- Time period
- August 2016 – August 2017
- Stand alone document – Basic COP Template
- Differentiation Level
- This COP qualifies for the Global Compact Active level
- Includes a CEO statement of continued support for the UN Global Compact and its ten principles
- Description of actions or relevant policies related to Human Rights
- Description of actions or relevant policies related to Labour
- Description of actions or relevant policies related to Environment
- Description of actions or relevant policies related to Anti-Corruption
- Includes a measurement of outcomes
- Statement of continued support by the Chief Executive Officer
Statement of the company's chief executive (CEO or equivalent) expressing continued support for the Global Compact and renewing the company's ongoing commitment to the initiative and its principles.
Unilever strongly supports the United Nations Global Compact (UNGC) Ten Principles and welcomes its recognition of the positive contribution business can make to create a more prosperous and socially and environmentally sustainable world. It sets a critical framework for establishing a culture of integrity, upholding business to meet their responsibilities to people and planet while setting the stage for long-term success. The Communication on Progress (COP) is an important tool of transparency that provides the chance for an internal and external yearly evaluation of achievements.
The adoption of the UN Sustainable Development Goals (SDGs) has provided for the first time in history a clear global framework to resolve the world’s biggest challenges. We have a unique opportunity to shape a more sustainable, inclusive and equitable future, and business plays a unique role in tackling these global challenges.
The SDGs are important drivers of business growth, innovation and investment. They have certainly reaffirmed our own belief in the relevance of the Unilever Sustainable Living Plan (USLP), acting as a further catalyst for our own action. Now entering its sixth year, the USLP is our blueprint for sustainable business.
By providing quality, affordable products, we are progressing well towards our goal of helping more than 1 billion people take action to improve their health and well-being.
By 2030 our goal is to halve the environmental footprint of the making and use of our products as we grow the business. This covers our entire value chain, from the sourcing of our raw materials and our own manufacturing, through to consumer use and disposal.
Our third big goal is to enhance the livelihoods of millions of people through our social and economic contributions to many communities through employment, training and advancing human rights.
We have set ourselves a new ambition to become ‘carbon positive’ in our operations by 2030, which includes sourcing 100% of our energy across our operations from renewable sources. We were also the first company to adopt and use the UN Guiding Principles Reporting Framework to produce a detailed, stand-alone Human Rights report, published in June 2015.
We are committed to making continuous improvements in the management of our environmental and societal impact and to the longer-term goal of developing a sustainable business. To achieve this, we work in partnership with others – including government, NGOs and other companies – to create the transformational change needed in today’s world, while also increasing our understanding and sharing of good practice.
Our commitment to responsible business is embedded into our business agenda through our purpose and vision. We are deeply committed to doing business with care for the environment, respect for human and labour rights, and with the highest standard of business integrity. That is why we are proud to be a founding signatory to the UNGC.
Chief Executive Officer
- Human Rights
- Assessment, policy and goals
Description of the relevance of human rights for the company (i.e. human rights risk-assessment). Description of policies, public commitments and company goals on Human Rights.
Unilever has long been committed to improving the working conditions of the many people around the world who are part of our business. We have striven to protect people from unlawful and immoral practices, and have policies and processes in place that make our position clear, and help to remedy situations that do not meet our required high standards.
Unilever Indonesia is committed to respecting and promoting human rights, as this is the foundation for a healthy, sustainable and equitable business. It also plays a crucial role in maintaining conducive relationships with all the stakeholders on whom the business depends.Our approach is to uphold and promote human rights in
• In our operations by upholding our values and standards.
• In our relationships with our suppliers and other business partners.
• By working through external initiatives, such as the UN Global Compact.
Description of concrete actions to implement Human Rights policies, address Human Rights risks and respond to Human Rights violations.
A key requirement of the UN Guiding Principles is for businesses to have a policy statement that addresses their responsibility to respect human rights. Our Human Rights Policy Statement provides clarity on our commitment to respect universal principles, our due diligence processes and our governance. We were the first company to adopt and use the UN Guiding Principles Reporting Framework to produce a comprehensive, standalone Human Rights report, published in June 2015, fulfilling our commitment to report publicly on our implementation of the UN Guiding Principles on Business and Human Rights.
