2022 Universal Registration Document

(iv) Training on the Environment, Health and Safety (EHS) in the workplace

Training sessions dedicated to L’Oréal’s EHS policy and practices have been provided at all levels of the Company, as well as for temporary workers and subcontractors working on Group sites. They constitute one of the cornerstones in the implementation of risk identification and management systems, and the deployment of the EHS culture in all Group entities.

EHS training includes the various training actions for health and safety in the workplace, or the environment and covers general EHS training, EHS training by métier and specific EHS training.

General EHS training includes:

• core general training completed, for example, when a new employee arrives at a Site (L’Oréal employee or temporary staff) regardless of their position; and
• fire safety training, first aid, pollution prevention, recycling, general EHS awareness raising, etc.

EHS training by métier refers to training specific to a given métier area or activity (for example, all of the filling and packing staff of a factory).

Specific EHS training refers to EHS training for a particular

workstation and the activities carried out by the employee.

In terms of ergonomics, a “Manual handling” e-learning course is provided to all employees.

A high level of expertise for global EHS Teams and the development of an EHS culture for “Top managers”, managers and supervisors is assured via the deployment of training specific to each person.

To support the Environmental aspect of the L’Oréal for the Future programme, a training programme on the challenges related to climate, water, biodiversity and resources (Green steps for all) has been launched with the intention of training100% of the Group’s employees.

3.4.5.2. Monitoring compliance with the Plan

Risk hierarchy of non-compliance with the Applicable Rules

The risk hierarchy is used to enhance controls on compliance with the Applicable Rules by defining procedures for monitoring compliance with the Rules that are consistent with the risks, including via a policy of third-party audits, monitoring and evaluation of Suppliers conducted by third-party companies such as EcoVadis. The Group’s vigilance is strengthened in circumstances where conflict is involved, in line with applicable international standards.

As far as Subsidiaries are concerned, the risk hierarchy of non‑compliance with the Applicable Rules was created taking into account the type of activity and, thereafter, the type of Site⁽¹⁾.

With respect to the Suppliers, the risk mapping of non‑compliance with the Applicable Rules was created for Human Rights, Fundamental Freedoms, the environment, and health and safety in the workplace using a methodology that takes the following parameters into account:

• The country in which the Supplier’s sites are located:a country is considered vulnerable in terms of Human Rights and Fundamental Freedoms, and environment, health and safety, if it meets at least one of the following criteria:1. The country is classified as “High risk” or “Extreme risk”according to the criteria of the consultancy firm Verisk Maplecroft: 12 evaluation indices are used in this methodology and aggregated in a single grade compared with the threshold values set by Verisk Maplecroft; and2. The results of social audits conducted by L’Oréal in the country include cases of Zero Tolerance or Need Immediate Action (“NIA” rating that corresponds to the most severe non-conformities).
• The business sector: each Supplier is associated with a sector area according to a governance ranking of Purchases (“Global Purchasing Categories”).
• The nature of operations: the activities most heavily exposed to labour risk are the activities with high manual added value, implying work on a production line.