Code of Business Principles and Code

Unilever
Code of Business Principles

and Code Policies
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 Alan Jope 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
The Code
of Business Countering
Countering Respecting
Respecting Safeguarding
Safeguarding Engaging
Engaging
Principles Corruption
Corruption People
People Information
Information Externally
Externally Glossary 02
02
The Code and
our Standard
of Conduct
Our Framework
A message from Alan Jope
The Code of Business Principles
Living the Code
Legal Consultation
Responsible Risk Management
Responsible Innovation
Product Safety & Product Quality
The Code
Engaging
Corruption People
People Information
03
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.
The Code
Engaging
Corruption People
People Information
04
Foreword from Alan Jope
Welcome to the most important up’ in this connected, social media world
document we have at Unilever has become more complicated than ever.
– our Code of Business Principles. What’s more, the accelerating pace of
change, and the greater speed with which
When I think of my time at Unilever, and we must operate, often intensifies these
consider why I have stayed for over 30 challenges.
years, I put it down to two core reasons: our
The Code of Business Principles is our
geographical diversity and the values of the
guidebook for putting our values into
business. Values that give us the instinct to
practice. It sets out a clear standard of
do the right thing and to treat each other
conduct to ensure that we always make
with respect.
the right choice, providing a framework
Having a strong set of values that respect of simple “musts” and “must nots”. It’s a
people, society, and the planet has always document which not only protects Unilever,
been at the heart of Unilever, and will and each and every one of us, but will help
continue to be critical to building our us to have a meaningful impact on the lives
purpose-led, future-fit company. Our licence of millions of people across our value chain.
to operate and our ability to compete
Much of Unilever’s strength lies in the shared
successfully, are dependent on each and
values of our people. Behaving with integrity
every one of us living these values, day in
is part of who we are. Thank you for your
and day out.
diligence and for helping to create a fairer
Yet we know that in this volatile and and more principled world as we work
unpredictable world, we face numerous towards delivering our vision of being the
challenges in doing so. Challenges, but not global leader in sustainable business.
excuses. Many of the countries in which we
Read and re-read our Code.
operate rank poorly in global corruption
It matters.
indices. The digital world increasingly
presents us with new considerations for
Thank you,
managing cyber and data security, and
Alan
how our company and our brands ‘show
The Code
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05
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 planet.
their intended use. Products and services We will work with these partners to raise
We will recruit, employ and promote
Standard of Conduct employees on the sole basis of the will be accurately and properly labelled, standards so that their employees are
advertised and communicated. paid a living wage and are not subject
We conduct our operations with honesty, qualifications and abilities needed for the
to forced, compulsory, trafficked or
integrity and openness, and with respect work to be performed.
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
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
business interests.
Policy Committee which is chaired by the We will work on the basis of sound Data
Chief Legal Officer. science, applying rigorous standards Unilever neither supports political
of product safety. Unilever is committed to the responsible,
parties nor contributes to the funds of
Day-to-day responsibility is delegated ethical and fair use of data.
groups whose activities are calculated to
to all senior management of the
geographies, divisions, functions
Competition promote party interests. We collect and use data in line with our
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
principles, supported by local Business of appropriate competition laws. Unilever
Unilever does not give or receive, Note
Integrity Committees. companies and employees will conduct
whether directly or indirectly, bribes or In this Code the expressions ‘Unilever’
their operations in accordance with the
Assurance of compliance is given and other improper advantages for business and ‘Unilever companies’ are used for
principles of fair competition and all
monitored each year. Compliance is or financial gain. No employee may offer, convenience and mean the Unilever Group
applicable regulations.
subject to review by the Board supported give or receive any gift or payment which of companies comprising Unilever N.V.,
by the Corporate Responsibility is, or may be construed as being, a bribe. Unilever PLC and their respective subsidiary
Committee and for financial and The Planet companies. The Board of Unilever means the
Any demand for, or offer of, a bribe must
accounting issues the Audit Committee. Unilever is committed to making be rejected immediately and reported to Directors of Unilever N.V. and Unilever PLC.
Any breaches of the Code must be continuous improvements in the management.
reported. The Board of Unilever will not management of our environmental impact
Unilever accounting records and
criticise management for any loss of and to the longer-term goal of developing
supporting documents must accurately
business resulting from adherence to a sustainable business.
describe and reflect the nature of the
these principles and other mandatory Unilever will work in partnership with underlying transactions. No undisclosed
policies. Provision has been made others to promote environmental care, or unrecorded account, fund or asset will
for employees to be able to report increase understanding of environmental be established or maintained.
in confidence and no employee will issues and disseminate good practice.
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
values are the foundation of our could have very serious consequences and Code Policies cannot cover every
for Unilever and for individuals involved. eventuality, particularly as laws differ
success and essential to achieving
Where illegal conduct is involved, these between countries. If specific situations
our ambition of making sustainable could include significant fines for Unilever, are not expressly covered, the spirit of the
living commonplace. 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 as required
legal action. by their Line Manager or Business
Unilever’s Code of Business
Principles (the Code), and the Integrity Officer
References in the Code and Code Policies
policies that support it (Code to ‘employees’ include the following: • Follow the Code and Code Policies: if they
Policies), set out the standards are unsure of how to interpret these or
• Unilever employees, whether full time,
required from all our employees. have any doubts about whether specific
part time, fixed term, permanent or
Unilever also requires its third- behaviours meet the standards required
trainees
party business partners and their they must seek the advice of their Line
• Persons with statutory director roles Manager or Business Integrity Officer
employees to adhere to business
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
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 • Complete an annual Code declaration discretion and discussing them with reporting a potential or actual breach or
Committee in the country where their Business Integrity Officer as ask them to ignore an issue
concerns occur • Ensure that all their team members, soon as possible to determine the
including new joiners: 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 read the Code and Code Policies
by telephone or web using the • Collaborate further and complete any • Discuss any potential or actual breach
telephone number or web address – Have completed any related documentation (e.g. case information under investigation with other persons,
communicated locally mandatory training and lessons learnt) as may be unless this has been cleared with the
required of them by their Business investigation team
• If asked not to report a potential breach – Understand how to raise concerns Integrity Officer
by their Line Manager or another and / or report actual or suspected
employee, they must immediately breaches • Insofar as a breach may have occurred
report it to their Business Integrity within their operations, consider what
Officer and / or the Code Support Line • Deliver training that the Business additional communications, training
Integrity Committee or their Line or changes to business controls and
Manager has asked of them, e.g. procedures are necessary to reduce the
Business Integrity Moments, face-to- likelihood of similar breaches occurring
face briefings and team discussions
• 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
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 market Cluster/country

