Code of Business Principles and Code Policies

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

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Safeguarding Information Engaging Externally Glossary

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The Code of Business CounteringCountering RespectingRespecting SafeguardingSafeguarding EngagingEngaging Principles CorruptionCorruption PeoplePeople InformationInformation ExternallyExternally Glossary 0202 The Code and our Standard of Conduct

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.

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

Code of Business Principles and Code Policies Introduction Employees We will provide transparent, fair and Business Partners 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 suppliers, customers and business Our Code of Business Principles defines the employees that raise issues with us. 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. We will work with these partners to raise We will recruit, employ and promote their intended use. Products and services standards so that their employees are Standard of Conduct employees on the sole basis of the will be accurately and properly labelled, paid a living wage and are not subject qualifications and abilities needed for the advertised and communicated. We conduct our operations with honesty, to forced, compulsory, trafficked or work to be performed. integrity and openness, and with respect 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.

Code of Business Principles and Code Policies 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 associations, in the development themselves or others through misuse of The Chief Executive Officer is responsible In our scientific innovation to meet of proposed legislation and other their positions. for implementing these principles and is consumer needs we will respect the regulations which may affect legitimate supported in this by the Global Code and concerns of our consumers and of society. business interests. Policy Committee which is chaired by the We will work on the basis of sound Data science, applying rigorous standards Unilever neither supports political Chief Legal Officer. Unilever is committed to the responsible, of product safety. 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 Competition promote party interests. We collect and use data in line with our geographies, divisions, functions values, applicable laws and with respect and operating companies. They are Unilever believes in vigorous yet fair for privacy as a human right. responsible for implementing these competition and supports the development Bribery & Corruption of appropriate competition laws. Unilever principles, supported by local Business Unilever does not give or receive, companies and employees will conduct Note Integrity Committees. whether directly or indirectly, bribes or their operations in accordance with the In this Code the expressions ‘Unilever’ Assurance of compliance is given and other improper advantages for business principles of fair competition and all and ‘Unilever companies’ are used for monitored each year. Compliance is or financial gain. No employee may offer, applicable regulations. convenience and mean the Unilever Group 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 The Planet Committee and for financial and Any demand for, or offer of, a bribe must companies. The Board of Unilever means the 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. management of our environmental impact reported. The Board of Unilever will not Unilever accounting records and and to the longer-term goal of developing criticise management for any loss of supporting documents must accurately a sustainable business. business resulting from adherence to 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.

Code of Business Principles and Code Policies 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 success and essential to achieving for Unilever and for individuals involved. eventuality, particularly as laws differ 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 All employees must: customers trust us for doing report suspected or actual breaches, and business with integrity. This is one outlines how such situations must be • Ensure they know and understand managed. Any failure to comply with the of our greatest assets, and to the requirements of our Code and Code and any of the Code Policies is taken maintain our reputation, requires 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. Unilever’s Code of Business by their Line Manager or Business Integrity Officer Principles (the Code), and the 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 behaviours meet the standards required Unilever also requires its third- trainees party business partners and their they must seek the advice of their Line Manager or Business Integrity Officer employees to adhere to business • Persons with statutory director roles or equivalent responsibilities principles consistent with our own. • 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

Code of Business Principles and Code Policies 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

Code of Business Principles and Code Policies 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.

Code of Business Principles and Code Policies 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 11 or at Unilever’s instigation; and arrangements/relationships with Legal Group third-party shareholders

Code of Business Principles and Code Policies Unilever takes an embedded approach Musts • Complete an annual holistic risk to risk management which puts risk and discussion during which: opportunity assessment at the core of All managers and above must implement the leadership team agenda. Unilever Unilever’s Principles of Risk Management - Key business risks for which they are defines risks as actions or events that as follows: responsible are identified; have the potential to impact our ability to - How those risks are being managed is achieve our objectives. Unilever identifies • Accountability: they must identify and reviewed; and mitigates downside risks such as loss manage the risks that relate to their role - Any gaps in their desired risk appetite of money, reputation or talent as well are identified. as upside risks such as failure to deliver • Risk Appetite: they must determine strategy if it does not strengthen brand the level of risk, after the • Perform regular reviews and ensure equities or grow in growing channels. implementation of controls, that they risks are mitigated as desired.