We have strengthened our Business Integrity framework by explicitly incorporating the prohibition of human trafficking into our public Human Rights Policy Statement, as well as into our Code of Business Principles (Code) and the associated internal Code Policy on Respect, Dignity and Fair Treatment. Information on our Code, Code Policies and related complaints mechanisms is provided to employees globally. We have also incorporated human trafficking and forced labour guidelines into our supply chain and external business partner policies: the Responsible Sourcing Policy (RSP), and the Responsible Business Partner Policy (RBPP).
To give human rights issues the focus they require, in 2013 we appointed a Global Vice President for Social Impact within our Chief Sustainability Office and devised a five-year strategy on human rights. In July 2016, we expanded this role to Global Vice President Integrated Social Sustainability and move it inside our Supply Chain function. The role now has responsibility for all areas of Supply Chain Social Sustainability including accountability, compliance and audit. This move enables us to focus on effective integration and implementation of our policies and commitments in our vast supply chain.
We are committed to ensuring that all our employees work in an environment that promotes diversity, trust, human rights and equal opportunities, and is free from discrimination or victimisation. Our Respect, Dignity and Fair Treatment Code Policy sets out what we and our employees must do to ensure this, and forms part of the framework of policies supporting our Code of Business Principles.
- Measurement of outcomes
Description of how the company monitors and evaluates performance.
The Company has a policy of sourcing raw materials locally, wherever this is feasible, and complies with the procurement standards and practices specified in the Unilever Responsible Sourcing Policy, the Code, and the Sustainable Agriculture Code. The Responsible Sourcing Policy is designed to ensure fair
working conditions throughout the supply chain, including respect for human rights, freedom of association, and remuneration and working hours that are in compliance with the laws.Our Responsible Sourcing Policy sets out our expectations with regards to the respect for the human rights, including labour rights, of the workers in our extended supply chain. We will only work with suppliers who implement our Responsible Sourcing Policy. They must agree to ensure transparency, to remedy any shortcomings, and to drive continuous improvement. We continue to build the awareness and knowledge of our employees and workers on human rights, including labour rights, encouraging them to speak up, without retribution, about any concerns they may have, including through our grievance channels. We are committed to continue increasing the capacity of our management to effectively identify and respond to concerns.
We recognise that we must take steps to identify and address any actual or potential adverse impacts with which we may be involved whether directly or indirectly through our own activities or our business relationships. We manage these risks by integrating the responses to our due diligence into our policies and internal systems, acting on the findings, tracking our actions, and communicating with our stakeholders about how we address impacts. We undertake impact assessments for high risk commodities/countries and take proactive steps to identify activities that may contribute to negative human rights impacts. We undertook a comprehensive assessment of how best to implement the UN Guiding Principles on Business and Human Rights. This included issuing our Human Rights Policy Statement, reviewing our Code Policies and ensuring alignment with the USLP. Our assessment was also informed by a two-year research project conducted by Oxfam that used our Vietnamese operations as its main case study.
In 2017, we have also released Modern Slavery & Human Trafficking Statement, which explains the steps Unilever has taken to prevent, detect and respond to slavery
and human trafficking within our business and throughout our supply chain.
- Assessment, policy and goals
Description of the relevance of labour rights for the company (i.e. labour rights-related risks and opportunities). Description of written policies, public commitments and company goals on labour rights.
Unilever is committed to diversity in a working environment where there is mutual trust and respect and where everyone feels responsible for the performance and reputation of our company. We will recruit, employ and promote employees on thesole basis of the qualifications and abilities needed for the work to be performed. We are committed to safe and healthy working conditions for all employees. We will provide employees with a total remuneration package that meets or exceeds the legal
minimum standards or appropriate prevailing industry standards. We will not use any form of forced, compulsory or child labour. We are committed to working with employees to develop and enhance each individual’s skills and capabilities. We respect the dignity of the individual and the right of employees to freedom
of association. We will maintain good communications with employees through company based information and consultation procedures. We will ensure transparent, fair and confidential procedures for employees to raise concerns.The rights and interests of all Unilever Indonesia’s employees are enshrined in and protected by the provisions of our Code of Business Principles (CoBP) and Code Policies, and the terms of the Collective Labour Agreement, which is renegotiated and signed every two years by the employees’ union and Management. The Code defines the Company’s responsibilities to employees, which include ensuring a safe and healthy workplace, upholding all relevant employment and other laws, and ensuring that the working relationship is based on mutual respect and trust.
