2023 universal registration document

3.4.6 Whistleblowing mechanism and reporting system

3.4 Vigilance Plan

3.4.6 Whistleblowing mechanism and reporting system

In the event that the existence of a serious non conformity with the Applicable Rules is reported, a specific audit can be initiated. Visit reports are issued as part of the process of routine visits made to Suppliers. They can result, if necessary, in additional audits.

Additional procedures: L’Oréal also uses analyses and ratings provided by EcoVadis, an analytical company, to evaluate the policies implemented by the Suppliers, among others, in terms of the issues covered by the Plan. This evaluation is an indicative guide that can be added to the audits described above. By participating in the EcoVadis assessment, L’Oréal compares its environmental and social policy with the expertise and the recommendations of external auditors qualified in the analysis of multi sector risks. This is a useful rating for the continuous improvement of L’Oréal’s programme, it also contributes to the transparency of industry practices. This assessment is used to select suppliers by taking their environmental and social performance into consideration. L’Oréal is co founder of the Responsible Beauty Initiative (RBI), a sector initiative created in 2017 with EcoVadis. It brings together eight major players in the cosmetics industry for the sustainable transformation of the entire beauty supply chain.

(ii) Self-assessment system

Human Rights and Fundamental Freedoms: An annual ethics reporting system enables monitoring of the implementation of the Applicable Rules in the Subsidiaries, namely with regard to Human Rights and Fundamental Freedoms.

Environment, health and safety in the workplace: The Management Committees of L’Oréal Sites have tools for the self assessment of their practices based on the audit standards provided to them. This enables them to produce an improvement plan, if required. These self assessments are input data in the EHS risk audits.

To direct its performance:

  • every year, each Subsidiary site defines and revises its safety and environmental roadmaps to achieve the targets set by the Group. It tracks EHS indicators monthly;
  • at Group level, the indicators are consolidated monthly by region and globally for the Group’s results; and
  • a Greenhouse Gas Assessment is prepared annually (in accordance with the GHG Protocol).

3.4.6. Whistleblowing mechanism and reporting system

“L’Oréal Speak Up”, L’Oréal’s internal whistleblowing mechanism, has been in place since 2008. This system gives employees and stakeholders access to a secure website that they can use to raise any concerns they may have, including serious infringements of Human Rights and Fundamental Freedoms, the health and safety of people at work, and respect for the environment, with the Chief Ethics, Risk and Compliance Officer in a secure, effective manner that

provides all the guarantees of confidentiality necessary for the reporting of potential breaches. Any allegations expressed in good faith are examined in detail and adequate corrective measures are taken, if applicable. Employees have several other methods of raising their concerns (line management, dedicated local hotlines etc.). The whistle blowing line was opened to employees in 2008, and then to stakeholders in 2018.

3.4.7. Update on the effective implementation of the Plan

This paragraph provides the 2023 results of the application of the Plan for Subsidiaries and Suppliers.

3.4.7.1. General results of whistleblowing mechanisms and reporting

In 2023, there were 678 reports on potential non compliance with the Applicable Rules, including:

  • 34 on sexual harassment, 19 of which were proven, in whole or in part, and which resulted in 7 departures from the Group;
  • 111 on bullying, 37 of which were proven, in whole or in part, and which resulted in eight departures from the Group;
  • 30 on discrimination, six of which were proven, in whole or in part, and which did not result in any departures from the Group;
  • 24 on health and safety, six of which were proven, in whole or in part, and which resulted in three departures from the Group; and
  • 2 on the environment, neither of which were proven, in whole or in part.
3.4.7.2. Results of the application of the Plan to Subsidiaries
Adoption of the Applicable Rules by the Subsidiaries

The Applicable Rules are incorporated into the Group’s Subsidiaries’ internal rules. Employees learn through an online learning programme on ethics. At the end of 2022, 87% of the relevant employees had completed this learning programme. A new version was launched in July 2023 as part of the publication of the new Code of Ethics. As at 31 December 2023, 66% of the relevant employees had already completed it.

Each EHS manager and each person working in a factory or distribution centre is trained in the Applicable Rules on Health, Safety and the Environment (EHS). All new employees are trained in the Rules on Health and Safety in the workplace and the Environment, regardless of their work location.