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

opportunity assessment at the core of All managers and above must implement - How those risks are being managed is
the leadership team agenda. Unilever Unilever’s Principles of Risk Management reviewed;
defines risks as actions or events that as follows: - Any gaps in their desired risk appetite
have the potential to impact our ability to are identified.
achieve our objectives. Unilever identifies • Accountability: they must identify and
and mitigates downside risks such as loss manage the risks that relate to their role • Perform regular reviews and ensure
of money, reputation or talent as well risks are mitigated as desired.
as upside risks such as failure to deliver • Risk Appetite: they must determine
strategy if it does not strengthen brand the level of risk, they are prepared to Heads of Countries must:
equities or grow in growing channels. accept to guide them in deciding what
mitigation should be taken • Highlight significant country regulatory
or statutory compliance risks to either
Unilever’s Risk Management approach
• Risk Mitigation: they must put adequate the relevant Business Group(s) or the
is embedded in the normal course of
controls in place, and ensure that they Chief Legal Officer;
business with a set of global Principles
are operational, in order to deliver their
of Risk Management with local • Highlight significant country customer
objectives
implementation. or channel risks to either the relevant
Where leadership teams of key global Business Group(s) or the Chief Digital &
Its structural elements include: functions are responsible for any of Commercial Officer
Unilever’s Key Business Risks, they must:
• Governance of Unilever, organisational All project leaders of transformational
structure and delegation of authority • Define the risk and ensure that projects must, together with their teams:
mitigating actions are taken as
Risk management is integral • Vision, Strategy and Objectives required • Identify the key risks associated with
their project achieving its objectives
to Unilever’s strategy and to • Ensure supporting documentation is
• Code of Business Principles, Code
the achievement of Unilever’s available • Prepare risk mitigation plans
Policies and Standards
longterm goals. Our success as
Leadership teams of Business Groups, • Review progress with the project
an organisation depends on our • Risk and Control Frameworks
Business Operations, Unilever steering group.
ability to identify and exploit the International, Africa, and any listed
opportunities generated by our • Performance management and
entities where risk assessments are a
operational processes execution
business and the markets Unilever regulatory requirement must:
operates in. • Compliance and assurance activities.
• 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
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 Employees must not:
are suitably assessed and managed
Unilever’s business success and
• Deliver presentations or publications
a core part of our global strategy. • Ensure appropriate specifications of raw
materials, products and packaging that have not been approved via
The integrity and objectivity of internal clearance procedures
our Science are a key foundation • Ensure effective management of
for our approach to responsible consumer safety risks from food allergens • Collaborate with third parties outside
innovation. Safety is non- a structured and approved contractual
• 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
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
services we provide meet and / • Promptly and proactively report all
or exceed the expectations of our product safety or product quality
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
high standards or those required by Employees must not:
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 same process if they are - Create any liability for Unilever.
significant negative impact on the publicly traded pension funds, index interested in taking up, in a personal The employee must inform the other
reputation and effectiveness of linked or tracker funds that represent: capacity, a proposed directorship (or organisation that they take up this
equivalent) of another organisation, position on a personal basis, with no
Unilever, its business and its people. - Substantial interests in a whether commercial or not-for-profit, responsibility for Unilever and that any
They arise when an employee allows competitor, State controlled or including roles in trade associations and fees or benefits that arise from their
their actual, perceived or potential influenced entity, or any other third roles for public bodies. This obligation engagement are not passed on
personal, financial or non-financial party relevant to Unilever business extends to new joiners that hold to Unilever
interests to affect their objectivity (5% of the net worth of any of these directorships and have not disclosed
when performing their job at Unilever. entities) them as part of the recruitment process
Must nots
- Any interest in a third party if The above disclosure requirements
This Code Policy sets out what
they, or one of their team, are excludes roles of school governors, Employees must not:
employees must do to prevent and involved in engaging, monitoring governing positions in amateur sporting
to manage these situations. or investigating the third party’s or recreational groups, and directors • Accept appointments, debate, vote,
performance of property/housing blocks in which an or participate in any decision-making
A conflict of interest may arise, and
employee lives process or activity when a conflict of
disclosure is required, when an employee: • Allows their non-financial interests interest exists or might arise before their
• Hires, manages, or has an influence on such as personal values, beliefs, • Obtain written approval from the Chief Business Integrity Officer has provided
the workload, performance assessment, welfare and political views to take Legal Officer and the Chief Business clearance
granting of approvals and / or reward precedence over Unilever’s lawful and Integrity Officer, before becoming a
of someone with whom they have a ethical expectations, affecting their director of any publicly listed company • Take, or divert to others, any business
close personal relationship performance or objectivity at work opportunities that arise in the course of
• Ensure that external commitments doing their job at Unilever that could be
• Accepts or performs a Public Official
do not: of interest to Unilever
role, or has a family member or a close Musts
personal contact who is a Public Official - Detract them from their commitment • Misuse their position in Unilever to
with the ability to take decisions that Employees must: and contribution to Unilever advance personal interests
could impact Unilever business
• Ensure Unilever is best placed to benefit - Provide access to commercially
• Has a close personal interest in the • Hire, contract or engage any individual
from potential business opportunities sensitive information concerning
business of competitors or other or organisation without ensuring they
actual or potential Unilever
third parties relevant to Unilever. This are free of conflict of interest with
• Follow the process outlined here competitors (see Code Policies on
includes cases where the employee, Unilever
to immediately disclose an actual, Fair Competition and Competitors’
their family members or a close Information); and / or
perceived or potential conflict of interest • Hire or retain the services of former
personal contact:
to their Business Integrity Officer who Public Officials without following
- work for or provide any services to will determine the best way to manage Unilever’s Principles on ‘revolving
competitors or to any other third the situation in consultation with the doors’.
parties relevant to Unilever’s business employee’s Line Manager
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Anti-Bribery
Musts Must nots
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
