2021 UNIVERSAL REGISTRATION DOCUMENT

Forced or compulsory labour

L’Oréal refers to the definition of forced labour sets for in the Convention 29 of the International Labour Organisation. Forced labour is defined as “all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily”.

In certain regions of the world where L’Oréal operates, certain practices that violate internationally recognised Human Rights, such as holding the identity papers of migrant workers, are common.

Any form of forced labour is prohibited. As a result:

• unless there is a legal obligation, employees’ identity papers, passports or any other personal documents may not be held from them. In the event of a legal obligation, these documents must be returned to employees at their first request;
• employees may not be asked to pay for recruitment costs or to make cash deposits to obtain employment;
• if workers from foreign regions are hired, the employer must pay the costs related to these hires;
• the use of prison labour is possible only when it is voluntary within the scope of a professional reinsertion programme, and paid at the market rate. Suppliers must request authorisation from L’Oréal before they use this type of labour;
• security personnel must only ensure the safety of people and property; and
• any salary with holding must be strictly authorised by law. It may not under any circumstances be used for the purpose of confiscation, for the direct or indirect benefit of the employer.

Employees must be free to move around their place of work, with the exceptions of areas to which access is restricted for confidentiality or safety reasons, and must have access to drinking water and bathrooms.

Working hours

Whichever the region of the world in which L’Oréal operates, the working hours in Subsidiaries and Suppliers, including overtime, may not exceed 60 hours a week for employees whose working time is monitored.

All employees must also be granted at least one day of rest for every seven-day period, or two consecutive days of rest for every fourteen-day period. They must have reasonable breaks when they work.

Freedom of association

Violations of freedom of association and the right to collective bargaining, such as discrimination against employee representatives, may occur in all regions of the world in which L’Oréal operates.

Employees’ freedom of association and right to collective bargaining must be respected:

• elections of employee representatives must take place without interference from the employer, preferably by secret ballot;
• employee representatives have access to the work premises subject to safety and/or confidentiality requirements, if any; and
• discrimination against employees conducting union activities is prohibited.

In regions where freedom of association and the right to collective bargaining are limited or discouraged, L’Oréal authorises its employees to meet independently in order to discuss their professional concerns. L’Oréal requires that its Suppliers do the same.

Additional actions for Human Rights

In addition to the actions resulting from the risk analysis on the activities of the Group and the Suppliers, L’Oréal conducts actions on Human Rights in addition to those implemented in the context of the French law on Duty of Vigilance, which are described in Chapter 4 “L’Oréal’s Social, Environmental and Societal Responsibility” of this document.

For example, L’Oréal set up actions with the aim to improve the working conditions of the Indian communities whose livelihood depends on the mineral mica. Since 2017, L’Oréal has been one of the 20 founding members of the Responsible Mica Initiative (RMI), joined by 74 other organisations that use mica. The RMI has three goals:

• implement standards on the responsible workplace on 100%of the supply chains of its members for mica from Bihar and Jharkhand (standards on employment, health, safety in the workplace, the environment and non-use of child labour);
• support the abilities of communities through an inclusive programme that improves the standard of living and generates additional sources of income; and
• establish a legal framework and related control systems with mica pickers, processing units, and mica operators in Bihar and Jharkhand.

L’Oréal also participates in the development of the RMI audit standard in order to facilitate member collaboration and effectively deploy the collective actions necessary in cooperation with local authorities. L’Oréal also supports the establishment of a price calculated using the living wage approach in addition to diversified income contributing to a more resilient living conditions.

To complete this approach, L’Oréal requires that its suppliers have their own due diligence process in place on their scope of supply of Indian mica. In 2021, 99% of Indian mica used in the Group’s formulas came from suppliers committed to obtaining their supply from verified sources.