CORRESP 1 filename1.htm

 

 

Unilever PLC

Unilever N.V.

Unilever House

PO Box 760

100 Victoria Embankment

3000 DK Rotterdam

London EC4Y 0DY

The Netherlands

 

Weena 455

T: +44 (0)20 7822 5252

3013 AL Rotterdam

F: +44 (0)20 7822 5951/5898

 

www.unilever.com

T: +31 (0)10 217 4000

 

F: +31 (0)10 217 4798

 

www.unilever.com

 

 

Jenn Do

Office of Manufacturing and Construction
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

 

 

 

 

9 September 2019

 

Dear Ms. Do,

 

Re:     Unilever PLC (File No. 1-4546) and Unilever N.V. (File No. 1-4547)

 

I refer to your letters dated 26 July 2019, which set out a comment of the Staff of the Division of Corporation Finance (the “Staff”) to the Unilever PLC and Unilever NV Forms 20-F filed on 11 March 2019. The text of the Staff’s comment is set out below, followed by our response.

 

Note 2. Segment information

 

1.                                      We have read your response to comment 2 in our letter dated June 7, 2019. Given the breadth of your product offerings, it appears that there are groups of similar products underlying your operating segments for which sales trends may be useful in assessing both past performance and prospects for growth. Those trends can be compared to benchmarks such as industry statistics or information reported by competitors. Please therefore reconsider the disclosure requirements of IFRS 8.32 and your conclusion that detailing revenue by product line would not be helpful. Refer to paragraph 103 of IFRS 8 BC.

 

Response to Comment:

 

Unilever complies with IFRS 8.32 through our disclosure of revenue for our Divisions, which comprise similar product groups. We ensure that all relevant product revenue information is available to a reader of our financial reporting through our segment disclosures and related commentary. Unilever’s revenue is derived from the sale of FMCG products, almost all of which is through retailers or distributors. All of the products in any one segment are subject to similar economic trends.

 

We have reconsidered the requirements of IFRS 8.32 and assessed that it may be helpful to supplement our existing disclosures with the relative size of our product categories to the overall Unilever group. This would provide more context for our commentary and enable investors to understand significant developments in the group’s product range, whilst minimising the distortion from small non-underlying developments in revenue such as exchange rates or acquisitions and disposals. Accordingly, Unilever will provide this information in future Form 20-F filings, commencing with the year ending 31 December 2019.

 

The Unilever Group expects that future disclosures would be substantially in the following form, which is derived from the financial information used to produce our financial statements:

 

Unilever PLC

 

Unilever N.V.

Registered in England and Wales, number 41424

 

Registered office Rotterdam

Registered Office: Port Sunlight, Wirral

 

Commercial Register no 24051830

Merseyside CH62 4ZD

 

Vat no NL001868214B01

 

 

SEGMENTAL REPORTING

 

Beauty & Personal Care

 

— primarily skin care (soap, shower, face cleansing), hair care (shampoo, conditioner, styling) and deodorant categories

Foods & Refreshment

 

— primarily ice cream, savoury (soups, bouillons, seasoning), dressings (mayonnaise, ketchup) and tea categories

Home Care

 

— primarily fabric category (washing powders, liquids, rinse conditioners) and includes a wide range of cleaning products

 

Our segments are comprised of similar product categories. Eight categories (2017 and 2016: nine) individually accounted for 5% or more of our revenue in one or more of the last three years. The following table shows the relevant contribution of these categories to group revenue for the periods shown:

 

Category

 

Segment

 

2018

 

2017

 

2016

 

Skin care

 

Beauty & Personal Care

 

17

%

16

%

15

%

Fabric

 

Home Care

 

15

%

15

%

14

%

Ice cream

 

Foods & Refreshment

 

13

%

13

%

13

%

Hair care

 

Beauty & Personal Care

 

12

%

11

%

11

%

Savoury

 

Foods & Refreshment

 

11

%

11

%

11

%

Deodorant

 

Beauty & Personal Care

 

8

%

8

%

8

%

Tea

 

Foods & Refreshment

 

6

%

5

%

6

%

Dressings

 

Foods & Refreshment

 

5

%

6

%

6

%

Spreads

 

Foods & Refreshment

 

3

%

6

%

6

%

Other

 

 

 

11

%

11

%

11

%

 

We are available to discuss any of the foregoing and to the extent that you have any questions please do not hesitate to contact Matthew Cannon at +44 207 822 5059 or matthew.cannon@unilever.com.

 

Yours sincerely,

 

 

/s/ Graeme Pitkethly

 

 

 

Graeme Pitkethly

 

Chief Financial Officer

 

Unilever PLC & Unilever N.V.

 

 

 

cc:                             David Schwartz, Vice President and General Counsel, North America, Unilever United States, Inc.

Mike Bienenfeld, Linklaters LLP