We have strong values and clear policies and standards to ensure our employees not only do things right but also do the right thing.
We expect everyone at Unilever to be an ambassador for our high ethical standards – what we call ‘business integrity’. We want to create an environment where employees not only live our values in their own work – integrity, respect, responsibility and pioneering– but are vigilant in identifying potential concerns, and confident about speaking up in such situations.
Our ambitions do not stop there. We aim to have a positive influence across our value chain, working with suppliers, distributors and all third parties to raise the bar on issues such as human rights and anti-bribery and corruption.
Unilever’s Business Integrity programme brings our values to life for all employees, and helps them apply our ethical standards day-to-day. In addition to our Code of Business Principles, it includes clear policies, guidelines and related learning materials, as well as robust procedures and controls to help us prevent, detect and respond to any inappropriate behaviour.
Our focus on business integrity makes Unilever stronger. It helps us to attract, retain and engage the best employees, and better able to select the right suppliers and business partners. It protects our people, our assets, our reputation and our relationships with stakeholders. It supports the conditions to work collaboratively, both internally and with our partners. And ultimately it helps us grow sustainably and deliver on the Unilever Sustainable Living Plan (USLP).
Despite the usual business pressures we all need to deal with, it is good to remind ourselves once more that we will never compromise on running our company in an ethical way. Success without integrity is failure.Paul Polman, Unilever CEO
Setting out our standards of behaviour
Our Business Integrity framework ensures that how we do business is fully aligned with our values and applicable laws and regulations in countries where we operate. It has three pillars:
- Prevention – we seek to embed a culture of integrity at all levels, in all geographies
- Detection – we encourage employees to speak up and give voice to their values
- Response – We have the tools to investigate and if necessary sanction confirmed breaches, and use what we learn to continually improve.
Our Code of Business Principles (launched in 1995) and 24 related Code Policies (updated and also published externally in 2016) are at the heart of our Business Integrity framework. They help us put our values of integrity, respect, responsibility and pioneering into practice. They play a key role in setting out how we seek to ensure compliance with laws and regulations, protect our brands and reputation, and prevent harm to people or the environment.
The Code and Code Policies provide a framework of simple ‘Musts’ and ‘Must Nots’ designed to be readily applied by employees in their day-to-day work. They are mandatory for all employees and others working for Unilever, including our Board of Directors, and apply to all Unilever companies, subsidiaries and organisations over which Unilever has management control.
Business integrity & the USLP: values & value
Doing business ethically – and with integrity – is central to the Unilever Sustainable Living Plan. Further disclosures on how we implement and report on the outcomes of Code of Business Principles and Code Policies, which directly relate to the Unilever Sustainable Living Plan, can be found below and throughout our Sustainable Living Report.
Our global reach and the USLP give us a unique opportunity to make a positive difference in the world. Achieving this requires clear insights, patient focus on long-term sustainable growth – and above all else – integrity.Paul Polman, Unilever CEO
Code of Business Principles
Our Code of Business Principles (PDF | 5MB) is a simple ethical statement of how we should operate. We publish this externally and expect all others who work with us to set themselves equally high principles. Find out more about these Principles below.
Standard of Conduct
We conduct our operations with honesty, integrity and openness, and with respect for the human rights and interests of our employees. We shall similarly respect the legitimate interests of those with whom we have relationships.
Supporting Code Policies: Respect, Dignity & Fair Treatment (PDF | 147KB); Responsible Sourcing (PDF | 314KB); Responsible Marketing (PDF | 169KB); Contact with Government, Regulators & Non-governmental Organisations (NGOs) (PDF | 384KB); External Communications – The Media, Investors & Analysts (PDF | 138KB)
Obeying the law
Unilever companies and employees are required to comply with the laws and regulations of the countries in which we operate.
Supporting Code Policies: All Code Policies and ‘Legal Consultation’ (PDF | 5MB)
Supporting Code Policies: Respect, Dignity & Fair Treatment (PDF | 147KB)
Unilever is committed to a working environment that promotes diversity and equal opportunity and where there is mutual trust, respect for human rights and no discrimination.