to bribery and corruption and will not • Offer or give bribes or improper
(directly or indirectly) offer, pay, seek advantages (including facilitation
or accept a payment, gift or favour payments) to any public official or other
to improperly influence a business individual or third party, which are,
outcome or give the impression that they are,
intended to influence decisions by any
• Immediately notify their Business person about Unilever
Integrity Officer and Cluster General
Counsel if they become aware of any • Request or receive bribes or improper
suggested or actual payment or other advantages from any third party, which
transaction which has the potential to are, or give the impression that they
be in breach of this Code Policy may be, intended to influence decisions
by Unilever about that third party
To support global efforts to fight Unilever’s commitment to doing • Follow Unilever’s third party compliance
corruption, most countries have business with integrity requires policies and controls in accordance with In exceptional situations where
the Responsible Sourcing and Business employees cannot escape imminent
laws that prohibit bribery: many consistently high global standards:
Partnering Code Policy threat to their life, liberty, or physical
apply these ‘internationally’ to our zero-tolerance approach harm without meeting a demand for
behaviour beyond their borders. towards bribery and corruption • Use electronic communications or payment, such a payment may be made
A breach of such laws may result in applies to all Unilever operations, e-government solutions (in areas but those involved must immediately
legal and financial consequences regardless of local business such as licencing, procurement, taxes, report full details to their Business
practices, and prohibits both public brand protection, etc) or any other Integrity Officer and Cluster General
for Unilever and individuals.
means available to reduce face-to-face Counsel in the country where the incident
Dealings with public officials are and commercial bribery (e.g. to or
interactions with public officials and the occurred. This is to ensure that the matter
particularly high risk: even the from any third party). can be fully investigated, necessary
connected risks of bribe solicitation
appearance of illegal conduct financial records kept, and further steps
could cause significant damage to This Code Policy covers what taken where appropriate (see also Code
employees must and must not do to Policy 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
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
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
monetary limits for gifts, are one- In exceptional circumstances where
• Ensure that hospitality is only offered or employees seek to offer or accept • Offer or accept any gifts or hospitality,
off or irregular in nature and always
accepted if: hospitality above the local monetary or any other favours which are intended
comply with the Code Policy on
limits for hospitality, they must: or might be seen to influence business
Avoiding Conflicts of Interest. Although
- There is a legitimate business interest 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
their own records for inspection. All proposal
- Its value does not exceed the local • Offer or accept any gifts that are in cash
exceptions require prior clearance by or a cash equivalent, such as lottery
monetary limits for hospitality; and • Obtain clearance from their Business
their Business Integrity Officer tickets, gift certificates, vouchers, loans,
Integrity Officer; and
- It remains one-off or irregular in guarantees or any other granting of
• Ensure that if they are offered a gift credit, shares or options
that exceeds the local monetary limits nature • Once approval is received, ask the
for gifts they must politely decline and third party to confirm that the offer or • Offer or accept any hospitality involving
explain the Unilever rules. In exceptional - It is in the form of a locally hosted acceptance of such hospitality also overnight stays or foreign travel without
situations where such gifts have to meal, attendance at, or participation complies with its equivalent gifts and prior written clearance from their
be accepted to avoid causing serious in an organised ‘team-building’ hospitality policy Business Integrity Officer
offence, or circumstances genuinely occasion, local cultural or sporting
preclude their return, employees must: event, local industry award In other circumstances where employees • Offer or accept any hospitality that is
ceremony, business site visit or similar are offered or asked for hospitality that not consistent with the Code Policy on
– Obtain clearance from their Business responsible activity exceeds relevant local monetary limits for Respect, Dignity and Fair Treatment, or
Integrity Officer; and hospitality they must politely decline by may cause offence under local norms
- Usual business contacts from Unilever reference to this Code Policy. and customs
– Where appropriate take steps for the and other parties are physically
gift to be donated to charity present 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
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 Market Cluster/Country Heads, Finance
accurate and complete. • Only perform transactions, such as Employees who are responsible for Directors and Controllers must complete
buying, selling or transferring goods/ reporting financial and other business quarterly and annual Financial Reporting
Our records provide valuable assets, for which they are authorised information must: Declarations in line with instructions
information for the business and issued by Unilever Financial Group.
evidence of our actions, decisions • Ensure transactions they approve • Comply with all applicable laws, for
are legitimate and based on valid example, those regarding financial
and obligations. Procedures and statements, tax and environmental Must nots
documentation
processes must be in place to requirements
ensure that underlying transactions • Notify their Business Integrity Officer and Employees must not:
are properly authorised and the Head of Finance of any potential • Adhere to all applicable external
fraud or arrangements to facilitate tax reporting standards and regulations, • Do anything to artificially inflate or
accurately recorded.
evasion, or other misrepresentation of such as international and national shift sales or profit between reporting
Any failure to record transactions accounting or other information, or if a accounting standards, stock market periods
accurately, or falsifying or ‘facilitation payment’ has been paid to listing standards and rules, financial
avoid physical danger or due to an error regulator rules, health and safety • Create, maintain or procure others to
creating misleading information produce or maintain undisclosed or
in judgment requirements, corporate governance
or influencing others to do so, codes and regulatory standards unrecorded accounts, funds or assets
could constitute fraud and result • Where instructed in the context of a
in fines or penalties for employees legal hold, retain records in accordance • Follow Unilever’s Accounting Manual, • Conceal, alter or falsify company
or for Unilever. with Unilever’s Data Retention reporting instructions and timetables, records, accounts and documents
Standard, or longer if required by local information standards and information
This Code Policy sets out what laws/regulations definitions
employees must do to ensure the
accuracy of our business records • Retain records that may be relevant Employees involved in accounting must:
to any ongoing audit, litigation or
and financial information. • Ensure sales, profits, assets and
regulatory investigation, even if they
exceed the normal retention period if liabilities are recorded in the correct
instructed to do so time period
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Protecting Unilever’s Physical & Financial Assets & Intellectual Property
Musts Financial assets • Ensure all necessary checks and

