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Principles and
Code Policies
Code of Business Principles and Code Policies
CONTENTS 2
Contents
The Code and our Standard of Conduct Countering Corruption Respecting People
In this section:
Our Framework
A message from Paul Polman, CEO
The Code of Business Principles
Living the Code
Legal Consultation
Responsible Risk Management
4
Our
Framework Our Values of Integrity, Respect, Responsibility
and Pioneering are the simplest statement
of who we are. They govern everything we do.
Legal Consultation (1 of 2)
Employees must at all times Employees must immediately notify
comply with laws and regulations their line manager (or other appropriate
person – see Code Policy on Living
that apply to the countries in which
the Code) and take legal advice if they
Unilever operates. Ignorance of suspect or discover any illegal activity
the law is no excuse. Timely legal in relation to Unilever’s operations
consultation is essential to ensure or associated activities involving
that Unilever’s legitimate business third parties.
interests and opportunities Employees must promptly seek advice
are protected. from their Legal business partner in
This Code Policy sets out how and the following situations:
in what circumstances employees • Commercial contracts, leases,
must seek legal advice from Unilever licences and transactions –
Legal Group. Commercial contracts for goods or
services (unless Legal Group has
Musts expressly delegated authority to
the business or set up a route for
Heads of all market Cluster/country direct consultation of an external
boards or senior leadership teams legal advisor); Contracts relating to
and heads of all category, corporate intellectual property, such as, licences
and functional leadership teams must for technology, trademarks, joint
ensure the relevant Legal business development or technical assistance
partner is a member of that leadership contracts; Treasury transactions, for
team upon request and/or that they example, raising equity or debt, asset
have an open invitation to attend all leasing, derivative transactions (such
team meetings and receive copies of as currency hedging or interest rate
all associated agendas and minutes. swaps) or guarantees of Treasury
transactions; Transactions involving
mergers, acquisitions, disposals or
joint ventures;
Code of Business Principles and Code Policies
THE CODE AND OUR STANDARD OF CONDUCT 11
Legal Consultation (2 of 2)
• Litigation and regulatory action – Code Policies on Fair Competition, Potential product recalls; Consumer, Must nots
Civil litigation, such as employment Competitors’ Information and product, workforce or environmental
Employees must not do anything that
or contractual disputes, whether Intellectual Property); safety incidents that could have
Legal Group has advised is illegal and/
threatened or actual, by or against legal implications;
• Communication – Press releases that or unlawful. Where an activity is not
a Unilever company or employee,
could impact Unilever’s reputation or • Legal or governance structures – illegal and/or unlawful but legal advice
including commencement of or
create legal liability, or contain ‘inside’ Changes to, or issues around, legal or highlights significant risks for Unilever,
settlement of such litigation; Criminal
or ‘price sensitive’ information (see governance structures at geographic such as litigation, they must not proceed
prosecutions, whether threatened
Code Policy on Preventing Insider or corporate level, such as changes without express senior line management
or actual, by or against a Unilever
Trading); in capital structures or Board authorisation.
company or employee, or at Unilever’s
membership, public company filings
instigation; Communication with • Claims, brands, trademarks, Employees outside Legal Group must
and arrangements/relationships with
government or regulatory bodies about marketing materials – Product claims not appoint, manage or remove external
third-party shareholders;
investigations, including unexpected and marketing materials, including legal counsel or pay any legal fees that
investigations, or where Unilever advertising, promotional materials, • Bribery and corruption – Bribery or differ from the fee structures agreed by
is seeking regulatory action, such packaging and labelling, trade corruption issues, including related Legal Group.
as non-compliant labelling actions materials, advertorials, point-of-sale allegations or uncertainty about
Employees must not appoint a private
through local governmental bodies materials, and web content; Clearance situations that may have bribery or
investigator without prior approval from
(see Code Policy on Contact with for use of all brand names, marks, corruption implications (see Code
their General Counsel.
Government, Regulators and Non- logos, slogans, celebrity endorsements Policy on Anti-Bribery).