We will recruit, employ and promote employees on the sole basis of the qualifications and abilities needed for the work to be performed.
Further disclosures: Developing and engaging our people
We are committed to safe and healthy working conditions for all employees.
Supporting Code Policies: Occupational Health & Safety (PDF | 436KB)
We will provide employees with a total remuneration package that meets or exceeds the legal minimum standards or appropriate prevailing industry standards.
We will not use any form of forced, compulsory, trafficked or child labour.
We are committed to working with employees to develop and enhance each individual’s skills and capabilities. We respect the dignity of the individual and the right of employees to freedom of association and collective bargaining.
We will maintain good communications with employees through company based information and consultation procedures. We will ensure transparent, fair and confidential procedures for employees to raise concerns.
Unilever is committed to providing branded products and services which consistently offer value in terms of price and quality, and which are safe for their intended use. Products and services will be accurately and properly labelled, advertised and communicated.
Unilever will conduct its operations in accordance with internationally accepted principles of good corporate governance. We will provide timely, regular and reliable information on our activities, structure, financial situation and performance to all shareholders.
Supporting Code Policies: Preventing Insider Trading (PDF | 65KB); External Communications – The Media, Investors & Analysts (PDF | 138KB)
Unilever is committed to establishing mutually beneficial relations with our suppliers, customers and business partners. In our business dealings we expect our partners to adhere to business principles consistent with our own.
Supporting Code Policies: Responsible Sourcing (PDF | 314KB)
Unilever companies are encouraged to promote and defend their legitimate business interests. Unilever will co-operate with governments and other organisations, both directly and through bodies such as trade associations, in the development of proposed legislation and other regulations which may affect legitimate business interests. Unilever neither supports political parties nor contributes to the funds of groups whose activities are calculated to promote party interests.
Supporting Code Policies: Political Activities & Political Donations (PDF | 415KB)
Further disclosure: Engaging with our stakeholders
Unilever is committed to making continuous improvements in the management of our environmental impact and to the longer-term goal of developing a sustainable business. Unilever will work in partnership with others to promote environmental care, increase understanding of environmental issues and disseminate good practice.
In our scientific innovation to meet consumer needs we will respect the concerns of our consumers and of society. We will work on the basis of sound science, applying rigorous standards of product safety.
Supporting Code Policies: Responsible Innovation (PDF | 199KB)
Unilever believes in vigorous yet fair competition and supports the development of appropriate competition laws. Unilever companies and employees will conduct their operations in accordance with the principles of fair competition and all applicable regulations.
Supporting Code Policies: Fair Competition (PDF | 776KB); Competitors’ Information & Intellectual Property (PDF | 373KB)
Bribery & Corruption
Unilever does not give or receive, whether directly or indirectly, bribes or other improper advantages for business or financial gain. No employee may offer, give or receive any gift or payment which is, or may be construed as being, a bribe. Any demand for, or offer of, a bribe must be rejected immediately and reported to management.
Supporting Code Policies: Anti-Bribery (PDF | 155KB); Gifts & Hospitality (PDF | 354KB); Conflicts of Interest (PDF | 68KB); Anti-Money Laundering (PDF | 219KB); Competitors’ Information & Intellectual Property (PDF | 373KB)
Further disclosure: Business integrity
Conflicts of Interest
All employees and others working for Unilever are expected to avoid personal activities and financial interests which could conflict with their responsibilities to the company. Employees must not seek gain for themselves or others through misuse of their positions.
Supporting Code Policies: Avoiding Conflicts of Interest (PDF | 68KB)
Compliance – Monitoring – Reporting
Compliance with these principles is an essential element in our business success. The Unilever Board is responsible for ensuring these principles are applied throughout Unilever.
The Chief Executive Officer is responsible for implementing these principles and is supported in this by the Global Code and Policy Committee which is chaired by the Chief Legal Officer.
