2023 universal registration document

4.3 Policies, performance indicators and results

4.3.4 Policy to prevent corruption

4.3.4. Policy to prevent corruption

Wishing to act in all circumstances in accordance with the ethical principles it has set itself, and to comply with the laws and regulations in force in all the countries where it operates, the Group applies a zero tolerance policy in terms of corruption. These policies enable it to respond to the main corruption risks set out in subsection 4.2.2.

A long-standing commitment at the highest level of the Company

L’Oréal has been a member of the United Nations Global Compact since 2003 and supports the fight against corruption. The Group is committed to complying with the United Nations Convention against Corruption of 31 October 2003 and to applying all applicable laws, in particular the Sapin 2 law in France. L’Oréal is a member of the International Chamber of Commerce Anti-Corruption Commission and of Transparency International France. This commitment 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 every year.

The involvement of everyone in preventing corruption

The Executive Committee	Regularly reviews the corruption prevention programme presented to the Board of Directors.
The Chief Ethics, Risk and Compliance Officer	The Chief Ethics, Risk and Compliance Officer Regularly reviews the corruption prevention programme presented to the Board of Directors. Reporting to the Chief Executive Officer, the Chief Ethics, Risk & Compliance Officer is responsible for designing and monitoring the corruption prevention programme in collaboration with the departments involved in the programme (Legal, Purchasing, Finance, Human Resources, Internal Audit etc.). He leads the specific risk mapping.
Country Managers	Country Managers Regularly reviews the corruption prevention programme presented to the Board of Directors. Country Managers ensure the correct deployment of the corruption prevention programme and its compliance. Their involvement in this issue is required on an annual basis by the Chief Ethics, Risk and Compliance Officer and by their local Corruption Prevention Committee.
Corruption Prevention Committees	Corruption Prevention Committees Regularly reviews the corruption prevention programme presented to the Board of Directors. They oversee the progress of the corruption prevention programme within their entities and involve the Management Committee in an annual review of the programme. They include the Internal Control Manager, the Chief Financial Officer, the Legal Director, the Human Resources Director and the Ethics Correspondent.
Internal Control Managers	Internal Control Managers Regularly reviews the corruption prevention programme presented to the Board of Directors. Internal Control Managers are responsible for the day-to-day running of the programme within their entities, with the support of the Chief Financial Officer and the Legal Director.
Employees	Employees Regularly reviews the corruption prevention programme presented to the Board of Directors. Employees apply the corruption prevention policy in the context of their activities. In case of doubt or questions about compliance with these commitments, they may contact their line managers, the General Counsel, the Chief Financial Officer, the Internal Control Manager, the Ethics Correspondent and, ultimately, the Chief Ethics, Risk & Compliance Officer.

L’Oréal’s Code of Ethics and practical corruption prevention guides

L’Oréal’s Code of Ethics publicly declares a zero-tolerance policy on corruption. It applies to all employees, directors and corporate officers and members of the Executive and Management Committees of the Group and its subsidiaries worldwide. L’Oréal’s Code of Ethics was updated in 2023. Available in 30 languages, and as an audiobook in French and English, it is distributed to all employees worldwide.

L’Oréal has also published a more detailed corruption prevention policy that is available on its website, loreal.com.

The Group also has other reference documents for employees to specify the practices to be adopted to fight against corruption.

Specific Corruption Prevention Guide: rolled out throughout the Group as a whole since 2013 and supplemented in 2018, it covers the relationships with each of L’Oréal’s stakeholders, in particular with the public authorities and intermediaries. This practical Guide is intended to specify the Group’s standards and to help employees handle situations that they might encounter in the performance of their duties. It reaffirms L’Oréal’s corruption prevention policy which was approved by the Chief Executive Officer and the Executive Committee. The policy was presented to the Board of Directors.

This policy posted online on L’Oréal’s website restates the following principles:

- the zero-tolerance policy on corruption;
- the prohibition of facilitation payments;
- the prohibition of all contributions to political parties or politicians with the aim of obtaining a commercial advantage;
- the prohibition on giving and accepting gifts and/or invitations that might influence or be perceived as influencing a business relationship;
- communication of the commitment to preventing corruption to the Group’s business partners; and
- respect for these commitments by intermediaries representing L’Oréal, particularly in countries where there is a high risk of corruption.

Employee Guide – Gifts/Invitations: distributed in 2014 on a Group-wide basis, it sets out the rules in this area. It is now integrated within the specific Corruption Prevention Guide.
Employee Guide – Management of intermediaries withpublic authorities: distributed in 2018 to the relevant personnel, it specifies the rules in this area.
“The Way We Work with our Suppliers” Guide: distributed in 2022, it specifies the rules concerning relationships between suppliers and any employees involved in purchasing decisions.
“The Way We Do Philanthropy” Guide: distributed in 2021, this guide specifies the rules surrounding providing philanthropy in compliance with ethical principles, the Code of Ethics and the Group’s in-house standards.
“The Way We Work with Healthcare Professionals” Guide: updated in 2023, this guide helps the Group’s employees to work with these third parties in an ethical manner.
“Responsible Lobbying Policy”: distributed in 2021, this policy specifies the responsible lobbying commitments and how they should be implemented.
“Conflicts of Interest Policy”: published in 2023, this policy governs the definition of conflicts of interest and the procedure for reporting and managing such conflicts.