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
contracts or transactions Must nots
• Identify potential hazards from
activities and services on site
Employees must not:
Intellectual property
Employees are responsible for • Evaluate the risk of damage to site
• Remove Unilever’s physical assets or
ensuring Unilever’s assets are assets of such hazards and of any Employees must:
property from company premises
protected. potential business interruption or
without permission or use them for
liability that could result • Report to Legal Group any suspected
inappropriate purposes
For information on the protection counterfeit products or any product,
• Take steps to reduce identified risks to packaging, communication or
of several other asset types see • Knowingly infringe the valid patents,
an acceptable level marketing practice that are suspected
the Code Policies on Occupational of infringing our copyright, trademarks,
design rights, trademarks, copyright
Health and Safety and Protecting and other intellectual property rights
patents, design rights, domain names
of any third party
Unilever’s Information. and / or other 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
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 Cluster not part of the contract indicate money laundering is taking place
General Counsel if they have any
offence of money laundering. - Made in advance when not part of
suspicions about actual or potential
money laundering activity or about normal terms of business Must nots
This Code Policy sets out essential transactions with sanctioned countries
steps employees must take to avoid 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 Geography Head, in consultation with distributors must: screening has already taken place:
laundering. their most senior Legal and 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 from
outside the country of their operation • Determine, with guidance from their their Cluster General Counsel on how to
Business Integrity Officer, which tools handle the matter with the third party
- Take payments in a form outside the
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 providing • Only undertake work that they are • Regularly review and comply with This Code Policy is shared globally through
healthy and safe working conditions. trained, competent, medically fit, all applicable local health and our local SHE team members who work
sufficiently rested and alert enough to do safety legislation, including relevant closely with their local leadership teams
Unilever complies with all applicable
mandatory Unilever requirements In countries where directors of the
legislation and regulations and aims • Make sure they know what to do if an local legal company/entity must take
to continuously improve health and emergency occurs at their place of work • Develop site and role specific health responsibility for health and safety matters
safety performance. / on the road or at a location they are and safety improvement objectives for all national premises in order to meet
visiting and monitor performance, including legal regulatory requirements, Unilever
Everyone at Unilever has a role to an annual review of the management premises leaders must liaise with the
play. Managers are responsible for • Promptly report to local Unilever system’s effectiveness and adequacy relevant board of directors to agree the
cascading and implementation of management any actual or near miss health and safety at work management
the occupational health and safety accident or injury, illness, unsafe or • Report mandatory Key Performance system and the approach required to
unhealthy condition, incident, spill or Indicators (KPIs) via Unilever’s Safety, ensure appropriate ongoing review
of their direct reports and third
release of material to the environment, Health and Environment (SHE)
parties under their control. As a so that steps can be taken to correct, reporting system
condition of our employment, we prevent or control those conditions Must nots
all have a duty to work safely. immediately • Report all incidents, accidents and
near misses in line with reporting Employees must not:
This Code Policy outlines All Unilever team leaders have overall requirements, including thorough
our individual and shared operational responsibility for health and investigation, follow-up and • Undertake work or related activity, such
responsibilities for health and safety. safety at their location and must: communication of lessons learned as driving, when under the influence
of alcohol or drugs, or when using
• Establish and maintain an appropriate medication improperly
Musts • Maintain, communicate and test both
health and safety at work management
site and role emergency plans
system for their sites and their • Carry on with any work that becomes
Employees must:
teams, including the appointment of unsafe or unhealthy
• Ensure all employees, contractors and
• Work and behave safely committees, managers, competent
visitors receive information and training
experts and a system for gathering • Assume someone else will report a risk
in health and safety relevant to their
• Comply with health and safety employees’ concerns/input or concern
roles and activities
procedures and instructions relevant
to their work and / or about which they • Identify health and safety hazards and
have been trained or notified manage/control risks arising from their
team and their site’s routine and planned
• Support team leaders to ensure that operations, activities and services
everyone they work with, including
contractors and visitors, are familiar
with and follow applicable health and
safety procedures and instructions
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Respect, Dignity & Fair Treatment (1 of 2)
Business can only flourish in Musts
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
There is both a business and identity, colour, religion, country of
a moral case for ensuring that origin, sexual orientation, marital
human rights are upheld across status, dependants, disability, social