Governmental Organisations); and sponsorships; Maintenance,
Employees must use their common
protection and disposal of trademarks,
• Competition/antitrust – Compliance sense and judgement in situations not
copyrights and domain names used by
issues or questions involving covered above: if they are unsure, they
the business; Competitor challenges to
competition/antitrust laws, such as must always err on the side of caution
claims, brands, trademarks either by
trade terms, exclusivity arrangements and consult Legal Group.
or against a Unilever company;
or pricing; Meetings, contacts,
collaboration, agreements or other • Employment – Issues relating to
activity, including participation in trade non-compete obligations, employment
associations or industry groupings disputes and terminations and non-
(formal and informal or ad hoc), routine employment contract terms;
which may involve the exchange of • Safety – Product tampering or
information with a competitor or counterfeiting; Consumer complaints
restrictions on competition (see that may lead to legal disputes;
Code of Business Principles and Code Policies
THE CODE AND OUR STANDARD OF CONDUCT 12
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.
In this section:
Avoiding Conflicts of Interest
Anti-Bribery
Gifts & Hospitality
Accurate Records, Reporting &
Accounting
Protecting Unilever’s Physical & Financial
Assets & Intellectual Property
Anti-money Laundering
Code of Business Principles and Code Policies
COUNTERING CORRUPTION 14
Anti-Bribery
Unilever’s commitment to doing business • Ensure that before employing or Must nots
with integrity requires consistently high entering into contracts with any third
Unilever employees must not, directly
global standards: our zero-tolerance parties to represent Unilever or its
or indirectly (e.g. via suppliers, agents,
approach towards bribery and corruption interests externally, relevant Unilever
distributors, consultants, lawyers,
applies to all Unilever operations, teams have undertaken appropriate
intermediaries or anyone else):
regardless of local business practices. due diligence checks to assess the
This Code Policy covers what employees third party’s integrity. The outcome • Offer or give bribes or improper
must and must not do to meet Unilever of such checks must be considered advantages (including facilitation
requirements. carefully before deciding whether to payments) to any public official or
appoint the third party: employees other individual or third party, which
must inform their Business Integrity are, or give the impression that they
Musts
Officer of any concerns. are, intended to influence decisions
Employees must: by any person about Unilever;
In exceptional situations where
• Always make clear, internally and employees cannot escape imminent • Request or receive bribes or improper
To support global efforts to fight when dealing with third parties, threat of physical harm without meeting advantages from any third party, which
corruption, most countries have that Unilever has a zero tolerance a demand for payment, such a payment may, or give the impression that they
laws that prohibit bribery: many approach to bribery and corruption may be made but those involved must may be, intended to influence decisions
apply these ‘internationally’ to and will not (directly or indirectly) offer, immediately report full details of by Unilever about that third party.
behaviour beyond their borders. pay, seek or accept a payment, gift the demand and any payment to the
Where an employee considers that a
or favour to improperly influence Business Integrity Officer and Cluster
A breach of such laws may bribe, improper advantage or facilitation
a business outcome; General Counsel in the country where
result in fines for Unilever and in the incident occurred. This is to ensure
payment has been given or received,
personal penalties for individuals. • Immediately notify their Business they must not conceal this or take any
Integrity Officer and Cluster General that the matter can be fully investigated,
steps that could delay information being
Dealings with public officials are necessary financial records kept, and
Counsel if they become aware of any passed to the Business Integrity Officer
particularly high risk: even the suggested or actual payment or other further steps taken where appropriate
and Cluster General Counsel.
appearance of illegal conduct transaction which has the potential (see also Code Policy on Accurate
could cause significant damage to be in breach of this Code Policy; Records, Reporting and Accounting).
to Unilever’s reputation.
