excuse. Timely legal consultation is
essential to ensure that Unilever’s
legitimate business interests and
opportunities are protected.

This Code Policy sets out how and in

what circumstances employees
must seek legal advice from Unilever
Legal Group.

Musts

Heads of all Business Groups, Business

Units, Global Business Units, Countries,
or members of Senior Leadership teams
must ensure the relevant Legal Business
Partner is a member of that leadership
team upon request and / or that they
have an open invitation to attend all
team meetings and receive copies of all
associated agendas and minutes.

All employees must:

• Immediately notify their Line Manager

(or other appropriate person – see
Code Policy on Living the Code) and
take legal advice if they suspect or
discover any illegal activity in relation
to Unilever’s operations or associated
activities involving third parties.

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 Legal Consultation (2 of 2)
Musts Communication with government - Claims, brands, trademarks, - Bribery and corruption – Bribery or
Code of Business Principles and Code Policies

or regulatory bodies about marketing materials – Product claims corruption issues, including related
• Promptly seek advice from their investigations, including unexpected and marketing materials, including allegations or uncertainty about
Legal Business Partner in the following investigations, or where Unilever advertising, promotional materials, situations that may have bribery or
situations: is seeking regulatory action, such packaging and labelling, trade corruption implications (see Code
as non-compliant labelling actions materials, advertorials, point- of- Policy on Anti-Bribery)
- Commercial contracts, leases, licences through local governmental bodies sale materials, and web content;
and transactions – Commercial (see Code Policy on Contact with Clearance for use of all brand names, Employees must use their common sense
contracts for goods or services (unless Government, Regulators and Non- marks, logos, slogans, celebrity and judgement in situations not covered
Legal Group and/or BG General Governmental Organisations) endorsements and sponsorships; above: if they are unsure, they must
Counsel has expressly delegated Maintenance, protection and always err on the side of caution and
authority to the business or set up - Competition/antitrust – Compliance disposal of trademarks, copyrights consult Legal Group.
a route for direct consultation of an issues or questions involving and domain names used by the
external legal advisor); Contracts competition/antitrust laws, such as business; Competitor challenges to
relating tointellectual property, trade terms, exclusivity arrangements claims, brands, trademarks either by Must nots
such as, licences for technology, or pricing; Meetings, contacts, or against a Unilever company
trademarks, joint development collaboration, agreements or other Employees must not
or technical assistance contracts; activity, including participation - Employment – Issues relating to non-
Treasury transactions, for example, in trade associations or industry compete obligations, employment • Do anything that Legal Group has
raising equity or debt, asset leasing, groupings (formal and informal or ad disputes and terminations and advised is illegal and/ or unlawful.
derivative transactions (such as hoc), which may involve the exchange non routine employment contract Where an activity is not illegal
currency hedging or interest rate of information with a competitor terms Safety – Product tampering or and / or unlawful but legal advice
swaps) or guarantees of Treasury or restrictions on competition (see counterfeiting; Consumer complaints highlights significant risks for Unilever,
transactions; Transactions involving Code Policies on Fair Competition, that may lead to legal disputes; such as litigation, they must not
mergers, acquisitions, disposals or Competitors’ Information) Potential product recalls; Consumer, proceed without express senior line
joint ventures product, workforce or environmental management authorisation
- Communication – Press releases that safety incidents that could have legal
- Litigation and regulatory action – could impact Unilever’s reputation implications • Appoint a private investigator without
Civil litigation, such as employment or create legal liability, or contain prior approval from their General Counsel
or contractual disputes, whether ‘inside’ or ‘price sensitive’ information - Legal or governance structures –
threatened or actual, by or against (see Code Policy on Preventing Changes to, or issues around, legal or Employees outside Legal Group must not
a Unilever company or employee, Insider Trading) governance structures at geographic
including commencement of or or corporate level, such as changes • Appoint, manage or remove external
settlement of such litigation; Criminal in capital structures or Board legal counsel or pay any legal fees that
prosecutions, whether threatened membership, public company filings differ from the fee structures agreed by
or actual, by or against a Unilever and arrangements/relationships with Legal Group
company or employee, or at third-party shareholders
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Unilever’s instigation;

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 Responsible Risk Management
Unilever takes an embedded approach Musts - Key business risks for which they are
Code of Business Principles and Code Policies

to risk management which puts risk and responsible are identified;

opportunity assessment at the core of All managers and above must implement
the leadership team agenda. Unilever Unilever’s Principles of Risk Management - How those risks are being managed is
defines risks as actions or events that as follows: reviewed;
have the potential to impact our ability to
- Any gaps in their desired risk appetite
achieve our objectives. Unilever identifies • Accountability: they must identify and are identified.
and mitigates downside risks such as loss manage the risks that relate to their role
of money, reputation or talent as well • Perform regular reviews and ensure
as upside risks such as failure to deliver • Risk Appetite: they must determine risks are mitigated as desired.
strategy if it does not strengthen brand the level of risk, they are prepared to
equities or grow in growing channels. accept to guide them in deciding what Heads of Countries must:
mitigation should be taken
Unilever’s Risk Management approach • Highlight significant country regulatory
• Risk Mitigation: they must put adequate or statutory compliance risks to either
is embedded in the normal course of
controls in place, and ensure that they the relevant Business Group(s) or the
business with a set of global Principles
are operational, in order to deliver their Chief Legal Officer;
of Risk Management with local
objectives
implementation.
• Highlight significant country customer
Where leadership teams of key global or channel risks to either the relevant
Its structural elements include: functions are responsible for any of Business Group(s) or the Chief Digital &
Unilever’s Key Business Risks, they must: Commercial Officer
• Governance of Unilever, organisational
structure and delegation of authority • Define the risk and ensure that
mitigating actions are taken as All project leaders of transformational
• Vision, Strategy and Objectives projects must, together with their teams:
Risk management is integral required
to Unilever’s strategy and to • Code of Business Principles, Code • Identify the key risks associated with
• Ensure supporting documentation is
the achievement of Unilever’s Policies and Standards their project achieving its objectives
available
longterm goals. Our success as • Risk and Control Frameworks • Prepare risk mitigation plans
Leadership teams of Business Groups,
an organisation depends on our
• Performance management and Business Operations, Unilever • Review progress with the project
ability to identify and exploit the International, Africa, and any listed
operational processes execution steering group.
opportunities generated by our entities where risk assessments are a
business and the markets Unilever • Compliance and assurance activities. regulatory requirement must:
operates in.
• Complete an annual holistic business
risk assessment during which:

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 Responsible Innovation
Unilever conducts responsible, safe and • Uphold Unilever’s commitment to
Code of Business Principles and Code Policies

sustainable research and innovation, eliminate animal testing without

which fully respects the concerns of compromising on consumer safety (see
our consumers and society. In meeting Developing Alternative Approaches to
consumer needs, Unilever’s innovations Animal Testing)
are based on sound science and
technology, and reflect high standards • Ensure the integrity, robustness,
and ethical principles. objectivity and transparency of all
scientific research and collaborations
Unilever has global standards that apply with external partners (see Unilever’s
to all research and innovation, including Position on Science with Objectivity and
on: the safe and sustainable design of Integrity)
new products, processes and packaging;
product and brand development; • Maintain and make accessible records
open innovation collaborations; and of all research, including study protocols
publication of our scientific research. and data, and their interpretation and
decisions made

Musts • Raise any concerns about actual or

potential non-compliance with this
All employees involved in scientific research Code Policy with their Business Integrity
and innovation activity must comply with Officer, Line Manager or their relevant
all standards relevant to their area of work, Business Partner in R&D
notably in order to:

