We expect everyone at Unilever to be an ambassador for our high ethical standards – what we call ‘business integrity’.
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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, anti-bribery and corruption.
Unilever’s Business Integrity programme brings our values to life for all employees, and helps them apply our ethical standards in their day-to-day work. 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 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.
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:
Our Code of Business Principles (launched in 1995) and 24 related Code Policies 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. These are available in numerous languages. 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.
The Code of Business Principles (PDF 135.19 KB) 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.
Our non-negotiable high standards for doing business with integrity protect our people, assets, reputation, the communities in which we operate, our consumers, customers, and partners. Knowing the code and doing the right thing makes our company stronger.
Hein Schumacher, Unilever CEOOur Code Policies (PDF 5.39 MB) (see page 8 onwards) 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.
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.
Unilever has a global zero tolerance approach to all forms of 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.
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.
We’ve translated our Code of Business Principles into the following languages.
We are often asked how we manage and enforce our Code of Principles and Code Policies. Find out more below.
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.
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.
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.
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.
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.
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 2023, 55% 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, 43% of our 1,390 cases were anonymously reported utilising our external facing platform which provides both web reporting and hotlines with translator services.
In 2023, we received 1,390 reports from whistle-blowers. We substantiated 507 in breach of our Code Policies, which led to 337 people leaving the business. Furthermore, we initiated 6 cases of legal action and issued 567 written warnings – with 113 employees receiving a written warning and appropriate financial consequences. In total, we investigated and closed 969 Code cases during the year. A small number of cases remain ongoing. We cannot disclose details of these due to confidentiality.
2023 Code cases by relevant theme
Opened
Substantiated
Dismissal
