2022 Universal Registration Document

Chapter 3 : Risk factors and risk management

employment of young people in dangerous conditions. The Suppliers concerned have been asked to correct these situations, and a follow-up audit is planned.

(ii) Forced labour: 6% non-compliance☑.

During one audit, it was noted that employees were unable to mix freely or use the toilet facilities at their own convenience. The necessary measures have been taken to rectify this situation with the company concerned. Other cases of non‑conformity concern the demand for a monetary deposit at the time of hiring, withholding of identity documents without a legal requirement, the freedom for employees to end their contracts without being penalised (financially or other) except for those stipulated by social legislation, the absence or inadequacy of employment contracts, and the absence or inadequacy of work permits for foreign workers. The main corrective measures requested were the return of the identity documents and the updating of employee contracts.Follow‑up audits will check the effective implementation of these corrective measures.

(iii) Freedom of association and right to collective bargaining(1):3% non-compliance☑.

Most of the cases of non-conformity concern the failure to freely elect employee representatives without management interference. Elections must be carried out, or in countries where such elections are not legal, employee meetings must be organised or alternative arrangements made for employees to raise any concerns or complaints they may have.

(iv) Non-discrimination: 1.1% non-compliance☑.

These cases of non-conformity mainly concern the absence of a clear and uniform policy to ensure the absence of discrimination at recruitment or discrimination in the payment of wages and other costs. It was also noted that some suppliers required pregnancy tests as part of the recruitment process.

Suppliers were requested to take corrective action, which will be checked in future audits.

(v) Working hours: 25% non-compliance☑.

Cases of non-conformity involved failure to comply with the Applicable Rules for work time and regular days off, but also the lack of sufficient documents to ensure correct monitoring of the Applicable Rules. In all of these cases, corrective action plans are implemented and a follow-up audit is planned.

(vi) Wages and charges: 18.3% non-compliance☑.

The audits did not find undue salary withholding or charges.

Most of the cases of non-conformity concerned insurance and social security contributions, as well as a failure to monitor the payment of wages, or non-payment of the minimum wage. When an audit notes a case of non–compliance with regard to the correct settlement of wages, social benefits or the correct payment of overtime, even though these are not undue salary deductions, the Suppliers are requested to correct the situation and a follow-up audit is planned.

(vi) Sexual harassment and bullying: 3.1% non-compliance.

Most of these cases of non-conformity concerned the absence of a written policy prohibiting sexual harassment and bullying or the absence of an internal system allowing the situation to be reported without negative consequences for the employee concerned.

Suppliers were requested to draft these policies, which will be checked in future audits.

The other cases of non-conformity did not concern serious breaches of the Applicable Rules.

(viii) Disciplinary practices: 2.3% non-compliance.

Most of these cases of non-conformity concerned the absence of clear written rules regarding disciplinary practices, or a lack of communication of these rules to the company’s employees.

Suppliers were requested to draft these rules, which will bechecked in future audits.

(ix) Subcontracting: 1% non-compliance.

All cases of non-conformity related to a lack of practice on the part of the supplier to ensure that L’Oréal’s standards of ethics are upheld in their own supply chain.

Corrective action has been requested and will be checked in future audits.

Health, Safety and the Environment

39.1% of the cases of non-compliance concerned the applicable rules on Health, Safety and the Environment.

Most of these cases involved the absence of fire safety certificates, a lack of training in emergency evacuations, handling of fire extinguishers or the use of protective equipment, the absence of an evacuation plan, or shortcomings with regard to emergency routes or exits.

In all of these cases, corrective action plans are implemented and a follow-up audit is planned.

Sustainable sourcing of raw materials

In 2022, 100% of the renewable raw materials used by the Group were reassessed on the basis of criteria such as respect for biodiversity and forced labour. Out of the 329 plant species that are the source of the renewable raw materials usedby the Group, around 6%(2) present significant biodiversitychallenges (endangered species, impact of production on natural environments) depending on their geographic origin and the method of extraction or production used.They are the subject of specific action plans initiated withsuppliers and, if necessary, benefit from the systematic support of independent external third parties, in order to manage the real impacts on the territories of origin of the ingredients.

☑The Statutory Auditors have expressed reasonable assurance about this indicator.

(1) Figures exclude audits where verification could not be performed because of the specific nature of local regulations.

(2) Calculated on the basis of projected purchases between January and November 2022.