Code of Business Principles and Code Policies
COUNTERING CORRUPTION 16
Anti-money laundering
To protect Unilever’s reputation Musts Employees involved in engaging or
and avoid criminal liability, it contracting with third parties such
Employees must immediately notify their
as new suppliers, customers and
is important not to become Cluster General Counsel if they have
distributors must:
associated – however innocently any suspicions about actual or potential
– with the criminal activities of money laundering activity. • Ensure that the third parties in
question are subject to screening to
others. In particular, Unilever Employees must look out for warning
assess their identity and legitimacy
and its employees must ensure signs of money laundering, such as:
before contracts are signed or
Unilever does not receive the Supplier requests to: transactions occur. Various factors
proceeds of criminal activities, will determine the appropriate forms
• Pay funds to a bank account in the
as this can amount to the criminal name of a different third party or
and levels of screening;
offence of money laundering. outside the country of their operation; • Determine, with guidance from their
This Code Policy sets out Business Integrity Officer, which tools
• Make payments in a form outside the
essential steps employees must normal terms of business;
and processes should be used to
take to avoid being implicated in facilitate appropriate screening and Must nots
• Split payments to several bank record-keeping (see the Responsible
money laundering. Employees must not simply assume
accounts; Sourcing Policy and Responsible
Business Partner Policy); relevant third-party screening has
• Overpay.
already taken place: failure to check or
Customer payments to Unilever: • Carefully consider, where necessary update screenings periodically may put
in consultation with their Business Unilever and its employees at risk.
• From multiple bank accounts; Integrity Officer or General Counsel,
• From bank accounts overseas when screening outcomes before deciding
not a foreign customer; whether to do business with the
third party.
• Made in cash when normally made
by cheque or electronically; • Finance managers who support Supply
Chain Management and Customer
• Received from other third parties;
Development must regularly monitor
• Made in advance when not part and/or review suppliers, customers
of normal terms of business. and other third-party service providers
to identify business activity or
governance that could indicate money
laundering is taking place.
21
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.
In this section:
Occupational Health & Safety
Respect, Dignity & Fair Treatment
Code of Business Principles and Code Policies
RESPECTING PEOPLE 22
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.
In this section:
Protecting Unilever’s Information
Preventing Insider Trading
Competitors’ Information & Intellectual
Property
Personal Data & Privacy
Use of Information Technology
Code of Business Principles and Code Policies
SAFEGUARDING INFORMATION 26
Competitors’ Information
& Intellectual Property
Unilever respects the intellectual To promote fair competition, Unilever Musts Must nots
property and confidential gathers and uses competitors’
Employees must: Employees must not:
information that is in the public domain,
information of third parties,
for example, from newspapers, the • Check the latest internal training • Knowingly infringe the valid patents,
including competitors, suppliers internet and company filings. Accepting and guidance to understand what design rights, trademarks, copyright
and customers. Confidential or using competitors’ confidential are legitimate sources of data; and other intellectual property rights
information is information about information risks being a serious of any third party;
• Only gather and use competitors’
another company that is not in the infringement of competition laws and/
information that is known to • Seek to obtain competitors’
public domain and has value. or trade secrets/intellectual property
be legitimate; confidential information.
laws, leading to significant penalties for
Unilever and individuals. • Clearly record the sources of data Where employees acquire a
in all communications so their competitor’s confidential information
This Code Policy outlines what
legitimacy is beyond doubt; unintentionally, they must not use it or
employees must do to respect the
forward it to anyone except their Legal
confidentiality of other companies’ • If they acquire a competitor’s
business partner.
information. confidential information
unintentionally, they must notify their
Legal business partner immediately.
Code of Business Principles and Code Policies
SAFEGUARDING INFORMATION 29
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.
In this section:
Responsible Innovation Contact with Government,
Regulators & Non-governmental
Responsible Marketing Organisations (NGOs)
Product Quality Political Activities & Political
Responsible Sourcing Donations
Responsible Innovation
Unilever has global standards that apply Approaches to Animal Testing); Must nots
to all research and innovation, including
• Ensure the integrity, robustness, Employees must not:
on: the safe and sustainable design of
objectivity and transparency of all
new products, processes and packaging; • Deliver presentations or publications
scientific research and collaborations
product and brand development; that have not been approved via
with external partners (see Unilever’s
open innovation collaborations; and internal clearance procedures;
Position on Science with Objectivity
publication of our scientific research.
and Integrity); • Collaborate with third parties outside
a structured and approved contractual
• Maintain and make accessible
Musts records of all research, including
framework.