Unilever’s operations and value class or political views. This includes
consideration for recruitment,
chain. Unilever is committed to
redundancy, promotion, reward and
ensuring that all employees work benefits, training or retirement which
in an environment that promotes must be based on merit
diversity and where there is mutual
Line Managers must:
trust, respect for human rights and
equal opportunity, and no unlawful • Ensure all employees’ work is conducted
discrimination or victimisation. on the basis of freely agreed and
documented terms of employment,
This Code Policy sets out what clearly understood by and made
employees must do to ensure that available to relevant employees and
all workplaces maintain such an others working for Unilever
environment. • 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:
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
or appropriate prevailing industry • Provide transparent, fair and or insulting. This includes any form of • Use child labour, i.e. individuals under
standards, and that remuneration confidential procedures for employees sexual or other harassment or bullying, the age of 15 or under the local legal
terms established by legally binding to raise relevant concerns. These must whether individual or collective and minimum working age or mandatory
collective agreements are implemented enable employees to discuss any whether motivated by race, age, role, schooling age, whichever is the higher
and adhered to. Other than legally situation where they believe they have gender, gender identity, colour, religion,
mandated deductions, all other been discriminated against or treated country of origin, sexual orientation, • When young workers are employed
deductions from wages require the unfairly or without respect or dignity marital status, dependants, disability, (insofar as short-term work experience
express and written consent of social class or political views schemes and work that forms part of an
the employee educational programme are permitted),
• Engage in any indirect behaviour which require or allow them to do work
• Respect employees’ rights to form could be construed as sexual or other that is mentally, physically, socially or
and join a legally recognised union of harassment or bullying, such as making morally dangerous or interferes with
their choice choiceor any other body offensive or sexually explicit jokes or their schooling by depriving them of the
representing their collective interests, insults, displaying, emailing, texting, opportunity to attend school
and establish constructive dialogue or otherwise distributing, offensive
and bargain in good faith with trade material or material of a sexually
unions or representative bodies explicit nature, misusing personal
on employment conditions, labour information, creating a hostile or
management relations and matters intimidating environment, isolating
of mutual concern, to the extent or not co-operating with a colleague,
practicable taking national laws into or spreading malicious or insulting
consideration rumours
• Comply with local legal requirements in • Work more than the regular and
relation to short-term, casual or agency overtime hours allowed by the laws of
employees 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
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.
formats. Unilever has Information • Comply with the proper use of Unilever
Classification & Information Handling Information Technology and only share Personal data relating to employees,
standards which define how information Unilever information using Unilever- consumers and other individuals is
within Unilever must be classified, approved Information Technology in subject to specific laws and regulations
handled and protected. accordance with the Code Policy on Use in most countries and requires special
of Information Technology handling. Additional information relating
to the classification and protection
Musts • Report any events which you suspect requirements for personal and sensitive
could impact the security of Unilever personal data can be found in the Code
When handling Unilever’s information information by following the Cyber Policy on Personal Data and Privacy
employees must: Security reporting procedures.
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
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
on behalf of the Board – oversees to buy or sell a company’s shares. In addition to the general obligations set they know are false
Examples of inside information include out above, individuals on the Insider Lists
that Unilever has the necessary
the following: must also comply with the requirements • Encourage anyone to buy or sell
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
(see Unilever’s Share Dealing subsidiaries profit from the arrangement
Standard and Disclosure Manual). Musts
• A major new product, product claim or • Pass Inside Information relating to
This Code Policy explains what product incident/issue Employees must: Unilever to anyone within Unilever
insider trading is, how employees (unless they are on a relevant Unilever
• An acquisition, merger or divestment • Refer to Unilever’s Share Dealing Insider List) or outside Unilever,
can be sure they don’t engage in
Standard and Disclosure Manual or including family members or friends
it, and what to do if they discover • A sizeable restructuring project (see the Code Policy on Protecting
contact the Corporate Secretaries’
inside information is being misused. Department in the Legal Group, to Unilever’s Information)
• Major developments in litigation check whether something is Inside
cases or in dealings with regulators or Information • Spread false information or engage in
governments other activities to manipulate the price
• Immediately advise a member of the of publicly listed securities
• Revisions in dividend policy Disclosure Committee (the Corporate
Secretaries’ Department holds the
• Changes in executive directors. 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
employees and others working for

