Effective Date: 25 July 2025
Unum requires that all entities providing goods or services to us, including vendors, service providers, and contractors (hereinafter referred to as “Suppliers”), operate with integrity and in accordance with the highest ethical and legal standards. This Ethical Business Practices Guide for Suppliers (“Guide”) outlines the minimum standards we expect from our Suppliers. It supplements each Supplier’s contractual obligations, applicable laws, and internal codes of conduct.
- Legal Compliance
Suppliers must comply fully with all applicable laws and regulations in the jurisdictions in which they operate, including but not limited to:
- Polish Penal Code (Kodeks karny), particularly provisions on bribery, corruption, and fraud;
- Polish Labour Code (Kodeks pracy), including all regulations on employment contracts, working time, and occupational health and safety;
- Polish Civil Code (Kodeks cywilny), especially Book III on Obligations;
- Act on Equal Treatment (Ustawa o równym traktowaniu);
- Polish Environmental Protection Law (Prawo ochrony środowiska);
- EU General Data Protection Regulation (EU) 2016/679 – GDPR;
- Polish Act on the Protection of Personal Data (Ustawa o ochronie danych osobowych), which complements and implements aspects of the GDPR in Poland.
Suppliers operating outside Poland must comply with the local laws applicable in those jurisdictions as well.
- Commitment to Labor and Human Rights
Unum is committed to promoting human rights and fair treatment in its supply chain. We expect Suppliers to:
- Prohibit all forms of forced and child labour, human trafficking, and involuntary work, in accordance with international standards, including ILO Conventions and Polish labour law;
- Ensure fair pay, lawful working hours, and appropriate conditions, as required by Polish legislation and collective agreements;
- Promote a workplace free from discrimination, harassment, and violence, fostering equal opportunity and diversity;
- Provide a safe and healthy working environment, complying with occupational health and safety standards under Polish law and EU directives.
- Upholding Ethical Standards
Suppliers must conduct business ethically and with transparency. This includes:
- Prohibiting bribery, facilitation payments, and any corrupt practices. Compliance with the Polish Penal Code and relevant international anti corruption regulations is required;
- Respecting the intellectual property of Unum and others. Unauthorised use is strictly forbidden;
- Ensuring all personal data and confidential information is processed in accordance with the GDPR and Polish data protection law. Suppliers must implement appropriate technical and organisational security measures;
- Keeping complete and accurate business records;
- Refraining from offering or accepting gifts or hospitality that could influence business decisions. Modest, proportionate, and fully disclosed hospitality is acceptable;
- Disclosing promptly any actual or potential conflict of interest, such as personal relationships with Unum employees.
- Environmental Stewardship
Unum supports responsible environmental practices. Suppliers are expected to:
- Comply with Polish environmental legislation and EU environmental regulations;
- Minimise negative environmental impact through resource efficiency and pollution prevention;
- Adopt sustainable practices that support the circular economy, including waste and emission reduction.
- Confidential Information
Suppliers must maintain the confidentiality of all non-public information shared by Unum. This includes but is not limited to financial data, product strategies, user data, and other proprietary information. Disclosure is only permitted with Unum’s prior written approval or where required by law. Confidential data must be used solely to fulfil contractual obligations to Unum.
- Raising Concerns
Suppliers are encouraged to report suspected violations of this Guide, unethical conduct, or other integrity concerns through their regular Unum contact or by email at [email protected]. All reports will be treated with confidentiality and investigated thoroughly. - Enforcement and Review
Unum reserves the right to:
- Monitor compliance with this Guide through audits or assessments;
- Take corrective measures in response to non compliance, including possible suspension or termination of the supplier relationship;
- Update this Guide periodically. Suppliers will be informed of material changes.