Business Integrity

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).

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 and subsequently updated in 2020) 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.

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 Code of Business Principles (PDF | 9MB) 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.

Our Code Policies (PDF | 9MB) 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.

We are often asked how we manage and enforce our Code of Principles and Code Policies. Find out more below.

In 2019, we received 1,575 reports from whistleblowers. We substantiated 733 in breach of our Code Policies, which led to 413 people leaving the business. In total we investigated and closed 1,410 Code cases during the year. A small number of cases remain ongoing. We cannot disclose details of these due to confidentiality.

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 2019, we initiated 11 cases of legal action and issued 623 written warnings – with 217 employees receiving a written warning and appropriate financial consequences.

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.

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. On a quarterly basis we collect key case information across each geography for the purposes of creating case studies and lessons learnt.

These lessons learnt are shared extensively and form part of the Unilever Leadership Executive quarterly reporting and are subsequently used in meetings and employee engagements. The lessons learnt are shared with both country and functional leaders, Code Policy owners and across our Business Integrity network.

On an annual basis our employees participate in global surveys which include Business Integrity questions, with responses reviewed at both our Global Code Policies Committee (GCPC) and at the various geographic Business Integrity Committee meetings. In addition to the case analytics review, these responses enable the business to focus on potential hotspots, the overall effectiveness of the Business Integrity programme and provide insights into how strongly Business Integrity is embedded into the business. This then drives both engagement and action plans going forward.

We routinely seek input to improve the robustness and quality of the user experience in relation to our Code breach channels. Over the past 12 months we have proactively engaged with our platform service provider to review whistleblowing hotline scripts, expand further the languages serviced and accelerated the speed with which we can connect users to local language interpreters and simplified the online reporting process. 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.

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 that forms the basis of ongoing dialogue with suppliers on the standards we expect them to meet and will work with them to achieve. Find out more about 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 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.