We have strong values, a clear purpose and want to do business with integrity.
We expect everyone at Unilever to be an ambassador for our high standards. We want to create an environment where employees not only live our common values in their own work, but are vigilant in identifying potential concerns, and confident about speaking up in such situations. But our ambitions do not stop there. We aim to have a positive influence beyond our own business, working with others to promote human rights and fight corruption.
Unilever’s Business Integrity programme brings our values to life for all employees, and helps them apply our 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 provides 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.
Paul Polman, Unilever CEO
"OUR GLOBAL REACH AND UNILEVER SUSTAINABLE LIVING PLAN GIVE US A UNIQUE OPPORTUNITY TO MAKE A POSITIVE DIFFERENCE IN THE WORLD. ACHIEVING THIS REQUIRES CLEAR INSIGHTS, PATIENT FOCUS ON LONG-TERM RESPONSIBLE GROWTH, AND – ABOVE ALL ELSE – INTEGRITY."
Our framework for integrity
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) 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.
The Code and Code Policies reflect our desire to fight corruption in all its forms including fraud and financial misrepresentation, conflicts of interest, bribery and facilitation payments, antitrust violations and misuses or misappropriations of competitor information. They also draw on our commitments to protect Unilever people, information and assets, and to behave responsibly towards customers and other external stakeholders. We seek to meet relevant external standards such as the UN Guiding Principles on Business and Human Rights.
- Respecting People
- Safeguarding Information
- Countering Corruption
- Engaging Externally.
We likewise 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 (PDF | 9MB) (PDF | 9MB) that forms the basis of ongoing dialogue with suppliers on the standards we expect them to meet and will work with them to achieve; and
- Responsible Business Partner Policy (PDF | 3MB) (PDF | 3MB), which is being rolled out to distributors and other third parties within Unilever’s downstream route to market network. We have not changed the Responsible Business Partner Policy requirements since it was issued in 2015.
Governance and management
Our Chief Executive Officer 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.
At group executive level, our Global Code & Policy Committee (GCPC) provides global oversight. The GCPC is chaired by the Chief Legal Officer and, in addition to the Chief Business Integrity Officer, has as members the Group Controller, Chief Auditor, EVP HR Europe, Chief Procurement Officer, Chief Customer Officer and VP Integrated Social Sustainability. The GCPC meets minimum once a quarter to review our Business Integrity strategy, the adequacy of our controls and management systems, performance on training, status of investigations and associated sanctions.
Our global Procurement Business Integrity Committee (PBIC) has responsibility for reviewing third-party compliance issues arising from our Responsible Sourcing Policy. It reviews responsible sourcing and quality audit issues, red flags for risk, and other issues relating to non-compliance by our suppliers.
Our Chief Business Integrity Officer, reporting to the Chief Legal Officer, advises on the strategy and execution of our global Business Integrity programme and leads a network of local and regional Business Integrity Officers. The Business Integrity team works closely with internal stakeholders, including specialist subject-matter experts and teams involved in implementing the third-party compliance programme. Members of the Business Integrity community liaise regularly to share information and best practices.
Every country Chairman is accountable for business integrity and related compliance matters in their market. Business Integrity Committees for relevant geographies oversee investigations into alleged breaches of the Code of Business Principles, Code Policies and local aspects of the implementation of Unilever’s third party compliance programme. Members typically include the Country Chairman, and Heads of Finance, Human Resources, Supply Chain, Customer Development and Legal.
Committees review and report quarterly on significant compliance risks and mitigations, training and awareness efforts, status of investigations and sanctions including disciplinary and asset recovery proceedings. Our local Business Integrity Officers assist our markets and local Business Integrity Committees in carrying out these responsibilities.
All Unilever managers and directors are required to sign an annual declaration to confirm they live the Code and have reported any known or suspected Code breaches. Exceptions are systematically investigated. In 2016 we broadened the opportunity for others to affirm their commitment to Unilever’s values and saw over 50,000 employees sign the Code Declaration as a result of our first ever annual Integrity Pledge Week.
Training and awareness
Everyone who works at Unilever should know our Code and Code Policies and understand how to apply them in their work.
Employees are regularly asked to complete business integrity training. Learnings materials, which were updated in 2016 (see case study), are available both online and for face-to-face awareness and learning sessions: they are designed to highlight key risks and are available in numerous languages. Materials target not only office-based employees, but also those working in factories and more remote areas.
A certain level of training is mandatory for all Director and managers, 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 supports 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, messages learnt in training. Our 2016 approach focused on the role every individual plays in living our values.
What does integrity mean to you?
What inspires you to work for a company with strong values and a clear purpose? What are your favourite quotes about passion, leadership, respect? How does Business Integrity come to life in your local team or area?
These are some of questions we asked Unilever employees to consider during our 2016 Integrity Pledge Week. This high profile internal campaign challenged employees to think about what business integrity means to them prior to signing their Code Declaration, and to share their thoughts with colleagues by creating a personal integrity poster.
The campaign included insights from Paul Polman, our CEO, and other leaders who encouraged employees to have open conversations on this topic across the business. Over 30,000 employees took part in the Pledge in the first five days alone.
“Integrity is a core part of Unilever’s culture. It means that wherever I go across the company in my role as finance manager, I can expect my colleagues to uphold the same levels of integrity – whether they are dealing with me, my team, or the external stakeholders we work with. My association with Unilever helps me build sustainable, meaningful and positive relationships in my role. Knowing that the company I work for takes integrity seriously means I can take real pride in the work I do.”
Thusitha Mahipala, Finance Manager (Singapore)
Risk assessment and due diligence
We use a risk-based approach to implement our Business Integrity programme. We constantly seek to improve our analytics capabilities so trends, hot spots and root causes are rapidly identified and addressed.
When it comes to our Responsible Sourcing Policy and our Responsible Business Partner Policy, 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.
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.
Raising concerns and reporting channels
We are committed to a culture of transparency and have a clear “no retaliation” policy. 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 internet. These options are highlighted during Business Integrity training and in communications.
Details of our web-based reporting process are published externally and shared with suppliers and other business partners.
Responding to breaches of our Code
Our Business Integrity Committees oversee investigations of all potential breaches of our Code and Code Policies, save where senior executives and involved: this role lies with our Chief Legal Officer and Chief Business Integrity Officer, regardless of where such executives are located are located.
In 2016, we closed 1388 incidents across all areas of our Code, with 596 confirmed breaches of our Code. In 2016 we issued 246 written warnings (53 with a downgrade in individual performance rating), initiated 9 cases of legal action and dismissed 179 employees. The number of issues raised per 1,000 employee and substantiation rates benchmark well against industry average, pointing to ongoing employee willingness to report concerns.
Our Business Integrity guidelines and processes seek to ensure a consistent approach across the Unilever group. This includes clear processes for managing allegations, involving where concerns relate to potential competition law, bribery or money-laundering considerations. 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. 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 Partnering Against Corruption Initiative.