Day-to-day responsibility is delegated to all senior management of the geographies, divisions, functions and operating companies. They are responsible for implementing these principles, supported by local Business Integrity Committees. Assurance of compliance is given and monitored each year. Compliance is subject to review by the Board supported by the Corporate Responsibility Committee and for financial and accounting issues the Audit Committee.
Any breaches of the Code must be reported. The Board of Unilever will not criticise management for any loss of business resulting from adherence to these principles and other mandatory policies. Provision has been made for employees to be able to report in confidence and no employee will suffer as a consequence of doing so.
Supporting Code Policies: All Code Policies (PDF | 5MB)
Our Code Policies (PDF | 5MB) define the ethical behaviours that we all need to demonstrate when working for Unilever. They are mandatory. While these are for internal use, we also publish them externally in support of transparency. Find out more about these Policies below.
People should be treated with dignity, honesty and fairness. Unilever and its employees celebrate the diversity of people, and respect people for who they are and what they bring. Unilever wants to foster working environments that are fair and safe, where rights are respected and everyone can achieve their full potential.
Overarching Code of Business Principles: Employees
Occupational Health & Safety
Unilever is committed to providing healthy and safe working conditions. Unilever complies with all applicable legislation and regulations and aims to continuously improve health and safety performance.
Everyone at Unilever has a role to play. Managers are responsible for the occupational health and safety of their reports and third parties under their control. As a condition of our employment, we all have a duty to work safely. This Code Policy (PDF | 436KB) outlines our individual and shared responsibilities for health and safety.
Respect, Dignity & Fair Treatment
Business can only flourish in societies where human rights are respected, upheld and advanced. Unilever recognises that business has the responsibility to respect human rights and the ability to contribute to positive human rights impacts.
There is both a business and a moral case for ensuring that human rights are upheld across Unilever’s operations and value chain. Unilever is committed to ensuring that all employees work in an environment that promotes diversity and where there is mutual trust, respect for human rights and equal opportunity, and no unlawful discrimination or victimisation.
This Code Policy (PDF | 147KB) sets out what Unilever and its employees must do to ensure that all workplaces maintain such an environment.
Information is essential to our success: it fuels our research, keeps us in touch with consumer needs and helps us work effectively together. If used inappropriately, information can cause considerable damage to our business.
Overarching Code of Business Principles: Shareholders, Fair Competition
Protecting Unilever’s Information
Information is one of Unilever’s most valuable business assets: Unilever is committed to safeguarding and protecting our information and any other information entrusted to us.
Information within Unilever is held in many different formats, including on paper, electronically in documents or in IT applications & systems. Our requirements to protect information apply to all formats. Unilever has data classification standards which define how information within Unilever must be classified, handled and protected. This Code Policy (PDF | 356KB) explains how employees should handle company information.
Preventing Insider Trading
Employees must not use inside information to buy or sell securities of Unilever PLC, Unilever N.V. or any listed Unilever subsidiary, or any other publicly traded company. Securities include shares, equities and related derivatives or spread bets.
Unilever’s Disclosure Committee is responsible – on behalf of the Board – for ensuring that Unilever has the necessary procedures in place to ensure Unilever complies with applicable insider trading laws and regulations (see Unilever’s Share Dealing and Disclosure Manuals). This Code Policy (PDF | 65KB) explains what insider trading is, how employees can be sure they don’t engage in it, and what to do if they discover inside information is being misused.
Trading or encouraging others to trade on inside information, or giving it to unauthorised parties, is a criminal offence in many countries: a breach of the applicable laws can lead to fines and/or imprisonment. Inside (or price sensitive) information means information that is not available to the public and that a reasonable investor would probably consider important in deciding whether to buy or sell a company’s shares. Examples of inside information include the following:
- Business results or forecasts for the whole company or for one of our listed subsidiaries
- A major new product, product claim or product incident/issue
- An acquisition, merger or divestment
- A sizeable restructuring project
- Major developments in litigation cases or in dealings with regulators or governments
- Revisions in dividend policy
- Changes in executive directors.
