SecProbe.io

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