October 21, 2024

Fernando Fernandez
Chief Financial Officer
UNILEVER PLC
100 Victoria Embankment
London, England

       Re: UNILEVER PLC
           Form 20-F for the Year Ended December 31, 2023
           Filed March 14, 2024
           File No. 001-04546
Dear Fernando Fernandez:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Year Ended December 31, 2023
Review of the Year, page 6

1.     We reference certain statements on pages 6 and 8 that begin with a
discussion of
       underlying sales growth, underlying operating margin and underlying
earnings per
       share without including the most directly comparable GAAP measure more
       prominently. In future filings, please review your presentations of all
non-GAAP
       measures disclosed throughout your filing, and revise as needed to
present with equal
       or greater prominence the most directly comparable financial measure or
measures
       calculated and presented in accordance with GAAP as required by Item
10(e)(1)(i)(A)
       of Regulation S-K. You may also reference Question 102.10(a) of the
Compliance and
       Disclosure Interpretations for Non-GAAP Financial Measures.
 October 21, 2024
Page 2
Our Performance, page 56

2.     In future filings, expand your definition of    non-underlying items
on page 61 to
       clarify why certain items are identified as    non-underlying    based
on their nature and
       frequency, and why management believes it provides useful information to
investors.
       In this regard, your disclosure should discuss what it is about the
nature and frequency
       of certain items that results in an item of income or expense to be
classified    non-
       underlying.
3.     Revise future filings to also present your GAAP operating cash flow to
net profit
       ratio, GAAP return on invested capital and GAAP return on assets, since
the non-
       GAAP measure of these items are presented. Refer to Item 10(e)(1)(i)(A)
of
       Regulation S-K, Question 102.10(a) of the Compliance and Disclosure
Interpretations
       for Non-GAAP Financial Measures and footnote 27 to SEC Release No.
33-8176.

        In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

       Please contact Julie Sherman at 202-551-3640 or Kristin Lochhead at
202-551-3664
with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Industrial Applications and
                                                            Services