Competitors’ Information & Intellectual Property
Unilever respects the intellectual property and confidential information of third parties, including competitors, suppliers and customers. Confidential information is information about another company that is not in the public domain and has value.
To promote fair competition, Unilever gathers and uses competitors’ information that is in the public domain, for example, from newspapers, the internet and company filings. Accepting or using competitors’ confidential information risks being a serious infringement of competition laws and/ or trade secrets/intellectual property laws, leading to significant penalties for Unilever and individuals.
This Code Policy (PDF | 373KB) outlines what employees must do to respect the confidentiality of other companies’ information.
Personal Data & Privacy
Unilever respects the privacy of all individuals and the confidentiality of any personal data Unilever holds about them. This Code Policy (PDF | 365KB) sets out what steps employees must take to ensure personal data is handled appropriately.
Use of Information Technology
Unilever’s Information Technology (IT) – including desktops and laptops, mobile devices, networks, software, email, data, business applications and internet/intranet – are critical to our operations. This Code Policy (PDF | 205KB) explains what employees need to do to ensure the responsible and secure use of IT in Unilever, including compliance with all relevant laws and regulations.
Integrity defines how we behave, wherever we are. It guides us to do the right thing for the long-term success of Unilever.
Overarching Code of Business Principles: Bribery & Corruption, Conflict of Interest
Avoiding Conflicts of Interest
Conflicts of interest can have a significant negative impact on the reputation and effectiveness of Unilever, its business and its people. This Code Policy (PDF | 68KB) sets out what employees must do to avert or manage actual or perceived conflicts of interest.
To support global efforts to fight corruption, most countries have laws that prohibit bribery: many apply these ‘internationally’ to behaviour beyond their borders. A breach of such laws may result in fines for Unilever and in personal penalties for individuals. Dealings with public officials are particularly high risk: even the appearance of illegal conduct could cause significant damage to Unilever’s reputation.
Unilever’s commitment to doing business with integrity requires consistently high global standards: our zero-tolerance approach towards bribery and corruption applies to all Unilever operations, regardless of local business practices. This Code Policy (PDF | 155KB) covers what employees must and must not do to meet Unilever requirements.
Gifts & Hospitality
All Unilever’s relationships must reflect its ongoing commitment to doing business with integrity. Hospitality can play a positive role in building relationships with customers, suppliers and other third parties. Likewise, it is sometimes appropriate to offer reasonable gifts, e.g. in the context of promotional events or product launches. However, as accepting or receiving gifts and hospitality can be open to abuse or generate actual or perceived conflicts of interest, this should occur sparingly and always be legitimate and proportionate in the context of Unilever’s business activities.
This Code Policy (PDF | 354KB) sets out responsibilities of employees in relation to gifts and hospitality. It makes clear what forms of gifts and hospitality are always prohibited. It also explains in what circumstances gifts or hospitality may legitimately be given or received.
Accurate Records, Reporting & Accounting
The financial reports and other information that Unilever maintains internally and the financial information it provides to shareholders, regulators and other stakeholders must be accurate and complete.
Our records provide valuable information for the business and evidence of our actions, decisions and obligations. Procedures and processes must be in place to ensure that underlying transactions are properly authorised and accurately recorded.
Any failure to record transactions accurately, or falsifying or creating misleading information or influencing others to do so, could constitute fraud and result in fines or penalties for employees or for Unilever. This Code Policy (PDF | 66KB) sets out what employees must do to ensure the accuracy of our business records and financial information.
Protecting Unilever’s Physical & Financial Assets & Intellectual Property
Employees are responsible for ensuring Unilever’s assets are protected. This Code Policy (PDF | 171KB) covers the protection of physical assets/ property, financial assets and intellectual property.
For information on the protection of several other asset types see the Code Policies on Occupational Health and Safety and Protecting Unilever’s Information.