are prepared to accept such that there Unilever’s Risk Management approach is not a significant threat to achieving All project leaders of transformational is embedded in the normal course of their objectives projects must, together with their teams: business with a set of global Principles of Risk Management with local • Risk Mitigation: they must put adequate • Identify the key risks associated with implementation. controls in place, and ensure that they their project achieving its objectives are operational, in order to deliver their Its structural elements include: objectives • Prepare risk mitigation plans

• Governance of Unilever, organisational All members of leadership teams must: • Review progress with the project structure and delegation of authority steering group. • Ensure that the risk management Risk management is integral to • Vision, Strategy and Objectives activities, as outlined in Unilever’s Unilever’s strategy and to the Risk and Control Frameworks, are • Code of Business Principles, Code achievement of Unilever’s long- being undertaken for their areas of Policies and Standards responsibility term goals. Our success as an organisation depends on our • Risk and Control Frameworks ability to identify and exploit the opportunities generated by our • Performance management and business and the markets Unilever operational processes execution operates in. • Compliance and assurance activities.

Code of Business Principles and Code Policies 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 are suitably assessed and managed Employees must not: Unilever’s business success and a core part of our global strategy. • Ensure appropriate specifications of raw • Deliver presentations or publications 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 framework negotiable. • Ensure research on human subjects is conducted to the highest ethical standards

Code of Business Principles and Code Policies 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, value chain. take effective preventative steps or 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

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

Code of Business Principles and Code Policies 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 This Code Policy sets out what The above disclosure requirements they, or one of their team, are excludes roles of school governors, employees must do to prevent and Employees must not: 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 or participate in any decision-making A conflict of interest may arise, and of property/housing blocks in which an process or activity when a conflict of disclosure is required, when an employee: employee lives • 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 - Provide access to commercially • Ensure Unilever is best placed to benefit • Hire, contract or engage any individual • Has a close personal interest in the sensitive information concerning from potential business opportunities or organisation without ensuring they business of competitors or other 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 perceived or potential conflict of interest Information); and / or • 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

Code of Business Principles and Code Policies 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 laws that prohibit bribery: many consistently high global standards: the Responsible Sourcing and Business employees cannot escape imminent 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 for Unilever and individuals. practices, and prohibits both public brand protection, etc) or any other Integrity Officer and Cluster General Counsel in the country where the incident Dealings with public officials are and commercial bribery (e.g. to or means available to reduce face-to-face interactions with public officials and the occurred. This is to ensure that the matter particularly high risk: even the from any third party). connected risks of bribe solicitation can be fully investigated, necessary 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 Unilever’s reputation. Policy on Accurate Records, Reporting and meet Unilever requirements. Accounting).

Code of Business Principles and Code Policies 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 launches. However, as accepting • Familiarise and observe the local 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.

Code of Business Principles and Code Policies 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 Gifts merchandising materials must be their own records for inspection and Employees must not: legitimate and proportionate ensure expenditure associated with any 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: or received do not exceed the local Business Integrity Officer monetary limits for gifts, are one- In exceptional circumstances where • Ensure that hospitality is only offered or • Offer or accept any gifts or hospitality, off or irregular in nature and always employees seek to offer or accept accepted if: or any other favours which are intended comply with the Code Policy on hospitality above the local monetary or might be seen to influence business Avoiding Conflicts of Interest. Although limits for hospitality, they must: - There is a legitimate business interest decisions or create an obligation to do employees are not required to record in doing so something in return such gifts centrally, they must keep • Check their Line Manager supports the 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 - It is in the form of a locally hosted explain the Unilever rules. In exceptional acceptance of such hospitality also overnight stays or foreign travel without meal, attendance at, or participation situations where such gifts have to complies with its equivalent gifts and prior written clearance from their in an organised ‘team-building’ be accepted to avoid causing serious 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

