Business Integrity

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).

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.

Code of Business Principles

Our Code of Business Principles (PDF | 3MB) 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.

Code Policies

Our Code Policies (PDF | 3MB) 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.

Respecting People

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

Safeguarding Information

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

Countering Corruption

Integrity defines how we behave, wherever we are. It guides us to do the right thing for the long-term success of Unilever. In addition to the information provided on this website and in our Annual Report, we report publicly on the status of our anti-corruption programme through our annual Communication on Progress to the UN Global Compact.

Overarching Code of Business Principles: Bribery & Corruption, Conflict of Interest

Engaging Externally

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

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. Learning materials, which are regularly updated, 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.

The table below shows individual training sessions for our employees who have access to our online training resources. In addition to the numbers below we provide training to our employees without access to our digital tools, for example through face-to-face training, as well as our third parties.

Online Code trainingSessions in 2018

Countering corruption

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

168,469

Respecting People

Code Policies on Respect, Dignity & Fair Treatment and Occupational Health & Safety

56,635

Safeguarding Information

Code Policies on Protecting Unilever’s Information, Preventing Insider Trading, Competitors’ Information & Intellectual Property, Personal Data & Privacy and Use of Information Technology

109,248
Total334,352

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. 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 approach

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.

Each Business Integrity Committee is responsible for ensuring the timely investigation of all alleged or suspected Code breaches by an individual employee – with a view to reaching a final determination within 60 days. See Investigating Code Breaches (PDF | 74KB) for detail of the process.

In 2018 1,206 whistleblowing incidents were opened (defined as Code Policy cases raised). We closed 1,252 incidents across all areas of our Code and Code Policies, with 662 confirmed breaches. These are broken down per Code theme in the table below.

Code cases by relevant themeOpened in 2018Substantiated in 2018

Governance

Code Policies on Living the Code, Legal Consultation and Responsible Risk Management

6344

Countering corruption

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

518333

Respecting People

Code Policies on Respect, Dignity & Fair Treatment and Occupational Health & Safety

536216

Safeguarding Information

Code Policies on Protecting Unilever’s Information, Preventing Insider Trading, Competitors’ Information & Intellectual Property, Personal Data & Privacy and Use of Information Technology

7057

Engaging Externally

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

1912
Total1,206662

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 2018, we terminated the employment of 330 people, initiated 7 cases of legal action and issued 337 written warnings – with 97 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 | 8MB), 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.

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