2023 universal registration document

Learning programmes on EHS policy and practices

Learning sessions dedicated to L’Oréal’s EHS policy and practices have been provided at all levels of the Company.

They help to establish risk identification and control systems, and to embed the EHS culture at the Group’s sites. Their main objectives are:

• defining and sharing the EHS vision, challenges, and values across the Group;
• enabling managers to implement the EHS policy effectively within their entities;
• identifying the EHS risks inherent in a role, task, behaviour, or the use of equipment, and establishing appropriate preventive and corrective measures; and
• enabling managers to identify, in their activities, the actions that help to improve the EHS performance of their site.

From 2020, the Group launched new remote learning courses on environmental subjects. The Green steps for all course, in particular, has raised awareness of the challenges related to climate, water, biodiversity, and resources among more than 45,000 employees. Following this first worldwide campaign to raise awareness of global challenges, a second wave of learning was launched worldwide in May 2023 with Going Sustainable Together. This drills down on the specific challenges faced by the Group’s various functions and specifically highlights the drivers of transformation for each business line. This learning module has been delivered to more than 32,000 employees since May 2023.

In addition to these specialised learning sessions, every new L’Oréal employee completes general and position specific learning programmes about the Group’s EHS rules before taking up their position.

A worldwide audit programme

To ensure compliance with the Group’s EHS policy, a system of worldwide audits has been in place since 1996. Since 2001, this has been reinforced by the presence of external auditors, who are experts in local contexts and regulations. These audits take place regularly at L’Oréal sites: every three years for production sites and distribution centres and every four years for administrative sites and research centres. A follow up visit is scheduled for the following year if necessary.

There are two types of audits: “risk” and “culture” audits. They are performed depending on the maturity, and type of activity at the sites.

Risk audits are carried out by external and independent experts. They assess in particular:

• compliance of practices and facilities with the significant requirements of local regulations, and Group procedures and rules;
• control of risks to health, safety and the environment generated by technical equipment, processes and operating modes available for use by employees; and
• progress in environmental, health, and safety performances.

The results of these audits give the Group’s General Management objective knowledge of the risks in the areas of EHS on L’Oréal sites and provide the assurance that they are under control.

Culture audits are carried out by internal EHS specialists through interviews with at least 20% to 30% of the site’s workforce. The leadership of site management, all operational managers and the deployment level of the EHS culture with all employees are evaluated.

The results of these audits provide information on the knowledge of EHS management tools and the maturity of sites with regard to the safety and environment culture at all structural levels.

Depending on the case, EHS audits are exclusively risk or culture audits, audits that combine risks and culture, or even audits that combine risks, culture, quality and performance.

Furthermore, L’Oréal shares with its subcontractors the objective of improving EHS performance. Audits are carried out by independent third party specialists in addition to social audits. They are conducted on manufacturing or logistics subcontracting sites, according to the criteria defined by L’Oréal and similar to those used for the Group’s entities.