The monitoring of compliance with the Applicable Rules by all Subsidiaries is bolstered by the Speak Up whistleblowing mechanism. An extensive communication campaign explains how Group employees can access the mechanism; the results for 2022 are shown in the preceding paragraph. The annual Ethics Day dialogue sessions held with the Chief Executive Officer and the Directors of Subsidiaries give employees the opportunity to have their say on these topics. Action plans may be initiated, including corrective measures when necessary.
In addition, the Group’s entities self-assess compliance with the Applicable Rules and submit these self-assessments as part of the annual ethics reporting on Human Rights, in accordance with the Group’s Employee Human Rights Policy.
The entities ensure that their employees are familiar with this policy. They have organised training and communication sessions on the topics covered by this policy (health/safety at work, diversity and equity and inclusion, anti-harassment policy etc.).
The completed self-assessments are consolidated at Group level; some of the key information from these self-assessments is given below.
(i) Child labour: it was reported that in 2022:
(ii) Forced labour: no use of prison labour was identified.
(iii) Freedom of association and right to collective bargaining:the Subsidiaries uphold freedom of association and employees’ right to collective bargaining, in particular the right to form/join a union, except in countries that limit or restrict this right. In this case, they ensure there are other methods of dialogue with employees in place that allow them to raise any concerns they may have.
(v) Working hours: all Subsidiaries complied with the Applicable Rules on rest time.
In 2022, 85 “Top managers” (managers of factories or distribution centres, Management Committee members, etc.)attended the Leadership & Safety Culture seminar, held at the CEDEP, The European Centre for Executive Development, at the INSEAD campus in France. Since the start of this programme, 754 senior managers have been trained. The seminar aims to raise awareness with top managers about safety issues, increase their leadership ability and see these behaviours adopted and maintained over the long term.
34 factories are certified ISO 45001, representing 89% of the Group’s factories. 35 factories are certified ISO 14001,representing 92% of the Group’s factories.
In 2022, the following EHS audits were conducted:
The most frequently identified risks during EHS risk audits are related to fire protection, procedure safety, hazardous energies, containment of fire water runoff and wastewater management. The cases of non-conformity and formal notice were systematically subject to corrective actions.
One factory was the subject of a neighbourhood complaint in2022, for two reasons: the first involving the noise caused by the use of a chiller and the second involving an odour problem originating from the site’s filtration garden (an installation that uses plants to treat wastewater).
Two cases of non-compliance with environmental regulations were notified by an administrative authority in 2022. They involve 2 factories, the first of which relates to wastewater quality, and the second to the management of lightning risk.
No fines were imposed in 2022.
100% of strategic Suppliers in the direct purchases category and 95% of strategic Suppliers in the indirect purchases category have made a contractual commitment to comply with the Applicable Rules.
All purchasers know the Applicable Rules and know which people to contact in the event of doubts.
In 2022, 103 newly recruited purchasers in the Group received in-depth training in responsible purchases.
The Applicable Rules are controlled through external audits. These audits cover questions on Human Rights as well as Environment, Health and Safety and cover all activities of the audited Site without being limited to the parts of the Site that operate for L’Oréal.
1,145 on-site audits were conducted in 2022, as part of regular audits, but also ad hoc audits following a risk analysis(29 ad hoc audits in 2022)(2). Thus, 99% of Supplier production sites requiring audits were audited at least once.
The cases of non-compliance noted during these social audits that come under the Plan are described below.
In 2022, 859 suppliers conducted an Ecovadis assessment of their social, environmental and ethical policies, as well as the implementation of those policies by their own suppliers in 2022.
(i) Child labour: 1.3% of non-conformities.
The employment of a child under the age of 16 was identified in 3 audits. One of the three suppliers was granted exemption by L’Oréal upon presentation of a comprehensive file certifying that the young workers only carry out light duties that have no effect on their health and safety or their regular attendance at school, that their employment complies with local legislation and that the supplier has appointed an in‑house “guardian” for these young people. The necessary measures have been taken to discontinue any commercial relationship with the other two suppliers. Other cases of non‑conformity involved in particular, the absence of procedures to verify age at the time of hiring by the Supplier, the absence of copies of identity documents, and the
(1) The scope of consolidation of human rights data arising from ethics reporting is identical to that of social data.
(2) Audits for which the Supplier is not part of the scope, but in respect of which the purchaser decided to conduct a social audit as a precaution. They represent 3% of the total number of audits.