• Ensure that risks for consumer safety, Must nots

occupational safety and the environment
Innovation is fundamental to are suitably assessed and managed Employees must not:
Unilever’s business success and • Deliver presentations or publications
• Ensure appropriate specifications of raw
a core part of our global strategy. that have not been approved via
materials, products and packaging
The integrity and objectivity of internal clearance procedures
our Science are a key foundation • Ensure effective management of
consumer safety risks from food allergens • Collaborate with third parties outside
for our approach to responsible a structured and approved contractual
innovation. Safety is non- • Ensure research on human subjects framework
negotiable. is conducted to the highest ethical
standards

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 Product Safety & Product Quality
Unilever’s reputation and success Musts
Code of Business Principles and Code Policies

is founded upon providing safe

Employees must:
high quality products and services
that meet all applicable standards • Apply effective processes to measure
and regulation, both internal and and record product and process
external within the end to end performance and, where appropriate,
take effective preventative steps or
value chain.
corrective action to assure great product
quality experiences for our customers
All employees have a role to play and consumers
in ensuring that the products and
• Promptly and proactively report all
services we provide meet and /
product safety or product quality
or exceed the expectations of our concerns to their Line Manager or
consumers and customers. Business Integrity Officer

Unilever will take prompt and

timely action to recall products or Must nots
services that don’t meet our own
Employees must not:
high standards or those required by
the marketplace. • Knowingly produce or distribute
products, including promotional items,
or services that could adversely impact
employees’ or consumers’ health,
endanger customers or adversely
impact Unilever’s brand reputation

• Take decisions about product safety or

product quality without the authority
and / or sufficient knowledge to do so

• Respond to customers or consumers

about the product quality or safety of
products without authorisation to do so

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Countering
Corruption
Integrity defines how we behave, wherever
we are. It guides us to do the right thing for
the long-term success of Unilever.

Avoiding Conflicts of Interest

Anti-Bribery
Gifts & Hospitality
Accurate Records, Reporting & Accounting
Protecting Unilever’s Physical & Financial
Assets & Intellectual Property
Anti-Money Laundering and Economic Sanctions

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 Avoiding Conflicts of Interest
Conflicts of interest can have a - hold investments other than in • Follow the process outlined here competitors (see Code Policies on
Code of Business Principles and Code Policies

significant negative impact on the publicly traded pension funds, index to immediately disclose an actual, Fair Competition and Competitors’
reputation and effectiveness of linked or tracker funds that represent: perceived or potential conflict of interest Information); and / or
to their Business Integrity Officer who
Unilever, its business and its people. - Substantial interests in a - Create any liability for Unilever.
will determine the best way to manage
They arise when an employee allows competitor, State controlled or The employee must inform the other
the situation in consultation with the
their actual, perceived or potential influenced entity, or any other third organisation that they take up this
employee’s Line Manager
party relevant to Unilever business position on a personal basis, with no
personal, financial or non-financial
(5% of the net worth of any of these • Follow the same process if they are responsibility for Unilever and that any
interests to affect their objectivity fees or benefits that arise from their
entities) interested in taking up, in a personal
when performing their job at Unilever. capacity, a proposed directorship (or engagement are not passed on
- Any interest in a third party if equivalent) of another organisation, to Unilever
This Code Policy sets out what they, or one of their team, are whether commercial or not-for-profit,
employees must do to prevent and involved in engaging, monitoring including roles in trade associations and Must nots
to manage these situations. or investigating the third party’s roles for public bodies. This obligation
performance extends to new joiners that hold Employees must not:
A conflict of interest may arise, and
directorships and have not disclosed
disclosure is required, when an employee: • Produces, promotes or advises on
them as part of the recruitment process • Accept appointments, debate, vote,
• Hires, manages, or has an influence on products or services that could be in or participate in any decision-making
the workload, performance assessment, direct competition with Unilever. This The above disclosure requirements process or activity when a conflict of
granting of approvals and / or reward prohibition extends to paid or unpaid excludes roles of school governors, interest exists or might arise before their
of someone with whom they have a engagements to advise on products, governing positions in amateur sporting Business Integrity Officer has provided
close personal relationship services, processes or systems that may or recreational groups, and directors clearance
be relevant to Unilever. of property/housing blocks in which an
• Accepts or performs a Public Official employee lives • Take, or divert to others, any business
role, or has a family member or a close • Allows their non-financial interests opportunities that arise in the course of
personal contact who is a Public Official such as personal values, beliefs, • Obtain written approval from the Chief doing their job at Unilever that could be
with the ability to take decisions that welfare and political views to take Legal Officer and the Chief Business of interest to Unilever
could impact Unilever business precedence over Unilever’s lawful and Integrity Officer, before becoming a
ethical expectations, affecting their director of any publicly listed company • Misuse their position in Unilever to
• Has a close personal interest in the
performance or objectivity at work advance personal interests
business of competitors or other • Ensure that external commitments
third parties relevant to Unilever. This do not: • Hire, contract or engage any individual
includes cases where the employee, Musts or organisation without ensuring they
their family members or a close - Detract them from their commitment
are free of conflict of interest with
personal contact: Employees must: and contribution to Unilever
Unilever
- work for or provide any services to - Provide access to commercially
• Ensure Unilever is best placed to benefit • Hire or retain the services of former
competitors or to any other third sensitive information concerning
from potential business opportunities Public Officials without following
parties relevant to Unilever’s business actual or potential Unilever
Unilever’s Principles on ‘revolving doors’.

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 Anti-Bribery
Musts Must nots
Code of Business Principles and Code Policies

Employees must: Employees must not directly or indirectly

(e.g. via suppliers, agents, distributors,
• Always make clear, internally and consultants, lawyers, intermediaries or
when dealing with third parties, that anyone else):
Unilever has a zero tolerance approach
• Offer or give bribes or improper
to bribery and corruption and will not
advantages (including facilitation
(directly or indirectly) offer, pay, seek
payments) to any public official or other
or accept a payment, gift or favour
individual or third party, which are,
to improperly influence a business
or give the impression that they are,
outcome
intended to influence decisions by any
• Immediately notify their Business person about Unilever
Integrity Officer and Business Group
• Request or receive bribes or improper
and Country General Counsel if they
advantages from any third party, which
become aware of any suggested or
are, or give the impression that they
actual payment or other transaction
may be, intended to influence decisions
which has the potential to be in breach
by Unilever about that third party
of this Code Policy
To support global efforts to fight Unilever’s commitment to doing In exceptional situations where
• Follow Unilever’s third party compliance
corruption, most countries have business with integrity requires policies and controls in accordance with
employees cannot escape imminent
laws that prohibit bribery: many consistently high global standards: threat to their life, liberty, or physical
the Responsible Sourcing and Business
harm without meeting a demand for
apply these ‘internationally’ to our zero-tolerance approach Partnering Code Policy
payment, such a payment may be made
behaviour beyond their borders. towards bribery and corruption but those involved must immediately
• Use electronic communications or
A breach of such laws may result in applies to all Unilever operations, e-government solutions (in areas report full details to their Business
legal and financial consequences regardless of local business such as licencing, procurement, taxes, Integrity Officer and Business Group
for Unilever and individuals. practices, and prohibits both public brand protection, etc) or any other and Country General Counsel in the
and commercial bribery (e.g. to or means available to reduce face-to-face country where the incident occurred.
Dealings with public officials are
interactions with public officials and the This is to ensure that the matter can be
particularly high risk: even the from any third party).
connected risks of bribe solicitation fully investigated, necessary financial
appearance of illegal conduct records kept, and further steps taken
could cause significant damage to This Code Policy covers what
where appropriate (see also Code Policy
employees must and must not do to on Accurate Records, Reporting and
Unilever’s reputation.
meet Unilever requirements. Accounting).

