It has been noted in several sources (e.g. J. Romero et al. Strategies for quantum computing molecular energies using the unitary coupled cluster ansatz. refarXiv:1701. 102691 [quant-ph]) that one of the disadvantages of the Coupled Cluster method for the description of electron correlation is that, since $e^T$ in $E_{CC} = \langle0|e^{-T}He^T|0\rangle$ $$E_\mathrm{CC} = \langle0|e^{-T}He^T|0\rangle$$ isn't unitary, the method isn't variational (the energy obtained by solving CC equations isn't a rigorous upper bound to the exact energy).
Could someone please explain to me the connection between non-unitarity of $e^T$ and the method not being variational.