a4637a
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Unilever
PLC
(Exact
name of registrant as specified in its charter)
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United
Kingdom
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001-04546
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(State
or other jurisdiction of
incorporation
or organization)
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(Commission
File
Number)
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(IRS
Employer
Identification
No.)
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Unilever
House, 100 Victoria Embankment, London EC4Y 0DY UK
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(Address
of principal executive offices)
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(Zip
code)
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Ritva
Sotamaa, Chief Legal Officer
Tel:
+44(0)2078225252, Fax: +44(0)2078225464
Unilever
House, 100 Victoria Embankment, London EC4Y 0DY UK
|
(Name
and telephone number, including area code, of the person to contact
in connection with this report.)
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Check
the appropriate box to indicate the rule pursuant to which this
form is being filed,
and
provide the period to which the information in this form
applies:
__X___
Rule13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for
the reporting period from January 1 to December 31,
2020.
Section
1 -Conflict Minerals Disclosure
Item
1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This specialized disclosure report on Form SD is
filed pursuant to these rules and available on our website
at http://www.unilever.com/sustainable-living/what-matters-to-you/conflict-minerals.html.
The Dodd-Frank Act
The
Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
and rules promulgated thereunder by the Securities and Exchange
Commission impose certain reporting obligations on public companies
that manufacture or contract to manufacture products containing
columbite-tantalite (coltan), cassiterite, gold, wolframite, or
their derivatives, tantalum, tin and tungsten (“Conflict
Minerals”) that may have originated from the Democratic
Republic of the Congo or adjoining countries (“Covered
Countries”). Under these rules, if any Conflict Minerals are
necessary to the functionality or production of a product
manufactured by us or contracted by us to be manufactured, we must
conduct in good faith a reasonable country of origin inquiry to
determine whether (a) any Conflict Minerals originate in the
Covered Countries or (b) are from recycled or scrap sources, as
defined by paragraph (d)(6) of Item 1.01 of Form S-D.
Description of Reasonable Country of Origin Inquiry
We
manufacture or contract to manufacture a broad range of home care,
personal care, refreshment and food products sold throughout the
world in over 190 countries. In order to produce these products, we source raw materials
from thousands of suppliers on a global basis supplying a
manufacturing network in more than 100 countries. Based on the good
faith, reasonable country of origin inquiry described below, we
determined that we have no reason to believe that any
Conflict Minerals in such products may have originated from the
Covered Countries
We
conducted an in-depth review of our portfolio of products to
determine whether Conflict Minerals are present in such products
and also whether such Conflict Minerals are necessary to the
functionality or production of such products. For purposes of this
review, we excluded the packaging and containers for our products
in accordance with the guidance provided on May 30, 2013 by the
staff of the Securities and Exchange Commission.
As the
first step in our review, we examined the specifications for all
products contained within our internal specification system, which
maintains the specifications of substantially all products that we
sell throughout the world. In an effort to address products that
may not be included in our internal specifications systems, such as
electronic devices and other appliances manufactured by third
parties, which represent an insignificant portion of our revenues,
we engaged with employees at the appropriate levels in our
procurement and third party manufacturing functions to identify
additional products that may contain Conflict Minerals. On an
annual basis, we use a risk-based approach to update our review of
certain existing products and new products introduced for sale
during the relevant calendar year.
As a
result of our review of products sold during calendar year 2020, we
determined that gold, tungsten and tin are present in certain of
our products and necessary to the functionality or production of
such products, as described below.
Electronic Devices
Tin,
Tungsten and Gold were identified as present in some components in
certain electronic devices (i.e., water purifier system, tea making
equipment, ice cream machine) sold by us. These devices contain tin
(e.g., tin solder), tungsten or gold in some components (e.g.,
electronic components such as printed circuit boards, solenoid
valves or other components). We have previously provided our
contract manufacturers and certain upstream suppliers with
questionnaires to solicit input about the presence of Conflict
Minerals in these components and the ultimate origin of these
minerals. They have confirmed that the components contain tin,
tungsten or gold and provided information about the origin of these
minerals, including the identity of any known smelter. There is no
indication from the responses received that the tin, tungsten or
gold may have originated in the Covered Countries, unless from a
smelter independently certified as conflict free.
Responsible Sourcing Policy
Unilever has adopted a Responsible Sourcing
Policy that covers, among other things, the use of Conflict
Minerals originating from the Covered Countries. The policy is
available on our website at https://www.unilever.com/Images/slp-unilever-responsible-sourcing-policy-2014_tcm244-409819_en.pdf.
We aim
to not use conflict minerals from the Democratic Republic of the
Congo and adjoining countries that have been mined in support of
armed conflict in any products. Our suppliers may continue to
source minerals from this region so long as they are sourced from
mines or smelters that are verified as conflict-free. We are
committed to conducting ongoing due diligence and setting clear
expectations from our suppliers.
SIGNATURES
Pursuant
to the requirements of the Securities Exchange Act of 1934, the
registrant has duly caused this report to be signed on its behalf
by the duly authorized undersigned.
Unilever
PLC
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(Registrant)
/s/
Ritva Sotamaa
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By:
Ritva Sotamaa, Chief Legal Officer
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June 1,
2021
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