2022 Universal Registration Document

(ii) Environment, Health and Safety in the workplace governance

The Chief Operations Officer, reporting to the Chief Executive Officer and a member of the Executive Committee, is responsible for the general policy to prevent serious adverse impacts on the environment, and health and safety. The implementation of this policy is the responsibility of the Group’s Subsidiaries and Group Sites.

The Chief Operations Officer is supported by and delegates the deployment and monitoring of the policy to:

• factory and distribution centre Directors who are responsible for the deployment and effective implementation of the policies defined by the Group. Their remuneration is partly linked to their performance in the areas of the environment, health and safety in the workplace;
•  EHS managers who are trained and dedicated to compliance with the EHS policy. They are responsible for deploying the rules, procedures and associated performance objectives of the Group in all of its entities; and
•  country Operations Directors who are responsible for compliance with the EHS policy by the distribution centres, the administrative Sites and stores in their country.

The Purchasing teams are responsible for collecting confirmation of acceptance of Applicable Rules from the Suppliers via the Letter of Ethical Commitment.

They use audits carried out by third-party companies to ensure that Suppliers included in the Risk Matrix implement the prevention measures for EHS risks. As for Human Rights, the Purchasing teams discuss, during Management Committee meetings that include representatives from all Zones and purchasing areas, the results of audits, their consequences for commercial relations, and the related actions plans to achieve continuous improvement of results at the Group’suppliers.

Communication and training

Communication of the Applicable Rules and training of the teams involved complete and support the effective application of the measures set out in the Plan by L’Oréal’s Subsidiaries and Suppliers.

(i) Communication on Human Rights and Fundamental Freedoms

Human Resources teams are informed of the Applicable Rules by their line manager.

All new Group employees must receive a hard or electronic copy of the Group’s Code of Ethics and must confirm that they have read it. Employees must be reminded of the Code of Ethics and its contents on a regular basis.

Any employee in contact with Suppliers must receive the “The Way We Work with our Suppliers” guide when they are hired. It explains ethical standards that apply to Supplier relations.

An Ethics Intranet site is available to employees.

An annual Ethics Day, including Human Rights, has been held since 2009. This day enables employees to discuss matters such as respect for Human Rights and fundamental freedoms via a lives tream with L’Oréal’s Chief Executive Officer and the other members of the Executive Committee. Discussions on ethics are also organized in the Subsidiaries to let employees exchange conversations with their Subsidiary’s General Manager.

In 2022, nearly 35,000 people logged on to Ethics Day sessions and more than 7,600 questions were asked worldwide.

With respect to Suppliers, in addition to the communication of Applicable Rules via the letters of ethical commitment, they are given access to the following documents⁽¹⁾:

• he Code of Ethics; and
• L’Oréal’s policy on Suppliers/subcontractors and child labour.

(ii) Training on Human Rights and fundamental freedoms

A specific, compulsory e-learning course on ethics covers Human Rights and fundamental freedoms issues.

New buyers receive compulsory training on Responsible Purchasing to learn about how to ensure respect of the Group’s Ethical Principles.

An e-learning course on Supplier audits, detailing the applicable audit procedure, is also available for all buyers. A Suppliers version is available on the same website as the above information. There is also an e-learning course available called “Ethics e-learning for business partners”.

(iii) Communication on the Environment, Health and Safety (EHS) in the workplace

EHS managers are informed of the Applicable Rules by their functional hierarchy.

Group Sites are encouraged to hold a day dedicated to EHS to raise the awareness among all employees about the risks to which they are exposed and suitable prevention, in addition to specific local actions.

A Group awareness-raising campaign about major safety risks, deployed over three years, and the implementation of a specific topic every four months, serve to develop employee awareness of risks over time.

A monthly newsletter for the Group’s EHS managers and their team leaders enables performance tracking and the sharing of best EHS practices.