The rights and interests of all Unilever Indonesia’s employees are enshrined in and protected by the provisions of our Code of Business Principles (CoBP) and Code Policies, and the terms of the Collective Labour Agreement, which is renegotiated and signed every two years by the employees’ union and Management. The Code defines the Company’s responsibilities to employees, which include ensuring a safe and healthy workplace, upholding all relevant employment and other laws, and ensuring that the working relationship is based on mutual respect and trust. The Company’s whistle-blower mechanism ensures that employees and stakeholders will be protected against violations of the Code or any other arbitrary, unfair or illegal action taken by any member of the Company.
In 2015, the government enacted a new mechanism to determine the minimum wage in the form of a Government Regulation on minimum wage setting in organisations. The provisions of this Government Regulation were used as a reference during the collective bargaining process with the labour union to determine the 2017 and 2018 salary increases for employees. All discussions between the labour union and the management were conducted in a constructive and positive manner and were concluded to mutual satisfaction.
Labour rights are an integral part of human rights, and we have been increasing our dialogue with our stakeholders on labour rights for several years, including with the OECD, ILO, UN Global Compact and International Union of Food Workers (IUF). We meet the IUF and its affiliates twice a year to discuss labour rights issues. This enables us to identify any emerging issues at an early stage. We are also in dialogue with the IUF on the issues of sustainable employment practices and diversity. Today, around 80% of our factories are unionised. We consider dialogue with all trade unions to be very important and will continue to engage and learn from best practices. In those countries where the right to freedom of association is restricted, we are exploring how we can develop dialogue through joint working groups.
With constant changes in the labour regulation, we have an obligation to maintain good relationship with our employees and labour union. Disruptions to the issue could affect our operations, costs and reputation. To mitigate this risk, we constantly keep update with the changes in labour regulation and maintain a good communication with our labour union. Regular discussion is periodically done to better understand each interest and keep the harmonisation within the industrial stakeholders.
Description of concrete actions taken by the company to implement labour policies, address labour risks and respond to labour violations.
Since 2012, we provide a web-based reporting process for both employees and suppliers, in addition to existing telephone and email reporting systems. Employees can also report concerns to their line manager, local 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. Business Integrity training and communications materials provide details of available options. All reported breaches of the Code of Business Principles are monitored and dealt with by our local business leaders at country level.
In our factories, we previously used SEDEX (Supplier Ethical Data Exchange) to monitor and track social and environmental performance. The Self-Assessment
Questionnaire (SAQ) looks at four core pillars in the areas of Labour Standards, Health and Safety, Environment and Business Integrity. In 2014, 98% of
our factories completed updates to the SEDEX self-assessment questionnaire. Going forward, our factories are now checked by external auditors using the URSA (Unilever Responsible Sourcing Audit) process. This ensures that all internal sourcing units are held to the same standard as external suppliers. We are seeking to improve our analytical capabilities to make sure any internal trends, hot spots and root causes are rapidly identified and remediated through the introduction of appropriate controls.
Significant efforts go into maintaining high awareness of the Code of Business Principles (Code). We provide employees with regular training, both online and
face-to-face, designed to address key risks and user needs. Corporate leaders, including our Chief Executive Officer and Unilever Board Members, also receive
training. Our Business Integrity team, led since 2015 by a Chief Business Integrity Officer, helps local stakeholders develop mitigation plans tailored to local needs. Our training is not only for office-based employees, but also those working in factories or remote areas. We monitor and benchmark our efforts to ensure continuous improvement and successfully embed a culture of Business Integrity across all operations. Where needed, and with input from our subject matter experts, we develop advanced guidance on specific areas covered by our Code Policies for employees in higher risk positions. Training is complemented by globally designed but locally implemented communications campaigns. Our 2016 approach focuses on the important role every individual plays in living our values. Members of our Business Integrity community liaise regularly to ensure global coherence and two-way exchanges on compliance activities – so best practices can be shared, and any feedback or specific queries addressed promptly.
