2022 Universal Registration Document

3.4. Vigilance Plan

Chapter 3 : Risk factors and risk management

3.4. Vigilance Plan

3.4. Vigilance Plan

3.4.1. Introduction

L’Oréal is built on strong Ethical Principles that guide its development: Integrity, Respect, Courage and Transparency. These Principles form the foundation of its policies on sustainable development, corporate social responsibility, and philanthropy. L’Oréal promotes respect for all internationally recognised Human Rights and Fundamental Freedoms.

In line with the United Nations Guiding Principles on Business and Human Rights, L’Oréal’s particular point of reference is the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural rights, and the Fundamental Conventions of the International Labour Organisation.

L’Oréal’s Vigilance Plan (the “Plan”) meets the obligations of the French law of 27 March 2017 on the duty of vigilance for French parent companies and order-giver companies. It contains reasonable due diligence measures intended to prevent the risk of serious adverse impacts on Human Rights and Fundamental Freedoms, health, as well as safety and the environment within the framework of a best efforts obligation. It applies to L’Oréal, the parent company of the Group, and to the subsidiaries controlled directly or indirectly by L’Oréal (the “Subsidiaries”), as defined by Article L. 233-16 of the French Commercial Code, and to suppliers and subcontractors with which the companies of the Group have an “permanent commercial relationship”, that is, a direct, ongoing and stable commercial relationship based on the definition in French case law (the “Suppliers”), depending on the risk level as identified in the Plan. It is understood that in its own activities, L’Oréal complies with the rules and diligences contained in the Plan, even when L’Oréal is not expressly mentioned therein. The Plan contains the rules applied to prevent the risk of serious adverse impacts on Human Rights and Fundamental Freedoms, the health and safety of people and the environment resulting from the activities of L’Oréal, its Subsidiaries and Suppliers (see section 3.4.4.). It also includes reasonable measures for the effective application of these rules by L’Oréal, its Subsidiaries and Suppliers as well as regular assessment procedures to evaluate their compliance (see section 3.4.5.). It provides a whistleblowing mechanism and reporting system (see section 3.4.6.) and presents a report on the plan’s implementation (see section 3.4.7.). The actions to support, encourage and prevent serious adverse Human Rights, Fundamental Freedoms, health, safety and the environment contained in the Plan constitute reasonable efforts to be implemented by Suppliers and Subsidiaries. Given the diversity of the businesses of the Subsidiaries and Suppliers, the Plan contains common measures for them.