All employees involved in scientific study protocols and data, and their
research and innovation activity must interpretation and decisions made;
comply with all standards relevant to
• Raise any concerns about actual or
their area of work, notably in order to:
potential non-compliance with this
• Ensure that risks for consumer Code Policy with their line manager or
Innovation is fundamental to safety, occupational safety and the their relevant business partner in R&D.
Unilever’s business success environment are suitably assessed
and a core part of our global and managed;
strategy. The integrity and • Ensure appropriate specifications
objectivity of our Science are of raw materials, products and
a key foundation for our approach packaging;
to responsible innovation. • Ensure effective management
Safety is non-negotiable. of consumer safety risks from
Unilever conducts responsible, safe and food allergens;
sustainable research and innovation, • Ensure research on human subjects
which fully respects the concerns of is conducted to the highest ethical
our consumers and society. In meeting standards;
consumer needs, Unilever’s innovations
• Uphold Unilever’s commitment to
are based on sound science and
eliminate animal testing without
technology, and reflect high standards
compromising on consumer safety
and ethical principles.
(see Developing Alternative
Code of Business Principles and Code Policies
ENGAGING EXTERNALLY 33
Responsible Marketing
Unilever is committed to Musts Must nots
developing, producing, marketing Integrity, responsibility and Employees must not:
and selling all its products and transparency
• Alter images used in marketing
services responsibly. Unilever Employees who are involved in Unilever communications in such a way that
can and should conduct marketing activities must: advertising is rendered misleading;
marketing activities in line with
• At all times, respect applicable • Misuse technical data or use scientific
societal expectations. marketing laws; terminology or vocabulary in such a
This Code Policy sets out global way as falsely to suggest that a claim
• Describe our products/services and
minimum standards that apply to has scientific validity;
their effects truthfully, accurately
all of Unilever’s marketing activities
and transparently, with appropriate • Associate our products or services
everywhere. This covers but is not
factual and, where relevant, nutritional Freedom of choice with – or feature within any Unilever
limited to: brand names, packaging
information; marketing – themes, figures or
and labelling; consumer planning and Employees involved in Unilever marketing
images likely to cause serious or
market research; trade advertising; • Ensure there is sufficient information activities must show respect for people
widespread offence to any religion,
sales materials; brand merchandising for consumers and customers to who choose not to buy our products
nationality, culture, gender, race,
and sponsorship; all forms of advertising understand how to use our products and services, and ensure there is
sexual orientation, age, disability
including television, radio, print, digital and services; sufficient information about our products
or minority group;
media, promotional activities and events, • Ensure our marketing is based on and services for consumers to make
product placements, ‘advergaming’ – informed choices. • Advertise in any media known for
adequate support for the claims
whether created by Unilever, agencies, promoting violence, pornography
Unilever makes; Taste and decency
crowdsourcing or other third parties. or insulting behaviour.
• Comply with our principles and Employees involved in Unilever
standards on marketing, including marketing activities must ensure
(but not limited to) those with respect our marketing reflects and respects
to children, women and social media; generally accepted contemporary
• Be mindful of the environmental standards of good taste and quality, in the
implications of marketing activity, context for which it is designed, showing
in such areas as new product awareness of both wider society and
development, marketing activation sensitivity to different cultural, social,
plans, packaging and content ethical and religious groups.
recycling.
Code of Business Principles and Code Policies
ENGAGING EXTERNALLY 34
Product Quality
Unilever will take prompt and timely Musts
action wherever and whenever we
Employees must:
encounter products which don’t meet
our standards or those required in the • Apply effective processes to measure
market place. We will continuously and record product and process
improve product quality experiences performance and, where appropriate,
by using the insights gained from our take effective preventative steps or
performance measures and from corrective action to assure great
consumer and customer feedback. product quality experiences for our
customers and consumers; and
This Code Policy applies to all aspects
of product quality including safety, • Promptly discuss concerns with line
design, formulation, raw materials, management and take steps to address
primary/secondary/tertiary packaging, any information regarding a potential
manufacture, storage, transport, display, or actual product quality, regulatory
marketing, communication, sales or safety issue.
and disposal of Unilever products –
at Unilever, third-party or business
Must nots
partner facilities.
