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July 22, 2022
Graeme Pitkethly
Chief Financial Officer
Unilever PLC
100 Victoria Embankment
London, EC4Y 0DY, United Kingdom
Re:Unilever PLC
Form 20-F for the Year Ended December 31, 2021
Response dated July 1, 2022
File No. 001-04546
Dear Mr. Pitkethly:
            We have reviewed your July 1, 2022 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
May 25, 2022 letter.
Form 20-F for the Year Ended December 31, 2021
Report of the Corporate Responsibility Committee
Protecting and enhancing Unilever's reputations, page 81
1.We acknowledge your response to our prior comment, your recent announcement on June
29, 2022 that you have sold your Ben & Jerry's business interests in Israel, and note that
you state you do not believe any effects of the Ben & Jerry’s board's decision (including
those caused by the divestment of your securities by certain shareholders) are material to
you. You also state that you do not believe there are any material risks to you resulting
from Ben & Jerry's having an independent board as Unilever retains primary
responsibility for the operational and financial performance of the business. Please
provide an analysis to support these conclusions, and include in your analysis why any
future decisions by the independent Ben & Jerry's board will not be material to you or

 FirstName LastNameGraeme Pitkethly
 Comapany NameUnilever PLC
 July 22, 2022 Page 2
 FirstName LastName
Graeme Pitkethly
Unilever PLC
July 22, 2022
Page 2
result in material risks to you, as we note that the referenced sale only covers the Ben
& Jerry's business in Israel and you have retained the remainder of the business. In
addition, to the extent applicable, also include in your analysis how the retention of the
Ben & Jerry's business in Israel might affect your assessment, as we note recent press
reports indicating that the Ben & Jerry's board has commenced legal action against you
regarding the sale, claiming that the independent board did not approve the sale.
            You may contact Nudrat Salik at at (202) 551-3692 or Daniel Gordon at (202) 551-3486
if you have questions regarding comments on the financial statements and related matters.
Please contact Dorrie Yale at (202) 551-8776 or Suzanne Hayes at (202) 551-3675 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Maria Varsellona