2022 Universal Registration Document

Chapter 3 : Risk factors and risk management

In the event that the existence of a serious non-conformity with the Applicable Rules is reported, a specific audit can be initiated. Visit reports are issued as part of the process of routine visits made to Suppliers. They can result, if necessary, in additional audits.

Additional procedures: L’Oréal also uses analyses and ratings provided by EcoVadis, an analytical company, to evaluate the policies implemented by the Suppliers, among others, in terms of the issues covered by the Plan. This evaluation is an indicative guide that can be added to the audits described above. By participating in the EcoVadis assessment, L’Oréal compares its environmental and social policy with the expertise and the recommendations of external auditors qualified in the analysis of multi-sector risks. This is a useful rating for the continuous improvement of L’Oréal’s programme, it also contributes to the transparency of industry practices. This assessment is used to select suppliers by taking their environmental and social performance into consideration. L’Oréal is co-founder of the Responsible Beauty Initiative (RBI), a sector initiative created in 2017 with EcoVadis. It brings together eight major players in the cosmetics industry for the sustainable transformation of the entire beauty supply chain.

(ii) Self-assessment system

Human Rights and fundamental freedoms: An annual ethics reporting system enables monitoring of the implementation of the Applicable Rules in the Subsidiaries, namely with regard to Human Rights and Fundamental Freedoms.

Environment, health and safety in the workplace: The Management Committees of L’Oréal Sites have tools for the self-assessment of their practices based on the audit standards provided to them. This enables them to produce an improvement plan, if required. These self-assessments are input data in the EHS risk audits.

To direct its performance:

  • every year, each Subsidiary site defines and revises its safety and environmental roadmaps to achieve the targets set by the Group. It tracks EHS indicators monthly.
  • at Group level, the indicators are consolidated monthly by region and globally for the Group’s results.
  • a Greenhouse Gas Assessment is prepared annually(in accordance with the GHG Protocol).

3.4.6. Whistleblowing mechanism and reporting system

“L’Oréal Speak Up”, L’Oréal’s internal whistleblowing mechanism, has been in place since 2008. This system gives employees and stakeholders access to a secure website they can use to raise any concerns they may have, including serious infringements of Human Rights and Fundamental Freedoms, health and safety at work and respect for the environment, with the Chief Ethics, Risk and Compliance Officer, in a secure, effective manner that provides all the

guarantees of confidentiality necessary for the reporting of potential breaches. Any allegations expressed in good faith are examined in detail and adequate corrective measures are taken, if applicable. Employees have several other methods of raising their concerns (line management, dedicated local hotlines etc.). The whistle-blowing line was opened to employees in 2008, and then to stakeholders in 2018.

3.4.7. Update on the effective implementation of the Plan

This section provides the 2022 results of the application of the Plan for Subsidiaries and Suppliers.

3.4.7.1. General results of whistleblowing mechanisms and reporting

In 2022, there were 510 reports on potential non-compliance with the Applicable Rules, including:

  • 22 on sexual harassment, 6 of which were proven, in whole or in part, and which resulted in 5 departures from the Group;
  • 73 on bullying, 12 of which were proven, in whole or in part, and which resulted in 1 departure from the Group;
  • 28 on discrimination, 3 of which were proven, in whole or in part, and which resulted in 3 departures from the Group;
  • 20 on health and safety, 1 of which was proven, in whole or in part, which resulted in no departures from the Group;and
  • none on environmental issues.
3.4.7.2. Results of the application of the Plan to Subsidiaries
Adoption of the Applicable Rules by the Subsidiaries

The Applicable Rules are incorporated into the Group’s Subsidiaries’ internal rules.

95% of employees individually acknowledged the receipt of the Code of Ethics and 87% of employees have been trained using an e-learning training tool on ethics.

Each EHS manager and each person working in a factory or distribution centre is trained in the Applicable Rules on Health, Safety and the Environment (EHS). All new employees are trained in the Rules on Health and Safety in the workplace and the Environment, regardless of their work location.