We’ve translated our Code of Business Principles into the following languages.
Code of Business Principles - multiple language versions
Deep link to Our Sustainability Governance page
Other key documents
Frequently asked questions
We are often asked how we manage and enforce our Code of Principles and Code Policies. Find out more below.
How do employees raise concerns?
We are committed to a culture of transparency and have a 100% prohibition on retaliation against those who report or seek guidance on ethical or compliance issues and/or report cases under our Code of Business Principles. See our Non-Retaliation Policy (PDF 568.39 KB) for further details.
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 online.
In addition to the internal and external channels provided, where available, employees are able to utilise other external reporting channels and report directly to the authorities.
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 is business integrity governed and managed?
Our CEO 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.
In addition to the externally published Code of Business Principles breach data, we conduct extensive internal analysis of breaches to deliver insights, identify root causes and drive actions. This analysis is shared across the business with quarterly oversight and review by the Board’s Corporate Responsibility Committee, Unilever Leadership Executive, Global Code and Policy Committee and other Business Integrity Committees in line with the Governance of Unilever.
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, hotspots 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 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. 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.
Our investigation processes also incorporate our commitment to learning from our code cases and include the proposal of management actions and remediations. The scope of remedial actions is broad and can range from reviews of internal controls, creation of new Standard Operating Procedures, leadership training or coaching, HR team interventions, mandatory retraining of teams across a broader geographic footprint, sharing of learnings across the global Business Integrity network, enhanced local communications to drive up awareness and integrity moments delivered by leadership focused on what went wrong.
The impact of sharing real cases helps make these incidents tangible for our workforce. The cases recorded over the course of a year are a consideration for the build of the following year’s mandatory learning. The Business Integrity team works closely with both the Corporate Audit teams and the local Internal Controls teams to ensure process gaps are closed to minimise reoccurrence risk.
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. We proactively engage with our platform service provider to review whistleblowing hotline scripts, expand the number of languages serviced and accelerate the speed with which we can connect users to local language interpreters and simplify 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.
What is our commitment to anti-corruption?
Unilever’s zero-tolerance approach towards bribery and corruption is outlined in our Code of Business Principles and Code Policies and applies to all Unilever operations, regardless of local business practices. This extends to all our employees, Board members, third parties, new acquisitions and joint ventures, irrespective of financial values involved. It prohibits both public and commercial bribery – to or from any third party. We explicitly prohibit facilitation payments.
Our Anti-Corruption Compliance Programme ensures our zero-tolerance approach is maintained in all our internal and external interactions. The Programme utilises the ‘prevent-detect-respond’ framework (see setting out our standards of behaviour above) with some enhancements in the following areas:
- A bespoke risk assessment exercise is conducted on an annual basis to determine the business activities and geographies that require specific actions to enhance our controls and respond to changes in our risk exposure. Recent exercises have confirmed the higher risk that exist in activities like interactions with public officials, customs clearance, transportation, inventory management and third-party engagements. A range of tailor-made enhancements are continuously introduced to mitigate these risks.
- In addition to our Code of Business Principles and Code Policies, we have additional anti-corruption written standards and controls for interactions with public officials, brand protection, corporate transactions (M&A), customer incentives, gifts and hospitality, grants and donations and conflicts of interest.
- Our annual Business Integrity mandatory training is deployed to all employees and includes anti-corruption lessons based on our learnings from investigations, risk assessments and business partnering. Additional bespoke training is offered to employees that face a greater risk in their activities.
The Programme is sponsored by the Chief Legal Officer and Business Integrity Officer and led by the Chief Counsel – Ethics & Compliance. It is overseen by our Corporate Responsibility Committee of the Board of Directors.
We support international organisations like the United Nations and the Organisation for Economic Cooperation and Development in their efforts to implement their anti-corruption international conventions and best practice. We also participate actively in key anti-corruption forums like the World Economic Forum (PACI and Global Future Councils), the UN Global Compact, the International Chamber of Commerce, the B-20 and Transparency International.
We provide thought leadership and influence key policymakers on positive regulatory change that can help our consumers, Unilever and our business partners (including small and medium enterprises) to live and be able to do business in corruption free environments. We also benchmark externally, disseminate good practices and actively participate in knowledge exchange opportunities with peers.
