2022 Universal Registration Document

Chapter 3 : Risk factors and risk management

Additional actions for Human Rights

In addition to the action taken as a result of the risk analysis conducted on the business activities of the Group and its Suppliers, L’Oréal conducts initiatives in addition to those implemented under the French law on Duty of Vigilance. These are described in chapter 4.

For example, L’Oréal set up actions with the aim to improve the working conditions of the Indian communities whose livelihood depends on the mineral mica. Since 2017, L’Oréal has been one of the 20 founding members of the Responsible Mica Initiative (RMI). This year, the RMI has 82 members.

The RMI has three goals:

  • implement standards on the responsible workplace on 100%of the supply chains of its members for mica from Bihar and Jharkhand (standards on employment, health, safety in the workplace, the environment and non-use of child labour);
  • support the abilities of communities through an inclusive programme that improves the standard of living and generates additional sources of income; and
  • establish a legal framework and related control systems with mica pickers, processing units, and mica operators in Bihar and Jharkhand.

L’Oréal also participates in the development of the RMI audit standard in order to facilitate member collaboration and effectively deploy the collective actions necessary in cooperation with local authorities. L’Oréal also supports the establishment of a price calculated using the living wage(1) approach in addition to diversified income contributing to a more resilient living conditions.

L’Oréal requires its Suppliers to have their own due diligence processes in place as regards their own scope of supply of Indian mica. In 2021, 99% of Indian mica used in the Group’s formulas came from suppliers committed to obtaining their supply from verified sources.

The Group has set up two ambitious programmes aimed at improving working conditions for the employees and communities our suppliers use; the Living Wage programme and the Solidarity Sourcing programme.

Evaluation of the Human Rights Impact in the bergamot supply chain

In 2022, as part of L’Oréal’s partnership with the Danish Institute for Human Rights, the latter conducted an evaluation of the human rights impact of the bergamot supply chain in the Calabria region of Italy. This evaluation aimed to ensure that human rights standards are observed in a region that is affected by forced labour issues, particularly in the agricultural sector. The full evaluation report has been published(2) and it states that, despite the risks identified in the region, the practices of players in our supply chain are in compliance with human rights.

The Living Wage programme

In line with its commitment to fair pay for all of its employees, L’Oréal aims to ensure that, by 2030, all employees of its strategic suppliers will be paid at least a living wage, in line with best practices.

L’Oréal is supported by the Fair Wage Network, a rigorous and internationally recognised NGO.

In order to roll out this approach to our strategic suppliers, we initiate dialogue, work together and establish common strategic frameworks, in collaboration with partners within our supply chains, other companies, civil society, governments, etc.

In 2022, L’Oréal launched a pilot programme that included about 20 of its strategic suppliers, who were selected to represent different purchasing categories and various geographic areas. The aim of the programme was to explore the principle of a decent living wage and to help them look at gaps and the potential obstacles to implementation. The pilot consisted of a series of regular meetings with the assistance of the Fair Wage Network.

The Solidarity Sourcing programme

Through its Solidarity Sourcing programme, established in 2010,due to its many industrial and administrative sites all over the world, L’Oréal is heavily involved in the life of local communities in the areas neighbouring its sites and suppliers.

The programme aims to use the Group’s purchasing power to serve social inclusion by dedicating part of its purchases to suppliers providing access to work and a sustainable income for people who are generally excluded from the labour market, economically vulnerable communities, including small businesses and those that have trouble accessing major contractors.

The programme concerns all the Group’s suppliers and values their commitment to Diversity, Equity and Inclusion. The Solidarity Sourcing programme concerns, for example: fair trade producers, companies which employ people with disabilities, social insertion enterprises, or companies owned by minorities (when this is permitted by national legislation).

As part of L’Oréal for the Future, the Group is renewing its goal to enable over 100,000 people from underprivileged or poor communities to find work by 2030.

3.4.4.2. Risks and Applicable Rules to prevent serious adverse impacts on Safety and Health in the workplace and the Environment
Analysis of Risks to Safety and Health in the workplace and the Environment

The risk analysis covers generic risks related to industrial activities and specific risks related to Suppliers’ and Subsidiaries’ own business activities.

Generic risk analysis process

As is the case for any production (manufacturing and packing), distribution, research and general administration operations, the Group and its Suppliers are exposed to safety and environmental challenges.

Based on the risk prevention work on the Environment, Health and Safety at the workplace carried out by L’Oréal for many years, the major risks below have been identified. On this basis, the Subsidiaries and Suppliers must define at each of their sites, the measures designed to prevent the risks identified in the Plan (the “Prevention System”).