1. PREVENTION OF CORRUPTION BEHAVIOUR:
A PRACTICE IN PT UNILEVER INDONESIA TBK
IACF- 11 June 2014
Yeni Fatmawati
Corporate Legal Director
WEDNESDAY, JUNE 11, 2014

2. UNILEVER INDONESIA
Strong Local Roots with 80 Years of History
1933
Unilever was
established
under the name
Lever’s
Zeepfabrieken
N.V. in Angke,
Jakarta.
1936
Blue Band
margarine and
Lux soap are
marketed in
Indonesia.
1980
The Company is
renamed as PT
Unilever Indonesia.
Yamani Hasan
is the first Indonesian
citizen to
be appointed as the
Company’s
President Director.
1982
Unilever Indonesia
goes public, listing
15% of its shares on
the Indonesia
Stock Exchange.
1990
The Personal Care
factory is opened
in Rungkut,
Surabaya. The
Company
enters the tea
business with the
acquisition of
SariWangi.
1992
The Wall’s ice cream
factory opens
in Cikarang. Conello
and Paddle Pop
appear on the market
for the first time.
2000
The Company enters
the soy sauce
business, with Bango
acquisition.
2004
Knorr Indonesia is
acquired
from Unilever
Overseas Holding
Ltd and merged with
Unilever Indonesia.
The hair care factory
relocates from
Rungkut to Cikarang.
2008
Asia’s largest Skin
Care factory is built at
our Cikarang site.
The Company enters
the fruit juice
business by acquiring
the Buavita and Gogo
brands. SAP
is implemented
throughout Unilever
Indonesia.
2010
The Company enters
the water purification
business by
launching Pureit.
2012
Unilever Indonesia
succeeded in
doubling the business
within five years and
recorded a sales
more than 2 billion
euro.
2013
Unilever Indonesia
celebrate its 80-years
journey in Indonesia,
by launching “Project
Sunlight” to inspire
people to create a
brighter future not
only for our children,
but for future
generations as well.

3. UNILEVER INDONESIA
Legal Structure
----- Indirect Ownership

4. UNILEVER INDONESIA
Our Profile – Key Facts
80
Years of
Unilever in
Indonesia
40
Product
Brands
8
Owned
Factories
6719
Employee in
2013

5. UNILEVER INDONESIA
Product Portfolio
Home and Personal Care, 73%
Foods and Refreshment, 27%
14 categories
40 brands
1000 SKUs

6. UNILEVER INDONESIA
Wide Distribution Network as Competitive Advantage
Pekan Baru
Pontianak Manado
Banjarmasin
Palembang
Padang
Makassar
Jakarta
East
Jakarta
West Bandung
Yogya
Semarang Surabaya
West
Surabaya
East
Lampung
Papua
Jambi
Medan
Aceh
Samarinda
Denpasar
Balikpapan
Palangkaraya
Kepri
Bengkulu
8 Own Factories, 16 Third Party Manufacturers,
2 Central Distribution Centers (inc. 1 Mega DC)
10 Depot Warehouses
30 Sales Area Offices
641 Distributor /Sub Dist GT, MT, IC
Our products are available in 1 million stores…
…and every house use at least one Unilever products

7. BUSINESS ETHICS : THE COMPONENTS
Corporations have important roles to play
Good
Governance
Good
Corporate
Governance
Good
Civil Society
Governance

8. ANTI BRIBERY LAWS
• International bodies, national governments and legal authorities are
all taking measures to combat bribery and corruption
• Compliance with our Code Policies will ensure that you stay on the
right side of the law, wherever you work
• National Laws: Many national governments have reacted to
international conventions by introducing or strengthening their own
anti-bribery and corruption laws, often with severe sanctions for both
companies and individuals.
• Cross border Laws: Laws introduced by some countries extend beyond
their own national boundaries  United Kingdom Bribery Act (UKBA)
and Foreign Corrupt Practices Act (FCPA)
• You can be found guilty of a bribery offence even if you do something
that is legal or acceptable in your local jurisdiction.
E.g. Freeport Indonesia offered money / bribes to Indonesia police,
hence this was reported to US department of Justice.

