2023 universal registration document

In the annual appraisal system for all employees, overall performance includes the employee’s achievements in compliance with the Code of Ethics and the Group’s ethical principles.

This policy enables employees to express any concerns they may have, particularly with regard to corruption, via a secure website or directly to the Group’s Chief Ethics, Risk and Compliance Officer. Any allegation raised in good faith is examined in detail. In the event of non-conformity to the corruption prevention policy, corrective measures are taken, which may include disciplinary action. The whistle-blowing line was opened to employees in 2008, and then to stakeholders in 2018.

A compulsory online learning programme on the prevention of corruption, available in 18 languages, has been rolled out in all countries. As at 31 December 2023, this programme had been completed by 88% of the employees concerned.

In accordance with L’Oréal’s risk mapping, specific learning courses for the staff most exposed to the risk are developed and deployed within departments and entities. In 2023, Purchasing, Public Affairs and Real Estate teams were trained centrally, as well as targeted persons within local entities.

The Group’s Internal Control process provides for control procedures on operational activities, in particular for the separation of tasks. The implementation of the corruption prevention programme is part of the Internal Control self‑assessment process rolled out in operational entities.

Moreover, accounting controls for the prevention of corruption are performed periodically.

The system for monitoring the corruption prevention programme is based on the three levels of control and covers all the measures in the programme.

L’Oréal’s Internal Audit teams are particularly vigilant in this respect. Implementation of the corruption prevention programme is systematically reviewed during audit assignments, using a dedicated audit guide which contains specific checks. Individual interviews are conducted separately with the Country Manager and the Chief Financial Officer. They give rise to an individual report reviewed and signed by these latter persons. Specific audits may also be conducted as part of the annual audit plan.

A specific corruption risk procedure integrates appropriate and proportionate checks at the different stages of the acquisition or investment process.

Responses to the ethics questionnaire submitted to target companies are intended to identify whether corruption risk prevention has been taken into account by the companies, and to prepare for integration or collaboration, as applicable.

The third-party management process (clients/suppliers/philanthropic arrangements) includes the corruption risks both when entering into and during a relationship. A corruption risk assessment is carried out on the Group’s third parties. Appropriate verifications are implemented, which rely primarily on a dedicated tool and risk analysis guide.

A specific guide has been made available to employees concerning relationships between intermediaries and public authorities.

Real estate projects are also subject to a specific process.