- Measurement of outcomes
Description of how the company monitors and evaluates performance.
We are committed to transparency, but know many challenges remain which must be resolved. In the Salient Issues section of our Human Rights report we discuss the complexities present in our Kericho tea plantation in Kenya. In Turkey, we identified excessive working hours in our tea supply chain. In India, we found incidents of poor health and safety practices and a lack of proper process of wage payment at a salt pan. We also outline, in each case, the actions we are taking to remedy these issues.
Training was provided to procurement professionals at the launch of the RSP in 2014 with refresher training provided mid-year 2016. In addition, we have hosted conferences in Brazil, India, Vietnam, China and Costa Rica to engage with our suppliers, build their understanding of the RSP and provide basic tools for improving responsible sourcing. We have carried out training, coaching and capability building for suppliers in a variety of formats. We provide: gap assessment tools for suppliers for initial evaluation; support materials including understanding the audit assessment and system use; white papers on individual topics; and audio
conferences with specific suppliers according to needs. In October 2016 we held a virtual conference in Turkey and an industry collaboration event in Thailand. Both had a strong focus on migrant workers.
- Assessment, policy and goals
Description of the relevance of environmental protection for the company (i.e. environmental risks and opportunities). Description of policies, public commitments and company goals on environmental protection.
Unilever Indonesia’s corporate vision, ‘to grow the business while increasing positive social impacts and reducing our environmental impacts,’ underlines the
Company’s longstanding commitment to sustainable and responsible growth. This is not only our responsibility as a good corporate citizen; it also makes good business sense, by maintaining the Company’s reputational value, protecting our raw material sources and ensuring a potential market for our products by contributing to the growth of a healthy, prosperous society.
Through these actions, our purpose is to make sustainable living commonplace. This purpose informs our corporate social responsibility (CSR) programme, which is aligned with both the Code and the Unilever Sustainable Living Plan (USLP), a comprehensive blueprint that defines more than 50 targets covering the entire value chain, from the practices used in the production of our raw materials to supporting inclusive business development in our communities. Achievement of these targets is designed to deliver the three key global USLP goals for 2020:
• To help more than 1 billion people take action to improve their health and wellbeing;
• To halve the environmental footprint of our products;
• To source 100% of our agricultural raw materials sustainably.
Unilever Indonesia’s CSR programme is designed to contribute to the achievement of these targets by addressing the interaction between our business and various challenges related to health, education, poverty, waste management, and resource sustainability in Indonesia, as well as our specific responsibilities, as a business operator, to our stakeholders. The CSR programme is implemented in partnership with various not for-profit organisations, including the Company’s social welfare organisation, the Unilever Indonesia Foundation (UIF), as well as communities, and in some cases, the Indonesian Government. Our approach is to engage stakeholders on these critical issues to find solutions that will support economic empowerment and growth, promote healthier, more sustainable lifestyles, and encourage more sustainable consumption and environmental management. We believe that our CSR agenda supports profitable growth while contributing to a bright future.
Our Code of Business Principles states that we are committed to making continuous improvements in the management of our environmental impact and to the
longer-term goal of developing a sustainable business. Furthermore, our Code states we will work in partnership with others to promote environmental care, increase understanding of environmental issues and disseminate good practice.
Description of concrete actions to implement environmental policies, address environmental risks and respond to environmental incidents.