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 Gifts & Hospitality (1 of 2)
All Unilever’s relationships must Musts
Code of Business Principles and Code Policies

reflect its ongoing commitment to

doing business with integrity. Employees must:

Hospitality can play a positive • Apply this Code Policy in good faith to
role in building relationships ensure gifts and hospitality are never
considered to be excessive, confer
with customers, suppliers and improper advantage or create an
other third parties. Likewise, it is actual or perceived conflict of interest
sometimes appropriate to offer (see Code Policies on Anti-Bribery and
reasonable gifts, e.g. in the context Avoiding Conflicts of Interest)
of promotional events or product • Familiarise and observe the local
launches. However, as accepting monetary limits that Unilever has set
or receiving gifts and hospitality separately for gifts and for hospitality,
can be open to abuse or generate unless exempted in accordance with
actual or perceived conflicts of this Code Policy
interest, this should occur sparingly
and always be legitimate and
proportionate in the context of
Unilever’s business activities.
This Code Policy sets out
responsibilities of employees in
relation to gifts and hospitality. It
makes clear what forms of gifts and
hospitality are always prohibited. It
also explains in what circumstances
gifts or hospitality may legitimately
be given or received.

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 Gifts & Hospitality (2 of 2)
Musts • Ensure that all gifts by employees that Employees are not required to record Must nots
Code of Business Principles and Code Policies

take the form of Unilever branded such hospitality centrally, but must keep
merchandising materials must be their own records for inspection and
Gifts legitimate and proportionate ensure expenditure associated with any
Employees must not:

hospitality provided by, or on behalf of, • Discuss, offer or receive any gifts or
Employees must:
Unilever is approved using Unilever’s hospitality activity involving public
• Ensure that any gifts offered (other
Hospitality standard local expense processing and officials or their family members
than Unilever branded merchandise) clearance systems. without prior clearance from their
Employees must: Business Integrity Officer
or received do not exceed the local
In exceptional circumstances where
monetary limits for gifts, are one- • Ensure that hospitality is only offered or • Offer or accept any gifts or hospitality,
employees seek to offer or accept
off or irregular in nature and always accepted if: or any other favours which are intended
hospitality above the local monetary
comply with the Code Policy on or might be seen to influence business
- There is a legitimate business interest limits for hospitality, they must:
Avoiding Conflicts of Interest. Although decisions or create an obligation to do
employees are not required to record in doing so
• Check their Line Manager supports the something in return
such gifts centrally, they must keep proposal
- Its value does not exceed the local
their own records for inspection. All • Offer or accept any gifts that are in cash
monetary limits for hospitality; and
exceptions require prior clearance by • Obtain clearance from their Business or a cash equivalent, such as lottery
their Business Integrity Officer - It remains one-off or irregular in Integrity Officer; and tickets, gift certificates, vouchers, loans,
nature guarantees or any other granting of
• Ensure that if they are offered a gift • Once approval is received, ask the
credit, shares or options
that exceeds the local monetary limits - It is in the form of a locally hosted third party to confirm that the offer or
for gifts they must politely decline and meal, attendance at, or participation acceptance of such hospitality also • Offer or accept any hospitality involving
explain the Unilever rules. In exceptional in an organised ‘team-building’ complies with its equivalent gifts and overnight stays or foreign travel without
situations where such gifts have to occasion, local cultural or sporting hospitality policy prior written clearance from their
be accepted to avoid causing serious event, local industry award Business Integrity Officer
offence, or circumstances genuinely In other circumstances where employees
ceremony, business site visit or similar
preclude their return, employees must: are offered or asked for hospitality that • Offer or accept any hospitality that is
responsible activity
exceeds relevant local monetary limits for not consistent with the Code Policy on
– Obtain clearance from their Business - Usual business contacts from Unilever hospitality they must politely decline by Respect, Dignity and Fair Treatment, or
Integrity Officer; and and other parties are physically reference to this Code Policy. may cause offence under local norms
present and customs
– Where appropriate take steps for the
gift to be donated to charity All clearances from their Business Integrity
Officer referred to in this Code Policy
must be obtained following the gifts
and hospitality disclosure process
available here

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 Accurate Records, Reporting & Accounting
The financial reports and other Musts • Co-operate fully, openly and honestly • Properly document assumptions that
Code of Business Principles and Code Policies

information that Unilever with internal/external auditors, tax underpin accounting records, especially
Employees must: authorities and other regulators those relating to provisions, journal
maintains internally and the
entries and contingent liabilities,
financial information it provides • Ensure they are aware of all information including tax
• Record all transactions accurately,
to shareholders, regulators and completely and promptly relevant to their work
other stakeholders must be All Senior Leadership must complete
• Only perform transactions, such as Employees who are responsible for quarterly and annual Financial Reporting
accurate and complete. reporting financial and other business
buying, selling or transferring goods/ Declarations in line with instructions
assets, for which they are authorised information must: issued by Unilever Financial Group.
Our records provide valuable
information for the business and • Ensure transactions they approve • Comply with all applicable laws, for
evidence of our actions, decisions are legitimate and based on valid example, those regarding financial Must nots
and obligations. Procedures and documentation statements, tax and environmental
requirements Employees must not:
processes must be in place to
• Notify their Business Integrity Officer and
ensure that underlying transactions the Head of Finance of any potential • Adhere to all applicable external • Do anything to artificially inflate or
are properly authorised and fraud or arrangements to facilitate tax reporting standards and regulations, shift sales or profit between reporting
accurately recorded. evasion, or other misrepresentation of such as international and national periods
accounting or other information, or if a accounting standards, stock market
Any failure to record transactions ‘facilitation payment’ has been paid to listing standards and rules, financial • Create, maintain or procure others to
accurately, or falsifying or avoid physical danger or due to an error regulator rules, health and safety produce or maintain undisclosed or
in judgment requirements, corporate governance unrecorded accounts, funds or assets
creating misleading information codes and regulatory standards
or influencing others to do so, • Where instructed in the context of a • Conceal, alter or falsify company
could constitute fraud and result legal hold, retain records in accordance • Follow Unilever’s Accounting Manual, records, accounts and documents
in fines or penalties for employees with Unilever’s Data Retention reporting instructions and timetables,
Standard, or longer if required by local information standards and information
or for Unilever. definitions
laws/regulations
This Code Policy sets out what Employees involved in accounting must:
• Retain records that may be relevant
employees must do to ensure the
to any ongoing audit, litigation or • Ensure sales, profits, assets and
accuracy of our business records regulatory investigation, even if they liabilities are recorded in the correct
and financial information. exceed the normal retention period if time period
instructed to do so

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 Protecting Unilever’s Physical & Financial Assets & Intellectual Property

Musts Financial assets • Ensure all necessary checks and

Code of Business Principles and Code Policies

filings have occurred with respect

Physical assets/property Employees must: to patents, designs and trademarks
or other intellectual property rights,
Employees must: • Protect Unilever’s financial assets – when researching, developing or
such as cash, bank accounts and credit preparing to launch new brands, sub
• Take care to ensure that all Unilever cards - guarding against misuse, loss, brands, services, designs, inventions,
physical assets and property they come fraud or theft communication, advertising and
into contact with while working are not promotional materials
damaged, misused or wasted. Physical • Only authorise commitments,
assets and property includes factory expenditure, borrowing or other • Ensure a contract is in place with
and laboratory equipment, Unilever financial transactions in line with their appropriate clauses to protect
products or components, buildings, role as specified in local, regional and Unilever’s intellectual property rights
computers and company motor / or global financial and / or treasury and ensure freedom to use results when
vehicles authority schedules undertaking collaborative work with
third parties
The head of each Unilever site must: • Comply with the relevant Unilever
standards when involved in hedging
• Identify potential hazards from contracts or transactions Must nots
activities and services on site
Intellectual property Employees must not:
• Evaluate the risk of damage to site
Employees are responsible for assets of such hazards and of any Employees must: •  Remove Unilever’s physical assets or
ensuring Unilever’s assets are potential business interruption or property from company premises
protected. liability that could result • Report to Business Group or IP General without permission or use them for
Counsel any suspected counterfeit inappropriate purposes
• Take steps to reduce identified risks to products or any product, packaging,
For information on the protection an acceptable level communication or marketing practice • Knowingly infringe the valid patents,
of several other asset types see design rights, trademarks, copyright
that are suspected of infringing our
the Code Policies on Occupational copyright, trademarks, patents, design and other intellectual property rights
Health and Safety and Protecting rights, domain names and / or other of any third party
Unilever’s Information. intellectual property rights

This Code Policy covers the

protection of physical assets and
property, financial assets and
intellectual property.

