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 |
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www.unilever.com | T: +31 (0)10 217 4000 | |
| F: +31 (0)10 217 4798 | |
| www.unilever.com | |
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Jenn Do Office of Manufacturing and Construction |
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| 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 |
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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 |
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| 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 |
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Graeme Pitkethly |
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Chief Financial Officer |
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Unilever PLC & Unilever N.V. |
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cc: David Schwartz, Vice President and General Counsel, North America, Unilever United States, Inc.
Mike Bienenfeld, Linklaters LLP