By 2030 our goal is to halve the environmental footprint of the making and use of our products as we grow our business. This covers our entire value chain, from the
sourcing of our raw materials and our own manufacturing, through to consumer use and disposal. We have set a new ambition to become ‘carbon positive’ in our operations by 2030 which includes sourcing 100% of our energy across our operations from renewable sources. We are founding members of the CDP (formerly
Carbon Disclosure Project) Supply Chain Leadership Collaboration. CDP aims to increase companies’ disclosure of their GHG management plans and impacts, and to encourage them to put reduction plans in place. CDP’s supplier programme has a global reach and involves businesses collaborating through their supply chains. We are promoting the involvement of suppliers of both agricultural and non-agricultural based raw materials in the CDP programme. This represents a global standard approach for disclosure of GHG management plans and performance. We believe that involvement in the CDP programme is of intrinsic value to our
suppliers and we encourage their participation. Our environmental management system (EMS) underpins our environment strategy. All Unilever companies must comply with the Unilever standards for occupational safety and health and environmental care (SHE), as well as our Consumer Safety Policy. They must comply in a manner that also recognises, and is consistent with, local legislation. Lifecycle assessment (LCA) is one of a number of techniques we use to help us understand the impacts of our products on the environment. We conduct LCAs on our existing products and ingredients to help identify improvement opportunities, to improve data quality and relevance to our studies.
The Company has a policy of sourcing raw materials locally, wherever this is feasible, and complies with the procurement standards and practices specified in the Unilever Responsible Sourcing Policy, the Code, and the Sustainable Agriculture Code. The Responsible Sourcing Policy is designed to ensure fair working conditions throughout the supply chain, including respect for human rights, freedom of association, and remuneration and working hours that are in compliance with the laws. The Sustainable Agriculture Code is aimed at encouraging our suppliers and farmers to adopt sustainable farming practices. To become a Unilever Indonesia approved supplier, prospective suppliers undergo an audit of their performance on reliability, quality management, environment management, human rights and other social issues set out in the standards. All suppliers are required to comply with the Company’s health, safety and environmental protection standards.
Our environmental management systems are designed to achieve continuous improvement. They are based on, and compatible with ISO 14001. We require all suppliers to comply with our Responsible Sourcing Policy, which requires suppliers to conduct their business in a manner which embraces sustainability and reduces environmental impact. Our mandatory requirement is that suppliers are environmentally compliant with all necessary legal permits, but the policy expects them to proceed towards best practice. We are willing to apply more stringent criteria than those required by law when we believe this to be appropriate.
Within our own operations, our approach is to deliver tools, techniques and awareness, and share best practice directly with those people responsible for reducing the environmental impact of our manufacturing operations. Much of our progress has been achieved through good manufacturing practices at our factories. We continue to promote this through an environmental roadmap that includes an awareness-raising programme called Simple Solutions. Our successful eco-efficiency projects known as ‘Proud Practice’ projects, aim to involve as many people in our factories as possible in improving our eco-efficiency and GHG footprint. We found that a ‘Proud Practice’ from one factory can in many cases be easily replicated elsewhere. We are harnessing the enthusiasm generated by the campaign through sharing more than 170 of these projects globally.
Many of our employees have sustainable business ideas. Factory teams can apply for investment for these via our Small Actions Big Difference fund. Ideas are evaluated on the basis of environmental benefit and financial return. In 2015, we invested €25 million in 287 projects. We use a number of metrics to assess our
environmental impacts across the value chain covering: greenhouse gas (GHG) emissions, water, waste and sustainable sourcing. Eco-efficiency data is used to track performance, set targets and identify the best opportunities to drive reductions in each of our key indicators.
Our approach has five aspects, which aim to affect change within our own operations and beyond:
1. Working to eliminate deforestation
2. Championing sustainable agriculture and the development of smallholder farmers
3. Leveraging our brands and innovation to help consumers live well - by using less water, less energy and recycling more
4. Shaping our manufacturing and distribution operations to be more eco-efficient
5. Advocating for ambitious public policy to tackle climate change.
- Measurement of outcomes
Description of how the company monitors and evaluates environmental performance.
Many of our manufacturing sites also make use of real-time eco-efficiency data. This is collected through automated systems – known as measurement,
monitoring and targeting (MM&T) systems. This helps our manufacturing sites to better track their performance and identify reduction opportunities. Environmental auditing programmes have been implemented within each region to help sites achieve continuous improvement in environmental performance.
