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, 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.
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. 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.
Code of Business Principles
The Code of Business Principles
(PDF 218.11 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. Find out more about these Principles below.
Code Policies
Our Code Policies
(PDF 8.99 MB) 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
Governance
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.
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.
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 501.13 KB) for detail of the process.
In 2021, 76% 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, 30% of our 1,275 cases were anonymously reported utilising our external facing platform which provides both web reporting and hotlines with translator services.
In 2021, we received 1,275 reports from whistleblowers. We substantiated 694 in breach of our Code Policies, which led to 369 people leaving the business. Furthermore, we initiated 11 cases of legal action and issued 446 written warnings – with 97 employees receiving a written warning and appropriate financial consequences. In total, we investigated and closed 1,246 Code cases during the year. A small number of cases remain ongoing. We cannot disclose details of these due to confidentiality.
2021 Code cases by relevant theme
Opened
Substantiated
Dismissal
Written warnings
Other sanctions
Governance
Code Policies on Living the Code, Legal Consultation, Responsible Risk Management, Responsible Innovation, and Product Safety and Product Quality
76
38
30
6
15
Countering Corruption
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
533
316
252
207
69
Respecting People
Code Policies on Respect, Dignity & Fair Treatment and Occupational Health & Safety
594
292
83
224
88
Safeguarding Information
Code Policies on Protecting Unilever’s Information, Preventing Insider Trading, Competitors’ Information, Personal Data & Privacy and Use of Information Technology
59
40
4
7
43
Engaging Externally
Code Policies on Responsible Innovation, Responsible Marketing, Responsible Quality, Responsible Sourcing and Business Partnering, Fair Competition, Contact with Government, Regulators & NGOs, Political Activities & Political Donations and External Communications – The Media, Investors & Analysts
13
8
0
2
9
Total
1,275
694
369
446
224
In 2021, 49% of our substantiated cases were in Europe, the Middle East and Africa, 32% in the Americas and 19% 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 is based on a combination of external and internal risks which result in learning curriculums deployed tailored to 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 risks. Materials target not only office-based employees, but also those working in factories and more remote areas.
In 2021 our offline learning approach, which was expanded to include more African and Asian languages, was centred around animated videos supported by guidance materials for the local trainers and 43,016 of our offline employees to date have been trained using these materials.
100% of our employees* who have access to the online learning management system and are employed under a full-time, part-time, fixed-term, permanent or trainee contract, received training on anti-corruption policies and procedures in 2021.
*Excludes those with a statutory Director role or equivalent responsibilities; Unilever employees of joint ventures; and employees of new acquisitions.
442,349Individual online training sessions
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.
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
2021
Governance: Living the Code, Legal Consultation, Responsible Risk Management, Product Quality & Product Safety, Responsible Innovation
92,951
Countering Corruption: Accurate Records Reporting & Accounting, Protecting Unilever's Physical & Financial Assets, Avoiding Conflicts of Interest, Anti-Bribery, Gifts & Hospitality, Anti-Money Laundering
Safeguarding Information: Protecting Unilever's Information, Preventing Insider Trading, Competitor's Information, Personal Data & Privacy, Use of Information Technology
114,338
Externally Engaging: Fair Competition, Responsible Marketing, Contact with Government, Regulators and Non-Governmental Organisations (NGOs), Political Activities & Political Donations, External Communications – The Media, Investors & Analysts, Responsible Sourcing & Business Partnering
63,094
Total of online capsules
442,349
Employees who received offline learning
43,016
New joiners who received consolidated capsule training
11,619
Total learning delivered in 2021
496,984
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 8.25 MB) underpins our sustainable sourcing commitments.
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.