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 Anti-Money Laundering and Economic Sanctions
To protect Unilever’s reputation Musts Third party payments to Unilever: • Carefully consider, where necessary in
Code of Business Principles and Code Policies

and avoid criminal liability, it consultation with their Business Integrity

Employees must: - From multiple bank accounts Officer or General Counsel, screening
is important not to become
outcomes before deciding whether to do
associated – however innocently – - From bank accounts from a different
• Comply with the Responsible Sourcing business with the third party
with the criminal activities of others. geography than the one where the
and Business Partnering Code Policy,
third party is resident Finance managers who support Supply
In particular, employees must the Global Economic Sanctions
Standard, and any local anti-money Chain Management and Customer
ensure Unilever is in compliance - Deposited in cash when normally
Development must regularly monitor and
laundering or sanctions procedures, made by cheque or electronically
with economic sanctions laws and / or review suppliers, customers and other
when they onboard, contract or monitor
regulations and does not deal with third parties - Received from other third parties that third-party service providers to identify
the proceeds of criminal activities, have not been onboarded and/or are business activity or governance that could
as this can amount to the criminal • Immediately notify their Business Group not part of the contract indicate money laundering is taking place
and Country General Counsel if they
offence of money laundering. - Made in advance when not part of
have any suspicions about actual or
potential money laundering activity normal terms of business Must nots
This Code Policy sets out essential or about transactions with sanctioned
steps employees must take to avoid countries or sanctioned third parties Employees involved in engaging or Employees must not:
contracting with third parties such
breaching economic sanctions • Obtain prior clearance from their • Simply assume relevant third-party
as new suppliers, customers and
rules or being implicated in money Business Group and Country General distributors must: screening has already taken place:
laundering. Counsel alongside senior Finance failure to check or update screenings
business partners before allowing any • Ensure that the third parties in question periodically may put Unilever and its
of the following events to happen: are subject to screening to assess their employees at risk
identity and legitimacy before contracts
Third party requests to: • Inform a third party suspected of
are signed or transactions occur. Various
money laundering that they are subject
factors will determine the appropriate
- Pay funds to a bank account in the of an internal or external investigation.
forms and levels of screening
name of a different third party or Employees must obtain guidance
outside the country of their operation • Determine, with guidance from their from their Business Group and Country
Business Integrity Officer, which tools General Counsel on how to handle the
- Take payments in a form outside the matter with the third party
and processes should be used to
normal terms of business
facilitate appropriate screening and
- Split payments to several bank record-keeping (see the Responsible
accounts Sourcing and Business Partnering Policy)

- Overpay

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Respecting
People
People should be treated with dignity,
honesty and fairness. Unilever and its
employees celebrate the diversity of people,
and respect people for who they are and
what they bring. Unilever wants to foster
working environments that are fair and safe,
where rights are respected and everyone can
achieve their full potential.

Occupational Health & Safety

Respect, Dignity & Fair Treatment

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 Occupational Health & Safety
Unilever is committed to protecting Musts All Unilever team leaders have overall • Maintain, communicate and test both
Code of Business Principles and Code Policies

and promoting the occupational operational responsibility for health and site and role emergency plans
Employees working at Unilever sites must: safety at their location and must:
health and safety of its people. This • Ensure all employees, contractors and
is supported by following Unilever’s • Work and behave safely and in a • Establish and maintain an appropriate visitors receive information and training
global occupational health manner protective of health occupational health and safety at work in occupational health and safety
standards and safety standards. management system for their sites and relevant to their roles and activities in
• Comply with defined occupational
These apply to all Unilever employees their teams, including the appointment the local language
health and safety procedures and
of committees, managers, competent
working at Unilever sites. In addition, instructions relevant to their work and / • Ensure all employees, contractors
experts and a system for gathering
Unilever complies with all applicable or about which they have been trained
concerns and input from employees,
and visitors receive information and
legislation and regulations and aims or notified training about applicable emergency
contractors, and visitors
to continuously improve health and notifications and procedures in local
• Support team leaders to ensure that
• Identify occupational health and language.
safety performance. everyone they work with, including
safety hazards and manage/control
employees, contractors and visitors,
risks arising from their team and their Must nots
Everyone at Unilever has a role to are familiar with and follow applicable
site’s routine and planned operations,
play. Managers are responsible for health and safety procedures and
activities and services
instructions Employees must not:
communicating and implementing
the occupational health and safety • Regularly review and comply with all • Breach the Life Critical Standards as
• Only undertake work that they are
applicable local occupational health outlined in the Unilever standards.
standards as they apply to their trained, competent, medically fit,
and safety legislation, including relevant
direct reports and third parties sufficiently rested, functionally capable
mandatory Unilever standards • Undertake work or related activity, when
under their supervision. Employees and alert enough to do under influence of any substance that
are empowered to speak up about • Develop site and role specific may negatively impact occupational
• Make sure they know what to do if an
improvement objectives and monitor health or safety
hazards without fear of retaliation. emergency occurs at their place of
performance, including an annual
As a condition of employment, we all work / on the road or at a location they
review of the management system’s • Carry on with any work that becomes
have a duty to work in a healthy and are visiting unsafe or unhealthy
effectiveness and adequacy
safe way. • Promptly report to local Unilever • Assume someone else will report a risk
• Report mandatory Key Performance
management any actual or near miss or concern
This Code Policy outlines our individual Indicators (KPIs) via Unilever’s
accident or injury, illness, unsafe or
and shared responsibilities for health and occupational health and safety Team leaders must not:
unhealthy condition, incident so that
safety. Where local Unilever companies/ reporting system
steps can be taken to correct, prevent or • Ask for any work to continue that
entities are governed by a local board of control those conditions immediately • Report all incidents, accidents and
directors, those entities are responsible for becomes unsafe or unhealthy.
near misses in line with reporting
their employees’ occupational health and • Notify their manager or supervisor if • Discourage reporting of a risk, concern,
requirements, including thorough
safety, including the required occupational there is a concern with meeting any of or incident.
investigation, follow-up and
health and safety management systems these minimum requirements.
communication of lessons learned
and appropriate governance.