At least once a year, all operating units conduct a review of their environmental business risks and their compliance with corporate policies. They also conduct
a continuous self-assessment of their operating controls. These exercises are summarised in a Positive Assurance letter that is sent to our Corporate Risk
Committee each year. Our environmental policy requires that we audit our compliance with legislation and Unilever Standards and investigate all environmental safety incidents in order to prevent recurrence.
- Assessment, policy and goals
Description of the relevance of anti-corruption for the company (i.e. anti-corruption risk-assessment). Description of policies, public commitments and company goals on anti-corruption.
Countering corruption continues to be a focus area in 2016 and we are deploying new mandated interactive training capsules across the business to all employees.
Any suspected CoBP breach is subject to an accelerated review procedure that involves subject-matter experts (SMEs) from Legal Group to ensure compliance with the UK Bribery Act and US Foreign Corrupt Practices Act. Confirmed breaches result in disciplinary action in line with our Sanctions standard. Unilever are committed to working with others who share our values and seek to operate to the same standards as we do. Both our suppliers and distributors are prohibited through mandatory compliance with our Responsible Sourcing Policy and Responsible Business Partner Policy from all forms of bribery, corruption, extortion or embezzlement and there are adequate procedures in place to prevent bribery in all commercial dealings undertaken by a Business Partner.
Unilever (UL) is a founding signatory of the United Nations Global Compact (UNGC): as a Board member CEO Paul Polman actively helps drive global efforts to
combat bribery. Realising UNGC Principle 10 (regarding corruption in all its forms) is a core focus for us. In addition, the Chief Legal Officer (CLO) is a member of the UNGC’s Business for the Rule of Law Steering Committee (B4ROL). UL contributed to UNGC resources launched in June 2015, that engage business and the legal profession in advancing the rule of law, good governance and corporate sustainability, timed to mark 15th anniversary of UNGC. A new B4ROL Framework (Framework) guides businesses around the world. It followed 19 consultation workshops around the world including some hosted by Unilever. A Guide for General Counsel on Corporate Sustainability (Guide) gives practical guidance on how to advance corporate sustainability issues and reinforce the UNGC Ten Principles that focus on human rights, labour, environment and anti-corruption. It specifically features UL’s CLO.
Our CoBP framework is built on the pillars of Prevent – Detect – Respond to ensure we have a continuous ability to develop our compliance programme based on learnings (e.g. from CoBP cases, self-assessments and audits). We also actively monitor regulatory developments and participate in conferences to share, learn and adopt best practices.
The Chief Legal Officer (CLO) is responsible for the strategy and implementation of the Code compliance programme, including CoBP and Code Policies. She is supported by a new Chief Business Integrity Officer (CBIO). The CCO’s global Compliance team is now part of Unilever’s Legal function, giving Unilever dedicated, expert resource to embed a compliance culture and make the business more agile in identifying and mitigating compliance risks.
The CLO chairs the Unilever Global Code & Policy Committee (GCPC), which oversees compliance globally including related policies and standards. The GCPC reports to the Unilever Leadership Executive and to the Audit & Corporate Responsibility Committees of the Board of Directors.
To foster dialogue on best practices in ABC, Unilever partners with external organisations on intercompany benchmarking exercises. The most recent results saw Unilever ranked No 1 in the full report. Unilever’s CBIO is on the expert advisory panel of the TI UK & PwC project to issue guidance on third party management.
She is also a member of the B20 Anticorruption Taskforce. We look out for third party learnings through our membership of the Corporate Executive Board Compliance & Ethics Leadership Council. We partner with Maplecroft for detailed indices of compliance risk by country and we recently engaged PwC to review our
third party compliance programme for external validation and recommendations to build into our 2016-2020 Roadmap. Further, Unilever’s risk assessment
methodology builds on UN Global Compact, OECD, Transparency International and external advisor PwC’s best practice. We have a global process for reporting actual or potential CoBP breaches. Employees are encouraged to report CoBP breaches via internal channels: line manager, local Business Integrity Officer, member of the local Business Integrity Committee or email directly to the Unilever Executive. SMEs or Legal business partners may also be informed of concerns. We provide external channels for employees and Third Parties to log concerns through a portal (14 languages) or a 24-hour toll-free ‘hotline’ (200 languages). Concerns can be reported anonymously if the individual wish to do so and local law permits. A dedicated helpdesk covers questions about CoBP compliance. Potential CoBP and Code Policies breaches are monitored by country-based senior management, supported by the local Business Integrity Officer with oversight from five dedicated and experienced regional Legal Directors who report to the CBIO. Breaches are tackled through to a local Business Integrity Committee unless senior executives are involved (in which case the CLO and CBIO are personally involved).
