2022 Universal Registration Document

Chapter 4 : Social, environmental and societal responsibility

Code of Ethics L’Oréal’s commitments to respecting and promoting Human Rights, with reference in particular to the1948 Universal Declaration of Human Rights and the 2011 United Nations Guiding Principles on Business and Human Rights.
Human Rights Policy L’Oréal’s commitments to its stakeholders, particularly its consumers and civil society, describing the way in which these commitments are fulfilled in practice.
Employee Human Rights Policy A specific policy launched in 2020 by which the Group undertakes to respect a base of universal Human and Social Rights for its employees, regardless of their position or location worldwide.
“The Way we work with our Suppliers” Guide A practical guide intended to specify the Group’s standards and to help employees handle situations that they might encounter in the performance of their duties in relationships with suppliers. This Guide was updated in 2022.
Mutual Ethical Commitment Letter Published in 2021, replacing the Ethical Commitment Letter, this document specifically contains the Human Rights standards the Group expects its suppliers to uphold.
Code of Ethics “Suppliers/Subcontractors and Child Labour” Description of the main commitments concerning child labour by suppliers/subcontractors.
L’Oréal’s Influencer Value Charter L’Oréal does not work with influencers under the age of 16 or the legal contractual age.
Employee evaluation system In the annual appraisal system for all employees, overall performance includes the employee’s achievements in compliance with the Code of Ethics and the Group’s ethical principles.
Speak Up policy

Since 2008, L’Oréal’s Speak Up policy has enabled employees to report serious violations of Human Rights and Fundamental Freedoms, health and safety of people and respect for the environment, notably via the Group’s ethics whistleblowing channel ( www.lorealspeakup.com), which falls under the remit of the Chief Ethics, Risk and Compliance Officer.

This has been available to all of the Group’s stakeholders since 2018.

An annual ethics reporting system The system is used to monitor the implementation of the Ethics and Human Rights programme. The subsidiaries are informed of their potential areas for improvement by the Global Ethics, Risk & Compliance Department. 100% of the subsidiaries completed their annual ethics reporting in 2022.
Procedures for prospective acquisitions When prospective acquisitions are being considered, L’Oréal submits an Ethics and Human Rights questionnaire to target companies. This procedure is intended to identify how they have taken into account risks related, amongst other things, to breaches of Human Rights (abolition of child labour and forced labour, etc.).
Raising employee awareness
Ongoing communication The Group’s Human Rights policy and Employee Human Rights Policy are communicated to all Group employees. The Chief Ethics, Risk & Compliance Officer regularly visits the Group’s entities all over the world to meet employees at all levels of the Company. 100% of the subsidiaries have communicated on at least one Human Rights subject(1).
Training

Specific training is being rolled out for the Management Committees.

  • A specific, compulsory e-learning course on Ethics, covering certain Human Rights topics, is currently being rolled out in all subsidiaries. As at 31 December 2022, 87% of the employees with access to the training had completed this course.
  • In 2022, 103 purchasers were trained in responsible purchasing practices. This training is compulsory for any new purchaser. 100% of the Group’s subsidiaries included issues related to Human Rights in their local training programme.
4.3.3.2. L’Oréal’s commitment to protecting personal data

The Group attaches great importance to the principle of transparency and aims to establish a relationship of trust with its stakeholders. It ensures that its responsible use of personal data is underpinned by the protection and security of that data.

In support of this ambition, the Group’s principles governing the processing of personal data (data privacy) have been shared all over the world to raise the awareness of all employees about respect for ethical principles and the legal and regulatory requirements in this area. These principles are supplemented by a framework of policies, procedures and operational guidelines.

The Group has put in place a structure based on a Data Privacy Office (Global DPO Office), which consists of a Legal unit and a Programme unit. A Group Data Protection Officer(DPO) was appointed in 2018 and a network of Country DPOs has been set up worldwide and is growing in strength (44 DPOsin 2022). This structure also relies on a network of Heads of Personal Data Protection in each region and in each business area (IT, Digital, Marketing, HR, Research & Innovation, Retail, Operations, etc.). They are responsible for defining and deploying personal data protection policies that are tailored to the challenges and specific features of their fields.

(1)The scope of consolidation of human rights data arising from ethics reporting is identical to that of social data.