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Shruti J. Shah
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Eric Carlson
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Benchmarking Alert: Unilever’s short and sweet anti-bribery policy

London-based consumer goods conglomerate Unilever employs around 150,000 people worldwide. It has over 400 brands, including Dove, Hellmann’s, Axe, Knorr, and Vaseline, and its employee anti-bribery policy is a single page. How does it compare?

1. Zero-tolerance approach.

Unilever’s commitment to doing business with integrity requires consistently high global standards: our zero-tolerance approach towards bribery and corruption applies to all Unilever operations, regardless of local business practices, and prohibits both public and commercial bribery (e.g. to or from any third party).

2. Employees should tell third parties about Unilever’s zero-tolerance approach. 

Always make clear, internally and when dealing with third parties, that Unilever has a zero tolerance approach to bribery and corruption and will not (directly or indirectly) offer, pay, seek or accept a payment, gift or favor to improperly influence a business outcome

3. No facilitating payments.

Employees must not directly or indirectly (e.g. via suppliers, agents, distributors, consultants, lawyers, intermediaries or anyone else):

Offer or give bribes or improper advantages (including facilitation payments) to any public official or other individual or third party, which are,
or give the impression that they are, intended to influence decisions by any person about Unilever

This is similar to Carlsberg, Apple, Novartis,  MicrosoftVolkswagenAirbusGM3M, and Pfizer which ban all facilitating payments. Coca-Cola and Tesla might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. Don’t meet with officials in-person if you can avoid it. 

Use electronic communications or e-government solutions (in areas such as licensing, procurement, taxes, brand protection, etc) or any other means available to reduce face-to-face interactions with public officials and the connected risks of bribe solicitation

5. The extortion defense. 

In exceptional situations where employees cannot escape imminent threat to their life, liberty, or physical harm without meeting a demand for payment, such a payment may be made but those involved must immediately report full details to their Business Integrity Officer and Cluster General Counsel in the country where the incident occurred. This is to ensure that the matter can be fully investigated, necessary financial records kept, and further steps taken where appropriate (see also Code Policy on Accurate Records, Reporting and Accounting).

This is similar to CarlsbergGMMicrosoft, and Pfizer, the only four other mentions of extortion we’ve seen.

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View more anti-corruption policy benchmarks here.

Click here to view the Unilever anti-bribery policy

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