To protect Unilever’s reputation and avoid criminal liability, it is important not to become associated – however innocently – with the criminal activities of others. In particular, Unilever and its employees must ensure Unilever does not receive the proceeds of criminal activities, as this can amount to the criminal offence of money laundering.
This Code Policy (PDF | 219KB) sets out essential steps employees must take to avoid being implicated in money laundering.
Throughout our value chain, from innovation through to our consumers, Unilever and its employees need to demonstrate the same ethical standards when engaging with others externally as when dealing with colleagues.
Overarching Code of Business Principles: Innovation, Consumers, Business Partners, Competition, Public Activities
Innovation is fundamental to Unilever’s business success and a core part of our global strategy. The integrity and objectivity of our Science are a key foundation for our approach to responsible innovation. Safety is non-negotiable.
Unilever conducts responsible, safe and sustainable research and innovation, which fully respects the concerns of our consumers and society. In meeting consumer needs, Unilever’s innovations are based on sound science and technology, and reflect high standards and ethical principles.
This Code Policy (PDF | 199KB) sets out essential steps employees involved in scientific research and innovation activity must comply with.
Unilever is committed to developing, producing, marketing and selling all its products and services responsibly. Unilever can and should conduct marketing activities in line with societal expectations.
This Code Policy (PDF | 169KB) sets out global minimum standards that apply to all of Unilever’s marketing activities everywhere. This covers but is not limited to: brand names, packaging and labelling; consumer planning and market research; trade advertising; sales materials; brand merchandising and sponsorship; all forms of advertising including television, radio, print, digital media, promotional activities and events, product placements, ‘advergaming’ – whether created by Unilever, agencies, crowdsourcing or other third parties.
Unilever’s reputation is founded on delighting our consumers and customers with consistently great product quality that meets or exceeds their needs and expectations. Our aim is to be the most trusted and preferred customer and consumer choice on every occasion.
Unilever is committed to achieving this goal by meeting or exceeding all legal and regulatory requirements and through the rigorous application of our Quality Management System. Each personal product quality experience for our consumers depends upon all employees understanding their roles and responsibilities and ensuring that they adhere to Unilever’s quality standards, business processes and regulatory requirements at all times.
Unilever will take prompt and timely action wherever and whenever we encounter products which don’t meet our standards or those required in the market place. We will continuously improve product quality experiences by using the insights gained from our performance measures and from consumer and customer feedback.
This Code Policy (PDF | 435KB) applies to all aspects of product quality including safety, design, formulation, raw materials, primary/secondary/tertiary packaging, manufacture, storage, transport, display, marketing, communication, sales and disposal of Unilever products – at Unilever, third-party or business partner facilities.
Unilever expects its business partners to adhere to values and principles consistent with our own. Unilever is developing new business practices to grow our company and communities, by doing business in a manner that improves lives of workers across our supply chain, their communities and the environment, consistent with the Unilever Sustainable Living Plan.
Our requirements of suppliers (companies that supply Unilever with goods and/or services, across both production and non-production areas of our business) are set out in our Responsible Sourcing Policy (PDF | 5MB) (RSP). Unilever’s reputation could suffer significant damage if suppliers fail to comply with these requirements. The RSP affirms the following Fundamental Principles:
- Business is conducted lawfully and with integrity
- Work is conducted on the basis of freely agreed and documented terms of employment
- All workers are treated equally and with respect and dignity
- Work is conducted on a voluntary basis
- All workers are of an appropriate age
- All workers are paid fair wages
- Working hours for all workers are reasonable
- All workers are free to exercise their right to form and/or join trade unions or to refrain from doing so and to bargain collectively
- All workers’ health and safety are protected at work
- All workers have access to fair procedures and remedies
- Land rights of communities, including indigenous peoples, will be protected and promoted
- Business is conducted in a manner which embraces sustainability and reduces environmental impact.
