2023 universal registration document

3.4 Vigilance Plan

3. Risk factors and risk management

3.4 Vigilance Plan

3.4. Vigilance Plan

3.4.1. Introduction

L’Oréal is built on strong Ethical Principles that guide its development: Integrity, Respect, Courage and Transparency. These Principles form the foundation of its policies on sustainability, corporate social responsibility, and philanthropy. L’Oréal promotes respect for all internationally recognised Human Rights and Fundamental Freedoms.

In line with the United Nations Guiding Principles on Business and Human Rights, L’Oréal’s particular point of reference is the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural rights, and the Fundamental Conventions of the International Labour Organisation.

L’Oréal’s Vigilance Plan (the “Plan”) meets the obligations of the French law of 27 March 2017 on the duty of vigilance for French parent companies and order-giver companies. It contains reasonable due diligence measures intended to prevent the risk of serious adverse impacts on Human Rights and Fundamental Freedoms, health, as well as safety and the environment within the framework of a best efforts obligation. It applies to L’Oréal, the parent company of the Group, and to the subsidiaries controlled directly or indirectly by L’Oréal (the “Subsidiaries”), as defined by Article L. 233-16 of the French Commercial Code, and to suppliers and subcontractors with which the companies of the Group have a “permanent commercial relationship”, that is, a direct, ongoing and stable commercial relationship based on the definition in French case law (the “Suppliers”), depending on the risk level as identified in the Plan. It is understood that in its own activities, L’Oréal complies with the rules and diligences contained in the Plan, even when L’Oréal is not expressly mentioned therein. The Plan contains the rules applied to prevent the risk of serious adverse impacts on Human Rights and Fundamental Freedoms, the health and safety of people and the environment resulting from the activities of L’Oréal, its Subsidiaries and Suppliers (see subsection 3.4.4.). It also includes reasonable measures for the effective application of these rules by L’Oréal, its Subsidiaries and Suppliers as well as regular assessment procedures to evaluate their compliance (see subsection 3.4.5.). It provides a whistleblowing mechanism and reporting system (see subsection 3.4.6.) and presents a report on the plan’s implementation (see subsection 3.4.7.). The actions to support, encourage and prevent serious adverse Human Rights, Fundamental Freedoms, health, safety and the environment contained in the Plan constitute reasonable efforts to be implemented by Suppliers and Subsidiaries. Given the diversity of the businesses of the Subsidiaries and Suppliers, the Plan contains common measures for them. In addition to these common measures, L’Oréal and its Subsidiaries voluntarily conduct additional actions on these same issues. These initiatives are described in other chapters, in particular chapter 4. Suppliers voluntarily conduct additional actions on these issues and L’Oréal encourages them to do so.

3.4.2. A continuous improvement process

As part of a continuous improvement process, the Plan is regularly reviewed by a committee composed of the Ethics, Risk and Compliance Department, the Operations Department (EHS, Purchasing), the Human Resources Department, the Corporate Social Responsibility Department and the Legal Department. It meets several times a year. Each of these representatives leads a local network (Ethics Correspondents, Environmental, Health and Safety, Purchasing, and Human Relations teams, managers from Internal Control, and Sustainability Leaders) around the world, making it possible to take into account feedback from the field when improving the Plan.

The Vigilance Plan was presented to internal stakeholders (such as the employee representatives in the context of the European Works Council (Instance Européenne de Dialogue Social) and qualified outside stakeholders (NGOs and members of civil society). The Audit Committee and the Board of Directors are informed each year of the update to the Plan’s content. As part of the preparation for the Corporate Sustainability Reporting Directive (CSRD), the Group conducted double materiality analyses of the main sustainability risks, impacts and opportunities. These studies enabled the Group to continue its dialogue with experts and stakeholders on the potential impacts of its business activity, specifically on the environment and human rights (see section 4.1.).

3.4.3. General framework of risk analysis

The risks of serious impacts on Human Rights, the environment, health and safety, have been analysed on the basis of the business of L’Oréal, its Subsidiaries and its Suppliers. The risk analysis was used, first, in the definition of the applicable Rules and, second, to the measures for effective application and monitoring of these Rules. L’Oréal’s activity consists of production of cosmetic products and distribution of these products to the Group’s clients.

1. Manufacturing of finished products

L’Oréal manufactures the vast majority of the finished products that it sells in its own factories, with a presence in the major growth markets. Its network of 37 factories is equipped with the very latest technologies and advances in automation and adapts constantly, and with agility, to incorporate acquisitions and embrace external innovations.