UNILEVER PLC
For the period ended Dec 31, 2024. Filed Mar 13, 2025.
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The yearly report of a company based outside the US. It covers much of what a 10-K does, and may follow accounting rules other than US ones.
FY2024 · Filed Mar 13, 2025
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Contents
Investigating potential breaches
Our investigation standards require us to record and assess all Code concerns
reported, however they are raised. Once a report is received, it is formally
acknowledged and directed to a Business Integrity Officer to determine whether
a Business Integrity investigation is required.
Investigations are led by the responsible Business Integrity Officers, who ensure
fair, unbiased and independent investigations are undertaken. All Business
Integrity Officers are trained on Unilever’s standards and processes and are
required to uphold these at all times. Business Integrity has officers posted
around the world to respond to cases, with oversight from a central Business
Integrity team.
Investigation reports link the allegation made to the specific requirements under
the Code, summarising the evidence, findings in respect of any breach,
corrective measures, and recommended sanctions. Completed investigation
reports and associated evidence are submitted to Business Integrity Committees
for approval. In cases involving public bribery or senior executives, our Chief
Legal Officer and Chief Business Integrity Officer oversee investigations and an
ad hoc Business Integrity Committee determines any sanctions, regardless of
where such executives are located.
We encourage engagement from the initial reporter to facilitate the investigation
while maintaining any confidentiality. Where appropriate and possible, we aim to
provide transparency with regard to the investigation’s progress and anticipated
completion. It is the responsibility of the Business Integrity Committees to ensure
the timely investigation of all potential Code breaches raised by an individual
employee, with a view to reaching a final determination within 60 days,
depending on the nature and complexity of the concern raised.
Breaches of the Code or Code Policies are shared with various oversight
committees, including the Unilever Board’s Corporate Responsibility and Audit
Committees, the Unilever Leadership Executive, and the Global Code and Policy
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