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 Respect, Dignity & Fair Treatment (1 of 2)
Business can only flourish in Musts
Code of Business Principles and Code Policies

societies where human rights are

respected, upheld and advanced. Employees must:

Unilever recognises that each • Respect the dignity and human rights
business has the responsibility of colleagues and all others they come
to respect human rights and the into contact with as part of their jobs
ability to contribute to positive • Treat everyone fairly and equally,
human rights impacts. without discrimination on the grounds of
race, age, role, gender, gender identity,
There is both a business and colour, religion, country of origin, sexual
a moral case for ensuring that orientation, marital status, dependants,
human rights are upheld across disability, social class, political views
Unilever’s operations and value or any other class protected by law.
This includes consideration of all
chain. Unilever is committed to
terms and conditions of employment
ensuring that all employees work including, but not limited to, recruitment,
in an environment that promotes redundancy, promotion, reward and
diversity and where there is mutual benefits, training or retirement which
trust, respect for human rights and must be based on merit
equal opportunity, and no unlawful Line Managers must:
discrimination or victimisation.
• Ensure all employees’ work is conducted
This Code Policy sets out what on the basis of freely agreed and
employees must do to ensure that documented terms of employment,
all workplaces maintain such an clearly understood by and made
available to relevant employees and
environment. others working for Unilever

• Ensure that all employees have

obtained employment with Unilever
without the employee having paid
a recruitment fee or related cost
directly or indirectly as guided by the
International Labour Organisation
standards

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 Respect, Dignity & Fair Treatment (2 of 2)
Musts •  Maintain a clear and transparent Must nots Line Managers must not:
Code of Business Principles and Code Policies

system of employee and management

• Ensure all employees are provided communication that enables employees Employees must not: • Use, or permit to be used, forced or
with fair wages including a total to consult and have an effective compulsory or trafficked labour. We
remuneration package that meets or dialogue with management • Engage in any direct behaviour that have a zero tolerance of forced labour
exceeds legal minimum standards, is offensive, intimidating, malicious
appropriate prevailing industry •  Provide transparent, fair and or insulting. This includes any form of • Use child labour, i.e. individuals under
standards or a living wage – whichever confidential procedures for employees sexual or other harassment or bullying, the age of 15 or under the local legal
is higher and that remuneration to raise relevant concerns. These must whether individual or collective and minimum working age or mandatory
terms established by legally binding enable employees to discuss any whether motivated by race, age, role, schooling age, whichever is the higher
collective agreements are implemented situation where they believe they have gender, gender identity, colour, religion,
been discriminated against or treated • When young workers are employed
and adhered to. Other than legally country of origin, sexual orientation, (insofar as short-term work experience
mandated deductions, all other unfairly or without respect or dignity marital status, dependants, disability, schemes and work that forms part of an
deductions from wages require social class, political views or any other educational programme are permitted),
the express and written consent of class protected by law require or allow them to do work
the employee that is mentally, physically, socially or
• Engage in any indirect behaviour
•  Respect employees’ rights to form which could be construed as sexual morally dangerous or interferes with
and join a legally recognised union of or other harassment or bullying, their schooling by depriving them of the
their choice choice or any other body including, but not limited to, making opportunity to attend school
representing their collective interests, offensive or sexually explicit jokes or
and establish constructive dialogue insults, displaying, emailing, texting,
and bargain in good faith with trade or otherwise distributing, offensive
unions or representative bodies on material or material of a sexually
employment conditions, labour explicit nature, misusing personal
management relations and matters information, creating a hostile or
of mutual concern, to the extent intimidating environment, isolating
practicable taking national laws into or not co-operating with a colleague,
consideration or spreading malicious or insulting
rumours
•  Comply with local legal requirements in
relation to short-term, casual or agency • Work more than the regular and
employees overtime hours allowed by the laws of
the country where they are employed.
All overtime work will be on a voluntary
basis

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Safeguarding
Information
Information is essential to our success:
it fuels our research, keeps us in touch
with consumer needs and helps us work
effectively together. If used inappropriately,
information can cause considerable damage
to our business.

Protecting Unilever’s Information

Preventing Insider Trading
Competitors’ Information
Personal Data & Privacy
Use of Information Technology

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 Protecting Unilever’s Information
Information is one of Unilever’s • Only distribute or share Unilever’s Must nots
Code of Business Principles and Code Policies

most valuable business assets: information on a need to know basis,

ensuring that only employees or others Employees must not:
Unilever is committed to
working for Unilever, or authorised third
safeguarding and protecting parties, with a genuine business need, • Disclose Unilever’s information
our information and any other have access to the information externally to third parties unless in
information entrusted to us. accordance with Unilever’s Information
• Take care not to disclose information Classification & Information Handling
Information within Unilever is held in in public places, including taking all standards
many different formats, including on necessary steps to protect information
paper, electronically in documents or in IT in documents and on IT devices away • Use Unilever’s information for anything
applications & systems. Our requirements from the workplace other than a legitimate business
to protect information apply to all purposes or as required by law.
• Comply with the proper use of Unilever
formats. Unilever has Information
Information Technology and only share Personal data relating to employees,
Classification & Information Handling
Unilever information using Unilever- consumers and other individuals is
standards which define how information
approved Information Technology in subject to specific laws and regulations
within Unilever must be classified,
accordance with the Code Policy on Use in most countries and requires special
handled and protected.
of Information Technology handling. Additional information relating
to the classification and protection
• Report any events which you suspect requirements for personal and sensitive
Musts could impact the security of Unilever personal data can be found in the Code
information by following the Cyber Policy on Personal Data and Privacy
When handling Unilever’s information Security reporting procedures.
employees must: For example, information being shared If in doubt about how to handle any
• Understand the nature and with someone who was not authorised Unilever information, restricted or
classification of the information, to view it; if you have received or otherwise, employees must seek advice
as defined in the Information responded to a suspicious email, from their Line Manager, Business
Classification Standard; understand text message, phone call, instant Information Security Officer and / or Legal
and adhere to the handling message or MFA prompt; or any other Business Partner
requirements detailed in the relevant event.
Information Handling Standard; and
take personal responsibility for the
proper use, circulation, retention,
protection and disposal of Unilever’s
information

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 Preventing Insider Trading
Employees must not use inside Trading or encouraging others to trade Unilever Insiders Must nots
Code of Business Principles and Code Policies

information to buy or sell securities on inside information, or giving it to

unauthorised parties, is a criminal Unilever maintains Insider Lists that name Employees must not:
of Unilever PLC, or any listed
offence in many countries: a breach of the all employees and external advisors who
Unilever subsidiary, or any other applicable laws can lead to fines and / or have authorised access to Unilever’s • Buy or sell securities of any listed
publicly traded company. Securities imprisonment. Inside (or price sensitive) Inside Information (individuals will be company when in possession of inside
include shares, equities and related information means information that notified by the Corporate Secretaries’ information related to those securities
derivatives or spread bets. is not available to the public and that Department if they have Inside –even if they believe they are not relying
a reasonable investor would probably Information status). on it. This includes trading at times
Unilever’s Disclosure Committee – consider important in deciding whether when there are market rumours that
to buy or sell a company’s shares. In addition to the general obligations set they know are false
on behalf of the Board – oversees
Examples of inside information include out above, individuals on the Insider Lists
that Unilever has the necessary must also comply with the requirements • Encourage anyone to buy or sell
the following:
procedures in place to ensure in Unilever’s Share Dealing standard and securities of any listed companies when
Unilever complies with applicable • Business results or forecasts for the Disclosure Manual. they have inside information related
insider trading laws and regulations whole company or for one of our listed to those securities – even if they do not
subsidiaries profit from the arrangement
(see Unilever’s Share Dealing
Standard and Disclosure Manual). • A major new product, product claim or Musts • Pass Inside Information relating to
product incident/issue Unilever to anyone within Unilever
This Code Policy explains what Employees must:
(unless they are on a relevant Unilever
insider trading is, how employees • An acquisition, merger or divestment Insider List) or outside Unilever,
• Refer to Unilever’s Share Dealing
can be sure they don’t engage in • A sizeable restructuring project including family members or friends
Standard and Disclosure Manual or
it, and what to do if they discover (see the Code Policy on Protecting
contact the Corporate Secretaries’
• Major developments in litigation Unilever’s Information)
inside information is being misused. Department in the Legal Group, to
cases or in dealings with regulators or
check whether something is Inside • Spread false information or engage in
governments
Information other activities to manipulate the price
• Revisions in dividend policy of publicly listed securities
• Immediately advise a member of the
• Changes in executive directors. Disclosure Committee (the Corporate
Secretaries’ Department holds the
names of committee members) if they
suspect or know that some Inside
Information is not being managed as
Inside information

