In October 2020 Ethical Consumer viewed Unilever's website for the company's policy on supply chain management.
A strong policy would include the following commitments: no use of forced labour, permission of freedom of association, payment of a living wage, the restriction of working hours to 48 hours plus 12 overtime (without exception), no use of a child labour (under 15 or 14 if ILO exempt), no discrimination by race, sex or for any other reason.
Supply chain policy (rudimentary)
A document called 'Unilever Responsible Sourcing policy June 2017' was downloaded. A section called 'Mandatory Requirements for doing Business with Unilever' was viewed. This included workers' rights provisions which adequately addressed discrimination, forced labour, child labour and freedom of association. A page on the company website titled 'Fair compensation' stated that Unilever had been working with Fair Wage Network (FWN) to assure that all full-time direct employees were receiving a living wage. No statement was identified stating that it was the company policy for all employees, including those in the supply chain, to receive a living wage. In the company's Responsible Sourcing Policy, a living wage was said to be Good Practice but it was not a policy or requirement. The company also stated working hours per week should not exceed 48 hours, but stated that in exceptional circumstances the sum of regular and overtime hours might exceed 60 hours. Unilever was therefore considered to have a reasonable supply chain policy.
Stakeholder engagement (rudimentary)
Ethical Consumer deemed it necessary for companies to demonstrate stakeholder engagement, such as through membership of the Ethical Trade Initiative, Fair Labour Association or Social Accountability International. Companies were also expected to engage with Trade Unions, NGOs and/or not-for-profit organisations which could systematically verify the company's supply chain audits, and for workers to have access to an anonymous complaints system, free of charge and in their own language.
Unilever stated that it was a member of industry groups such as the Global Social Compliance Programme and the Leadership Group for Global Recruitment. However, Ethical Consumer did not consider these groups to be multi-stakeholder initiatives, as they were industry only groups with no civil society partners.
The document ‘Unilever Human Rights Report 2019’ stated that the company also worked with the Consumer Goods Forum, Humanity United and the Responsible Labour Initiative, which was part of the Responsible Business Alliance and which they joined in 2019. However these were also not considered multi-stakeholder initiatives.
In 2019, Unilever also signed a Memorandum of Understanding with the Fair Labor Association (FLA) to participate in the “Harvesting the Future” project,in Turkey. The project brought together the Sustainable Agriculture Initiative Platform (“SAI”), agricultural suppliers, and buyers to improve working conditions for migrants in seasonal agriculture work in Turkey. This was considered a multi-stakeholder initiative.
In May 2019, Unilever, the IUF and IndusriALL signed a joint Commitment on Sustainable Employment in Unilever manufacturing. Both of these organisations were considered multistakeholder initiatives.
Ethical Consumer viewed Unilever’s ‘Raise a Concern’ page on their website. It had numbers for toll-free confidential complaints lines in its different countries of operation. However, it did not state whether the complaints service would be in the employees’ own language. Ethical Consumer viewed the ‘Reporting on Breaches’ page in Unilever’s ‘Responsible Sourcing Policy 2017’. This stated that the lines were ‘anonymous (where permitted by law)’. This was not considered to meet Ethical Consumer's requirements.
Unilever was considered to have rudimentary stakeholder engagement overall.
Auditing and Reporting (reasonable)
Ethical Consumer deemed it necessary for companies to have an auditing and reporting system. Results of audits should publicly reported and quantitatively analysed. The company should have a scheduled and transparent audit plan that applies to their whole supply chain, including some second tier suppliers. The company should also have a staged policy for non-compliance. The costs of the audit should be borne by the company.
In its document called 'Unilever Human Rights Report 2017' Unilever stated "Alongside our own URSA (Understanding Responsible Sourcing Audit) standard, we now recognise SMETA (Sedex Members Ethical Trade Audit) audits, thus eliminating duplications for suppliers and reducing audit fatigue and cost. This is possible as we have worked with partners to strengthen standards and in June 2017 Sedex (an online platform for sharing responsible sourcing data on supply chains) updated and extended the scope of its compliance process and auditing tool (SMETA) incorporating critical elements of our RSP (URSA) audit." It was not specified whether the Unilever Responsible Sourcing Policy and associated auditing system appeared included any Tier 2 suppliers.
The results of audits were published and quantitatively analysed in the Unilever Human Rights Update Report 2019.
Any suppliers who had non-conformances were expected to create a remediation strategy with a corrective action plan. It stated “A supplier must provide a time-bound corrective action plan to address and remediate non-conformances, and the auditor must confirm the remediation has effectively addressed the non-conformance in a follow-up audit within a 90-day period for the supplier to be RSP compliant.”
No information could be found regarding the schedule of audits or who bore the costs of these audits.
Unilever was considered to have reasonable approach to auditing and reporting.
Difficult issues (rudimentary)
Ethical Consumer also deemed it necessary for companies to address other difficult issues in their supply chains. This would include ongoing training for agents, or rewards for suppliers, or preference for long term suppliers. It would also include acknowledgement of audit fraud and unannounced audits, and measures taken to address the issue of living wages, particularly among outworkers, and illegal freedom of association.
The Unilever website featured a page titled 'Partner to Win', which stated that the company had an approach to building long-term relationships with selected key strategic supplier partners.
The 'Unilever Human Rights Report 2017' contained information on Unilever’s Framework for Fairer Compensation. But this mainly focused on Unilever's direct employees, all of whom Unilever aimed to pay a living wage to by end 2018. The company also stated, "We compile annual status progress reports against the standards of our Framework in each country, and where any employees are identified as below the living wage benchmark, put remediation plans in place to bring the fixed earnings above the benchmark by the end of 2018. One of our focus areas is the need for more data relating to rural/agricultural living wage levels, and we are discussing this with the Fair Wage Network and certification organisations."
In terms of the wider supply chain the company was focused on "fair wages" rather than a living wage, as the company's Responsible Sourcing Policy 2017 stated: “All workers are provided with a total compensation package that includes wages, overtime pay, benefits and paid leave which meets or exceeds the legal minimum standards or appropriate prevailing industry standards, whichever is higher, and compensation terms established by legally binding collective bargaining agreements are implemented and adhered to.”
Unilever was considered to have a rudimentary approach to difficult issues found within supply chains.
Overall, Unilever received a middle rating for Supply Chain Management adn lost half a mark under this category.
Responsible Sourcing 2017 (2017)