Code of Business Principles and Code Policies 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 maintains internally and the Employees must: authorities and other regulators those relating to provisions, journal entries and contingent liabilities, financial information it provides • Record all transactions accurately, • Ensure they are aware of all information including tax 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 example, those regarding financial and obligations. Procedures and are legitimate and based on valid documentation statements, tax and environmental Must nots processes must be in place to requirements ensure that underlying transactions • Notify their Business Integrity Employees must not: are properly authorised and Officer and the Head of Finance • Adhere to all applicable external accurately recorded. of any potential fraud, other reporting standards and regulations, • Do anything to artificially inflate or misrepresentation of accounting or such as international and national shift sales or profit between reporting Any failure to record transactions other information, or if a ‘facilitation accounting standards, stock market periods accurately, or falsifying or payment’ has been paid to avoid listing standards and rules, financial • Create, maintain or procure others to creating misleading information physical danger or due to an error in regulator rules, health and safety judgment requirements, corporate governance produce or maintain undisclosed or 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: and financial information. to any ongoing audit, litigation or regulatory investigation, even if they • Ensure sales, profits, assets and exceed the normal retention period if liabilities are recorded in the correct instructed to do so time period

Code of Business Principles and Code Policies 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 Must nots • Identify potential hazards from contracts or transactions activities and services on site Intellectual property Employees must not: 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 potential business interruption or protected. 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 design rights, trademarks, copyright of infringing our copyright, trademarks, and other intellectual property rights Health and Safety and Protecting 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.

Code of Business Principles and Code Policies To protect Unilever’s reputation Musts Employees involved in engaging or Must nots and avoid criminal liability, contracting with third parties such it is important not to become Employees must: as new suppliers, customers and Employees must not: distributors must: associated – however innocently • Immediately notify their Cluster General • Simply assume relevant third-party – with the criminal activities of Counsel if they have any suspicions • Ensure that the third parties in question screening has already taken place: others. In particular, Unilever and about actual or potential money are subject to screening to assess their failure to check or update screenings its employees must ensure Unilever laundering activity identity and legitimacy before contracts periodically may put Unilever and its does not receive the proceeds are signed or transactions occur. Various employees at risk • Look out for warning signs of money factors will determine the appropriate of criminal activities, as this can laundering, such as: forms and levels of screening amount to the criminal offence of money laundering. Supplier requests to: • Determine, with guidance from their - Pay funds to a bank account in the Business Integrity Officer, which tools This Code Policy sets out essential name of a different third party or and processes should be used to steps employees must take to outside the country of their operation facilitate appropriate screening and record-keeping (see the Responsible avoid being implicated in money - Take payments in a form outside the Sourcing and Business Partnering Policy) laundering. normal terms of business • Carefully consider, where necessary in - Split payments to several bank consultation with their Business Integrity accounts Officer or General Counsel, screening outcomes before deciding whether to do - Overpay business with the third party Customer payments to Unilever: Finance managers who support Supply - From multiple bank accounts Chain Management and Customer Development must regularly monitor and - From bank accounts overseas when / or review suppliers, customers and other not a foreign customer third-party service providers to identify business activity or governance that could - Made in cash when normally made indicate money laundering is taking place by cheque or electronically

- Received from other third parties

- Made in advance when not part of normal terms of business

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.

