2022 Universal Registration Document

Training in EHS policy and practices

Training sessions dedicated to L’Oréal’s EHS policy and practices have been provided at all levels of the Company. They help to establish risk identification and control systems, and to embed the EHS culture at the Group’s sites, with the following main objectives:

• defining and sharing the EHS vision, challenges, and values across the Group;
• enabling managers to implement the EHS policy effectively within their entities;
• identifying the EHS risks inherent in a role, task, behaviour, or the use of equipment, and establishing appropriate preventive and corrective measures; and
• enabling managers to identify, in their activities, the actions that help to improve the EHS performance of their site.

The 2020 Covid-19 health crisis inspired the Group to adapt its EHS training programme. A substantial overhaul was conducted to enable it to be monitored remotely. Webinars were rolled out through which EHS programmes could be presented. The “Green steps for all” training programme in particular has brought awareness of the challenges related to climate, water, biodiversity, and resources to 17,559 Operations employees since 2021.

In addition to these specialised training sessions, every new L’Oréal employee receives general and specific training at their workstation on the Group’s EHS rules before taking up their position.

A worldwide audit programme

To ensure compliance with the Group’s EHS policy, a system of worldwide audits has been in place since 1996. Since 2001,this has been reinforced by the presence of external auditors, who are experts in local contexts and regulations. These audit stake place regularly at L’Oréal sites: every three years for production sites and every four years for distribution centres, administrative sites, and research centres. A follow-up visit is scheduled for the following year if necessary.

There are two types of audits: “risk” and “culture” audits. They are performed depending on the maturity, and type of activity at the sites.

Risk audits are carried out by external and independent experts. They assess in particular:

• compliance of practices and facilities with the significant requirements of local regulations, and Group procedures and rules;
• control of risks to health, safety and the environment generated by technical equipment, processes and operating modes available for use by employees; and
• progress in environmental, health, and safety performances.

The results of these audits give the Group’s General Management objective knowledge of the risks in the areas of EHS on L’Oréal sites and provide the assurance that they are under control.

Culture audits are carried out by internal EHS specialists through interviews with at least 20% to 30% of the site’s workforce. The leadership of site management, all operational managers and the deployment level of the EHS culture with all employees are evaluated.

The results of these audits provide information on the knowledge of EHS management tools and the maturity of sites with regard to the safety and environment culture at all structural levels.

Depending on the case, EHS audits are exclusively risk or culture audits, audits that combine risks and culture, or even audits that combine risks, culture, quality and performance.

Furthermore, L’Oréal shares with its subcontractors the objective of improving EHS performance. Audits are carried out by independent third-party specialists in addition to social audits. They are conducted on manufacturing or logistics subcontracting sites, in accordance with the criteria defined by L’Oréal and similar to those used for the Group’s entities.

In 2022, the following EHS audits were conducted:

• 20 risk audits;
• 8 combined risk and EHS culture audits;
• 7 combined Quality, Environment, Health, Safety and Performance audits and 3 combined Quality, Environment, Health and Safety audits;
• 66 additional EHS audits of subcontracting sites in factories, and 19 in external distribution centres.

In addition, annual prevention inspections are conducted by experts from the Group’s insurance companies as part of external Fire and Environment insurance policies. In 2022,11 sites (8 factories, 2 distribution centres, and 1 research centre) were inspected for environmental risks in 8 countries. In 2022, fire prevention inspections were carried out at 3 plants in France, and 11 sites worldwide.

All preventive audits and inspections mentioned above involved a risk component which is always carried out by external independent auditors specialised in the area being audited.