This network is completed by production subcontracting, to meet temporary demand peaks in the case of specific technologies (make-up pencils, soaps etc.). L’Oréal’s contracts prohibit cascade subcontracting. L’Oréal’s consent must be obtained by subcontractors, who need, as result of manufacturing constraints, to subcontract a portion of their
L’Oréal production. When, in certain cases, the subcontractor is authorised to subcontract a portion of its production, the same rules as those defined in this Plan are applied to the subcontractors of the subcontractors. The same types of controls and sanctions are in place in the event of non–compliance.
In order to execute their production, L’Oréal’s factories purchase different raw materials, filling and packaging articles and equipment from third-party suppliers. These suppliers have specific expertise, develop their products and have the infrastructures necessary for their production. They act with complete independence from L’Oréal, without depending on L’Oréal’s instructions or expertise.
The manufacture of filling and packaging articles is not part of L’Oréal’s activity (1) With the exception of one production unit in the Turkey factory.. The filling and packaging articles used are purchased from companies specialising in this area. The same is true for the production equipment.
Products are distributed by the Subsidiaries and independent third-party distributors in the countries or regions where the Subsidiaries are not present. In order to ensure this distribution, warehouses are operated by the Subsidiaries directly, or these services are entrusted to third-party logistics service providers that render services on the same type of activity: storage and preparation of orders in warehouses that they lease or own.
The Subsidiaries and Suppliers must comply with the applicable local legislation and the minimum common core of the rules listed below (the “Applicable Rules”) in order to prevent the risk of serious adverse impacts on Human Rights and fundamental freedoms, health and safety of people and the environment. When local laws and/or the internal rules of Subsidiaries and Suppliers provide more stringent standards than the Applicable Rules, such standards must take precedence. If, however, the Applicable Rules provide for stricter standards, the Applicable Rules take precedence unless they result in an unlawful activity. In the event of contradictions between local laws and internationally recognised Human Rights, L’Oréal works to comply with these international standards.
The Group expanded its mapping by identifying the potential key Human Rights risks worldwide and in all markets. L’Oréal relied on the reporting framework of the Guiding Principles on Business and Human Rights (UNGP Reporting Framework). This identification process takes into consideration the severity, scale and remediability, as well as the likelihood of its impacts for people throughout its value chain. This study was conducted with an NGO specialised in the area, providing an independent analysis, and was reviewed by different external stakeholders. As a result of this analysis, the following salient risks were identified in the context of the application of the French Law on Duty of Vigilance:
Other potential risks identified concern respect for the environment, the right to access water, consideration of Human Rights in the choice of raw materials and, in particular, respect for free, prior and informed consent of indigenous peoples.
Subsidiaries and Suppliers must comply with the minimum core rules, which consist of the following rules that result from an analysis of the risks related to the business activities of the Group and its Suppliers.
Non-discrimination: Acts of discrimination are serious violations of Human Rights thawt remain anchored in all regions of the world in which L’Oréal is present. Discrimination related to gender, sexual orientation and gender identity, disabilities, family situation, age, political and philosophical opinions, religious beliefs, union activities, or related to ethnic, social, cultural or national origins or pregnancy are prohibited. L’Oréal bans pregnancy testing when employees are hired within the Group, and requires its Suppliers to comply with this standard.
Bullying and sexual harassment: Bullying and sexual harassment are prohibited in the Group.
Child labour: L’Oréal’s presence in certain regions of the world that are particularly at risk for child labour, including Asia and Latin America, has led the Group to identify this issue as a priority. To take into consideration the vulnerability of young workers, L’Oréal has set the minimum hiring age at 16 years old. L’Oréal prohibits night work and work hazardous to health and safety for employees younger than 18 in its Subsidiaries.
(1) With the exception of one production unit in the Turkey factory.
(2) Definition of decent living wage in paragraph 4.3.2.5