Unilever must do to legitimately Employees must:
obtain and use competitor • Only gather and 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
the source
Unilever respects the confidential
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
To promote fair competition Unilever and individuals. Legal Business Partner immediately
Unilever gathers and uses
Competitor information encompasses
competitor’s information that is Must nots
many areas from marketing and financial
in the public domain, for example, information to Intellectual Property such
from newspapers, the internet as 2D and 3D designs. If you are in any Employees must not:
and company filings. This provides doubt consult your Legal Business Partner.
• 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
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
• Keep personal data confidential

If in doubt, employees must seek advice
and secure
from their line manager and / or Legal
• Act responsibly and ethically, upholding business partner.
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 to
employees should use Unilever Unilever systems and equipment to carry

out their role.
equipment and systems, or
personal devices to access Employees are permitted to use Unilever
information at Unilever, responsibly Equipment for personal use if this does
and securely in compliance with all not cause material impact to Unilever.
relevant laws and regulations Material impact includes excessive
storage, network usage, mobile data
usage, or voice utilisation which may
have an impact on the performance of
the environment.
All Unilever business information

processed by or stored on Unilever or
personal systems and equipment is not
private and may be monitored, inspected
or removed by Unilever, regardless of
whether it is work-related or ‘personal’.
Unilever may log, diagnose and assess