‘Reportable’ breaches are escalated to the GCPC as well as to the Unilever Leadership Executive & the Audit and Corporate Responsibility Committees of the Board. They see a quarterly review of case analytics and ‘reportable’ Code breaches by country.
In 2015, we investigated and resolved 1,027 incidents across all areas of our Code. We identified 402 confirmed breaches of our Code, issued 116 written warnings (30 with a downgrade in individual performance rating), initiated 13 cases of legal action and dismissed 175 employees. In 2016, a total of 31 reports or inquiries on potential CoBP and Code Policies breaches were received through the whistle-blower mechanism or line managers, Business Integrity Committee members or the Business Integrity Officer.
Description of concrete actions to implement anti-corruption policies, address anti-corruption risks and respond to incidents.
The Company’s anti-corruption policy is an integral part of our Code of Business Practice (CoBP) and focuses on avoiding conflicts of interest; anti-bribery; gifts and hospitality; keeping accurate records, reporting and accounting; protecting the Company’s physical and financial assets and intellectual property; and anti-money laundering. For each of these topics, the CoBP sets out what employees must and must not do in order to act with integrity. Details of how the Company counters
corruption can be found within our CoBP and Code Policies under www.unilever.co.id/investor-relations. To reinforce these principles, all new employees are required to undergo online training on Countering Corruption, and there are additional campaigns and activations throughout the year. In 2016, we organised a Business Integrity Week which included a talk show by the KPK (Indonesia’s Anti-Corruption Commission), attended by around 100 employees. The materials from KPK have
been used in trainings for additional employees. The Company’s Business Integrity Office also attended external anti-corruption trainings, including the Soft Launch of PROFIT (Professionals with Integrity), the KPK’s new national anticorruption movement, on 17 October 2016. Meanwhile, the UIF GM was the speaker at the International Business Integrity Conference (IBIC) 2016 on the ‘Role of Communities and Companies in Preventing Corruption through Corporate Social Responsibility’. The event was held in Jakarta on 16-17 November 2016.
In working with our downstream business partners (BP), i.e. distributors, we have also launched the Responsible Business Partner Policy (RBPP) in 2015. This policy is aligned with the RSP and requires BP to meet mandatory requirements to do business with the Company. The RBPP seeks to ensure that BP do business with integrity, consistent with standards Unilever sets itself. This is consistent with the requirements under Unilever’s code policies including the Anti-Bribery Code Policy, Fair Competition Policy and etc., where Unilever employees must ensure that before entering into contracts with any Unilever BP or its interests externally, the relevant Unilever teams have undertaken appropriate due diligence checks to assess the BP's integrity. The RBPP starts with documenting the business justification for entering into a business relationship with a BP, as well as potential commercial opportunities, and goes on to assessing the BP’s risk matrix, conducting due diligence on the BP and its owners/directors (through an advance screening system), reviewing and approvals, contracting (which includes anti-bribery terms), and ongoing monitoring and renewals.
During the year we also held refresher sessions on the Company’s Code and continued our company-wide campaign on business integrity, focusing particularly on controlling the giving or receiving of gratuities, for which we invited representatives of the Corruption Eradication Commission (KPK) to participate in discussions.
In 2016, several initiatives were taken to introduce and strengthen corporate values and the Code compliance, including the
• Newly recruited management staff were introduced to the corporate values and ethics through the induction programme, ‘HR Familiarization’, which is held every 2-3 months.
• Refreshment of the Code and the new Gift and Hospitality policy during 2016, which were approved by the Business
Integrity Committee meeting on 24 May 2016.
