2023 universal registration document

Monitoring and control system

The Applicable Rules are controlled through external audits. These audits cover questions on Human Rights as well as Environment, Health and Safety and cover all activities of the audited site without being limited to the parts of the site that operate for L’Oréal.

1,242 on site audits were conducted in 2023 ☑, as part of regular audits, but also ad hoc audits following a risk analysis (16 ad hoc audits in 2023 ⁽¹⁾Figures exclude audits where verification could not be performed because of the specific nature of local regulations.

The cases of non conformity noted during these social audits that come under the Plan are described below.

In 2023, 965 suppliers conducted an Ecovadis assessment of their social, environmental and ethical policies, as well as the implementation of those policies by their own suppliers in 2023.

In terms of Human Rights

Results of audits by topic

1. Child labour: 1% non conformity☑. The non conformities noted concerned in particular the absence of procedures to verify age at the time of hiring by the Supplier, as well as failure to adhere to the conditions prescribed by the law regarding the employment of young people and apprentices. The concerned Suppliers were asked to correct these situations, and follow up audits were planned.
2. Forced labour: 5.6% non conformity ☑. Cases of non conformity concerned the demand for a monetary deposit at the time of hiring, withholding of identity documents without a legal requirement, the freedom for administrative staff to end their contracts without being penalised (financially or otherwise), the absence or inadequacy of employment contracts, and the absence or inadequacy of work permits for foreign workers. The main corrective measures requested were the return of the identity documents and the updating of worker contracts. Follow up audits will check the effective implementation of these corrective measures.
3. Freedom of association and right to collective bargaining⁽²⁾: 2.4% non conformity ☑. Most of the cases of non conformity concern the failure to freely elect worker representatives without management interference. Elections must be carried out, or in countries where such elections are not legal, worker meetings must be organised or alternative arrangements made for workers to raise any concerns or complaints they may have.
4. Non-discrimination: 0.9% non conformity ☑. These cases of non conformity mainly concern the absence of a clear and uniform policy to ensure the absence of discrimination in recruitment or discrimination in the payment of wages and other costs. It was also noted that some suppliers required pregnancy tests as part of the recruitment process. In addition, there was one proven case of discrimination. Suppliers were requested to take corrective action, which will be checked in future audits.
5. Working hours: 25% non conformity ☑. Cases of non conformity involved failure to comply with applicable legislation regarding working hours and mandatory rest periods, but also the lack of sufficient documents to ensure correct application of legislation. In all of these cases, corrective action plans are implemented and a follow up audit is planned.
6. Wages and charges: 18.1% nonconformity ☑. The audits did not find any salary withholdings or undue charges. Most of the cases of non conformity concerned insurance and social security contributions, as well as a failure to monitor the payment of wages, or non payment of the minimum wage. When an audit notes a case of non compliance with regard to the correct settlement of wages, social benefits or the correct payment of overtime, even though these are not undue salary deductions, the Suppliers are requested to correct the situation and a follow up audit is planned.
7. Sexual harassment and bullying: 2.5% non conformity☑. Most of these cases of non conformity concerned the absence of a written policy prohibiting sexual harassment and bullying or the absence of an internal system allowing the situation to be reported without negative consequences for the concerned worker. Suppliers were requested to draft these policies, which will be checked in future audits. The other cases of non conformity did not concern serious breaches of the Applicable Rules.
8. Disciplinary practices: 1.8% non conformity☑. Most of these cases of non conformity concerned the illegality or absence of clear written rules regarding disciplinary practices, or a lack of communication of these rules to the workers. Suppliers were requested to draft these rules, which will be checked in future audits.
9. (ix) Subcontracting: 1.3% non conformity☑. Most cases of non conformity related Suppliers not ensuring that L'Oréal's standards of ethics are upheld in their own supply chain. Corrective action has been requested and will be checked in future audits.

Health, Safety and the Environment

41.4% ☑ of the cases of non conformity concerned the applicable rules on Health, Safety and the Environment. Most of these cases involved the absence of fire safety certificates, a lack of learning about emergency evacuations, handling of fire extinguishers or the use of protective equipment, the absence of an evacuation plan, or breaches with regard to emergency routes or exits. In all of these cases, corrective action plans are implemented and a follow up audit is planned.