Unilever’s reputation is founded Unilever is committed to achieving Employees must not:
on delighting our consumers this goal by meeting or exceeding all
• Knowingly produce or distribute
legal and regulatory requirements and
and customers with consistently products, including promotional items,
through the rigorous application of
great product quality that meets or services that could adversely impact
our Quality Management System. Each
or exceeds their needs and employees’ or consumers’ health,
personal product quality experience
endanger customers or adversely
expectations. Our aim is to be for our consumers depends upon all
impact Unilever’s brand reputation;
the most trusted and preferred employees understanding their roles and
customer and consumer choice responsibilities and ensuring that they • Take decisions about quality without
adhere to Unilever’s quality standards, sufficient knowledge or authority; or
on every occasion.
business processes and regulatory • Respond to customers or consumers
requirements at all times. about the quality or safety of products
without authorisation to do so.
Code of Business Principles and Code Policies
ENGAGING EXTERNALLY 35
Responsible Sourcing
Unilever expects its business 1. Business is conducted lawfully All Unilever Purchasing Agreements/
partners to adhere to values and with integrity Contracts (UPAs/Global GTCs), Master
and Local Purchase Agreements (MPAs/
and principles consistent with 2. Work is conducted on the basis of
LPAs) or Unilever Master Services
our own. Unilever is developing freely agreed and documented terms
Agreements (MSAs) specify that
new business practices to grow of employment
suppliers must acknowledge adherence
our company and communities, 3. All workers are treated equally to our RSP as a condition of supply.
by doing business in a manner and with respect and dignity
This Code Policy sets out responsibilities
that improves lives of workers 4. Work is conducted on of employees who engage with suppliers.
across our supply chain, their a voluntary basis
communities and the environment, 5. All workers are of an appropriate age Musts
consistent with the Unilever
6. All workers are paid fair wages Employees who contract and/or work
Sustainable Living Plan.
7. Working hours for all workers with Unilever’s suppliers must:
Our requirements of suppliers (companies are reasonable • Read and understand the Fundamental Must nots
that supply Unilever with goods and/or
8. All workers are free to exercise their Principles and consult their line
services, across both production and Employees who contract and/or work
right to form and/or join trade unions manager or the relevant Supply
non-production areas of our business) with Unilever’s suppliers must not
or to refrain from doing so and to Management business partner if they
are set out in our Responsible Sourcing agree to any contractual changes or
bargain collectively have any questions;
Policy (RSP). Unilever’s reputation could exclusions with respect to the RSP
suffer significant damage if suppliers 9. Workers’ health and safety are • Notify their line manager and, if without consulting their Legal business
fail to comply with these requirements. protected at work appropriate, the relevant Supply partner and prior written authorisation
Management business partner if they from their Regional Director Supplier
The RSP affirms the following 10. Workers have access to fair know or suspect that suppliers are not Excellence or Vice President Supplier
Fundamental Principles: procedures and remedies meeting relevant RSP requirements Excellence.
11. Land rights of communities, including within the Responsible Sourcing Policy;
indigenous peoples, will be protected • Ensure that any shortlists or tendering
and promoted processes for new suppliers for which
12. Business is conducted in a manner they are responsible consider potential
which embraces sustainability and suppliers’ credentials in areas covered
reduces environmental impact. by the RSP.