activity on Unilever systems and
equipment to the extent permitted by
law, to ensure this policy is being followed
and Unilever’s technical environment is
optimised.
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Use of Information Technology (2 of 2)
Musts Must nots • Expose Unilever information by:
When using Unilever’s Systems and Employees must not: - Using non-public Unilever information
Equipment, employees must: for anything other than Unilever
• Try to disable, defeat or circumvent business
• Ensure Unilever equipment is used Unilever security controls, including
appropriately and protected from but not limited to firewalls, browser - Forwarding emails containing
damage, loss or theft configuration, privileged access, anti- non-public Unilever information to
virus and the deletion of system logs personal email accounts
• Use a password or PIN to lock
unattended Unilever equipment, or any • Use Unilever systems or Unilever - storing or synchronising Unilever
personal device used to access Unilever equipment to intentionally access, information from personal devices
information store, send, post or publish material
that is: - Sharing their Unilever access
• Immediately report to the IT Service credentials with anyone else,
Desk the loss or theft of any Unilever - Pornographic, sexually explicit, including work colleagues (unless
equipment, or any personal device used indecent or obscene, or formally approved by Information
to access or store Unilever Information Security), friends and family
- Promotes violence, hatred, terrorism
• Ensure any removable Unilever IT or intolerance, or - Using their Unilever password for
equipment is secured when left in the non-Unilever IT Systems
office overnight, is locked away or put - Is in breach of local, national or
out of sight when left unattended at international laws - Using their Unilever email address
home, in a hotel or in a vehicle. When for non-business related websites or
travelling, keep it with you at all times • Use Unilever systems or Unilever online activity
equipment to intentionally defame,
• Comply with copyright law and respect slander or lower the reputation of - Intentionally accessing Unilever
all applicable licenses for any graphics, any person or entity or their goods or Systems or Unilever Information that
documents, media and other materials services is not intended for them
stored on or accessed with Unilever
systems or equipment • Run or engage in any form of private
business using Unilever IT equipment
• Follow the appropriate IT request
process to install any software • Access Unilever Systems or Information
or applications on their Unilever after leaving Unilever employment
equipment
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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
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
minimum standards that apply to and transparently, with appropriate as falsely to suggest that a claim has
factual and, where relevant, nutritional scientific validity
all of Unilever’s marketing activities
information
everywhere. • Associate our products or services with,
• Ensure there is sufficient information Freedom of choice 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
names, packaging and labelling; understand how to use our products and Employees involved in Unilever marketing serious or widespread offence to any
consumer planning and market research; services activities must show respect for people religion, nationality, culture, gender,
trade advertising; sales materials; brand who choose not to buy our products race, sexual orientation, age, disability
merchandising and sponsorship; all • Ensure our marketing is based on and services, and ensure there is or minority group
forms of advertising including television, adequate support for the claims sufficient information about our products
radio, print, digital media, promotional Unilever makes and services for consumers to make • Advertise in any media known for
activities and events, product placements, informed choices promoting violence, pornography or
‘advergaming’ – whether created by • Comply with our principles and insulting behaviour
Unilever, agencies, crowdsourcing or other standards on marketing, including (but Taste and decency
third parties. not limited to) those with respect to
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
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 RSP or RBPP • Agree to any contractual changes or
environment. Unilever expects its policies and consult their Line Manager exclusions with respect to the RSP or
suppliers and business partners and / or the relevant responsible teams RBPP without consulting their Legal
to adhere to values and principles if they have any questions Business Partner and in respect of the
RSP, prior written authorisation from the
consistent with our own.
• Ensure that all our third parties are Integrated Social Sustainability function
subject to our RSP or RBPP policies and
This Code Policy sets out
controls. This includes adequate and • Continue transacting with third parties
responsibilities of employees who timely onboarding, contracting and that have been declared as not
engage with third parties. monitoring (including verification and compliant with the RSP or RBPP unless a
remediation where necessary) dispensation or exemption is provided,
Our requirements for third parties are set or when they have been identified on the
out in the Responsible Sourcing Policy • Ensure that all our agreements with Prohibited Third Parties list
(RSP) for suppliers and in the Responsible suppliers (inclusive of MSAs, UPAs, CTCs,
Business Partner Policy (RBPP) for POs*) and distributors and customers *Footnote: Master Service Agreements, Unilever
distributors, customers and other partners (including DOs*), to the extent required Purchase Agreements, Commercial Terms Contracts,
subject to the RBPP. by our internal controls, include contract Purchase Orders, Distribution Orders.
clauses that specify that the supplier
Unilever could face legal and reputational must acknowledge adherence to our RSP
liabilities if third parties fail to comply with or RBPP as a condition of engagement
these requirements.
• Notify their Line Manager and the
The RSP and RBPP outline the fundamental relevant responsible team if they
principles and mandatory requirements know or suspect that third parties
that third parties must meet. are not meeting relevant RSP or RBPP
requirements or if they are performing
Teams responsible for setting the contrary to the agreed contractual terms
standards of these policies are Integrated
Social Sustainability (Supply Chain) for the • Ensure that any selection, shortlisting
RSP and Customer Development for the or tendering processes for new third
RBPP. parties consider their compliance with
the RSP or RBPP
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Fair Competition (1 of 2)
Investigations by competition Co-operating with competition
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
Market Cluster/country, Category and
• Certain restrictions imposed on Function Heads must, with the support
or agreed with distributors and of Legal, ensure that the requirements
other customers; and of competition law are understood by
employees, contractors and agents
• Abuses of dominant market operating in their categories, markets
positions. and functions, by providing appropriate
documentation, communication and
This Code Policy sets out what training, with tailored programmes for
employees must do to ensure specific (in particular ‘high risk’) groups.
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
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 control of the resale price, the territory
or events that involve competitors, such
have a strong market position and or channels in which they may resell
as awards ceremonies or associated • Discuss, agree or exchange information
Unilever’s commercial practices could Unilever products and the extent to
social contacts about, any of the following, directly
be perceived as unfair to customers which they may sell competing products
or indirectly, with competitors (unless
or competitors
• Object immediately if inappropriate approved by Legal Group):
topics are raised during any contact with • Where Unilever has a strong market
• Clearly record sources of competitor position, conduct itself in order to
competitors and leave immediately – - The price or terms of sale for products
information in all communications and take unfair advantage of customers
and noticeably – if any inappropriate and / or services
documents so their legitimacy is or unfairly prevent competitors from
discussion continues
beyond doubt entering, remaining or expanding in a
- The price or terms to be demanded
• Report incidents of inappropriate from suppliers market, e.g. selling below cost, certain
discussions immediately to their Legal types of conditional rebates, exclusivity
Business Partner - The co-ordination or allocation of bids arrangements
or quotes
• Promptly seek advice from their Legal
Business Partner: - Limitations on production or sales; or
- Whenever you need help applying the
- The division or allocation of
competition rules laid out in this Policy
geographic markets, customers or
to any specific business situation, and
product lines
in any case of doubt
- In situations which may involve the