Responding 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 and a global code policy committee determines any sanctions 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.
Our reporting platform allows two-way communication through a secure exchange between the reporter and the Business Integrity Officer even when the reporter chooses full anonymity. On receipt of a report, we formally acknowledge and encourage engagement to facilitate the investigation and, where appropriate and possible, we aim to provide transparency with regards to the investigation progression and anticipated completion. See Our Speak up Platforms and Investigating Code Breaches (PDF 494.51 KB) for detail of the process.
In 2022, 58% of our cases were reported directly to Business Integrity Officers which reassures us that we continue to embed a strong Speak Up process with trust in our Business Integrity Officers. Overall, 38% of our 1,279 cases were anonymously reported utilising our external facing platform which provides both web reporting and hotlines with translator services.
In 2022, we received 1,279 reports from whistle-blowers. We substantiated 554 in breach of our Code Policies, which led to 314 people leaving the business. Furthermore, we initiated 8 cases of legal action and issued 295 written warnings – with 83 employees receiving a written warning and appropriate financial consequences. In total we investigated and closed 1,088 Code cases during the year. A small number of cases remain ongoing. We cannot disclose details of these due to confidentiality.
* This includes breaches of all six Countering Corruption Code Policies in our Code of Business Principles and Code Policies (PDF 6.07 MB) (see pages 15-22). For certain external anti-corruption benchmarks, including the WEF IBC anti-corruption metric, we exclude cases that mainly relate to theft or breaches against Unilever assets. In such cases we report 144 cases as substantiated in 2022.
In 2022, 41% of our substantiated cases were in Europe, the Middle East and Africa, 31% in the Americas and 28% in Asia.
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.
Training 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.
For 2022, our new ‘edutainment’ approach to online Business Integrity training using storytelling and intrigue helped to shift the topic of Business Integrity from being a set of mandatory rules to showcasing Business Integrity in a real-life way, encouraging employees to make the right decisions in real integrity moments. It captured not only entertainment-hungry attention spans but also hearts and minds that got employees emotionally invested in learning.
Our content is based on a combination of external and internal risks. Materials target not only office-based employees, but also those working in factories and more remote areas.
In 2022 our offline learning approach, was centred around animated videos supported by guidance materials for the local trainers and 43,916 of our offline employees to date have been trained using these materials which covered the 4 code policies (Accurate records and Reporting and Accounting, Respect Dignity & Fair Treatment, Occupational Health & Safety and Protecting Unilever’s Assets). Additional employees have also completed the 2022 training in January 2023.
In addition to our offline training to 43,916 employees, specific groups such as our Sales teams in Latin America received tailored Spanish language training customised for their roles and market.
In 2022, 91% of our employees who were employed under a full-time, part-time, fixed-term, permanent or trainee contract, including acquired businesses, received training on anti-corruption policies and procedures. They received training covering five Code Policies (Avoiding Conflicts of Interest, Use of IT, Accurate Records and Reporting and Accounting, Respect Dignity & Fair Treatment).
In addition, we delivered targeted training relating to Personal Data and Privacy to 52,461 employees and new training relating to Anti-Money Laundering and Economic Sanctions to 35,352 employees.
91%of employees completed training on anti-corruption policies and procedures in 2022
A certain level of training is mandatory for all employees, including corporate leaders such as our CEO 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 support 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.
Our Business Integrity guidelines and processes seek to ensure a consistent approach across the Unilever group. This includes clear processes for fair, unbiased, independent investigation of 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 considered. We monitor developments centrally to ensure a consistent approach.
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.
Our Responsible Partner Policy (RPP) brings together our supplier-facing Responsible Sourcing Policy (RSP) and our distributor and customer-facing Responsible Business Partner Policy (RBPP) to create one policy that sets the standard for both our Responsible Sourcing Programme and our Responsible Business Partner Programme.
It sets out our 17 Fundamental Principles and defines the Mandatory Requirements, Mandatory Management Systems and Future Mandatory Requirements that partners must meet or exceed to do business with Unilever.
Our Responsible Partner Policy outlines our requirements for business partners and governs our Responsible Sourcing Programme and Responsible Business Partner Programme.
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.
Our channels for reporting concerns are also available to external parties.
Please visit reporting a concern.