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 Competitors’ Information
This Code Policy outlines what Musts
Code of Business Principles and Code Policies

employees and others working for

Unilever must do to legitimately Employees must:

obtain and use competitor • Only gather and/or use competitors’

information and at the same information from the public domain
time respect the confidentiality of
• Ensure the information is from a
competitor’s information. legitimate source and document
Unilever respects the confidential the source
information of third parties, including
• Keep up to date with training and the
competitors, suppliers and customers.
latest policies on obtaining competitor
Confidential information is information
information
about another company that is not in the
public domain, has value and could be • Clearly record the sources of data in all
used for commercial benefit. Accepting communications so their legitimacy is
or using competitor’s’ confidential beyond doubt
information risks being a serious
infringement of competition laws and/ • If they acquire a competitor’s
or trade secrets/intellectual property confidential information
laws, leading to significant penalties for unintentionally, they must notify their
Unilever and individuals. Legal Business Partner immediately
To promote fair competition
Unilever gathers and uses Competitor information encompasses
competitor’s information that is many areas from marketing and financial Must nots
in the public domain, for example, information to Intellectual Property such
as 2D and 3D designs. If you are in any Employees must not:
from newspapers, the internet
doubt consult your Legal Business Partner.
and company filings. This provides • Seek to obtain competitor’s confidential
Unilever with valuable insights information from new employees
and helps us achieve our purpose or otherwise
of making sustainable living
commonplace, and our vision
that being a purpose-led,
future-fit company will deliver
superior performance.

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 Personal Data & Privacy
Unilever respects the privacy of all Musts Must nots
Code of Business Principles and Code Policies

individuals including employees

When collecting, using or storing personal When collecting, using or storing personal
and consumers and their personal
data employees must: data, employees must not:
data, including digital information
Unilever holds about them. We • Only collect data that is adequate and • Retain personal data for longer than
relevant and use it solely for the purpose necessary to achieve the business
will collect and use personal data
for which it is collected objective or meet minimum legal
in accordance with our values, requirements
applicable laws and with respect • Be transparent with individuals in
for privacy as a human right. relation to how their personal data • Transfer personal data outside the
is used in alignment with Unilever country in which it is collected without
privacy notices advice from their Legal business partner,
This Code Policy sets out what as there may be legal restrictions/
steps employees must take to • Obtain consent from individuals in requirements relating to the transfer
ensure personal data is handled accordance with local law
• Collect and use personal data for
appropriately. • Keep personal data up to date purposes that are not reasonably
correcting inaccurate information when expected by our consumers and
requested and respecting individual employees
legal rights
If in doubt, employees must seek advice
• Keep personal data confidential
from their line manager and / or Legal
and secure
business partner.
• Act responsibly and ethically, upholding
Unilever’s core values, always
considering the risk to individuals in
using their personal data and take steps
to mitigate such risk

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 Use of Information Technology (1 of 2)
This Code Policy explains how Employees are provided with access
Code of Business Principles and Code Policies

employees should use Unilever to Unilever systems, software, digital

services, and equipment to carry out
equipment and systems, or
their role.
personal devices to access
information at Unilever, responsibly Employees are permitted to use Unilever
and securely in compliance with all Equipment for personal use if this does
not expose Unilever to cyber risk or harm,
relevant laws and regulations or materially impact Unilever systems or
operational resiliency. Material impact
examples include excessive storage,
network usage, mobile data usage,
storing non public data on personal
storage or voice utilisation which may
have an impact on the performance of the
environment. Cyber risk is defined as an
action that could expose Unilever systems
or data or damage the Unilever brand.

In accordance with our values, following

applicable laws and with respect for
privacy as a human right: :

• All information processed by or

stored on Unilever issued or owned
systems and equipment (and Unilever
information on personal devices) may
be monitored, inspected or removed by
Unilever without prior notification

• Unilever may log, diagnose,

investigate, and assess activity and
data on Unilever systems to ensure this
policy is being followed and Unilever’s
technical environment is optimised and
risk managed. Unilever reserves the
right to remove any software that is non
compliant / unapproved

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 Use of Information Technology (2 of 2)
Musts Must nots • Use a Unilever device for any activity
Code of Business Principles and Code Policies

that would be considered illegal by any

When using Unilever’s Systems and Employees must not: operating countries Computer Misuse
Equipment, employees must: Acts
• Try to disable, defeat or circumvent
• Ensure Unilever equipment is used Unilever security controls, including but • Expose Unilever information by:
appropriately and protected from not limited to browser configuration,
damage, loss or theft antivirus, privileged access, firewalls - Using non-public Unilever information
and system logs for anything other than Unilever
• Lock any device, used to access business
Unilever Information, when unattended • Use Unilever systems or Unilever
(e.g. password, PIN or biometrics) equipment to intentionally access, - Sharing or synchronising non-public
store, send, post or publish material Unilever information other than
• Immediately report to the IT Service your own personal information
that:
Desk the loss or theft of any Unilever (e.g. payslips), to personal accounts
equipment, or any personal device used - Is pornographic, sexually explicit, (e.g. email or storage) or devices not
to access or store Unilever Information indecent or obscene, or managed by Unilever
• Ensure any removable Unilever IT - Promotes violence, hatred, terrorism - Conducting business activities, or
equipment is secured when left in the or intolerance, or sharing any non-public Unilever
office overnight, is locked away or put information, on unapproved
out of sight when left unattended at - Is in breach of local, national or collaboration and messaging tools
home, in a hotel or in a vehicle. When international laws
travelling, keep it with you at all times - Sharing Unilever access credentials
• Use Unilever systems or Unilever with anyone, including work
• Comply with copyright law and respect equipment to intentionally defame, colleagues (other than in defined
all applicable licenses for any graphics, slander or lower the reputation of circumstances pre- authorised by
documents, media and other materials any person or entity or their goods or Cyber Security), friends and family
stored on or accessed with Unilever services
systems or equipment - Using Unilever email addresses as
• Run or engage in any form of private an identity for non-business related
• Follow the appropriate process to business using Unilever IT equipment activity
install any software or applications
on Unilever equipment and not install • Access Unilever Systems or Information - Using Unilever passwords anywhere
unapproved applications after leaving Unilever employment else

• Only store or communicate Unilever • Use removable media (USB storage) - Intentionally accessing Unilever
data on approved platforms unless unless an exception has been sought Systems or Unilever Information that
an exception has been sought and and approved is not intended for their role
approved by Cyber Security.

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Engaging
Externally
Throughout our value chain, from innovation
through to our consumers, Unilever and its
employees need to demonstrate the same
ethical standards when engaging with others
externally as when dealing with colleagues.