All Unilever Purchasing Agreements/ Contracts (UPAs/Global GTCs), Master and Local Purchase Agreements (MPAs/ LPAs) or Unilever Master Services Agreements (MSAs) specify that suppliers must acknowledge adherence to our RSP as a condition of supply.
This Code Policy (PDF | 314KB) sets out responsibilities of employees who engage with suppliers.
Competition laws prohibit anticompetitive agreements (or cartels) between competitors. Many national laws also prohibit abuses of dominant position and include specific rules relating to agreements with distributors and other customers. Investigations by competition authorities may result in significant fines and costs, and damage our reputation. Criminal sanctions may also apply.
Unilever believes in vigorous yet fair competition and supports the development of appropriate competition laws. Unilever companies and employees will conduct their operations in accordance with the principles of fair competition and all applicable regulations. Unilever prohibits participation in cartels in all countries, even those that do not have competition law.
This Code Policy (PDF | 776KB) sets out what employees must do to ensure Unilever upholds fair competition.
Contact with Government, Regulators & Non-governmental Organisations (NGOs)
Any contact by employees or other representatives with government, legislators, regulators or NGOs must be done with honesty, integrity, openness and in compliance with local and international laws.
Governments, regulators and legislators includes bodies that may be: global or international (e.g. United Nations); regional (e.g. European Union, ASEAN); national; or active at a local community level. Non-Governmental Organisations (NGOs) also operate at different levels, and their work includes social and consumer issues as well as environmental ones.
Interaction with these organisations must only be made by authorised and appropriately trained individuals. This covers all forms of communications, whether formal, informal or social interaction in relation to Unilever business including any kind of correspondence such as in-person, electronic media and/or written correspondence.
This Code Policy (PDF | 384KB) provides detailed guidance on how contact with the above authorities must proceed. It does not cover interactions about purely personal matters, such as personal charitable donations or personal tax.
Further disclosure: Engaging with our stakeholders
Political Activities & Political Donations
Unilever companies are prohibited from supporting or contributing to political parties or candidates. Employees can only offer support and contributions to political groups in a personal capacity. This Code Policy (PDF | 415KB) sets out how Unilever employees must manage their business relationship with political groups.
Further disclosure: Engaging with our stakeholders
External Communications – The Media, Investors & Analysts
Communication with investment communities – including shareholders, brokers and analysts – and the media must be managed carefully. Such communication has important legal requirements and demands specialist skills and experience. Only individuals with specific authorisation and training/briefing may communicate about Unilever with investment communities or the media, or respond to their enquiries or questions.
Unilever’s Disclosure Committee – on behalf of the Board – is responsible for ensuring Unilever has the necessary procedures to comply with relevant laws and regulations including Unilever’s Disclosure & Share-Dealing Manuals.
This Code Policy (PDF | 138KB) outlines how communication with investment communities and the media must operate.
Frequently asked questions
We are often asked how we manage and enforce our Code of Principles and Code Policies. Find out more below.
How is business integrity governed and managed?
Our Chief Executive Officer sets an unequivocal tone from the top: he communicates regularly with leaders and all employees on business integrity, making clear that adherence to our Code and Code Policies is non-negotiable. Many other members of our Executive are also vocal champions: they make time to regularly share their personal perspective on business integrity with their teams, through communications and ‘integrity moments’ at the start of meetings to briefly focus on a specific topic or learning where appropriate.
At Board level, our Corporate Responsibility Committee has oversight of the implementation of the Code and Code Policies. Our Audit Committee is updated on relevant compliance developments.
At group executive level, our Global Code & Policy Committee (GCPC) provides global oversight. The GCPC is chaired by the Chief Legal Officer and, in addition to the Chief Business Integrity Officer, has as members the Group Controller, Chief Auditor, EVP HR Europe, Chief Procurement Officer, Chief Customer Officer and VP Integrated Social Sustainability. The GCPC meets minimum once a quarter to review our Business Integrity strategy, the adequacy of our controls and management systems, performance on training, status of investigations and associated sanctions.
