Effective Date: March 13, 2025
Unum requires all entities providing goods or services to us, including vendors, service providers, and contractors (hereinafter referred to as “Suppliers”), to operate with the highest integrity and adhere to sound ethical principles. This document, the Ethical Business Practices Guide for Suppliers (“Guide”), outlines the minimum standards Unum expects. It’s designed to complement the Supplier’s own operational guidelines, legal obligations, and contractual agreements with Unum.
- Legal Compliance
Suppliers must rigorously respect and follow all relevant laws, rules, and regulatory mandates applicable to their operations, regardless of location. This includes, but is not limited to, compliance with the General Data Protection Regulation (GDPR), the Bundesdatenschutzgesetz (BDSG), and other applicable German laws.
- Commitment to Labor and Human Rights
Unum champions human rights and equitable treatment. We expect our Suppliers to share this commitment. 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 Labour: Suppliers must not use or benefit from any form of forced, involuntary, or compulsory labour, including slavery and human trafficking. Compliance with all applicable anti-slavery and anti-human trafficking legislation in Germany and the EU is mandatory.
- Fair Compensation and Work Standards: Suppliers must provide employees with remuneration, benefits, and work schedules that meet or exceed all legal requirements and industry best practices in Germany and the EU.
- Respectful Workplace: Suppliers must foster a workplace free from harassment, unlawful discrimination (including discrimination based on race, religion, gender, disability, or sexual orientation, as protected under German law and EU directives), and any form of mistreatment. Employment practices must be equitable, based on qualifications and performance.
- Safe and Healthy Working Conditions: Suppliers must establish and maintain a secure and healthy work environment, complying with all relevant occupational health and safety laws and regulations in Germany and the EU.
- Upholding Ethical Standards
Unum insists that its Suppliers maintain the highest level of ethical conduct in all aspects of their business dealings. This entails:
- Business Integrity: Suppliers must abstain from any form of corrupt practice, including bribery, extortion, embezzlement, or facilitation payments. Strict compliance with all anti-corruption and anti-money laundering laws in Germany and the EU is essential.
- Protection of Intellectual Property: Suppliers must respect and safeguard the intellectual property rights of Unum and third parties, including trademarks, copyrights, patents, and trade secrets. Use of Unum’s brand or trademarks is prohibited without explicit written consent.
- Data Protection and Security (GDPR/BDSG Emphasis): Suppliers handling personal data or Unum proprietary information must adhere to the GDPR, BDSG, and all other applicable data protection and security laws and regulations in Germany and the EU. Suppliers must implement robust security measures to prevent unauthorized access, use, or disclosure of such information.
- Accurate Financial Records: Suppliers must maintain accurate and transparent financial books and records for all business activities and transactions.
- Gifts and Hospitality: Suppliers should avoid offering gifts, hospitality, or other benefits that could create or appear to create undue influence in business relationships. Any interactions with Unum personnel must comply with Unum’s policies regarding gifts and hospitality.
- Disclosure of Conflicts of Interest: Suppliers must disclose any potential conflicts of interest, including familial or close personal connections with Unum employees or directors that might affect or appear to affect business decisions.
- Environmental Stewardship
Unum is committed to environmental sustainability and expects its Suppliers to demonstrate a similar commitment. Suppliers are expected to manage their operations in an environmentally responsible manner by:
- Assessing and minimizing the environmental impact of their activities, in accordance with German and EU environmental regulations.
- Complying with all relevant federal and state environmental laws and regulations in Germany and the EU.
- Promoting practices that safeguard the environment and support health and safety.
- Confidential Information
Suppliers have a duty to protect Unum’s confidential information. “Confidential Information” includes 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 used solely for the purpose of fulfilling agreed-upon obligations to Unum. Specific confidentiality obligations may be detailed in agreements with Unum.
- Raising Concerns
Unum encourages Suppliers to report any inquiries, concerns, or suspected breaches of this Guide or any unethical business conduct. Suppliers should communicate such matters to their designated Unum contact or through [email protected]. Unum is committed to investigating all reports and taking appropriate action, with protection for those who report in good faith (whistleblowers).
- Enforcement and Review
Unum reserves the right to evaluate Supplier compliance with this Guide. Non-compliance may result in the suspension or termination of the business relationship with Unum. This Guide may be updated periodically, and Unum will communicate revisions as necessary.