exchange of information with a
competitor
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Non-Governmental Organisations (NGOs) (1 of 2)
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
personal tax. interaction in relation to Unilever business
including any kind of correspondence
such as in-person, electronic media or
written correspondence.
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Non-Governmental Organisations (NGOs) (2 of 2)
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 Cluster 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 approval • Be aware of the up to date procedures
from cluster head of Function 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
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
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
Communication with investment Unilever’s Disclosure Committee – Relations or Media Relations functions information or opinion
communities – including on behalf of the Board – must follow Unilever’s Share Dealing and
is responsible for ensuring Unilever Disclosure Manuals and the departmental • Make any forward-looking financial
shareholders, brokers and analysts
processes and procedures (including statements or provide ‘inside
– and the media must be managed has the necessary procedures to
authorisations) in this area information’ (see the Code Policy on
carefully. Such communication comply with relevant laws and Preventing Insider Trading and the
has important legal requirements regulations including Unilever’s The above rules also apply outside formal Media Relations Protocol)
and demands specialist skills Disclosure & Share-Dealing Manuals. work settings, such as at external speaking
and experience. Only individuals engagements, courses, seminars, trade
This Code Policy outlines how association events or social occasions.
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
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 An officer, employee or representative
a 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 companies’ are used for convenience and
been launched or revealed publicly); a spouse, live-in partner, parent or mean the Unilever Group of companies
and proprietary software. child. The term includes sibling, step- or comprising Unilever N.V., Unilever PLC and
adopted child, step-parent, grandparent, their respective subsidiary companies. The
uncle, aunt, cousin, grandchild or any Board of Unilever means the Directors of
relative who has lived with you for the Unilever N.V. and Unilever PLC.
past 12 months or more.
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Code of Business Principles and Code

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Unilever

Code of Business Principles

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

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

Safeguarding Information Engaging Externally Glossary

Preventing Insider Trading 29 Responsible Sourcing & Business Partnering 36

Competitors’ Information 30 Fair Competition 37

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

The Media, Investors & Analysts

confidential procedures for employees

above must: concerns, or highlights potential or

• Offer guidance and support about the

with laws and regulations that apply

This Code Policy sets out how and

Heads of all market Cluster/country

All employees must:

• Immediately notify their Line Manager

to risk management which puts risk and responsible are identified;

sustainable research and innovation, eliminate animal testing without

Musts • Raise any concerns about actual or

• Ensure that risks for consumer safety, Must nots

is founded upon providing safe

Unilever will take prompt and

• Take decisions about product safety or

• Respond to customers or consumers

Avoiding Conflicts of Interest

Employees must: Employees must not directly or indirectly

reflect its ongoing commitment to

Musts Financial assets • Ensure all necessary checks and

filings have occurred with respect

This Code Policy covers the

and avoid criminal liability, it consultation with their Business Integrity

Occupational Health & Safety

societies where human rights are

environment. • Ensure that all employees have

system of employee and management

Protecting Unilever’s Information

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

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

employees and others working for

obtain and use competitor • Only gather and use competitors’

individuals including employees

• Keep personal data confidential

employees should use Unilever Unilever systems and equipment to carry

All Unilever business information

Unilever may log, diagnose and assess

Contact with Government, Regulators &

Political Activities & Political Donations

developing, producing, marketing

Unilever is committed to doing

authorities may result in significant authorities

• Sharing of commercially sensitive

• Comply with competition law for all

arrangements, or production, research competitors, customers or suppliers

- In situations which may involve the

Any contact by employees or Governments, regulators and legislators

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

• Ensure any personal political support

• Ensure where employees represent

• Offer guidance and support about the

• Immediately notify their Line Manager

Musts • Raise any concerns about actual or

• Ensure that risks for consumer safety, Must nots

• Take decisions about product safety or

• Respond to customers or consumers

Musts Financial assets • Ensure all necessary checks and

environment. • Ensure that all employees have

obtain and use competitor • Only gather and use competitors’

• Keep personal data confidential

• Sharing of commercially sensitive

• Comply with competition law for all

- In situations which may involve the

• Ensure any personal political support

• Ensure where employees represent