• The Business Integrity Division organised a campaign week in July which included:
- The release of three videos demonstrating how to handle value conflict situations that are frequently faced by employees in their day-to-day work;
- ‘Caught in the act’ – a ground activation to highlight the behaviour of colleagues who live Unilever’s values in their day-to-day activities, by writing down the colleague’s actions on a sticky note and putting it on one of the boards provided;
- Setting the tone from the top, as the BI Committee Chairman delivered an address at Unilever’s Townhall meeting;
- Inviting the national Anti-Corruption Agency (KPK) as a guest speaker at a BI Talkshow to talk about 'Developing Indonesia’s Culture of Integrity and Anti-Corruption by Strengthening the Private Sector'.
• Speaking on business integrity topics with internal or external parties in various forums, such as the Supplier Meetings in April and June, a CD team meeting in August, and the UFS meeting in October.
• An Integrity Pledge week in October, launched by the BI Chairman’s email blast to all employees reminding them to sign the integrity pledge online.
Any breach or suspected breach of the Code must be reported in accordance with specified procedures. In respect of any proven violation, action will be taken that is commensurate with the nature and severity of the violation. The Board of Commissioners will not criticize management for any loss of business resulting from adherence to these principles and other mandatory policies.
All incoming reports will be managed by the Business Integrity Officers that are responsible at each country level, as well as members of the Business Integrity/Blue Umbrella Committee. The Blue Umbrella committee comprises several members of the Board of Directors and the Unilever Indonesia’s Business Integrity Officer, and meets at least once a month.
Employees can report a breach of the CoBP and Code Policies:
1. To their Line Manager. The Line Manager assesses whether an incoming case is a breach of the CoBP and Code Policies. If it is considered a breach, the case is escalated up to the Blue Umbrella committee.
2. To the Business Integrity Officer.
3. To a Blue Umbrella Member. Cases are discussed at monthly Business Integrity Meetings with the Blue Umbrella Members.
4. Via Blue Umbrella Email. Any incoming emails are forwarded to select Blue Umbrella Members and processed further after their assessment.
5. To the Web Hotline. This is managed by a 3rd party for the global team. Incoming reports are received by the global team and then assigned to the country Business Integrity Officer. The Business Integrity Officer assesses whether the case is breach of the Code and escalates as necessary.
6. To the Phone Hotline. This is under the same management and follows the same process as the Web Hotline.
Furthermore, the conducts will be:
1. Reports are received by the Business Integrity Officer or Blue Umbrella committee.
2. The Business Integrity Officer makes an initial assessment to assess whether or not the case constitutes a breach of the Code. If it is considered a breach, the case will be discussed with the Board of Directors. If members of the Board of Directors approve, the case proceeds to an investigation.
3. The case is investigated by an external team. The team liaises with the Business Integrity Officer during the investigation.
4. The investigation result will be reviewed and shared by the Business Integrity Officer. The final result will be further reviewed by the Business Integrity Committee, which recommends action/sanctions commensurate with the nature and severity of the breach, if it is proved.
5. Any allegations are recorded in a system that can be accessed by the Business Integrity team in Unilever’s regional or global
offices. These offices also monitor the processing and followup of each case on a periodic basis.
- Measurement of outcomes
Description of how the company monitors and evaluates anti-corruption performance.
The anti-corruption policy is useful in ensuring that the business activities of a public company are conducted legally, prudently, and in accordance with the principles of good corporate governance. This policy can be part of the code of conduct, or a separate policy. The policy can include, among other matters, the programmes and procedures for addressing the practices of corruption, kickbacks, fraud, bribery and/or gratuities in a public company. The scope of this policy must cover the public company’s prevention of all corrupt practices including both giving and receiving from other parties.
The Anti-Corruption Policy is part of the Company’s Code of Conduct. Unilever’s commitment to doing business with integrity requires consistency with the highest global standards: a zero-tolerance approach to bribery and corruption applies to all Unilever businesses, without considering local business practices. These policies and guidelines cover what employees must and must not do to comply with Unilever’s provisions. These policies also explain the procedures that must be followed if
an employee cannot avoid threats of physical danger if he or she cannot fulfill a request for payment; those involved must immediately make a detailed report about the request and the payment to the Business Integrity Officer.