Blueprint
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Unilever
N.V.
(Exact
name of registrant as specified in its charter)
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The
Netherlands
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001-04547
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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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Weena
455, 3013 AL, Rotterdam, The Netherlands
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(Address
of principal executive offices)
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(Zip
code)
|
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,
2017.
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 update our review to include changes to 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 2017, 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 systems, tea making
equipment) 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 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 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.
Personal Care Products
Gold
was identified as a raw material that is purchased ultimately from
a single supplier by us or third party contract manufacturers on
our behalf to produce certain personal care products. The supplier
confirmed that the gold originated from recycled or scrap sources
and was sourced from a refiner certified by the Responsible
Jewellery Council, which is a not-for-profit, standards setting and
certification organization that has a well-recognized
Chain-of-Custody Certification for precious metals. During 2017, we
discontinued our sales of these products.
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
http://www.unilever.com/sustainable-living/the-sustainable-living-plan/enhancing-livelihoods/fairness-in-the-workplace/advancing-human-rights-with-suppliers/implementing-our-approach.html.
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
N.V.
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(Registrant)
/s/
Ritva Sotamaa
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By:
Ritva Sotamaa, Chief Legal Officer
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May 31,
2018
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