2023 universal registration document

The process safety risks are analysed using the HAZOP (HAZard and OPerability analysis) guide. This method focuses on operating conditions, or FMECAFailure Mode, Effects and Criticality Analysis, which analyses risks related to failures in the process at the different steps in production. The results and means of controlling industrial and specific risks are summarised in the GHAP (Global Hazard Assessment Procedure) programme.

Specific risk analysis process for Suppliers

In addition to their own risk analysis, Suppliers rely, at the very least, on the risks listed in the audit grid provided by L’Oréal when the Letter of Mutual Ethical Commitment is signed (see subparagraph 4.3.1.2.1.) to implement the appropriate prevention measures at each affected site. This grid was prepared in accordance with the list of the major risks described below and is applied during referencing and follow-up audits.

If the specific nature of the Suppliers’ activity requires identification of specific risks and/or additional prevention measures, the Suppliers are required to roll out these additional measures in accordance with best practices in their industry.

For example, in the subcontracting of finished products activity, specific risks may involve (i) the use of certain raw materials, (ii) wastewater treatment, (iii) the use of machines or electrical equipment in processing or storage areas, and (iv) handling techniques that may cause personal injury, in particular.

In the specific case of subcontracting suppliers of aerosolproduction or storage, bleaching powders, flammable products, the sites are subject to specific risks analyses concerning process safety.

Risks identified in the Environment, Health and Safety in the workplace

Risks of serious adverse impacts to Health and Safety in the workplace

(i) Risks associated with buildings and the use of equipment:

soundness of buildings (construction and interior fittings, including the compliance of equipment with operating authorisations and building permits issued by local authorities in compliance with the applicable legislation and, in any event, adaptation to the activity for which the buildings are intended);
use of motorised forklift trucks and Automatic Guided Vehicles (AGV): risks caused by interactions and interference between forklift trucks, AGVs and pedestrians; and
injuries caused by interactions between humans and machines: risks related to access to the moving parts of work equipment.

(ii) Risks related to energy sources, matter and materials:

exposure to energy sources, fluids and hazardous emissions including electricity, high pressure, steam, vapour, hot water and high temperatures;
fires resulting, notably, from flammable products and materials or electrical equipment;
exposure to hazardous dust and chemical products: by inhalation, ingestion or skin contact; and
exposure to high noise levels.

(iii) Risks related to human activities:

entry in confined spaces and/or the risk of anoxia;
isolated work: risks associated with working alone for long periods of time;
slipping and falls;
ergonomics of workstations related to load handling;
construction works (risks during construction activities); and
work at heights (risk of falls associated with the use of ladders and step stools, access to and work on platforms and roofs, use of lift tables and scaffolding etc.).

Environmental risks

The risks of serious damage to the environment are those associated with the consumption of resources or that could cause damage to soils, water, air and biodiversity (habitats and species) in the context of normal operation or the occurrence of an incident at a site of the Subsidiaries or Suppliers:

gradual or accidental pollution; and
pollution during the transport of hazardous materials.

Applicable rules to prevent risks of serious adverse impacts on Safety and Health in the workplace and the Environment

EHS Guidelines

The Group’s Environment, Health and Safety (EHS) policy aims to minimise the impact on the environment and guarantee the health and safety of the employees of its Subsidiaries and Suppliers, its customers and the communities in which L’Oréal carries out its activities. For the Subsidiaries, this policy is built on an EHS management system composed of standards with stringent requirements that set the principles of L’Oréal’s EHS policy, which is all included in the EHS guidelines.

Additional Environment, Health and Safety in the workplace actions

In addition to the action taken as a result of the risk analysis conducted on the business activities of the Group and its Suppliers, L’Oréal conducts Environmental Health and Safety in the Workplace initiatives in addition to those implemented under the French law on Duty of Vigilance. These are described in chapter 4.

L’Oréal’s commitment to Environment, Health and Safety in the workplace is supported at the highest level of the Company by its Chief Executive Officer who renews L’Oréal’s commitment to the United Nations Global Compact each year.

For example, this includes the following additional actions and commitments:

in 2015, L’Oréal was one of 100 leading companies to join the Science Based Targets programme;
in 2018, L’Oréal became a partner of the Ellen MacArthur Foundation: withAct4Nature, in the context of individual commitments, L’Oréal set biodiversity objectives for 2030;
in 2019, L’Oréal was one of the first companies to sign the Business Ambition for 1.5°C pledge of the UN Global Compact, thereby committing to reach “net zero emissions” by 2050 over its entire value chain, in accordance with the 1.5°C path of the IPCC; and
in 2020, L’Oréal became a signatory of the TCFD.

(1) Failure Mode, Effects and Criticality Analysis.