9. UNILEVER STAND POINT
Unilever has earned a reputation for conducting its business with
integrity and respect for others. This reputation is an asset, as
valuable as Unilever’s people and brands. To maintain this reputation
requires the highest standards of behaviour from all of its member.
Unilever’s Code of Business Principles (the ‘Code’), and the policies
that support it (‘Code Policies’), set out the standards required from
all employees and third parties acting on Unilever’s behalf. We also
expect our business partners to adhere to principles consistent with
our own.
Breaching the Code and/or Code Policies could have very serious
consequences for Unilever and its employees. These could include
significant fines for Unilever, imprisonment for individuals and
significant damage to our reputation. Failure to comply with the Code
and/or any of the Code Policies will be taken very seriously and could
result in disciplinary action, including dismissal and legal action.

13. STAYING TRUE TO OUR VALUES

14. OUR CODE POLICIES RELATED TO
FACILITATION PAYMENTS

17. CONTACT WITH GOVERNMENT,
REGULATORS & NON-GOVERNMENTAL
ORGANIZATIONS (NGO’S)
• Any contact made by Unilever employees (or agents), either
directly or indirectly (through trade associations etc), with
any government representatives, officials, employees,
legislators and regulators or NGOs must be done with,
integrity and openness and in compliance with any relevant
local or international laws.
• These interactions must only be undertaken by individuals
who are appropriately authorised.

18. GIFT & ENTERTAINMENT ONLINE SYSTEM

19. THE SUPPORT SYSTEM : CODE COMMITTEE
• Corporate Code Committee - Global
(CEO, Chief Legal Officer, Group Secretary, Chief Auditor,
SVP HR & SVP Communications)
• Cluster Code Committee - Regional
(Cluster Head, Head of Finance, Head of HR, Head of
Supply Chain, Head of Legal)
• Operating Country Committee – Indonesia
(Country Chairman, Finance Director, HR Director, External
Relations Director & Corp Secretary, HR Business
Partners, Head of Internal Audit, Head of Legal)

20. THE FUNCTION OF CODE COMMITTEE
• Reviewing significant reputational risks and overseeing risk mitigation
• Conducting an annual Code and Policy controls self-assessment
• Managing the quality and consistency of all local investigations into compliance
breaches and signing off on completion
• Ensuring that individuals who report breaches of the Code or Policy are
properly protected from retaliation
• Implementation of any Standards relating to Code of Business Principles and
Code Policy compliance
• Supporting operations with any Code and Policy related queries or concerns
• Ensuring that any reportable items are escalated to the Cluster Code and
Policy Committee
• Ensuring that individual countries within the MCO are properly supported,
including the creation

21. 360 DEGREES TOUCH POINTS
Code of Business
Principles
Booklet for
New
Employees
Mandatory
E-Learning
Offline
Classroom
Training
Annual
Campaign
Online
Resources
Code
Committee –
Blue
Umbrella

22. CAMPAIGN EXAMPLES
Promoting 4 code policies of :
Anti-Bribery, Gifts & Entertainment, Avoiding
Conflicts of Interest and Contacts with
government, regulators & NGO

23. CAMPAIGN EXECUTION

25. INTERNAL TRAINING: EXAMPLE

26. CHALLENGES
Internal :
• Effectively and efficiently communicate the policy to a wide range of
employees
• Encouraging people to reports any mishaps
• Low level of reported code incidents, despite the complex business nature
of Unilever Indonesia
External :
• A crystal clear, transparent and easily accessible procedures from
government bodies
• Level of commitment from government bodies (from top management
down to operational, from centre to areas)
• One roof coordinated service – avoiding inefficient multiple procedures

27. A THOUGHT : COMPONENTS OF
SUCCESSFUL IMPLEMENTATION
Top
Management
Commitment
Clarity of
Standards
Established
Systems &
Procedures
Easily
accessible
& simple
guidelines
Constant
Campaign
Walk the Talk

28. THE SUPREME QUALITY FOR
LEADERSHIP IS UNQUESTIONABLY
INTEGRITY. (DWIGHT D. EISENHOWER)

29. THANK YOU