Code of Business Principles and Code Policies
ENGAGING EXTERNALLY 36
Fair Competition (2 of 2)
Musts (continued) Must nots Co-operating with competition
authorities
• Where possible, always consult their Employees must not participate in
Legal business partner before meeting cartels. In particular, they must not Unilever co-operates fully with
a competitor or discussing or agreeing discuss or agree any of the following, the competition authorities, while
anything about which they have directly or indirectly, with competitors: consistently and robustly defending its
concerns (see the Code Policy on legitimate interests. All contact with
• The price or terms of sale for products
Legal Consultation); competition authorities (including,
and/or services
where relevant, national courts) are
• Take care that participation in industry
• The price or terms to be demanded co-ordinated by Legal Group. For more
or trade associations events and
from suppliers details, see the Code Policy on Contact
related contacts are not used for
with Government, Regulators & Non-
anti-competitive purposes; this also • The co-ordination or allocation of bids
Governmental Organisations (NGOs).
applies to less formal meetings or or quotes
events that involve competitors, such • Limitations on production or sales
as awards ceremonies or associated
social contacts; • The division or allocation of geographic
markets, customers or product lines
• Before taking part in a trade
association or industry event, ensure • Boycotts or refusals to deal with
all mandatory requirements set out certain competitors, customers or
in the Unilever Standard on Trade suppliers.
Association Memberships have been Legitimate joint purchasing
complied with; arrangements, production, research
• Object immediately if inappropriate and development and standardisation
topics are raised in any industry or agreements that have received prior
trade association discussion and leave written approval from Legal Group
immediately – and noticeably – if any are excluded from the above.
inappropriate discussion continues;
• Report incidents of inappropriate
discussions immediately to their
line manager and the relevant Legal
business partner.
Code of Business Principles and Code Policies
ENGAGING EXTERNALLY 38
Contact with regulators about products • Unilever site leaders must have up-
and/or ingredients to-date procedures for responding
to unannounced inspections from
Any contact with regulators about
relevant authorities. This must include
Unilever’s actual or planned use of
the nomination of Responsible Persons
products and/or ingredients must have
to lead the response for each type of
the prior approval of Regulatory Affairs
potential inspection.
(which will, in turn, seek necessary
clearances from Legal Group). • Employees must not attempt to
obstruct the collection of information,
Any contact with regulators must have
data, testimony or records by
the prior approval of the local Regulatory
authorised investigators or officials.
Affairs Departments. If employees do not
have such departments in their location, • Employees must not say or do
they must get approval from the local anything that may, or may be perceived
or cluster head of Regulatory Affairs. as seeking to, improperly influence
At times, this approval may be given decisions about Unilever by any
on a standing basis. government, legislators, regulators
or NGOs (see the Code Policies on
Contact with NGOs
Gifts & Hospitality and Anti-Bribery).
Any contact with NGOs must have the
prior approval of the local External or
Public Affairs Departments. If employees
do not have such departments in their
location, they must get approval from the
local or Cluster head of Communications.
At times, this approval may be given on a
standing basis.
Code of Business Principles and Code Policies
ENGAGING EXTERNALLY 40
Musts
Must nots
Employees must ensure that:
Unilever companies must not, directly or
• Any contributions towards, and indirectly, support or make contributions
support for, political parties are clearly to political parties or candidates.
personal and give no impression of Communication, financial contributions,
being connected to Unilever; benefits in-kind, gifts, sponsorships
• Any personal political support or and use of Unilever resources are
contributions do not affect their all prohibited.
performance or objectivity at work Involvement in the type of social or
(see the Code Policy on Avoiding economic advisory groups mentioned
Conflicts of Interest); above must not create a conflict of
• Where employees represent Unilever interest for employees (see the Code
in social or economic advisory Policy on Avoiding Conflicts of Interest).
groups set up by governments, their
participation is subject to the prior
approval of the Senior Vice President
Communications;
Code of Business Principles and Code Policies
ENGAGING EXTERNALLY 41
External Communications –
The Media, Investors & Analysts
Musts Must nots
Employees who have received Employees who are not part of the
authorisation to communicate with Investor Relations or Media Relations
investment communities or the media functions or a Board Member must not:
from the Investor Relations or Media
• Communicate with investment
Relations functions or a Board
communities or the media, either on
Member must:
or off the record, without authorisation
• Comply with any conditions attached from one of these functions and
to their authorisation, such as appropriate training/briefing;
constraints on when and/or with
• Respond to enquiries from investment
whom they may communicate;
communities or the media: all enquiries
Communication with investment Unilever’s Disclosure Committee – on • Always consult with the authorising must be directed to the Media Relations
communities – including behalf of the Board – is responsible for functions about the content of any or Investor Relations functions;
ensuring Unilever has the necessary message before they communicate.
