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.
Living the Unilever Code of Business Principles is a team effort. Much of Unilever’s strength lies in the shared values of our people.
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 our Unilever strategy.
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 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.
Code of Business Principles
The Code of Business Principles (PDF 218KB) 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 8.51MB) 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.
Behaving with integrity, day in and day out, is a non-negotiable, and will help in creating a fairer and more principled world. Know the code inside out – it matters.Alan Jope, our CEO
Having a strong set of values that respect people, society, and the planet has always been at the heart of Unilever, and will continue to be critical to building our purpose-led, future-fit company.
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.
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.
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.
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.
Frequently asked questions
We are often asked how we manage and enforce our Code of Principles and Code Policies. Find out more below.
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 Investigating Code Breaches (PDF 509KB) for detail of the process.
In 2020, 69% of our cases were reported directly into Business Integrity Officers which reassures us that we continue to embed a strong Speak Up process with trust in our Business Integrity Officers. Overall, 37% of our 1,357 cases were anonymously reported utilising our external facing platform which provides both web reporting and hotlines with translator services.
In 2020, we received 1,357 reports from whistleblowers. We substantiated 723 in breach of our Code Policies, which led to 338 people leaving the business. Furthermore, we initiated 8 cases of legal action and issued 554 written warnings – with 103 employees receiving a written warning and appropriate financial consequences. In total we investigated and closed 1,434 Code cases during the year. A small number of cases remain ongoing. We cannot disclose details of these due to confidentiality.
2020 Code cases by relevant theme
Code Policies on Living the Code, Legal Consultation, Responsible Risk Management, Responsible Innovation and Product Safety and Product Quality
Code Policies on Accurate Records Reporting & Accounting, Protecting Unilever’s Physical & Financial Assets, 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, Personal Data & Privacy and Use of Information Technology
Code Policies on Responsible Innovation, Responsible Marketing, Responsible Quality, Responsible Sourcing and Business Partnering, Fair Competition, Contact with Government, Regulators & NGO’s, Political Activities & Political Donations and External Communications - the Media, Investors & Analysts
In 2020, 46% of our substantiated cases were in Europe, Middle East and Africa, 32% in the Americas and 22% 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.
Our approach to training employees in 2020 was based on a combination of external and internal risks which resulted in tailored learning curriculums deployed based on geography and function. 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 risk, our “musts” and “must nots” and are available in numerous languages. Materials target not only office-based employees, but also those working in factories and more remote areas.
In 2020 our offline learning approach which was expanded to include more African and Asian languages, was centred around 6 animated videos supported by guidance materials for the local trainers and 34,529 of our offline employees were trained using these materials.
450,854 Individual online training sessions
A certain level of training is mandatory for all employees, 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 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.
The table below shows individual training sessions for our employees both those with access to our online training resources and those without access to our digital tools who have received offline face-to-face training.
Number of online capsules completed
Governance: Living the Code, Legal Consultation, Responsible Risk Management, Product Quality & Product Safety, Responsible Innovation
Countering Corruption: Accurate Records Reporting & Accounting, Protecting Unilever's Physical & Financial Assets, Avoiding Conflicts of Interest, Anti-Bribery, Gifts & Hospitality, Anti-Money Laundering
Respecting People: Respect, Dignity & Fair Treatment, Occupational Health & Safety
Safeguarding Information: Protecting Unilever's Information, Preventing Insider Trading, Competitor's Information, Personal Data & Privacy, Use of Information Technology
Externally Engaging: Fair Competition, Responsible Marketing, Contact with Government, Regulators and Non-Governmental Organisations (NGO's), Political Activities & Political Donations, External Communications - The Media, Investors & Analysts, Responsible Sourcing & Business Partnering
Total of online capsules
Employees who received offline learning covering 4 key topics
New joiners who received consolidated capsule training
Total learning delivered in 2020
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.
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:
- Our Responsible Sourcing Policy 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 (PDF 8.25MB) underpins our sustainable sourcing commitments.
- Responsible Business Partner Policy (PDF 7.79MB), 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.