Responsible Marketing
Responsible Sourcing & Business Partnering
Fair Competition

Contact with Government, Regulators &

Non-governmental Organisations (NGOs)

Political Activities & Political Donations

External Communications –
The Media, Investors & Analysts

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 Responsible Marketing
Unilever is committed to Musts Must nots
Code of Business Principles and Code Policies

developing, producing, marketing

and selling all its products and Employees who are involved in Unilever Employees must not:
marketing activities must:
services responsibly. Unilever can • Alter images used in marketing
and should conduct marketing • At all times, respect applicable communications in such a way that
activities in line with societal marketing laws advertising is rendered misleading
expectations.
• Describe our products/services and • Misuse technical data or use scientific
This Code Policy sets out global their effects truthfully, accurately terminology or vocabulary in such a way
and transparently, with appropriate as falsely to suggest that a claim has
minimum standards that apply to factual and, where relevant, nutritional scientific validity
all of Unilever’s marketing activities information
everywhere. • Associate our products or services with,
Freedom of choice
• Ensure there is sufficient information or feature within any Unilever marketing,
This covers but is not limited to: brand for consumers and customers to themes, figures or images likely to cause
Employees involved in Unilever marketing
names, packaging and labelling; understand how to use our products and serious or widespread offence to any
activities must show respect for people
consumer planning and market research; services religion, nationality, culture, gender,
who choose not to buy our products
trade advertising; sales materials; brand race, sexual orientation, age, disability
• Ensure our marketing is based on and services, and ensure there is
merchandising and sponsorship; all or minority group
adequate support for the claims sufficient information about our products
forms of advertising including television, and services for consumers to make
Unilever makes • Advertise in any media known for
radio, print, digital media, promotional informed choices promoting violence, pornography or
activities and events, product placements, • Comply with our principles and insulting behaviour
‘advergaming’ – whether created by standards on marketing, including (but Taste and decency
Unilever, agencies, crowdsourcing or other not limited to) those with respect to
third parties. children, women and social media Employees involved in Unilever marketing
activities must ensure our marketing
• Be mindful of the environmental reflects and respects generally accepted
implications of marketing activity, contemporary standards of good taste
in such areas as new product and quality, in the context for which it is
development, marketing activation designed, showing awareness of both
plans, packaging and content recycling wider society and sensitivity to different
cultural, social, ethical and religious
groups.

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 Responsible Sourcing & Business Partnering
As a purpose-led company, Musts Must nots
Code of Business Principles and Code Policies

Unilever is committed to doing

business in a manner that improves Employees who contract and / or work with Employees who contract and / or work with
Unilever’s third parties must: Unilever’s third parties must not:
the lives of workers across our value
chain, their communities and the • Read and understand the RPP and • Agree to any contractual changes
environment. Unilever expects its consult their Line Manager and / or the or exclusions with respect to the RPP
business partners to adhere to relevant responsible teams if they have without consulting their Legal Business
any questions Partner and in respect of the RPP,
values and principles consistent prior written authorisation from the
with our own. • Ensure that all our third parties are Responsible Business team
subject to our RPP policies and controls.
This Code Policy sets out This includes adequate and timely • Continue transacting with third
responsibilities of employees who onboarding, contracting and monitoring parties that have been declared as
(including verification and remediation not compliant with the RPP unless a
engage with third parties.
where necessary) dispensation or exemption is provided
by the Responsible Business team or
Our requirements for third parties are
• Ensure that all our agreements with when they have been identified on the
set out in the Responsible Partner Policy
suppliers (inclusive of MSAs, UPAs, CTCs, Prohibited Third Parties list
(RPP) which governs both our Responsible
POs*) and distributors and customers
Sourcing Programme for suppliers and our *Footnote: Master Service Agreements, Unilever
(including DOs*), to the extent required
Responsible Business Partner Programme Purchase Agreements, Commercial Terms Contracts,
by our internal controls, include contract
for distributors, customers and other Purchase Orders, Distribution Orders.
clauses that specify that the business
parties.
partner must acknowledge that they can
Unilever could face legal and reputational meet the requirements of our RPP as a
liabilities if third parties fail to comply with condition of engagement
these requirements.
• Notify their Line Manager and the
The RPP outlines the fundamental relevant responsible team if they know
principles and mandatory requirements or suspect that third parties are not
that third parties must meet. meeting relevant RPP requirements or
if they are performing contrary to the
The team responsible for setting the agreed contractual terms
standard of this policy is the Global
Sustainability Team with the governance • Ensure that any selection, shortlisting or
of and compliance with the Policy owned tendering processes for new third parties
by the Business Integrity team. consider their compliance with the RPP

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 Fair Competition (1 of 2)
Investigations by competition Co-operating with competition
Code of Business Principles and Code Policies

authorities may result in significant authorities

fines and costs, compensation Unilever co-operates fully with the
claims by our customers and competition authorities, while consistently
competitors, and damage to and robustly defending its legitimate
our reputation and commercial interests. All contacts with competition
authorities (including, where relevant,
relationships. Criminal sanctions national courts) are co-ordinated by the
for individuals may also apply. relevant Legal Business Partner. For more
details, see the Code Policy on Contact
Competition laws prohibit:
with Government, Regulators & Non
• Anticompetitive agreements Governmental Organisations (NGOs).

• Sharing of commercially sensitive

information between competitors, Musts
unless approved by Legal
Heads of Country and Senior Leadership
• Certain restrictions imposed on must, with the support of Legal, ensure
or agreed with distributors and that the requirements of competition law
other customers; and are understood by employees, contractors
and agents operating in their organisation
• Abuses of dominant market and country by providing appropriate
positions. documentation, communication and
training, with tailored programmes for
This Code Policy sets out what specific (in particular ‘high risk’) groups..
employees must do to ensure
Unilever upholds fair competition. Employees must:

• Comply with competition law for all

categories and markets in which they
operate and undertake all relevant
training

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 Fair Competition (2 of 2)
Musts - Before discussing joint purchasing Must nots • Boycott or refuse to deal with certain
Code of Business Principles and Code Policies

arrangements, or production, research competitors, customers or suppliers

and development, and standardisation Unilever prohibits participation in cartels without first seeking advice from their
• Before taking part in a trade association agreements with any competitors in all countries, even those that do not Legal Business Partner
or industry event, ensure all mandatory have competition law.
requirements set out in the Unilever - When contemplating restrictions on • Impose restrictions on the commercial
Standard on Trade Association the commercial activity of a customer Employees must not: activity of a customer or a distributor
Memberships have been complied with; or a distributor without first seeking advice from their
this also applies to less formal meetings • Participate in cartels Legal Business Partner, including
- In situations where Unilever might
or events that involve competitors, such control of the resale price, the territory
have a strong market position and • Discuss, agree or exchange information
as awards ceremonies or associated or channels in which they may resell
Unilever’s commercial practices could about, any of the following, directly
social contacts Unilever products and the extent to
be perceived as unfair to customers or indirectly, with competitors (unless which they may sell competing products
• Object immediately if inappropriate or competitors approved by Legal Group):
topics are raised during any contact with • Clearly record sources of competitor • Where Unilever has a strong market
competitors and leave immediately – - The price or terms of sale for products
information in all communications and position, conduct itself in order to
and noticeably – if any inappropriate and / or services
documents so their legitimacy is take unfair advantage of customers
discussion continues beyond doubt or unfairly prevent competitors from
- The price or terms to be demanded
from suppliers entering, remaining or expanding in a
• Report incidents of inappropriate
market, e.g. selling below cost, certain
discussions immediately to their Legal
- The co-ordination or allocation of bids types of conditional rebates, exclusivity
Business Partner
or quotes arrangements
• Promptly seek advice from their Legal
- Limitations on production or sales; or
Business Partner:
- The division or allocation of
- Whenever you need help applying the
geographic markets, customers or
competition rules laid out in this Policy
product lines
to any specific business situation, and
in any case of doubt

- In situations which may involve the

exchange of information with a
competitor

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 Contact with Government, Regulators &
Non-Governmental Organisations (NGOs) (1 of 2)
Code of Business Principles and Code Policies

Any contact by employees or Governments, regulators and legislators

other representatives with includes bodies that may be: global
or international (e.g. United Nations);
government, legislators, regulators
regional (e.g. European Union, ASEAN);
or NGOs must be done with national; or active at a local community
honesty, integrity, openness and level. Non-Governmental Organisations
in compliance with local and (NGOs) also operate at different levels,
international laws. and their work includes social and
consumer issues as well as
This Code Policy provides detailed environmental ones.
guidance on how contact with the Interaction with these organisations
above authorities must proceed. It must only be made by authorised and
does not cover interactions about appropriately trained individuals. This
purely personal matters, such as covers all forms of communications,
personal charitable donations or whether formal, informal or social
interaction in relation to Unilever business
personal tax. including any kind of correspondence
such as in-person, electronic media or
written correspondence.