shareholders, brokers and • Get drawn into conversations,
procedures to comply with relevant laws
analysts – and the media must and regulations including Unilever’s
Employees who are part of the Investor answer any questions or provide
be managed carefully. Such Relations or Media Relations functions any information or opinion;
Disclosure & Share-Dealing Manuals.
communication has important must follow Unilever’s Share Dealing
• Make any forward-looking financial
This Code Policy outlines how and Disclosure Manuals and the
legal requirements and demands communication with investment
statements or provide ‘inside
departmental processes and procedures
specialist skills and experience. information’ (see the Code Policy
communities and the media (including authorisations) in this area.
on Preventing Insider Trading and
Only individuals with specific must operate.
The above rules also apply outside the Media Relations Protocol).
authorisation and training/briefing formal work settings, such as at external
may communicate about Unilever speaking engagements, courses,
with investment communities seminars, trade association events
or the media, or respond to their or social occasions.
enquiries or questions.
Code of Business Principles and Code Policies
GLOSSARY 42
Glossary
Code Support Line Employee Family member Public official
Confidential online and telephone A person employed by Unilever under A relative, by blood or by marriage (or An officer, employee or representative
service, allowing the user to raise a one of a variety of contracts. The term similar informal relationship), notably a of a State or a State controlled or
concern about an actual or potential covers all employees, whether full-time, spouse, live-in partner, parent or child. owned entity. Term includes a person
breach of the Code or Code Policies, to part-time, fixed-term, permanent The term includes sibling, step- or representing a political party or public
ask a question if clarification is needed or trainees. adopted child, step-parent, grandparent, international organisation, or a candidate
and to check back on the status of a uncle, aunt, cousin, grandchild or any for political, municipal or judicial office.
Additionally, in this document, the term
concern raised or a question asked. relative who has lived with you for the Also covers anyone acting in an official
is used to cover other persons working
The service is available at www. past 12 months or more. capacity on behalf of any of the above,
for Unilever as follows: contractors,
unilevercodesupport.ethicspoint.com including the police and armed forces.
temporary staff, secondees, work
Improper advantages
experience placements; those with a
Competitor’s confidential information
statutory Director role or equivalent The offer or gift of anything of any value,
Non-public information about a responsibilities; employees of joint including nominal cash amounts, which
competitor’s product or the way in which ventures and approved third-party may be perceived as intended to cause
a competitor carries out its business. labour providers where Unilever the recipient to behave contrary to
Confidential information covers a broad has direct management control; customary ethical expectations. Includes
sweep of activities, including current and employees of new acquisitions. money, services (including favours),
or future prices; pricing terms (e.g. discounts, use of resources, loans,
discounts); buying prices, costs and Facilitation payment credit, the promise of future advantages
supplier information business or financial (including future employment or
Unofficial payment – in effect a bribe
strategies and plans (e.g. mergers, internships), and gifts or hospitality.
– made to a public official to secure or
acquisitions and divestments); marketing,
speed up the performance of a routine
promotional and sales plans; financial Operational units
action that the official is required to
results before any formal announcement;
provide anyway. Facilitation payments MCOs, Global Categories, Global &
R&D work (strategies, designs, formulae,
are illegal in most countries, although Cluster Supply Chain Leadership Teams,
drawings, technical information, manuals
a small number provide exceptions Global Supply Management, IT and
and instructions, product specifications
in certain circumstances. Also referred Global Business Services.
and samples of products that have not
to as a ‘facilitating’, ‘speed’ or ‘
been launched or revealed publicly);
grease’ payment.
and proprietary software.
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