Ethical Business Practices Guide for Suppliers

Effective date: 13 October 2026

ETUS DIGITAL LLC, owner of the Unum brand, requires the vendors, service providers and contractors it works with (“Suppliers”) to meet the minimum standards of integrity, responsibility and ethical conduct set out in this Guide. The Guide supplements the contracts signed with each Supplier and the obligations imposed on it by applicable law.

1. Legal compliance

Suppliers comply with the laws of the countries where they operate. In Namibia, this includes in particular:

  • The Labour Act 11 of 2007.
  • The Anti-Corruption Act 8 of 2003.
  • The Environmental Management Act 7 of 2007.
  • The Electronic Transactions Act 4 of 2019.
  • Their tax and accounting obligations.

2. Labour standards and human rights

  • Freely chosen employment: forced labour, slavery and human trafficking are prohibited.
  • Fair pay: workers receive at least the the minimum wage that applies to their sector, with the overtime and benefits required by law.
  • Equal opportunity: discrimination and harassment based on sex, origin, religion, disability or any other personal or social characteristic are prohibited. Employment decisions are based on merit.
  • Health and safety: the workplace meets applicable health and safety requirements.
  • Child labour: no one works below the legal minimum age.

3. Business ethics

  • Anti-corruption: bribes, kickbacks, facilitation payments and any other form of corruption are prohibited.
  • Intellectual property: Unum’s trademarks, content and other assets are used only with prior written permission.
  • Data protection: a Supplier that processes personal information on Unum’s behalf complies with data protection law and applies appropriate security measures.
  • Accurate records: financial information is accurate, transparent and verifiable.
  • Gifts and hospitality: anything offered to Unum staff is of modest value and does not influence, or appear to influence, any decision.
  • Conflicts of interest: any actual or potential conflict, including personal or financial relationships with Unum staff, is disclosed promptly.

4. Environmental responsibility

Suppliers are expected to:

  • Reduce their emissions, energy use and waste.
  • Comply with environmental laws and handle hazardous materials safely.
  • Adopt practices that support sustainability.

5. Confidential information

Suppliers protect all non-public information they receive from or on behalf of Unum, such as financial data, user information, business strategies, technical documentation and internal communications. They may disclose it only where required by law or with Unum’s written permission.

6. Reporting concerns

Any possible breach of this Guide can be reported to contact@unum.com.br or to the Supplier’s contact at Unum. Reports are handled confidentially and impartially. Retaliation against anyone who reports in good faith is prohibited.

7. Enforcement and review

Unum may check that Suppliers comply with this Guide. A breach may lead to the suspension or termination of the business relationship. The Guide is reviewed periodically, and the current version is published on this page.