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 Contact with Government, Regulators &
Non-Governmental Organisations (NGOs) (2 of 2)
Code of Business Principles and Code Policies

Musts • Seek prior approval when contacting • Have prior approval from the local Must nots
officials to represent our legitimate Finance Director, General Counsel or
Employees must: interests as follows; Corporate Tax Department, Group Employees must not:
Controller or Corporate Pensions
• Be appropriately trained and authorised - Global/international organisations Department for any contact relating • Attempt to obstruct the collection of
by their Line Manager = Global Head of Regulatory Affairs, to taxation, financial reporting, information, data, testimony or records
Global Head of Communications& accounting, pension or legal matters by authorised investigators or officials
• Be courteous, open and transparent Corporate Affairs or Global Head of
in declaring their name, company, Sustainability; • Have prior approval from Regulatory • Say or do anything that may, or may
role, status and, for any enquiry or Affairs (which will in turn liaise with be perceived as seeking to, improperly
‘representation’, the nature of the - Regional organisations legal group) before any contact with influence decisions about Unilever by
subject matter = Global Head of Communications, regulators about Unilever’s actual any government, legislators, regulators
Markets or relevant local External or planned use of products and / or or NGOs (see the Code Policies on Gifts
• Take all reasonable steps to ensure the Affairs/ Regulatory Affairs Head; ingredients & Hospitality and Anti-Bribery)
truth and accuracy of their information
- National or local organisations • Have prior approval from the local
• Keep a record of contacts and = National Head of External Affairs/ communications department before any
interactions with authorities at our own Regulatory Affairs Head. If employees contact with NGO’s
initiative do not have such departments
in their location, they must get • Be aware of the up to date procedures
approval from Head of Country or communicated by site leaders for
National Managing Director/Head of responding to unannounced inspections
Operations. from relevant authorities. This must
include the nomination of Responsible
• Where appropriate, obtain clearance Persons to lead the response for each
on a standing basis as a requirement of type of potential inspection.
their role, for example, employees from
regulatory affairs, communications
and advocacy

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 Political Activities & Political Donations
Unilever companies are prohibited Approval will only be given where the
Code of Business Principles and Code Policies

from supporting or contributing non-party-political nature of the activity

has been publicly communicated as
to political parties or candidates.
such by the advisory group, its work
Employees can only offer support relates to areas supporting Unilever’s
and contributions to political corporate vision, and the group includes
groups in a personal capacity. representatives from a broad range
of organisations, such as well-known
This Code Policy sets out how peer companies, national charities,
employees must manage their non-political think-tanks, research
business relationship with organisations and representatives of
academia, or similar such bodies.
political groups.

Must nots
Musts
Employees must not:
Employees must:
• Create a conflict of interest through
• Ensure any contributions towards, and their involvement in the type of social or
support for, political parties are clearly economic advisory groups mentioned
personal and give no impression of above. (see the Code Policy on Avoiding
being connected to Unilever Conflicts of Interest)

• Ensure any personal political support

or contributions do not affect their
performance or objectivity at work
(see the Code Policy on Avoiding
Conflicts of Interest)

• Ensure where employees represent

Unilever in social or economic advisory
groups set up by governments, their
participation is subject to the prior
approval of the head of communications

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 External Communications – The Media, Investors & Analysts
Musts Must nots
Code of Business Principles and Code Policies

Employees who have received Employees who are not part of the Investor
authorisation to communicate with Relations or Media Relations functions or a
investment communities or the media Board Member must not:
from the Investor Relations or Media
Relations functions or a Board Member • Communicate with investment
must: communities or the media, either on or
off the record, without authorisation
• Comply with any conditions attached to from one of these functions and
their authorisation, such as constraints appropriate training/briefing
on when and / or with whom they may
communicate • Respond to enquiries from investment
communities or the media: all enquiries
• Always consult with the authorising must be directed to the Media Relations
functions about the content of any or Investor Relations functions
message before they communicate
• Get drawn into conversations, answer
Employees who are part of the Investor any questions or provide any
Relations or Media Relations teams must information or opinion
Communication with investment Unilever’s Disclosure Committee – follow Unilever’s Share Dealing and
communities – including on behalf of the Board – Disclosure Manuals and the departmental • Make any forward-looking financial
is responsible for ensuring Unilever processes and procedures (including statements or provide ‘inside
shareholders, brokers and analysts
authorisations) in this area information’ (see the Code Policy on
– and the media must be managed has the necessary procedures to Preventing Insider Trading and the
carefully. Such communication comply with relevant laws and The above rules also apply outside formal Media Relations Protocol)
has important legal requirements regulations including Unilever’s work settings, such as at external speaking
and demands specialist skills Disclosure & Share-Dealing Manuals. engagements, courses, seminars, trade
association events or social occasions.
and experience. Only individuals
This Code Policy outlines how
with specific authorisation and
communication with investment
training/briefing may communicate
communities and the media must
about Unilever with investment
operate.
communities or the media, or
respond to their enquiries or
questions.

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Glossary
Glossary

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 Glossary
Code Support Line Employee Improper advantages
Code of Business Principles and Code Policies

Confidential online and telephone service, A person employed by Unilever under one The offer or gift of anything of any value,
allowing the user to raise a concern about of a variety of contracts. The term covers all including nominal cash amounts, which
an actual or potential breach of the Code employees, whether full-time, part-time, may be perceived as intended to cause
or Code Policies, to ask a question if fixed-term, permanent or trainees. the recipient to behave contrary to
clarification is needed and to check back customary ethical expectations. Includes
on the status of a concern raised or a Additionally, in this document, the term money, services (including favours),
question asked. The service is available at is used to cover other persons working for discounts, use of resources, loans,
www.unilevercodesupportline.com Unilever as follows: those with a statutory credit, the promise of future advantages
Director role or equivalent responsibilities; (including future employment or
Unilever employees of joint ventures; and internships), and gifts or hospitality.
Competitor’s confidential employees of new acquisitions.
information
Public official
Non-public information about a Facilitation payment
competitor’s product or the way in which a An officer, employee or representative
competitor carries out its business. Unofficial payment – in effect a bribe of a State or a State controlled or
Confidential information covers a broad – made to a public official to secure or owned entity. Term includes a person
sweep of activities, including current speed up the performance of a routine representing a political party or public
or future prices; pricing terms (e.g. action that the official is required to international organisation, members of
discounts); buying prices, costs and provide anyway. Facilitation payments royal families or a candidate for political,
supplier information business or financial are illegal in most countries, although municipal or judicial office. Also covers
strategies and plans (e.g. mergers, a small number provide exceptions in anyone acting in an official capacity on
acquisitions and divestments); marketing, certain circumstances. Also referred to as a behalf of any of the above, including the
promotional and sales plans; financial ‘facilitating’, ‘speed’ or ‘ grease’ payment. police and armed forces.
results before any formal announcement;
R&D work (strategies, designs, formulae,
drawings, technical information, manuals Family member Unilever
and instructions, product specifications A relative, by blood or by marriage (or The expressions ‘Unilever’ and ‘Unilever
and samples of products that have not similar informal relationship), notably a companies’ are used for convenience
been launched or revealed publicly); spouse, live-in partner, parent or child. and mean the Unilever Group of
and proprietary software. The term includes sibling, step- or adopted companies comprising Unilever PLC and
child, step-parent, grandparent, uncle, its respective subsidiary companies.
aunt, cousin, grandchild or any relative The Board of Unilever means the Directors
who has lived with you for the past 12 of Unilever PLC.
months or more.

The Code
of Business Countering
Countering Respecting
Respecting Safeguarding
Safeguarding Engaging
Engaging
Principles Corruption
Corruption People
People Information
Information Externally
Externally Glossary 44
44