Our global Procurement Business Integrity Committee (PBIC) has responsibility for reviewing third-party compliance issues arising from our Responsible Sourcing Policy and reports periodically into the GCPC. It reviews responsible sourcing and quality audit issues, red flags for risk, and other issues relating to non-compliance by our suppliers.
Our Chief Business Integrity Officer, reporting to the Chief Legal Officer, advises on the strategy and execution of our global Business Integrity programme and leads a network of local and regional Business Integrity Officers. The Business Integrity team works closely with internal stakeholders, including specialist subject-matter experts and teams involved in implementing the third-party compliance programme. Members of the Business Integrity community liaise regularly to share information and best practices.
Every country Chairman is accountable for business integrity and related compliance matters in their market. Business Integrity Committees for relevant geographies oversee investigations into alleged breaches of the Code of Business Principles, Code Policies and local aspects of the implementation of Unilever’s third party compliance programme. Members typically include the Country Chairman, and Heads of Finance, Human Resources, Supply Chain, Customer Development and Legal. Committees review and report quarterly on significant compliance risks and mitigations, training and awareness efforts, status of investigations and sanctions including disciplinary and asset recovery proceedings.
Our local Business Integrity Officers assist our markets and local Business Integrity Committees in carrying out these responsibilities. Complaints and concerns from both employees and third parties at both the individual and community level can be escalated to senior levels of the business as necessary.
All Unilever managers are required to make an annual declaration to confirm they live the Code and have reported any known or suspected Code breaches. Exceptions are systematically investigated. In 2016 and 2017 we broadened the opportunity for others to affirm their commitment to Unilever’s values and saw over 50,000 employees each year make the Code Declaration in our Global Business Integrity Pledge Week.
How do we train our employees on business integrity?
Everyone who works at Unilever should know our Code and Code Policies and understand how to apply them in their work.
Employees are regularly asked to complete business integrity training. Learnings materials, which were updated in 2016 (see case study), are available both online and for face-to-face awareness and learning sessions: they are designed to highlight key risks and are available in numerous languages. Materials target not only office-based employees, but also those working in factories and more remote areas.
A certain level of training is mandatory for all Director and managers, including corporate leaders such as our Chief Executive Officer and Unilever Board Members. Completion of training is tracked through our online learning platform and other tools. We follow up with employees who fail to complete mandatory training and take further action where required.
Our Business Integrity team and subject matter experts further supports operational teams to develop additional materials tailored and timed to meet local needs. We seek to provide advanced guidance on specific areas covered by our Code Policies for employees in higher risk positions. We monitor and benchmark our approach to ensure continuous improvement.
We run regular globally designed and locally implemented communications campaigns to reinforce awareness and, where relevant, share lessons learnt in training.
How do we assess business integrity risk and conduct due diligence?
We use a risk-based approach to implement our Business Integrity programme. We constantly seek to improve our analytics capabilities so trends, hot spots and root causes are rapidly identified and addressed.
Each operating company periodically reviews its Business Integrity programme and profile to identify focus areas for improvement. Development needs identified through this assessment are addressed as part of local, or where appropriate, global plans. The work of local teams is available for independent review by our Corporate Audit function.
We have additional detailed controls for preventing financial accounting errors and fraud. Our financial controls are externally audited annually. Our Corporate Audit function includes the audit of Business Integrity controls in their scope of business unit audit work.
How do employees raise concerns?
We are committed to a culture of transparency and have a clear “no retaliation” policy. We want employees to feel confident about speaking up and third parties are likewise encouraged to contact us with any concerns. We offer a variety of internal and external reporting solutions for raising concerns in confidence, anonymously if required.
Employees can get in touch with their line manager, a Business Integrity Officer or a member of their local Business Integrity Committee. Alternatively, they can use our confidential external Unilever Code Support Line (whistleblowing line) via telephone or internet. We highlight these options during Business Integrity training and in our communications. We aim to complete investigations within 60 days. Case closure statistics are reviewed by the Global Code Policy Committee on a quarterly basis and by the Board’s Corporate Responsibility Committee at each of its meetings. We publish details of our web-based reporting process externally and share them with our external business partners.