Code of Business Principles and Code Policies 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 Unilever complies with all applicable sufficiently rested and alert enough to do safety legislation, including relevant closely with their local leadership teams 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 of their direct reports and third Indicators (KPIs) via Unilever’s Safety, ensure appropriate ongoing review release of material to the environment, parties under their control. As a Health and Environment (SHE) 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 • Maintain, communicate and test both medication improperly Musts health and safety at work management site and role emergency plans system for their sites and their Employees must: • Carry on with any work that becomes teams, including the appointment of • Ensure all employees, contractors and unsafe or unhealthy committees, managers, competent • Work and behave safely visitors receive information and training experts and a system for gathering in health and safety relevant to their • Assume someone else will report a risk • Comply with health and safety employees’ concerns/input roles and activities or concern 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

Code of Business Principles and Code Policies 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 chain. Unilever is committed to consideration for recruitment, 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 trust, respect for human rights and Line Managers must: 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

Code of Business Principles and Code Policies 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

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.

Code of Business Principles and Code Policies 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, Unilever is committed to ensuring that only employees or others Employees must not: 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 • Immediately report events which requirements for personal and sensitive could impact the security of personal data can be found in the Code When handling Unilever’s information Unilever information by following Policy on Personal Data and Privacy employees must: the Information Security reporting procedures. This includes, but is not If in doubt about how to handle any • Understand the nature and limited to, clicking links or attachments Unilever information, restricted or classification of the information, in suspicious emails, inadvertently otherwise, employees must seek advice as defined in the Information sharing confidential information from their Line Manager, Business Classification Standard; understand with the wrong recipient or any other Information Security Officer and / or Legal and adhere to the handling relevant events Business Partner requirements detailed in the Information Handling Standard; and take personal responsibility for the proper use, circulation, retention, protection and disposal of Unilever’s information

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

Code of Business Principles and Code Policies 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 competitor’s information. • Ensure the information is from a 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 many areas from marketing and financial Must nots 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.

Code of Business Principles and Code Policies Unilever respects the privacy of all Musts Must nots individuals including employees When collecting, using or storing personal and consumers and their personal When collecting, using or storing 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 will collect and use personal data relevant and use it solely for the purpose necessary to achieve the business 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

Code of Business Principles and Code Policies This Code Policy explains how Employees are provided with access to employees should use Unilever Unilever systems and equipment to carry equipment and systems, or out their role. 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.

Code of Business Principles and Code Policies 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

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.

Code of Business Principles and Code Policies 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 all of Unilever’s marketing activities factual and, where relevant, nutritional scientific validity 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.

Code of Business Principles and Code Policies 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 consistent with our own. RSP, prior written authorisation from the • Ensure that all our third parties are Integrated Social Sustainability function This Code Policy sets out subject to our RSP or RBPP policies and 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

Code of Business Principles and Code Policies 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 Competition laws prohibit: details, see the Code Policy on Contact 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

Code of Business Principles and Code Policies 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 or events that involve competitors, such control of the resale price, the territory have a strong market position and as awards ceremonies or associated • Discuss, agree or exchange information or channels in which they may resell Unilever’s commercial practices could social contacts about, any of the following, directly Unilever products and the extent to be perceived as unfair to customers or indirectly, with competitors (unless which they may sell competing products 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 competitors and leave immediately – - The price or terms of sale for products position, conduct itself in order to information in all communications and and noticeably – if any inappropriate and / or services take unfair advantage of customers documents so their legitimacy is discussion continues or unfairly prevent competitors from beyond doubt - The price or terms to be demanded entering, remaining or expanding in a • 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

Code of Business Principles and Code Policies 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 government, legislators, regulators or international (e.g. United Nations); 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.

Code of Business Principles and Code Policies 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

Code of Business Principles and Code Policies Unilever companies are prohibited Approval will only be given where the from supporting or contributing non-party-political nature of the activity to political parties or candidates. has been publicly communicated as 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

Code of Business Principles and Code Policies 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 shareholders, brokers and analysts is responsible for ensuring Unilever Disclosure Manuals and the departmental • Make any forward-looking financial has the necessary procedures to processes and procedures (including statements or provide ‘inside – and the media must be managed 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.

Code of Business Principles and Code Policies 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.