Effective Date: 22 July 2025
Unum mandates that all entities providing goods or services to us, including vendors, service providers, and contractors (herein referred to as “Suppliers”), operate with the utmost integrity and adhere to sound ethical principles. This document, the Ethical Business Practices Guide for Suppliers (“Guide”), articulates the minimum standards Unum expects. It’s designed to work in conjunction with the Supplier’s own operational guidelines, legal obligations, and contractual agreements with Unum.
- Legal Compliance
Suppliers must comply fully with all applicable laws, regulations and standards in the jurisdictions where they operate. For Suppliers operating in or with ties to Australia, this includes, but is not limited to:
- Corporations Act 2001 (Cth)
- Australian Consumer Law (ACL), Schedule 2 of the Competition and Consumer Act 2010 (Cth)
- Work Health and Safety Act 2011 (Cth and state equivalents)
- Modern Slavery Act 2018 (Cth)
- Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs)
- Criminal Code Act 1995 (Cth) (particularly bribery and corruption provisions)
- Commitment to Labor and Human Rights
Unum champions human rights and equitable treatment. We expect our Suppliers to share this dedication. Suppliers should implement and maintain policies and procedures that demonstrate a commitment to safeguarding human rights for all individuals within their workforce and throughout their supply networks. Essential principles include:
- Voluntary Employment: Suppliers must not engage in or benefit from any form of forced, compulsory or involuntary labour, including modern slavery or human trafficking. Strict compliance with the Modern Slavery Act 2018 (Cth) is required.
- Fair Pay and Working Conditions: Suppliers must ensure workers are paid lawfully, provided appropriate benefits, and their working hours comply with the Fair Work Act 2009 (Cth) and any applicable modern awards or enterprise agreements.
- Respectful Work Environment: Suppliers must maintain a workplace free from harassment, unlawful discrimination and abuse. Employment decisions must be based on merit and comply with the Equal Opportunity Act applicable in the relevant state or territory.
- Health and Safety: Suppliers must provide a safe and healthy workplace, in full compliance with occupational health and safety legislation including the Work Health and Safety Act 2011 and related regulations.
- Upholding Ethical Standards
Unum insists that its Suppliers maintain the highest level of ethical conduct in all aspects of their business dealings. This entails:
- Anti Corruption: Suppliers must not engage in bribery, corruption, facilitation payments, or other forms of improper influence. Compliance with applicable Australian laws, including the Criminal Code Act 1995 (Cth), is essential.
- Intellectual Property: Suppliers must protect and respect the intellectual property rights of Unum and third parties. Unauthorised use of Unum’s trademarks or proprietary materials is strictly prohibited.
- Data Security: If Suppliers handle personal data or confidential Unum information, they must comply with the Privacy Act 1988 (Cth) and ensure secure storage, access and transmission of such data.
- Accurate Records: Suppliers must maintain honest and transparent records of their business dealings.
- Gifts and Hospitality: Suppliers must not offer or accept any gifts, benefits or hospitality that may influence or appear to influence business decisions. All interactions must align with Unum’s policies.
- Conflicts of Interest: Suppliers must promptly disclose any situation that could present a conflict of interest, including personal or family relationships with Unum personnel.
- Environmental Stewardship
Unum is committed to reducing its environmental impact and expects Suppliers to:
- Actively manage their environmental footprint;
- Comply with all relevant Australian environmental laws, such as the Environment Protection and Biodiversity Conservation Act 1999 (Cth);
- Promote responsible use of resources and environmentally sustainable practices.
- Confidential Information
Suppliers have a duty to protect Unum’s confidential information. “Confidential Information” encompasses any non-public data pertaining to Unum that could be exploited by competitors or cause detriment to Unum or its users if revealed. Suppliers must not disclose or distribute Unum’s confidential information unless explicitly authorized by Unum in writing or legally compelled to do so. Confidential information must be utilized solely for the purpose of fulfilling the agreed-upon obligations to Unum. Specific confidentiality obligations may be further detailed in agreements with Unum.
- Raising Concerns
Suppliers are encouraged to report any unethical conduct, suspected breaches of this Guide, or other concerns to their point of contact at Unum or via [email protected]. All reports will be handled in confidence, and Unum commits to investigating them thoroughly.
- Enforcement and Review
Unum reserves the right to monitor compliance with this Guide. Non compliance may result in corrective actions, including termination of the business relationship. This Guide may be updated periodically and Suppliers will be notified of any material changes.