How do we respond to breaches of our Code?
Our market-based Business Integrity committees oversee investigations of all potential breaches of our Code and Code Policies, except where senior executives are involved. In such cases, our Chief Legal Officer and Chief Business Integrity Officer oversee investigations, regardless of where such executives are located.
In 2017, we closed 1,654 cases of reported integrity concerns across all areas of our Code and Code Policies, with 709 confirmed breaches. These are broken down per Code theme in the table below.
Code cases by relevant theme in 2017
Code Policies on Living the Code, Legal Consultation and Responsible Risk Management
Code Policies on Accurate Records Reporting & Accounting, Protecting Unilever’s Physical & Financial Assets & Intellectual Property, Avoiding Conflicts of Interest, Anti-Bribery, Gifts & Hospitality and Anti-Money Laundering
Code Policies on Respect, Dignity & Fair Treatment and Occupational Health & Safety
Code Policies on Protecting Unilever’s Information, Preventing Insider Trading, Competitors’ Information & Intellectual Property, Personal Data & Privacy and Use of Information Technology
Code Policies on Responsible Innovation, Responsible Marketing, Responsible Quality, Responsible Sourcing, Fair Competition, Contact with Government, Regulators & NGO’s, Political Activities & Political Donations and External Communications - the Media, Investors & Analysts
The number of issues raised per 1,000 employees and substantiation rates benchmark well against available peer data, pointing to ongoing Unilever employee willingness to report integrity concerns. Our policy is to investigate all reported concerns, however they are raised, including minor ones. The number of confirmed Code Policy breaches reflects the high overall standards we set ourselves. We sanction individuals as appropriate, including through warnings and coaching, and share learnings that help reduce the likelihood of material breaches occurring.
In 2017 we dismissed 279 employees, initiated 3 cases of legal action and issued 284 written warnings – with 36 employees receiving a downgrade in individual performance rating.
Our Business Integrity guidelines and processes seek to ensure a consistent approach across the Unilever group. This includes clear processes for investigating any integrity concerns raised. We also seek to ensure that our businesses apply individual sanctions consistently, appropriately and fairly; our guidance sets out which mitigating and aggravating circumstances may be taken into account. We monitor developments centrally to ensure a consistent approach.
How do we ensure continuous improvement?
We aim to continuously improve how we work and to further embed a culture of business integrity. We analyse results of investigations, market assessments and audit findings to identify trends and opportunities for improvement. We act on feedback from users of our Code breach channels in order to improve the system. We engage with thought leaders and peer companies to understand and aspire to best practices.
We are a Corporate Supporter of Transparency International and a founding signatory of the United Nations Global Compact. We also contribute to various international initiatives, including with the B-Team, International Chamber of Commerce, the B20, and the WEF Partnering Against Corruption Initiative.
Beyond Unilever: business integrity across our value chain
We want to work with suppliers, customers, agents, distributors and other business partners who have values similar to ours and uphold the same standards as we do. We have therefore developed specific tools that set out the standards of integrity we expect from third parties who interact with us. These include our:
- Responsible Sourcing Policy (PDF | 9MB) that forms the basis of ongoing dialogue with suppliers on the standards we expect them to meet and will work with them to achieve. We updated and reissued our Responsible Sourcing Policy in 2017. Find out more about our approach how our Responsible Sourcing Policy underpins our sustainable sourcing commitments.
- Responsible Business Partner Policy (PDF | 3MB), which is being rolled out to distributors and other third parties within Unilever’s downstream route to market network. We have not changed the Responsible Business Partner Policy requirements since it was issued in 2015.
We use risk assessments and due diligence to identify suppliers, business partners or other third parties that may pose a legal or reputational risk to Unilever, and to determine how best to address concerns. Where possible, our aim is to encourage them to take active steps to improve their approach to embedding a culture of integrity across their business.